Justice Dr. Nasim Hasan Shah

Retd. Chief Justice of Pakistan

Males and females under Islam have equal rights, but perform complementary functions. The male is the protector and maintainer of the females (and the children) and working mainly outside the home, the female is in charge of the home taking care of the needs of her husband and looking after the upbringing of the children devoting herself mainly to the home. But the Sharia has given her legal rights commensurate with her responsibilities and requirements. Although a son has two shares in the property of his father as against one share given to the daughters but she has no responsibility in maintaining and satisfying the financial needs of the family. Moreover, she inherits 1/8th or 1/4th share in the property of her husband on his demise. Despite the fact that her main responsibility was in the management of the home and in bringing–up of the children she can engage in business and in commercial activity. She is the full owner of her property, over which she has complete dominion and enjoys an independent legal responsibility.

In matters of marriage she has full freedom. After attaining the age of puberty, she can marry whoever she pleases, as marriage in Islam is a contract. Though in matters of divorce the husband enjoys more power to divorce his wife. This freedom greatly circumscribed by the fact that this act of divorce is considered highly reprehensible in Islam, and is greatly discouraged through social and family pressures and is rarely resorted to.

Women are free to go out in the public for performance of their daily chores, but while doing so they should observe hijab i.e. modesty and cover their hair and not expose the sensuous parts of their body.

As for the matter of their weight of evidence before courts, it is true that is only the evidence of adult male truthful Muslims which is accepted in cases involving Hadd sentence i.e. penalties ordained in the Holy Quran but these sentences are very rarely imposed and the overwhelming: number of cases in practice are decided in which sentences are imposed according to those prescribed by laws framed by the State (tazir). Here their testimony is accepted and given full weight.

It is true that traditionally in Islamic Societies women have been mostly confined to their homes, and their property and their affairs have generally been managed by males, which has given rise to the impression that women enjoy inferior status to men in Islam and that they are being exploited by them. To correct this impression and ameliorate this situation, effective steps are being taken in Pakistan both by legislation as well as by decisions of the Courts.

At the outset, it should be stated that consistent with the provisions of our Constitution whereby all laws that are repugnant to the Qur’an and the Sunnah will be invalid and that hence–forth decisions of Courts are to be based on the Injunctions of Islam, Islamic law has become the rule of decision practically in all matters.

As far as Islamisation of laws is concerned, all customary laws which denied the rights of inheritance to females in respect of agricultural property have been repealed with the result that now every heir, male or female, is entitled to his or her share as fixed by the Shariat with‘ absolute property rights therein vesting in them including complete right of disposing it of. Considering that 75% of our population lives in rural areas and was being governed by customary laws, this is indeed a revolutionary change.

A remarkable example of this revolutionary change is manifest from how these matters are now being viewed by the Courts.

Thus in the case of Sartlar Ali Vs Ghulam Sarwar (PLD I990 S.C.I.) decided recently by the Supreme Court, the facts were that the brothers had been in possession of the land of their sister and had excluded her completely from it. Later on, they claimed that they had become owners of the land through adverse possession. This claim was negatived by the Supreme Court in a land-mark ruling wherein the rights of women and their status in an Islamic Society was discussed in great detail and it was held, relying on the Qur’an Verse in Sura IV, Verse 34, declaring men as “protectors and maintainers” that the petitioners being the brothers of the respondent were required by the Islamic Law to protect the property rights of their sister if ever they came into possession of her land in any capacity. The Court went on to observe the “one who is enjoined with the protection of the other’s property cannot lay claim adverse to the interests and rights of that other one who owns it”. No brother can now usurp the share of his sister on the ground that she has relinquished it in his favour or he has become its owner through adverse possession.

Again, differing from the earlier view held by the Courts in pre-partition India that a wife is entitled to claim dissolution of marriage only if she has been treated with cruelty by her husband, or she has not been maintained by him for two years or that his whereabouts have become unknown or that he is impotent; it has now been held by Courts in Pakistan that “in case of dislike by the wife of her husband Islam concedes the right to the wife, in circumstances of extreme discord and where life becomes a torture for both, on account of the fixed aversion on the part of the spouses to seek dissolution of marriage on the ground of Khula”.

Accordingly, the Court can order separation by Khula even if the husband is not agreeable to that course”. (Abdul Rehirn Vs Mst. Shahida Khan — PLD 1934 S.C. 329). In the same strain our Courts have declared that if there is disagreement between the husband and a wife, who is sui juris, she cannot be forced to live with her husband and is entitled to live separately from him (Mst. Sahi Bibi Vs Khalid Hussain I977 S.C.M.R. 577).

In addition to the rights accruing to women by Islamization of Laws, the attempt to secure status of equality for them has also been fortified by Article 25 of the Constitution. This provides that—

“All citizens are equal before law and are entitled to equal protection of law.”

And goes on to add that—

“There shall be no discrimination on the basis of sex alone.”

And to further safeguard the rights of women and children, it provided that—

“Nothing in this Article shall prevent the State from making any special provision for the protection of women and children.”

The Supreme Court has explained the scope and intent of this Article in the recent case relating to admission of girls to Medical Colleges as follows:—

“No discrimination on the ground of sex alone can be permitted except on the ground of reasonable and intelligible classification. Such classification in our Society permits, for the present, establishment of educational and professional institutions exclusively for the females or exclusively for the males. However, where co-education is permitted and the institution is not reserved for one sex alone, the fixation of number on the ground of sex will directly be opposed to the requirement of Article 25 (2) unless it is justified as a protective measure for women and children under Article 25 (3). In other words the number of girl students can be fixed as the minimum but not as the maximum particularly so where on merit they are likely to get more than the fixed number of seats. The Constitution assumes that the women and children in our Society need protection and not the males and as long as the Constitution mentions that assumption and basis, we cannot reverse it by affording protection on male and adults at the cost of women and children. That would he opposed to the very fundamental mandate of the Constitution.”

The conclusion was expressed thus—

“In view of the discussion that has proceeded on merits, the claim of the girl students merited acceptance on the ground that they have been discriminated against in the matter of admission to co-educational Medical Colleges by suppressing their merit as against the boys admitted thereto.”

And admission to co-educational Medical Colleges was allowed strictly on merit, while maintaining the right of girls to exclusive admission to the girl Medical College (like Fatima Jinnah Medical College for Girls) (Shirin Munir Vs Government of the Punjab PLD 1990 S.C. 295).

To further safeguard the position of women, it would be advantageous to take guidance from the Holy Qur’an. In Surah Al-Talaq verse 1 it is said herein—

“O Prophet, when you divorce women them for their prescribed period and calculate the period, and keep your duty to Allah, your Nourisher. Do not turn them out of their houses, nor should they themselves do that.”

According to Maulana Ashraf Ali Thanvi “their houses" means the house in which the wife lives. In the light of this Qur'anic verse, he transferred the ownership of his house to his wife. This Qur'anic Injunction is enforced in Egypt and some other Muslim Countries as Islamic Law.

Accordingly, if and when a husband divorces his wife or contracts a second marriage, the ownership of the house in which his first wife resides, is transferred automatically to her, such a measure could result in reducing drastically the ratio of divorces pronounced by husbands and second marriages contracted by them.

The rights given to women in Islam are therefore not only available to women in Pakistan but are also being duly enforced by Courts of Law.

 

 

 

 

 

 

 

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