To Register or not to Register? Reflections on Muslim Marriage Practices in Britain

This is an abridged version of the article. The full article is available in Jahrbuch für islamische Rechtswissenschaft, edited by Cefli Ademi and Mathias Rohe and published by C.H. Beck/Munich in 2020. The article looks at practices regarding Muslim marriages ( nikāh s) in Britain. In Britain, entry on the civil register is required for a Muslim marriage to be recognised as a valid marriage. However, some Muslims do not register their marriage and live in nikāh -only marriages. This article draws upon multiple pieces of research to investigate whether decisions not to register are informed and conscious. This includes surveys, focus group discussions and academic conference panels. The results clearly highlight the plurality and diversity of both Muslim thought and conduct in contemporary Britain, and finds that Muslims are developing a number of ‘new’ Muslim marriage practices, such as taking out a nikāh -only marriage as a means of validating a dating relationship. The article concludes with reflections on possible responses to the considerable challenges in accommodating Muslim and civil laws of marriage.


Introduction
In Muslim majority jurisdictions, as well as countries where Muslims form a minority population (such as Britain), Muslim marriages (nikāhs) are conducted in a variety of ways. These include 'oral' marriages with no written record, 2 or marriages for which written nikāhnāmahs (marriage certificates) have no official recognition. They also include marriages where nikāh is recorded by filling out and signing pre-printed marriage contracts in the presence of an official of the state, such as is prevalent in most jurisdictions in the Muslim world and beyond. 3 However, while in most Muslim majority jurisdictions there is a standard procedure for ensuring that a nikāh marriage gains formal recognition by the authorities, this is less the case in Europe, and especially in Britain. In Britain, entry on the civil register, separately from a nikāh, is required for a Muslim marriage to be recognised as a valid marriage; yet, there is little by way of an institutionalised legal mechanism to ensure that this happens. Therefore, a different dynamic relating to marriage comes into play among The debate about Muslim marriages seems to have intensified in recent years in Britain, as in many European nations. In particular, there has been considerable discussion of the apparent reluctance of some Muslims to register their nikāh marriages with the civil authorities. Why do many Muslims take out nikāh-only marriages, and why is formalising a nikāh through registration resisted by some British Muslims? Moreover, is this act of contracting an unregistered nikāh -often in the full knowledge that such a marriage does not carry official recognition, and with the full and free consent of both partners -an informed, conscious and new iteration of Muslim family law in England and Wales? This is the key question we seek answers to, and one that potentially offers important insights into the way forward for Muslim family law in non-Muslim jurisdictions including Britain.
These central questions also lead to further questions that the state has to engage. How far should Muslims be able to live under the jurisdiction of laws derived from their religious traditions in matrimonial and family questions, should they choose to do so? And, to what extent should modern states tolerate or accommodate the existence of these laws -for example, by permitting or recognising nikāh-only marriages and religious divorces within the legal system? Finally, what solutions might be suggested in bridging the gaps between official government policy and practice of Muslim communities in Britain? This paper touches on some of these additional issues.

Background and Context
It is worth mentioning at the outset that, in some ways, the debate about unregistered Muslim marriages in Britain is one of fairly recent prominence. Earlier generations of Muslims in Britain, often first-generation migrants, had mostly married in their countries of origin and brought along state certified documents testifying to their matrimonial status -and did not appear to have any problems with registering their marriages. Even those who were married in oral nikāh-only ceremonies appeared to have no qualms in approaching relevant state bodies for a marriage certificate and/or recognition of their marital status. This process was followed in order to shore up newly gained legal status as British citizens and called upon especially when couples sought spousal visas to travel abroad.
However, in more recent times, there has been an increasing sense in media and policy circles that younger (second and third) generations of British Muslims have shown increasing ambivalence to matters of marriage registration. As an example, we might cite the Register Our Marriage Campaign, set up in 2016 by Aina Khan, a practicing barrister who claims long experience of representing women whose nikāh marriages were unregistered, subjecting them to ills including being excluded from wills and deprived of shares in property. 4 The campaign has claimed that unregistered marriage is what she calls a 'ticking time-bomb' within the British Muslim community, and especially among young couples. 5 By neglecting to register their marriages, she argues, women (and men also) carry the legal status of co-habitees, rather than spouses, putting themselves and their children at risk of social and financial insecurity. Khan A major concern to us as researchers, academics, activists and members of diverse communities, with our own ideological, political religious and cultural positions on issues which include nikāh-only marriages in Britain, was to conduct research that included voices of members of Muslim communities from a diverse range of constituencies. We were conscious of the difficulty of basing our conclusions on a single research method; hence the decision of adopting a mixed method for obtaining information and views informing our research findings. We decided to use surveys, focus group discussions and academic conferences with dedicated panels on Muslim marriage practices to deepen and enrich our data set. This survey was then followed by two focus group discussions in Bolton and Manchester, and a subsequent panel discussion with solicitors, imams, Muslim community workers and activists at Oxford University in June 2018. All three methods collectively provided a rich canvass of information, opinions and perceptions on why some British Muslims register their marriages whereas others resist the practice -outwardly, at least -in the name of religion. It is to this we now turn our attention.
Reaching out through surveys: Responses of British Muslims regarding their marriage practices. Voices from the Field: Most of the respondents participating in the survey were in registered marriages, as well as having undergone a nikāh by holding two separate ceremonies. Out of the total of 88 respondents 39 respondents were married in the UK: of these, 11 had their civil ceremony followed by nikāh; and 24 respondents had a nikāh ceremony followed by a civil ceremony. Only 4 couples had marriages at a registered mosque. Most respondents found registration procedures at the registry office more complicated and time consuming. Respondents also emphasised the importance of registration for protecting women and provide them security in case of divorce.
The main reason given for conducting marriage in a registered mosque was that conducting the two ceremonies together will save time; will be more convenient and 9 Ethical and Access Issues: Informed consent of the participants was taken before asking them to fill out the survey form. All participants were informed about the purpose of the survey, use of the data, and were given assurances of anonymity for reasons of confidentiality, privacy, and data protection. Privacy of our participants and interviewees will be protected and all data anonymised. Warwick University's Research and Ethics Committee has scrutinized and approved the survey. cost effective; and most importantly, the marriage will also be registered and legally recognised under the law of the United Kingdom. To quote one participant: "holding it in a registered mosque allows me to practice my religion fully and the law of the land under same roof, don't have to do two ceremonies …Save time and money".
Another respondent commented: "Beneficial to conduct both ceremonies in one place as it would be economical too." A third remarked: "This would be a beneficial route and a time saver in view of conducting two ceremonies".
Information in the surveys also reflected awareness of the legal requirement of registering a marriage among professional men and women. At the same time, they were keen to maintain their religious tradition; hence the response from majority of the respondents of having undergone both civil ceremony as well as nikāh.
Amongst our respondents, we also found women who had been married overseas.
13 respondents were married in Pakistan; 5 had marriages registered in Pakistan, while 8 had nikāh in Pakistan but were not sure if the marriage was registered there.
1 respondent was married in Kenya. All 14 in their comments mentioned that it was important to have their marriages registered and wanted their children's marriages to be registered in the UK.
We also distributed questionnaires to unmarried young men and women between the ages of 18-35. The data shows that they wanted their marriages to be registered and also to have a nikāh ceremony. Out of 17 respondents in the unmarried category, 6 wanted nikāh in a mosque with registrar in attendance; and 7 wanted nikāh in a registered mosque with authorised person in attendance; and 2 participants preferred to have only civil ceremony in the registry office. It is also interesting to note that of all the respondents in this category, only 2 were content with a nikāh-only marriage (with no registration) to take place at home or in a mosque. They considered nikāh to be the only appropriate way "according to their faith and to seek Allah's blessings".
One of the respondents commented: "it's important to have the ceremony in a holy place, I will feel more comfortable and it will be easier to attend. I also trust mosques more".
A similar response was given by another respondent from Manchester who was also in favour of conducting the marriage ceremony in the mosque. He commented; "would be a blessing to conduct the wedding in a mosque. It will be a simple ceremony. The Islamic way of marriage would be more appropriate".
In our data sample, we had 18 respondents who had a nikāh-only marriage in the UK. 4 out of 18 were divorced. They regretted that their marriage was not registered, due to which they were unable to receive any support from the former husband and could not claim their share in the property of the husband. They could also not claim any child support from the former husband. The reasons given by respondents for having a nikāh-only marriage included lack of awareness (11 respondents), personal preference (2 respondents), and to fulfil parents desire of conducting a nikāh-only ceremony (1 respondent). The data also indicates that it was chiefly women who were not aware of the legal requirement of registering marriage. This was visible clearly from the responses of housewives, those who were married in Pakistan, and single mothers. It was also interesting to note that women who were in nikāh-only marriages wanted more information and awareness from the researchers about the legal requirements of a valid marriage in the UK. Another surprising finding was that very few have used registered mosques for marriage purposes.
An important fact emerging from the data brings into question the perception that young educated Muslim men and women do not want a registered marriage and want non-interference from the state and the right to exercise their personal choice.
Responses from the field also suggest that the trend is in fact towards registering marriages. Muslim men and women are registering their marriage either through separate civil ceremonies or by conducting the nikāh and civil ceremony in one place.
Our data shows that having a civil ceremony or registering marriage is more than just a 'tick box' exercise, and our respondents want to follow the law of the land. This is a sign of integration and adaptation to the socio-legal norms of the country that is now their home, while maintaining their religious values.
In summation, some questions and reflections arose from respondents' conversations with us beyond the survey as well as from responses provided in the questionnaire itself: For instance, why is it that despite the fact that some mosques are authorised to register, the number of marriages held at such mosques is very low? Should the law on marriage be amended to recognise Muslim marriages in the same way as Jewish or Christian marriages? To what extent is the perception that younger Muslims do not want to register their marriages a widespread emerging trend and reflective of reality on the ground?
Voices from a women's only group in Bolton and 'dars' group in Manchester: An inter-generational collage

Conscious of the diversity and inter-generational understandings and practices of
British Muslims relating to marriage, we also reached out to Muslim communities in north-west England including those in Bolton and Manchester. 10 Two groups were identified for focus group discussions, one in each city. Shaheen Sardar Ali was aware of, and had met some members of these groups from as far back as 1990 when she was a postgraduate law student at the University of Hull.
In 2018, the all-women group in Bolton invited Shaheen to their monthly meeting.
Set up as an informal women's only group over two decades ago, this inter-generational group included women from Bolton, Preston, Standish, Wigan and Manchester who met every month at different members' homes to catch up on social and family events.
At times, they would meet to read the Qur'an for some special occasion, and every now and again they would go for a picnic or go to the cinema together. These lunchtime meetings included generous spread of food contributed by the group. 11 Most of the women had met Shaheen on several previous social occasions and were pleased to see her at their meeting. They had already been made aware of the research questions, as the survey was shared with them both in its English and Urdu versions.

10
This access was made possible through the good offices of Shaheen's paternal uncle, Dr Miftaullah and his wife, Iffat who have lived in that part of the country since 1969. We gratefully acknowledge their facilitation and support.

11
Thirty-two women were present on the day. Ages of group members ranged between 25 -75); educational levels were quite varied with most women having obtained high school qualifications or below. A few were university graduates; most were home-makers; a couple of the younger were in employment.
The inter-generational dynamic was very interesting, particularly in how they engaged with the question of whether or not to register a Muslim marriage.
Views across the generations were almost unanimous. As voiced by the 75-year-old grandmother: "of course: marriages should be registered! How else would the wife get her rights within marriage in Britain?" Another woman, a mother whose daughter was in a nikāh-only marriage, said: "It is so unfair when the bride-groom's family insist on a nikāh-only marriage, saying they will register it shortly after the wedding, [when] they actually don't have any intention of doing so. Look at the case of our own daughter. Born and raised in England, she knew it was important to register her marriage, but we all conceded to the groom's family and left it at nikāh only. After a while their relationship became quite rocky and still is. We asked them to register the marriage but they wouldn't.
We now know why. They did not want my daughter to have any share in her husband's assets. She left her job to look after the family and her children but, if the marriage ends, she will be left penniless. I will say to all parents: make sure the marriage of your children is registered." Only one out of the 32 women in the group was of the view that marriage need not be registered and that a nikāh-only marriage is sufficient. Shaheen says that: "I noticed that beyond making this statement she was not prepared to elaborate, so I went up to her and sat next to her to broach the subject further". In a one to one whisper she said: "I say this because my son was married and upon his divorce, we feared his (ex) wife would take away everything. Thank God we realised that if you don't register the nikāh, then that is fine, as it is only in a civil marriage that the wife gets a share of the matrimonial property. Why should she (wife) take away my son's hard earned money? That is why I am not in favour of registering a nikāh." In our discussion, whether those in nikāh-only marriages do so due to their religious conviction believing that being married in the eyes of God and the community is all that counts, women were unanimous in their understanding that: "Our religion (Islam) wants us to follow the law of the land which we have made our home, and make all parties to the marriage safe. So even though nikāh means that we know the couple is married, registering is equally important. There is no contradiction between Islam and civil registration of marriage. In fact one supports the other." The general mood of the meeting led Shaheen to infer that this group of women were clear in their views regarding the importance of civil registration of a nikāh. They appeared aware of developments in their country of origin (Pakistan) declaring that: "people in Pakistan fill out marriage forms and have certificates that are recognised by law, so what is the difference between those marriage registrations and the one in 12 Describing it as the 'Manchester dars group' was due to the fact that it had been set up by those living in Manchester but with membership from surrounding towns.

13
Ages of members ranged from 35-80 years. Most members were over 60 although younger membership was being encouraged.
"Why are you asking us whether nikāh ought to be registered? Of course it has to. How else would the couple be married in the eyes of the law in this country?" When asked why some did not wish to register their marriage, a 75 year old gentleman who said he had lived in the country for over fifty years remarked: Significantly, she also noted that the cuts to legal aid since the Legal Aid, Sentencing and Punishment of Offenders Act (2012) has withdrawn funds from family law litigation, depriving victims of legal assistance and thus rendering many women even more vulnerable. They are put into weaker positions vis-à-vis family, and possibly, forced to seek intervention by unregulated community bodies, such as shari'ah councils. 15 Khan's statement reflected the common surprise -both within Britain's Muslim community and also internationally -that British law has adopted so few legal measures to promote civil registration of nikāh marriages. This is contrary to the laws 14 For a full transcript of the panel and more detailed commentary than is possible here, see the blog on ShariaSource available in seven parts at: https://islamiclaw.blog/2019/11/20/ muslim-marriage-and-divorce-practices-in-contemporary-britain-part-1-introduction/; https://islamiclaw.blog/2019/12/06/muslim-marriage-and-divorce-practices-in-contemporary-britain-part-7-conclusions-and-further-observations/.
implemented both in other Western European nations, like France and Germany, but also in most Muslim-majority nations. These countries, she argued, have done more to put an end to the existence of the kinds of 'clandestine marriages' that still exist in the UK.
As well acknowledging the prevalence of unregistered, marriage, many panellists were alert to an assortment of other problems that it creates. One example is Bana Gora, president of the Muslim Women's Council, a community organisation based in Bradford. 16 She noted a range of startling cultural practices which are, in different ways, by-products of unregistered nikāhs, many of which violate the rights of women especially. These include polygamous and underage marriages; the withholding of alimony after divorce; the unequal distribution of inheritance; and instant triple-ṭalāq divorce. All of these practices exist as a consequence of unregistered nikāhs.
Other panellists, however, indicated a body of other reasons for the choice to take out a nikāh-only marriage, some of which make for uncomfortable listening. Some confirmed that some members of the younger generation of Muslims as a form of 'halal dating', or a means of 'testing' a marriage before taking on the legal commitments of a registered marriage. Some also suggested that it often owed to carelessness on the part of young Muslims. Ajmal Masroor, one of Britain's most high-profile imams, 17 blamed especially the 'Bollywood' influence in popularising glamour weddings, and the frequent use of nikāh-marriages as easy means of licencing sexual relationships. A culture of celebrity and ebullience, he argued, can cloud reflection and judgement, and incite young people to take out 'DIY nikāh marriages,' or 'backstreet nikāhs', with little consideration of the consequences. The pressure of imams, khandans (families) and biradaris (community bodies), he argued, also exact unwelcome social influence in matrimonial matters.
16 https://islamiclaw.blog/2019/12/03/muslim-marriage-and-divorce-practices-in-contemporary-britain-part-6-bana-gora/; Bana Gora has particular expertise in matters of social policy and engagement with marginalized communities in particular, and at present is involved in the MWC's plans to build the first ever woman-led mosque in the UK.
17 ttps://islamiclaw.blog/2019/11/29/muslim-marriage-and-divorce-practices-in-contemporary-britain-part-5-ajmal-masroor/. Masroor leads prayers in four London mosques, and has been a high-profile spokesperson and broadcaster for British Muslims. He has been a well-known proponent of reformist Islamic thought, including on issues of family values and laws, and has headed the Barefoot Institute, which handles matters of marriage, divorce and family mediation for British Muslims. Departing from the idea that nikāh-only marriages stemmed chiefly 18 https://islamiclaw.blog/2019/11/27/muslim-marriage-and-divorce-practices-in-contemporary-britain-part-4-amra-bone/; Bone has also worked as a Muslim leader and chaplain within the community in Coventry and Birmingham for some thirty years.
19 ttps://islamiclaw.blog/2019/11/26/muslim-marriage-and-divorce-practices-in-contemporary-britain-part-3-musharraf-husain/; Trained at al-Azhar in Cairo, he is a scholar of the Qurʾan and Islamic sciences, and is a public community spokesperson and educator; he is also the chief executive of the Karimia Institute, an Islamic foundation that engages in numerous activities of religious education and charity. He has been an important Muslim spokesperson on issues of integration and community cohesion in the UK.
from ignorance, he argued that it was often a proactive choice, made either by partners or their families. Despite having registered his mosque to conduct parallel religious and civil marriages, he argued that many of even his own congregation have refused to take out the latter, asking him to perform nikāh-only marriages. Muslim marriage in the UK, he suggested in a striking metaphor, has become like a 'Drive Thru McDonalds', with Islamic marriages and divorces being contracted and terminated with minimal planning or consideration.
While he reflected some similar explanations to the other panellists (e.g. avoiding legal obligations to a spouse; carelessness by the parties), he also noted that Muslims do not instinctively consider their mosque as a natural location for marriage, meaning that, unlike Christians, Muslim families often envisage their nikāhs as being solemnised in private settings, rather than a religious building that can be licensed for marriages. But he also argued that many imams and religious leaders in Britain, fearing the erosion of community values, have wanted to keep marriage 'flexible…, feasible and easy' as possible, and thus, they have avoided complicating the nikāh with legal conditions or baggage in order to bring people into marital unions.
Attitudes within the community are only part of the explanation, however. The state has also played a part: by refusing to legislate on nikāh-only marriages, it has allowed them to persist. Indeed, elaborating on the state's role, Husain offered a striking interpretation of ongoing Muslim disengagement from marriage registration, which goes back to the initial migrations from South Asia in the 1950s-60s. At this time, he argues, economic migrants from Pakistan and Bangladesh considered the UK to be merely a 'transient home': they remained focused upon 'the myth of return', 20 while the state offered little support for these new communities and merely 'left' them to integrate. This 'laissez faire attitude' on the part of the state towards the Muslim population served to foster an ethic of community self-reliance that has led to tendencies among Muslims towards community autonomy in to handling personal and community affairs, and has meant that many Muslims have tended to see questions of state recognition as an irrelevance.
The views of the panellists, therefore, confirmed some of the same issues raised by respondents in other research elements of this study. Equally, they posited a range 20 This is an allusion to Anwar, Muhammad (1979), The Myth of Return: Pakistanis in Britain. London: Heinemann Educational Books.
of possible solutions to the problem of unregistered Muslim marriages. Aina Khan, speaking of her 'Register Our Marriage' campaign, outlined a three-fold approach to addressing the issue. First is the call for reform of the law. She proposes that the Marriage Act of 1949 be widened to automatically register all religious marriages as civil marriages, rather than, as now, only the marriages of Anglicans, Jews and Quakers: a fair and equal marriage law, she argues, should either cover all faiths, or none. Second, she argues for a public awareness campaign to target the Muslim community, working through 'roadshows' and other large events, to communicate the benefits of registering marriage. This is something that her campaign has consistently embarked upon. Third, there is a call for further research and professional advocacy, with a particular proposal for the construction of an international database to identify landmark court judgements and compare international mechanisms for adjudicating religious marriages.
Other community figures tried to answer the question not just in terms of the law, but the need for proactive engagement from community leaders. Musharraf Husain was among those who, unlike Aina Khan, saw little appetite within the government for any major interventions into the laws of Muslim marriage in the UK; and for him, this suggested that community practitioners needed to find solutions themselves.
He noted his own licencing of his mosque for marriage as an example, along with his encouragement of his congregations. He also describes how the nikāh certificates that his association provides include a written statement that a nikāh-marriage must be registered for it to be considered valid. This mechanism is comparable with some of the ways in which shari'ah councils have found ways to engage religious and civil laws alongside each other; for instance, issuing khula͑ s (Islamic divorces) upon the presentation of a civil divorce certificate. 21 There is, then, the prospect for aligning civil and religious laws of marriage and divorce in mutually constructive ways.
Ajmal Masoor identified the need for more responsible community handling of matrimonial issues: not just of families, but also, the need for qualified imams to  marriages, but also the Muslim women who as one panellist stated, wouldn't mind being in a polygamous union and in an almost 'part-time relationship'. These diverse factors at play mean that we cannot make generalisations.
Other quoted factors in the debate include pressure from in-laws to avoid registration; or an obsession with the glamour and show of marriages without due attention to legal niceties. There is also the matter of the difference between a Muslim idea of marriage, which is based around an officiating person (imam, qazi etc), and the Marriage Act of England and Wales that predicates the registration of marriage upon the place in which it occurs; as many respondents reflected, a mosque is not inherently seen as a natural location for a marriage. There is also the suggestion that long-term patterns of immigration and a 'laissez faire' state attitude towards integration in Britain have encouraged a disengaged attitude within the Muslim minority towards English civil laws, and a consciousness of organising the community's internal affairs on their own terms.
Yet, a striking feature evident that runs through these discussions is the sense that some That said, across this study, the overwhelming impression is that taking out a nikāh-only marriage reflects the value placed on the nikāh contract itself for British Muslims. It seems clear from these extracts that many British Muslims have maintained a deep sense of the need for religious marriages and divorces; and many consider the nikāh rather than the civil marriage to be the one that carries meaning for them, even when they may hold both together. To argue that this feeling will somehow dissipate in the face of authoritative civil laws seems to be a spurious debate. At the same time, though, these marital practices as discussed are all being developed within a self-consciously British Islam, rather than being 'foreign' cultural norms imported in wholesale from elsewhere.
While some speakers indicate that certain attitudes towards marriage reflect a residual 'memory' of countries and cultures of origin (South Asia particularly is cited by several), for the most part informants are keen to emphasise that these communities consider themselves as British Muslims and are thus in need of matrimonial customs and laws that work within the British context.
We pledged in the introduction to offer some possible responses to the considerable challenges in accommodating Muslim and civil laws of marriage as they exist in Britain today. Of course, bringing nikāh-only marriages into the fold of the English legal system via compulsory registration could take away some of the manipulative uses of nikāh-only marriage as discussed, and could resolve some of the 'nikāh horror stories' of women being divested of their rights or homes after the dissolution of their nikāhs.
However, as some point out, the state is in no mood to introduce any substantive legislation on the matter. The issue is perhaps too politically sensitive; and as one respondent notes, the state has come to rely increasingly on practices of arbitration to resolve disputes outside a crowded court system, especially in the aftermath of cuts to legal aid. State intervention, therefore, seems unlikely to provide a holistic response.
Instead, it is clear that the more lasting solution rests in a multiplicity of options. For instance, there are perhaps gentle shifts in debate at the judicial level. For example, the recent court case of Akhter vs Khan (2018) resolved that a nikāh-only marriage should be considered a 'void marriage' rather than a 'non-marriage', which would make a Muslim marriage subject to laws of financial reparation in the case of marital breakdown. 23 The verdict may yet be repealed, but it does indicate movement in legal thinking.
But major moves to resolution also have to come from within the community itself.
And contrary to some portrayals, these contributions reveal that there is obviously considerable will from within the community to do this. The vast majority of our respondents, as well as our panellists who include two imams and a panellist on a major Shariah council, argue that Muslims should register their marriages with the state and should remain cognisant of their rights and duties before the law. They also argue, explicitly or implicitly, that since the nikāh's fundamental status in Islam is that of an official contract, so an Islamic marriage needs to be legally recognised if it is to be legitimate. And they are finding ways to align the parallel issuing of civil divorces and Islamic khula͑ separations. These are just a few examples of how community leaders are advocating the engagement of British Muslims with the legal system.
Our findings hint at various possibilities for aligning Islamic and civil laws, finding ways to make them work together as mutually cognisant systems of law in British Muslim society. It seems to be a debate that is only likely to continue.