Dossier 21: Muslim Women on the Threshold of the 21st Century

Publication Author: 
Homa Hoodfar
September 1988
Word Document156.69 KB
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In the West, Islam has come to epitomize the worse kind of oppression of women, usually symbolized by the veil, polygyny, and more recently, by stoning. Muslim women are assumed to have passively accepted their bleak lives, either because they know of no alternative or because they have no means to fight this faith prescribed by God and administered by their male masters.[1] Images which characterize Muslim women as oppressed victims with no rights are tenacious: even the reality that women have been elected as leaders of the most populous Muslim states, that is Turkey, Pakistan, and Bangladesh, has not shaken this universal assumption.[2] Women's political participation at the highest ranks coupled with the deterioration of women's status in some Muslim societies - including those who have elected a woman leader illustrates the complexity and diversity of the situation of women in the Muslim world.

The contradictory trends and developments in these societies, and the diversity in practices and beliefs among Muslim societies and communities, urge observers to question the simplistic assumption that Islam is the source of oppression of Muslim women.[3]

Despite its ubiquity, the category of Muslim women implies a false homogeneity. As a classification, it is vague and ahistorical. However, due to the frequency of its historical use and misuse, the abstraction "Muslim women" has evolved to be a political rather than analytical concept, now used by diverse factions. In the media which cater to the dominant Western cultures, it is used to imply the many kinds of women's oppression.

Conservative male leaders in Muslim societies use the concept to legitimise their efforts to control women and protect their patriarchal and political privileges. On the other hand, Islamist activist women are increasingly using the concept to introduce their envisioned ideals of Muslim women's rights and virtues. As I demonstrate below, these activists subvert the Muslim conservatives' attempts to prolong their political privilege. As much has been written, though mostly with little impact, on the misuse of the term "Muslim women" in Western societies, my discussion here focuses on the diverse and contradictory uses of the category "Muslim women'' within Muslim societies. It is essential to my discussion to briefly establish the diversity of Muslim women's situations. Consequently, by reviewing recent trends, I show how Islam has been used to support contradictory political aims by religious leaders, governments and women's organizations.

The diversity of Muslim communities

There are 500 million women living in Muslim societies and communities; the large majority live in Asia and Africa. In fact, Indonesia, with 200 million people, is the largest Muslim nation in the world, making nonsense of the stereotype that Muslim are primarily Arab, or generally Middle Eastern. Contrary to the modern image of Islam as an unyielding religion, historically it has demonstrated considerable flexibility in adapting to diverse cultures.[4] The diversity found in Islamic schools of thought and practices among different Muslim communities confirms that Islam has absorbed the traditions of these historically, culturally, linguistically, and economically distinct communities. Although Islam, like all major world religions is undoubtedly patriarchal, matriarchal societies such as the Menangkabau of Indonesia have adopted Islam, apparently without viewing it contradictory to their traditional practices.[5] On the other hand many pre-lslamic and traditional patriarchal practices are legitimized in the name of Islam. In Sudan, genital mutilation, a pharaonic practice exercised on both
Muslim and Christian women, is enforced in the name of Islam. Similarly, in the Middle East and increasingly in other parts of the Muslim world, the pre-Islamic Semitic and Persian practice of veiling is now presumed by Muslims and non-Muslims alike to be Islamic. In India, Muslim communities have adopted the caste system, although it goes against the very principle of Islam, which calls for equality among Muslims of all races and classes. As a further example of how extra-Islamic customs have been incorporated into local tradition, in many Muslim cultures women are deprived of their inheritance (particularly land) in contradiction to Qur’anic norms. These cases illustrate that the use of religion and culture to justify subordination of a social group, most commonly women, is political, and that the significance attributed to religion and culture is often a move aimed at suppressing women's demand for their human rights. The realities of Muslim women's lives range from being powerless, segregated, deprived of basic human and religious rights and given forcibly in marriage as children, to enjoying equal and sometimes more freedom and legal protection than their non-Muslim sisters in the "developed" world.

The situation of women as a social group in any society is defined by a complex web of economy, political structure, and culture of which religion is only one element. The representation of Islam as a black box which is the source of oppression, particularly by secular feminists from both North and South, has retarded the development of an analytical approach to the workings of patriarchy in Muslim societies. Moreover, such an approach to Islam does not encourage dialogue and solidarity between Muslim and secular women from Muslim societies and other feminists, but creates distance and divisions which ultimately serve the interests of the patriarchy.[6] Although Islam does not prohibit women from studying and interpreting Islamic texts, throughout the history of the Muslim world men have been the primary interpreters of God's will, telling women what God, in his encompassing wisdom and justice, designed women for. Many Muslim women are now questioning this monopoly, not on the grounds of the secular and international rally for women's equality but based on a right Islam has given to all sexes and races.

Muslim women in the socio-political turmoil of the twentieth century

The advent of modern technology as a consequence of direct and indirect colonialism and integration of Muslim society in the world system has had various effects on women in different parts of the Muslim world. On one hand, the imposition of colonial laws and morality transposed European prejudices against women, and added them to the existing burden of women in these areas. On the other hand, close contact between Muslim and European cultures also intensified contact between Muslims of different cultures. These contacts engendered alternative views on the social organization of society and the position of women in it. Lively intellectual debates took place between Islamic scholars of all tendencies - conservative, modernist, secular, and nationalist.[7]

During the first half of the twentieth century, powerful women’s organizations emerged in India and Egypt; from these centers of activism, close ties developed with women's organizations and women activists in Palestine, Syria, and Lebanon. Women, individually and through formal organizations, took an active role in the anti-colonial struggle.[8] The success of liberation movements under the leadership of modernist forces and the establishment of independent states led to a great improvement in women's social and legal position, though it always fell short of women’s expectations. The 1960s and 1970s brought more improvement for women, and with the exception of some of the Gulf countries (including Saudi Arabia and Kuwait) women received full political rights. Women became ministers, members of parliament, and high officials, despite the disapproval of conservative religious leaders. The percentage of women with formal education increased and the economic participation of women extended from involvement in subsistence farming and the informal economy to the formal and modern sector. In many states there were major revisions of personal status laws which particularly affected women in the domain of marriage and divorce, where historically women did not enjoy equal rights with men.

However, these legal changes were rarely accompanied by campaigns to change societal attitudes or familiarize women with their legal rights. A fundamental shift in the process of legal and social change occurred in the late nineteenth century and first half of the twentieth century; legal reform began to occur as an outcome of public debates. Discussions taking place between policy makers on one hand, and intellectuals and activists on the other expanded to incorporate religious leaders and the public (though primarily in urban areas). In this process, religious discourse on social issues, particularly the "Woman Question", was forced to confront modern challenges. In the second half of the twentieth century development and legal changes were mostly mechanical top-bottom processes, from which the general public was excluded. Similarly, religious leaders, who were increasingly denied political power, adopted the role of critics and adversaries of the government, but were rarely challenged to provide answers to modern issues.

During the same period, many conservative religious leaders, distressed by their increasing exclusion from the formal political arena, developed an unprecedented agenda for creating a single universal Muslim law and moral code - an agenda which was now practicable via mass media. They did not talk of a village but of an 'Islamic community', whose morals and laws were dictated and controlled by elite religious leaders and theocrats.[9] The process has given voice to many conservative circles of male leaders who wish to limit women to the domestic sphere, and impose their vision of "Islamic" gender roles on all Muslims. This new vision, somewhat disingenuously called an "Islamic" vision, takes little account of cultural, economical and ecological diversities and has severe and disparate repercussions for women, as witnessed in many Muslim countries during the last decade

By the end of the 1970s, the economic recession and the increasingly undemocratic and unpopular regimes (which had embarked on plans of westernization rather than modernization), engendered growing negative attitudes toward the governments and their policies - including policies affecting women. In the wake of dictatorial regimes which eliminated all political channels for public expression, conservative forces shielding themselves behind the legitimacy of religion emerged as a major opposition force in many Muslim societies. As a result of the pressure exerted on governments in the 1980s, women's position worsened in many Muslim countries: under the banner of thwarting Western cultural imperialism, governments cancelled some of women's legal achievements.

In 1979 in Iran, the revolution resulted in the establishment of an Islamic regime whose mandate was to halt the process of westernization and to curtail cultural imperialism. Ironically, as a means to achieve this, the family protection law which had given women limited protection against unilateral divorce and polygyny was cancelled. Temporary marriage, a Shiite Muslim practice which had been illegal for more than fifty years due to its negative consequences for women was pronounced legal once again.[10]

Women also lost the right to be judges and to undertake studies in such fields as veterinary medicine and many of the technical engineering which were considered suitable for male students only.[11] In 1981, after two years of struggle against it, veiling was made compulsory. Those who do not observe it risk public flogging or jail, even though there is no historical precedent for punishing women who do not veil. Nonetheless, the use of force to regulate women's dress is not a new phenomenon. In the 1930s, the veil was outlawed and forcibly removed from women's heads; many women remained in their homes rather than risk being victims of police attacks. Ironically, until the downfall of the Shah, the day on which the veil was made illegal was celebrated as women's Liberation Day.

Post-revolutionary developments in Iran encouraged similar demands from Islamic conservative forces elsewhere. In 1984, as a compromise to conservative Muslim factions, the Egyptian family status law was rewritten and women lost the right to remain in the matrimonial home after divorce. In the same year Algerian women lost the right to marry without consent of their wali (guardian, usually the father or brother) regardless of the woman's age; by the same stroke, men also regained the right to polygyny and oral divorce.

In 1989, Algerians passed a law allowing the male head of household to vote for the entire family; this, of course, means that many women will be deprived of their voting rights. In 1986, in India after a campaign by conservative Muslim leaders, women in the Muslim community lost their right to maintenance after divorce. This law excludes only Muslim women and is ironically called "Muslim women's protection of the right of divorce". Iran, Pakistan, and more recently, Sudan have passed hudud or qisas laws which establish separate spheres of justice for women and men.

In these separate spheres, women are of much lesser value; according to these laws women's testimony (when it counts at all) is worth only half as much as a man’s and their bail money is half as much as a man's. Ironically, as these countries are celebrating the end of racial prejudices in South Africa as a victory of the oppressed, they are themselves installing a social and legal system that treats women as the lesser and inferior sex. While women have not been the only group targeted, conservative forces have had considerably more success in changing laws which affect women. Their success stems from the lack of effective and independent women's organizations which could have provided counter-pressure on governments
since many governments, as part of their modernization efforts, introduced some reforms concerning women’s legal status which tended to support feminist demands, independent women's organizations in many Muslim countries either by law or co-option - were effectively dismantled. Even Egypt, which had one of the world's most impressive women's organizations in the first half of the twentieth century, lacked any effective front to fight the conservative backlash.

Women’s responses at the national level: the case of Iran.

The shock of the overnight cancellation of family protection law reforms, re-introduction of polygyny and temporary marriage, harsh enforcement of compulsory hijab and introduction of early retirement programs for women employed in the formal sector had a sobering impact on Iranian women. The shock was particularly severe because a large number of women, including many educated middle-class women who were most adversely affected by these changes, had fought against the previous regime in hopes of democratizing their society. Women responded with spontaneous demonstrations against these undemocratic developments and women from all walks of life scrambled to organize and form their own independent organizations. Although many of these groups were dismantled during the severe repression following the Iran-lraq war, individuals and informal groups continued their struggle to improve women's position.

One strategy adopted by activists was to expose the injustices suffered by women in the name of creating a ''Just Islamic Society". Women's magazines, including those sponsored by the government, included stories of young poor women who were given in temporary marriage and became pregnant, but could not find the child's father, who had disappeared in the huge cities after the marriage had expired. The magazines also documented the lives of women who were married at a very young age, struggled against poverty, and through hard work and penny-pinching eventually improved their material condition until, middle aged, they were divorced without any financial compensation or alimony because their husbands wanted to marry younger women. Many other similar stories documented the unfair treatment of women. Women's magazines including those sponsored by the government carried open letters to religious leaders and transcriptions of public talks, asking them if this was the way to achieve Islamic justice.

Religious leaders were asked to explain how the regime intended to restore the respect Islam and the Islamic Republic had promised for women. The regime was obliged to react to these demands since, very early on, the religious leaders of Iran had realized that women as a social group were a very important constituency whose political support was necessary. Opposition to legal change did not come only from the secular and westernized classes of Iranian women. Many Islamist women activists who have had religious education and are well versed in religious matters – a considerable number of them are in fact daughters, wives, and relatives of political leaders - disagree strongly with the state vision of women's role and its attempt to return to what the religious leaders call ''old Muslim ways". They point out that much of what is presented to women as Islamic is but patriarchy in Islamic costume. The last decades of Iranian debate and discussion on the question of women, which is a highly politicized subject, has been colored by a sharp contrast between patriarchal and women centered interpretations of women’s rights in Islam. The image of a pragmatic feminism in Islamic costume can perhaps best capture the gist of much of these debates.

The first success of this campaign was Khomeini's introduction of a new family law. Although this law did not go as far as many Muslim women activists had hoped, it was nevertheless one of most advanced marriage laws in the Middle East (after Tunisia and Turkey), yet it did not deviate from any of the major conventional assumptions of "Islamic" law. Under this new law there are many conditions stipulated in the official marriage contract which give women a stronger position within marriage, and both bride and groom can add or remove clauses. This set form removes much of the burden on individual brides trying to secure a fairer marriage deal for themselves. It also provides some degree of protection for those given in marriage too young to be able to effectively negotiate more equitable marriage conditions for themselves; women continue to agitate for more fundamental change and in so doing they have adopted some unique and ingenious strategies. For instance, Iranian women campaigned for a ''wages for housework" law which was passed in December 1991. Islamist women activists argued that women, like all other Muslims, are entitled to the fruits of their labor; as well, in Islamic tradition, a woman is not required to work in her husband's home, to the extent that if she breastfeeds her child she is entitled to payment from her husband. Therefore, since in reality all women work in their husbands' homes, they are entitled to a salary. The argument, though novel and unconventional, was based on Islamic texts supported by the Qur'an. The bill was initially resisted by the Islamic parliament and conservative religious leaders because it was an unconventional interpretation of the "Islamic law". However, they were forced to agree that it is an Islamic right and eventually passed the law. Now men who intend to divorce their wives must first pay them housework wages. Many women feel that despite its problematic applications, this law has given them a better bargaining position than ever before.[12] Although the new wave of Islamist women activists may appear to be diametrically opposed to secular feminists and derives part of this current political legitimacy from its critique of secular groups, in practical terms the two camps are close allies and their demands are generally analogous as both groups fight to improve women's social and legal situation.

The new wave of Islamist feminists, with their unconventional and women-centered interpretations of Islam, is challenging and reforming Islamic doctrine from within, rather than imposing or advocating a Western model of gender relations. This irreversible shift has already changed women's consciousness and encouraged them to distinguish between patriarchal tradition and "Islam''. Similar movements are also becoming widespread in other Muslim countries including Bangladesh, Malaysia, Indonesia, Algeria, and Pakistan where the conservative forces, under the pretext of returning to Islamic ways, are trying to ensure the persistence of the patriarchy.[13]

Women's responses at the international level

Historically, in much of the Muslim world women were not only denied their right to Islamic education but, outside the family, they were also kept in isolation from one another. Moreover, little contact existed between women of different Muslim societies. Even the performance of religious duties which would bring women of different societies together, such as the pilgrimage to Mecca which is incumbent on all Muslims whose health and finances allow, was made difficult for women. Thus even though many Muslim women were independently wealthy and eligible for the pilgrimage, societal pressure meant that comparatively few fulfilled this requirement of their religion. The result of this isolation was that women often accepted that Islam as practiced in their society was the only one and that it was what God had prescribed for them. Consequently, open resistance to locally accepted practices was seen as heresy. However, mass media, wider education, and modern technology have to some extent undercut this imposed isolation. The diversity of views and practices has become apparent and, by comparing their situations, Muslim women today more than at any other time in history, are learning to distinguish between patriarchy and religion.

Realizing the importance of international networking, Muslim women have established several international and regional organizations whose mandates are to provide support, solidarity, and exchange of experiences and information between different Muslim societies. The availability of information and solidarity from other Muslim countries are significant organizations. In part, this is because it is impossible to separate women's problems from economic and other social problems. Furthermore, in many Muslim societies, independent political organizations and lobbying groups cannot operate openly.

Women Living Under Muslim Laws (WLUML) is an example of one such effort to link women in different Muslim communities.[14] Its impetus came from three successful campaigns in 1984. In Algeria, three feminists were jailed for having discussed the implication of the family code with other women. In India, a woman challenged the constitutionality of oral repudiation, which was allowed under India's Muslim Personal Law. In Abu Dhabi, a Sri Lankan worker who became pregnant after being raped was sentenced to death by stoning because she could not prove she was raped. The positive reaction of women activists in different Muslim countries and the effective use of their solidarity and support convinced the organizers of the necessity of a permanent organization, despite financial and political problems. The network at the moment has four official offices, three of which are based in different Muslim countries, as well as many informal centers carrying out the tasks of the network.[15] Although its initial mandate was to focus on women in Muslim societies, increasingly it deals with the problems of women of Muslim descent living in Europe and North America and non-Muslim women married to Muslims and affected by Muslim personal laws.

The WLUML network has managed, to a large extent, to provide a democratic platform for all those who are interested in promoting women's interests and fighting patriarchy presented in the name of Islam.[16] It is one of the few platforms which brings together women of diverse political and ideological tendencies, including Islamist women activists, those who consider themselves cultural Muslims, socialists, and secular feminists. Through this platform women are learning to share their experiences, respect each other's views, and work together for common goals. Although the organization started with only a handful of women, at the moment there are more than two thousand women as well as various organizations in contact with the network and there are many women who devote much of their time and lives to promote women's interests through the organization.

The active members and core organizers are primarily (but not exclusively) women lawyers, sociologists, anthropologists, journalists, and other social scientists. Broadly speaking, the network has two interdependent wings. The activists wing deals with mobilizing support for women's initiatives at local and international levels, linking and familiarizing women of different Muslim societies with each other's situations, and airing the voices and concerns of women in Muslim countries in international circles, including the United Nations and Human Rights Watch. The research wing designs and carries out collective projects in critical areas. The results of its research are made available for the use of women activists, development organizations, and interested members of the public. The network also publishes Dossier, a journal which contains research reports and articles on current issues as they relate to the lives of Muslim women worldwide.[17]

The network's current major research project is the organization of a global study on Women and Law in more than twenty-five Muslim countries and societies. The need for the research program was identified during an earlier project, a Qur'anic interpretation meeting in Pakistan which had brought fifty women of different Muslim communities and ideological tendencies together.  The Women and Law program examines different areas of codified, customary, and religious laws and their application to women's lives. The results of this study will be made available for women activists, who will use this knowledge to lobby and demand the laws which best protect their interests.

As Marie Aimée Hélie-Lucas, the international coordinator of the network, has put it, "By pooling our knowledge and resources together we can avoid the worst scenario and at the same time promote a more just environment". She then sums up the worse scenario imposed on women and justified in the name of Islam: oral divorce would become legal (as in India); women's right to vote would be delegated to men (as in Algeria); adultery would be punishable by stoning (as in Iran, Pakistan and a number of other Muslim countries); rape would require eye witnesses (as in Pakistan); women would lose the right to drive (as in Saudi Arabia); women would be circumcised (as in Somalia and Sudan); women would be forcibly given in marriage as in communities governed by the Malaki and Shafi schools of law. The best scenario, which has also been possible using Islamic justifications gives women: the right to choose their own husbands (as in countries governed by the Hanafi school of law); the right to share material property upon divorce (as in Iran and Malaysia); the right to custody and guardianship of their children after divorce (as in Tunisia); the right to remain in the matrimonial home after divorce, at least until children are adult (as in Libya); and the ban of polygamy (as in Tunisia).[18] Let me conclude by adding that Muslim women are entering the 21st century with a valuable lesson learned from their many unpleasant experiences during the second half of the twentieth century. They have learnt that unless they remain organized and alert in the political arena, the forces of patriarchy are ready to claim back every inch of success that women have managed to gain through their hard and long struggle.

Source: This paper was presented by Homa Hoodfar in May 1994, who teaches at the Department of Sociology and Anthropology, at Concordia University, Montreal.

[1] See, for instance, Mahmoody, Betty. (1987). "Not Without My Daughter." New York: St. Martin's Press.<?xml:namespace prefix = o ns = "urn:schemas-microsoft-com:office:office" />

Minces, Juliette. (1982). ''The House of Obedience: Women in Arab Society," trans. By Michael Pallis. London: Zed Press.

Sasson, Jean P (1992). ''Princess: A True Story of Life Behind the Veil in Saudi Arabia". New York: Morrow.

Jeffery, Patricia (1979). "Frogs in a Well: Indian women in Purdah". London: Zed Press.

[2] Benazir Bhutto was elected Prime Minister of Pakistan (population 120 million) in 1988 and again in 1993; Begum Khaleda Zia has been Prime Minister of Bangladesh (population 102 million) since 1991; Tansu Ciller has been Prime Minister of Turkey (population 50 million) since 1993.

[3] It is the author's point of view that Islam, like Christianity and Judaism, is a male-dominated religion and has been used as a tool to exert male dominance. However, this does not preclude, as I shall discuss in the paper, the possibility that women can also use the same tool to advance their own interests.

[4] This flexibility is often considered an important reason why Islam is the fastest growing religion in the world. See Michael Gilsenan. (1982). "Recognizing Islam Religion and society in the Modern Arab World. New York: Pantheon Books.

[5] The Menangkabau were among the first Indonesian societies to be Islamicized, beginning in the eleventh century. See also FM. Denny. (1983). "Another Islam: Contemporary Indonesia" in "Mormons and Muslims: Spiritual Foundations and Modern Manifestations. Spencer Palmer, (ed). Salt Lake City, Utah: Publishers Press.

[6] Canadian Muslim women often feel torn between wanting to question some of the patriarchal practices in their community and facing the prejudiced approach shown by dominant Canadian culture toward Islam and Muslims. See Hoodfar, H. (1994). "The Veil in their Minds and on Our Heads: Persistence of Colonial Images of Muslim Women" "Resources for Feminist Research" Vol. 22 (1 & 2). For more general discussion on the feminist writings on Third World women see Mohanty, C.T. (1991). "Under Western Eyes: Feminist Scholarship and Colonial Discourses". In C.T. Mohanty, A. Russo and L. Torres (eds.), "Third World Women and the Politics of Feminism" (pp. 51-80). Bloomington: Indiana University. Nader, Laura. (1989). ''Orientalism, Occidentalism and the Control of Women''. "Cultural Dynamics" 2:3, 323-355.

[7] It is important to recognize that both modernist and conservative trends existed within the Islamic framework. There were few who argued for secularism.

[8] See for instance Hoodfar, H. (1989). ''Background to the feminist Movement in Egypt", in "Le Bulletin" 9:2. Montreal: Simone de Beauvoir. Jayawardena, K. (1986) "Feminism and Nationalism in the Third World." London: Zed Books.

[9] This was a novel idea, since despite the existence of many religious leaders at different local levels, Muslim rituals take place on the personal level and do not require the specialized services of a mediator between the believer and God.

[10] Temporary marriage is a limited-term marriage practiced by Shiite Muslims. Whatever its merit in the old days, today it is frequently used to the disadvantage of women, particularly poor women. For a full discussion See Harei, Shahla. (1989). "Law of Desire: Temporary Marriage in Shi'i Iran". Syracuse: Syracuse University Press.

[11] Although men also lost rights (to be gynecologists, for instance), in comparison to the setbacks suffered by women their losses were negligible.

[12] For a discussion of recent developments on the situation of women in the Islamic Republic see Nesta Ramazani. (1993). "Women in Iran: The Revolutionary Ebb and Flow. "The Middle East Journal" Vol. 47: 3 (409428).

[13] Many organizations which are actively concerned with women's issues work under the banner of different non-governmental organizations such as legal literacy and women's self empowerment

[14] The name of the network bears significant subtleties. It indicates that its concern includes all women who are effected by Muslim laws and not just Muslim women. Secondly it indicates that Muslim laws are based on Muslim interpretation of what they understand as Islam. Thirdly the word law is used in plural form because as the extremely diverse laws of the Muslim countries and communities indicate there are very many different schools of interpretation of Islamic text.

[15] For a detail history of the network see Marie Aimée Hélie-Lucas, Farida Shaheed and Faizun Zackarya. (1991). "Background and History of WLUML." Montpellier, France.

[16] For more detail about the position of the network on the democratic front see Farida Shaheed (1994). "Controlled or Autonomous: Identity and the Experience of the Network Women Living Under Muslim Laws" in "Signs" 19(4), Summer.

[17] In addition to a long list of publications concerning issues of importance to women in Muslim societies, thirteen issues of "Dossier", have been published. A complete listing can be obtained through the author.

[18] See Marie Aimée Hélie-Lucas. (1993). Women Living Under Muslim Laws, in "Ours by Right Women's Rights as Human Rights". Joanna Kerr (ed.) London: Zed Books in association with the North-South Institute.