Islamic Sharia Council subservient to the English law." In an April 2013 report, the BBC's "Panorama" asked whether the Islamic Sharia Council was "failing vulnerable women and mothers" by requiring women seeking divorce to give back their marriage dowry (or "mahr"). The question of "khula" divorce often turns on the dower: if the woman is seeking the divorce, she has to return the dower to the man, or else the divorce cannot proceed. Since in traditional Islamic society, men are traditionally the bank account holders and women are traditionally homemakers, the woman has no purchase, and cannot obtain a loan in order to
Application of Islamic law by country against it in 2005 by the National Assembly of Quebec, while the province of Ontario allows family law disputes to be arbitrated only under Ontario law. The country has a common law system. The country has a civil law system. In the United States, various states have outlawed sharia, or passed some form of ballot measure which "prohibits the states courts from considering foreign, international or religious law." these include Alabama, Arizona, Kansas, Louisiana, North Carolina, South Dakota and Tennessee. Criminal law in Afghanistan continues to be governed in large part by Islamic law. The Criminal Law of September 1976