Wawan Hermawan, Mohammad Rindu Fajar Islamy, Achmad Faqihuddin, Miftahul Ulum
This study examines the implementation of Islamic law in diaspora naturalization, comparing dynamics across the Middle East, Southeast Asia, and the West. While naturalization has expanded globally due to economic integration, political participation, and security concerns, the role of Islamic law varies regionally. Using a qualitative comparative approach, this research analyzes policies in the three regions, supplemented by a Quantitative Systematic Literature Review (SLR) of Scopus-indexed journals under the PRISMA model. Findings reveal stark contrasts: In the Middle East, Islamic law is central to citizenship, particularly in religion-based status and family law, with deep integration into national legal systems. Southeast Asia adopts a more adaptive approach, prioritizing economic and skill-based naturalization while retaining Islamic principles in marriage and inheritance. Conversely, Western secular frameworks exclude formal recognition of Islamic law in naturalization, though diaspora communities often navigate dual legal realities. The study highlights how regional legal traditions, socio-political contexts, and migration policies shape these disparities. It concludes that Islamic law’s influence persists most strongly in the Middle East, remains contextually flexible in Southeast Asia, and operates informally in the West despite systemic secularization. These insights contribute to debates on religion, migration, and legal pluralism in global citizenship regimes. © 2025, Syarif Hidayatullah State Islamic University (UIN) Jakarta. All rights reserved.
Universitas Pendidikan Indonesia, Indonesia; Warwick University, United Kingdom
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