ABSTRACT
This dissertation explores the application of the CISG in Islamic countries – Egypt, Iraq, Syria, Libya, Oman, UAE, Bahrain, Yemen, Kuwait, Morocco, Malaysia, Qatar, and Saudi Arabia – examining how its provisions align or conflict with Islamic legal principles, especially in areas such as contract formation, obligations, and dispute resolution. It investigates the degree to which Islamic countries have adopted or rejected the CISG, analyzes legal and practical challenges to its implementation in these jurisdictions, and evaluates potential avenues for harmonizing international contract law with Shariah. The study draws on comparative legal analysis, case law, and doctrinal scholarship to assess the compatibility of the CISG with Islamic jurisprudence and suggests recommendations for improved integration and legal reform.
Daadoush, Ghazal Hisham, The Intersection Of The CISG (Convention On Contracts For The International Sale Of Goods) and Islamic Law (Saudi Arabia) (January 22, 2025).
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