Introduction: The Legal Discourse
The order of the judgment signed by the five judges of the Supreme Court dated 22 August 2017 clearly stated, “in view of the different opinions recorded, by a majority of 3:2 the practice of‘talaq-e-biddat’ — triple talaq is set aside.”1 The majority verdict has termed the instant triple talaq void ab initio (illegal at the outset) while describing the practice as ‘manifestly arbitrary.’ It was not the first time that an Indian court has invalidated the practice of instant triple talaq.
The majority view also unequivocally declared that the instant triple talaq went against the basic tenets of the Holy Quran and violated the Islamic law or the Shariat. The Supreme Court judgment in August 2017 mentions that in 1981, Justice Baharul Islam of the Guwahati High Court, who later became a judge in the Supreme Court, had invalidated the instant triple talaq. It was possible because he did focus on the Quranic verses while laying down the procedure for pronouncing talaq and how he had corrected the error of early English authors and judges who dealt with talaq in Muslim Law by favouring the famous comment, ‘good in law though bad in theology.’2 The lawyer and women’s activist, Flavia Agnes, points out that ‘since 1981 to 2002, various high courts had followed the Guwahati judgement.’3 In 2002, the Supreme Court also invalidated arbitrary triple talaq and suggested the correct talaq procedures in the Shamim Ara case.4 It was a judgment that was also recognised by the All India Muslim Personal Law Board (AIMPLB).5 There have been two more important judgments, one delivered in 2002 by the Bombay High Court in Dagdu Latur vs. Rahimbi Dagdu Pathan and another in 2007 by the Delhi High Court in Masroor Ahmed vs. State, where both judgments have questioned the validity of instant triple talaq as a legitimate form of divorce.6The majority verdict of the court has termed the instant triple talaq void ab initio (illegal at the outset) ‘manifestly arbitrary.’ It also issued an immediate injunction on such a practice for the next six months until the new legislation was enacted, along with a caveat that the injunction would cease to operate without such a law.
However, following the Supreme Court judgment of August 2017, the central government introduced and passed a legislation named The Muslim Women (Protection of Rights on Marriage) Bill in December 2017 in the Lok Sabha. In the Rajya Sabha, the government could not pass the bill. As a result, the government issued ordinances in September 2018 and February 2019. However, as the 16th parliament was dissolved, the bill lapsed. After the 2019 Lok Sabha elections, a newly formed government took the oath. In the first session of the 17th Lok Sabha, a new bill on triple talaq was introduced on 21 June 2019. The bill clearly states that talaq-e-biddat is illegal and puts deterrence to its usage by having a provision of three years imprisonment and a fine for any Muslim husband who pronounces such a form of talaq. The Lok Sabha subsequently passed the bill on 25 July 2019 and the Rajya Sabha on 30 July 2019.
The noted theologian and social activist Asghar Ali Engineer has been making a case for reforms of Muslim Personal Law in India for decades. The Muslim Personal Law is dated and needs urgent modification in the fast-changing modern world. The first step for such reforms of Muslim Personal Law is to codify it.7 It should be mentioned here that the grounds and procedure for talaq were not codified in the 1937 Shariat Act, as pointed out by the judgment ofJustice Kurian Joseph.8 A similar argument was made by the then-chiefJustice Jagdish Khehar and S. Abdul Nazeer in the 2017 Supreme Court Judgment.9 Apart from references to the Quran, the Supreme Court judgment made some references to noted Islamic scholars and theologians like Maulana Wahiduddin Khan and Asghar Ali Engineer, both of whom have passionately argued for reforming the Muslim Personal Law in their several treatises. Engineer, for instance, has long been popularising the idea of ijtihad (exertion and creative interpretation and application of Islamic fiqh or Islamic jurisprudence) in the light of new contexts and circumstances.
His treatise on the rights of women in Islam, by going through the lineage of Islamic history, debates within Islamic theological schools, and the sociological influences in the making of Shariah and engaging with a modernist interpretation (tafsir) of the Quran by Maulana Abul Kalam Azad, is a seminal contribution on the topic of Islamic law and theology about Muslim women.10 In this regard, a deeper scholarly look at the Islamic theological discourse concerning triple talaq and the provisions of prohibitions of uttering triple talaq and the deterrence for such a practice, if any, must be explored.of Islamic law, the divorce laws in Islam are unevenly distributed where the husband ‘has in principle an unlimited access to divorce, while the wife may only ‘borrow’ this access from the husband, and only under very specific circumstances’.12 Here, the exact Quranic source, ayah number 228 of Chapter 2 (Surah Al-Baqarah), reads:
And the divorced women shall undergo, without remarrying, a waitingperiod of three monthly courses: for it is not lawful for them to conceal what Allah may have created in their wombs, if they believe in Allah and the Last Day. And during this period their husbands are fully entitled to take them back, if they desire reconciliation; but, in accordance with justice, the rights of the wives [with regard to their husbands] are equal to the [husbands’] rights with regard to them, although men have precedence over them [in this respect]. And Allah is almighty, wise.13
In the case ofjudicial divorce, the Hanafi school is the most restrictive because of its great emphasis on ‘wording and formalities’.14 For women seeking a divorce, the Hanafi school typically accepts ‘an annulment (faskh orfasad) by a judge, not divorce per se because according to the Hanafi rules, only the husband can pronounce talaq or accept a khula’.15 Scholars of Islamic law points out that the Hanafi courts have often accepted that there is ‘a real weakness in their law, which has led to unacceptable hardship for women who through no fault of theirs have lost their only realistic provider’.16
The divorce laws favouring Muslim men have a close relationship with the idea of slavery and marriage in early Islam.
In this respect, Kecia Ali, a scholar of early Islam, suggests that the institutions of patriarchy, social stratification, and slavery, in particular, had a significant impact on the role and the status of the wife and the husband in marriage.17 The triad of marriage, slavery, and concubinage (milk al-yamin) intersected in early Islam.18 As Ali argues, ‘[s]lave concubinage helped define marriage both by comparison and contrast. To discuss marriage in the premodern period without reference to slavery would fundamentally distort the jurists’ ways of thinking; the one was bound up with the other, even more so in legal thinking than in actual practice’.19 According to classical Islamic jurisprudence, marriage, in essence, was seen as a type of ownership (milk), which is based upon a contract between the parties giving rise to mutually dependent gender-based rights and obligations. At the core of this contract was a transaction whereby a wife’s sexual availability was exchanged for her right to be financially supported and maintained.20 Furthermore, in a previous paper, she states that “at its most basic, the [classical] jurists shared a view of marriage that considered it to transfer to the husband, in exchange for the payment of dower, a type of ownership (milk) over his wife, and more particularly over her sexual organ (farj, bud )”.21 Based on such a concept of marriage, a woman's constant obligation to be sexually available to her husband resulted in granting to the husband ability to take control over his wife’s mobility to such an extent that he could prevent her from going to the mosque, visiting her parents, or even from attending the funeral of her immediate family, including her parents and children.22 Such a view of marriage, in addition to other laws of divorce and child custody and the strictly associated gender-differentiated marital rights and obligations, resulted in the creation of a hierarchical, authoritarian marital relationship and a creation of a classical Islamic tradition based on male epistemic privilege.23However, like any other community, divorce within the Muslim community is not just related to the rules of theology and laws of the state.
The divorce rates also depend on the socio-economic structure prevalent in a society at a given point in time. For example, in the late medieval urban centres of Cairo, Damascus, and Jerusalem, the divorce rates were high, and wives often initiated the divorce just like their husbands. Because of the relative economic independence of women in these late medieval cities with the transmission of dowries to women, women’s access to waged labour in textile-related cottage industries, and a strict separation of property between spouses were noticed.24 In contemporary India, social structure has been primarily responsible for the occurrence of divorce among Muslims. The divorce rates have been much lower among Indian Muslims. A positive approach to remarry Muslim widows is present within the Muslim community, although there is scope for the codification of Muslim divorce laws by combining various aspects of divorce laws prevalent within different theological schools among Indian Muslims.25The Supreme Court judgment mentions a hadith from Musannaf ibn Abi Shaybah regarding Caliph Umar’s punishment by beating the person who had pronounced triple talaq in one go. The exact wording in the judgment is as follows:
If a person who had pronounced Triple Talaq in one go was brought to Caliph Umar he would put him to pain by beating and thereafter separate the couple.26
However, the above hadith compiler is not regarded as a top-ranked one like the six Sahih hadith (authentic hadith) compilations like al-Bukhari, Muslim, Abu Dawud, al-Tirmidhi, al-Nasa’i, and Ibn Majah. Musannaf ibn Abi Shaybah is instead placed in the second-ranked hadith compilations because of its several dhaif (unauthentic) hadiths. However, one must note that this particular incident was reported in the Al-Kashshaaf (The Revealer), the seminal tafsir (commentary) on the Quran by the Persian Mutazilite scholar, al-Zamakhshari. Interestingly, it was quoted by none other than Sayyid Abul Ala Maududi, the founder of Jamaat-e-Islami in South Asia and a formidable Islamic scholar in his Tafhim al-Qur'an (The Meaning of the Qur’an).
In doing so, Maududi presented his argument against instant triple talaq while commenting on the Quranic verse on divorce.27 To quote Maududi, ‘Zamakhshari has stated in al-Kashshaf that Hadrat 'Umar used to beat the man who would pronounce three divorces on his wife (at one and the same time) and then would enforce his divorces.’28 Thus, it is not clear whether this particular hadith of Musannaf ibn Abi Shaybah is unauthentic. Otherwise, Maududi would not have cited it, given his tendency to look for authenticity and rely more on the purity of the Islamic tradition.If Caliph Umar’s beating up a person for pronouncing instant triple talaq is taken into consideration, then it is nothing short of a punishment for the use of talaq-e-biddat. Thus, the link between civil matters, in this case, and the issue of instant divorce to criminal offence, has a precedent in Islamic history and that too during the reign of the second caliph, Umar ibn al-Khattab, or Umar al-Faruq. The surprising fact is that talaq-e-biddat became widespread in the Muslim world for several centuries on the ground of an emergency to accept the practice of pronouncing three divorces in one sitting, as final and irrevocable.29 This particular ordinance of Caliph Umar had no impact on Hazrat Ali’s eldest son, Hasan, who had ‘a brief and inglorious reign of five or six months’ after Ali’s death.30 William Muir narrates the story of Hasan, the son of Ali and Prophet’s grandson, in the following manner. Hasan was more interested in his ‘ever changing harem than on the business of public life’, for his ‘vagrant passion gained him the nickname The Divorcer, for only by continual divorce could he harmonise his craving for new nuptials with the requirements of the law, which limits freeborn wives to four’. Hasan is said to have exercised the power of divorce ‘as a matter of simple caprice, seventy (other say ninety) times. When the leading men complained to Ali that his son was continually marrying their daughters, and is often divorcing them, Ali said that ‘the remedy lay in their own hands; they should refuse to give him their daughters as wife. These divorced wives were in addition to slave-girls, with whom there is no limit’.31 Interestingly, Ali was not harsh on Hasan by punishing him or beating him because one cannot divorce frequently and wishfully according to the ordinance once passed by the second Caliph, Umar.
The Supreme Court judgment mentions that it was an act of exigency on behalf of Caliph Umar to discourage the abuse of divorce and to ‘prevent misuse of the religion by the unscrupulous husbands’.32 During the lifetime of the Prophet and the caliphate of Abu Bakr, the first caliph and the first two years of Caliph Umar, three pronouncements of ‘talaq’ by three consecutive utterances were treated as one. This has also been the view of a noted Islamic scholar, Maulana Wahiduddin Khan.33
Significant sections within the Indian ulama have been primarily responsible for the selective interpretation of the practices of talaq. For example, in his biography on the second Caliph, Umar, Shibli Numani mapped the various civil, administrative, and military reforms and achievements of Umar but did not utter a single sentence regarding Umar’s act of punishing those who used to pronounce instant triple talaq.34 At the same time, the Indian ulama also had the backing of the Indian state in both the colonial and postcolonial periods that followed the policy of non-interference in personal laws, although such a principle of noninterference was not always practised consistently.35 In the context of the liberalised modernity in contemporary India, a new generation of men and women within the Muslim community has emerged who are increasingly inclined to control and govern their own lives rather than looking for advice from the religious clergy. At the same time, this liberalised modernity is also coupled with the emergence of the Hindutva right, which looks at personal laws as an impediment for national integration and favours a state policy of interference in personal laws, unlike the tradition of non-interference of the Indian state. This twin process has made the position of the Indian ulama more vulnerable. As a result, the conservative sections of the Indian Muslims, often backed by the conservative ulama within the Muslim community, sharply react to any proposal for reforms of the Muslim Personal Law.
In the wake of the triple talaq debates, of late, moderate Muslim commentators have been publicly arguing against the practice of triple talaq based on the Quranic principles and the practices and legal reforms of Islamic family laws in many Muslim countries, along with the call for introspection of the Muslim community in India to relinquish the practise of instant divorce.36 Weeks after the Indian parliament passed the triple talaq bill, Pakistan’s Council of Islamic Ideology, a constitutional body in Pakistan that advises the government on legal matters, recommended that the practice of triple talaq or instant divorce be deemed a punishable crime.37 The law minister of Pakistan, Farogh Naseem, also mentioned a precedent in Islamic history where the state was punishing an act of instant triple talaq. He said the second caliph, Hazrat Umar, had punished those who performed the act of instant divorce.38
The Muslim Personal Law in India does not have any guidance for the Muslims regarding domestic violence, although, in Islamic traditions, mild wife-beating for discipline is permissible. The exact Quranic reference in the form of ayah number 34 of Surah An-Nisa for such a justification of domestic violence is the following:
Men shall take full care of women with the bounties which God has bestowed more abundantly on the former than on the latter, and with what they may spend out of their possessions. And the righteous women are the truly devout ones, who guard the intimacy which God has [ordained to be] guarded. And as for those women whose ill-will you have reason to fear, admonish them [first]; then leave them alone in bed; then beat them; and if thereupon they pay you heed, do not seek to harm them. Behold, God is indeed most high, great!39
Only based on this one ayah of the Holy Quran, an entire scholarly book has been written recently by an Islamic feminist, Ayesha Chaudhry.40 Her work is a nuanced understanding of the Quranic verse number 34 of Chapter 4 (Q, 4: 34) that has implications for domestic violence in both precolonial and postcolonial Islamic traditions, along with the debates between the patriarchal cosmologies and egalitarian visions of Islam. Chaudhry suggests that in the living Muslim community of today, there could be a non-violent reading of the verse, but only after there is a process of demythologisation of Islamic tradition. Such demythologisation can be done by transferring authority from the mythically pristine tradition to the living Muslim community that could treat Qur’Tn as a performative text whose meanings could be derived through its interactions with various believing communities among Muslims. It is a work of contemporary Islamic feminism that has been inspired by the interpretative methodology and the rich interpretative tradition in Islamic studies. It is closer to what could be described as a hermeneutic tradition in Islam that scholars like Shahab Ahmed have recently suggested about a conceptually robust analytical framework for making a difference between Islam as a theoretical object and Islam as an actual historical phenomenon practised in the theological form.41
The issue of domestic violence is within the domain of private lives, but it is not within the bounds of the personal laws of Muslims in India, as expressed in the form of the Islamic Shariat Act of 1937. Instead, the issue of wife beating is within the purview of the country’s domestic violence laws. Thus, there have been cases of exceptions where the private domain is not treated as a civil matter but as a criminal matter. It is evident in the contradiction between the permissibility of wife beating in Islamic tradition and the criminal nature of such an act under the country’s domestic violence act. One could argue that if domestic violence as a private matter is not dealt with within the confines of the personal laws and instead dealt with by the country’s criminal laws, then the instant triple talaq that can be traced within the domain of the private lives of the Indian Muslims could also be dealt by a criminal procedure when instant triple talaq has grave consequences for the lives of Muslim women. According to Asaf Fyzee’s classic text, talaq-e-biddat either in the form of instant triple declaration of divorce or a single irrevocable declaration is sinful and disapproved but not illegal for the Hanafi school.42 Here, the relevance of law comes to the picture, for sin is the domain of morality. Morality, as such, does not consistently deliver justice and fairness. To reach the goal ofjustice and fairness, the domain and tool of law is a necessary starting point rather than appealing to the morals and the theological guidelines. Moreover, if the pronouncement of instant triple talaq has done some injustice, then there is no deterrence to such an act without a good law and that too without a clause for punishment. One might debate the nature of punishment in the existing Bill of 2019. However, the principle of punishment for pronouncing instant triple talaq has a precedent in Islamic history. The point is that laws are not static, and even what we know today as Muslim Personal Law is a result of an evolutionary process of reforms for centuries. Thus, personal laws can be and must be reformed to address the new contexts, necessities, and changing scenarios of the social lives of Indian Muslims.
In the recent past, Muslim women writers like Noor Zaheer have raised their voices against the medieval nature and sexist bias in Islamic laws that often deprive Muslim women of certain rights guaranteed under the Indian constitution. Based on several interviews and discussions with aggrieved Muslim women and attending public hearings on halala, triple talaq, muta’h, and khula, she has tried to expose how the archaic nature of Islamic laws in practice are negatively affecting the everyday lives of Muslim women in India.43 At the same time, survey-based empirical work on the problems of Muslim women concerning divorce has been present in the public domain for decades.44 In the context of stereotypical attacks against Islam and Muslims, of late, there has also been some literature from Muslim human rights scholars about how Islam discourages polygamy and divorce and how the Islamic laws were a deterrent to stop several unfair and inhuman practices in pre-Islamic Arabia.45
The judgment of the Supreme Court and the 2019 bill can usher in a new process of articulating political demands from both within and outside the Muslim community for reforming personal laws. Nevertheless, it will also have to go through the hegemonic struggle for a gender-just society by reforming the personal laws of all the religious communities in India. Otherwise, it would be too obvious that only a particular minority community is targeted for meeting the political ends of majoritarian nationalist politics. If a progressive initiative for personal law reforms is being made in the future, then it must be preceded by democratic forms of broader public debates, followed by a referendum among each religious community in the country. However, the first step towards reforming the Muslim Personal Law will be to create a space of honest dialogue, debates and discussions within the various Muslim communities in India across caste and linguistic differences. Through dialogue, genuine initiatives must be taken by the progressive sections of Indian Muslims to convince and pursue the conservative sections of the Muslim community in reforming the personal law in general and banning the practice of instant triple talaq in particular. The political discourse on reforming the Muslim Personal Law will be settled only through unanimity among various stakeholders of the Muslim community in India rather than mere legal pronouncements and administrative exercises implemented from above. Unless a broad agreement is reached among the Indian Muslims on this issue, abuse of settled law by the court will be experienced in some remote corner of the country given the patriarchal and conservative nature of a section of Muslim ulema in India.
Notes
1 The Supreme Court Judgment on Instant Triple Talaq, dated 22 August 2017, 395.
2 Ibid., 49-58, 181-182, 287-289.
3 Tish Sanghera, “‘Wrong to Brand Everything Concerning Islam Anti-Women': Lawyer-activist Flavia Agnes Speaks on Darul Qazas, Triple Talaq,” Firstpost.com, 23 September 2018, accessed September 19, 2019, https://www.firstpost.com/india/ wrong-to-brand-everything-concerning-islam-anti-women-lawyer-activist-flavia- agnes-speaks-on-darul-qazas-triple-talaq-5245221.html.
4 Supreme Court of India judgment on Shamim Ara vs State of U.P. & Anr on 1 October 2002, accessed September 19, 2019, available https://indiankanoon.org/doc/332673/a.
5 Moeena Halim, “Interview of Flavia Agnes: ‘Merely Getting Rid of Personal Laws Won't Reform Society',” India Today, 16 February 2019 accessed September 19, 2019, https://www.indiatoday.in/magazine/the-big-story/story/20170220-triple-talaq- flavia-agnes-womens-rights-activist-interview-985731-2017-02-16.
Sonakshi Awasthi, This Is Not the First Time Indian Courts Have Invalidated Instant TripleTalaq,’ ’ Indian Express, 22 August 2017, accessed September 19, 2019, https://indian express.com/article/india/this-is-not-the-first-time-indian-courts-have-invalidated- instant-triple-talaq/.
Engineer, Asghar Ali, “The Need for Codification and Reform in Muslim Personal Law in India,” in Dossier 22, ed. Harsh Kapoor (Grabels Cedex, France: Women Living Under Muslim Laws, 1999).
The Supreme Court Judgment on Instant Triple Talaq, 276.
Ibid., 173.
Engineer, Asghar Ali, Rights of Women in Islam [1994], 3rd enlarged ed. (New Delhi: Sterling Publishers, 2008).
Hallaq, Wael B., Sharia: Theory, Practice, Transformations (New Delhi: Cambridge University Press, 2009), 280.
Vikor, Knut S., Between God and the Sultan: A History of Islamic Law (New Delhi: Foundation Books, 2005), 309.
2:228 of The Holy Quran; source quoted from The Message of the Quran: The Full Account of the Revealed Arabic Text Accompanied by Parallel Transliteration, complete ed. [2003] trans. and explained by Asad (2008: 61).
Vikor, Knut S., Between God and the Sultan, 313.
Ibid.
Ibid., 313-314.
Ali, Kecia, Marriage and Slavery in Early Islam (Cambridge, MA: Harvard University Press, 2010).
Ibid., 8.
Ibid.
Ibid., 29-65.
Ali, Kecia, “Progressive Muslims and Islamic Jurisprudence: The Necessity for Critical Engagement with Marriage and Divorce Law,” in Progressive Muslims — On Justice, Gender and Pluralism, ed. O. Safi (Oxford: Oneword, 2003), 172-179.
Ibid., 170.
Duderija, Adis, Constructing a Religiously Ideal “Believer” and “Woman” in Islam: Neo- traditional Salafi and Progressive Muslims' Methods of Interpretation (New York: Palgrave Macmillan, 2011), 103.
Rapoport, Youssef, Marriage, Money and Divorce in Medieval Islamic Society, (Cambridge: Ca mbridge University Press, 2005).
For an elaborate discussion on these issues, see various chapters in Ahmad, Imtiaz, ed., Divorce and Remarriage among Muslims in India (New Delhi: Manohar, 2003).
The Supreme Court Judgment on Instant Triple Talaq, 134-135.
Sayyid Abul Ala Maududi, Tafhim al-Qur'an (The Meaning of the Qur'an): 65. Surah At-Talaq (Divorce), accessed September 15, 2019, https://archive.org/ stream/Maududi-Tafhim-al-Quran-The_Meaning_of_the_Quran/065%20-%20 At-Talaq%20%28%20The%20Divorce%20%29_djvu.txt.
Ibid. accessed September 15, 2019, https://www.englishtafsir.com/Quran/65/index. html.
The Supreme Court Judgment on Instant Triple Talaq, 90.
Muir, Sir Willia m, The Caliphate: Its Rise, Decline, and Fall. Orientalism: Early Sources, vol. III [1891]. (London: Routledge, 2000), 302.
Ibid., 302-304.
The Supreme Court Judgment on Instant Triple Talaq, 90.
The Supreme Court Judgment on Instant Triple Talaq, 77.
Numani, Shibli, ‘Umar: An Abridged Edition of Shibli Numani’s ‘Umar al-Faruq (New Delhi: Oxford University Press, 2004).
Williams, Rina Verma, Postcolonial Politics and Personal Laws: Colonial Legal Legacies and the Indian State (New Delhi: Oxford University Press, 2006).
See the arguments presented in A. Faizur Rahman, “The Muslim Law Board’s Decision on Triple Talaq Is Irrational and Wrong,” The Wire, 9 September 2015, accessed September 15, 2019, https://thewire.in/gender/the-muslim-law-boards- decision-on-triple-talaq-is-irrational-and-wrongAlso, see Moin Qazi, “The Triple Talaq Conundrum,” Countercurrents.org, 9 January 2018, accessed September 15, 2019, https://countercurrents.org/2018/01/triple-talaq-conundrum.
See the news report, “Make Triple Talaq a Punishable Crime in Pakistan: Islamic Advisory Body,” India Today, 6 September 2019, accessed September 15, 2019, https:// www.indiatoday.in/world/story/make-triple-talaq-a-punishable-crime-in-paki- stan-islamic-advisory-body-1596438-2019-09-06.
Ibid.
The Holy Quran; source quoted from The Message of the Quran: The Full Account of the Revealed Arabic Text Accompanied by Parallel Transliteration, complete ed., trans. and explained by Asad (2008), 126—127.
Chaudhry, Ayesha S., Domestic Violence and the Islamic Tradition (Oxford: Oxford University Press, 2013).
Ahmad, Shahab, What Is Islam? The Importance of Being Islamic (Princeton: Princeton University Press, 2015).
Fyzee, Asaf A. A., Outlines of Muhammadan Law [1949], 4th ed. (Delhi: Oxford University Press, 1974), 154-155.
Zaheer, Noor, Denied by Allah (New Delhi: Vitasta, 2015).
Moinuddin, S.A.H., Divorce and Muslim Women (Jaipur: Rawat Publications, 2000).
Muntaqim, Khwaja Abdul, Islam Discourages Polygamy and Divorce: A Reality, Not a Myth (Delhi: Kalpaz Publications, 2016).