The best answer is always to produce an "in rem" solution, i.e. wherever possible, the result must be accepted in the majority of states around the world. Thus, if the talaq is effective under the "lex loci actus" and recognized under the laws relevant to determine status and capacity, it will be recognized so long as the best interests of the children are protected in any orders or agreements made by the parties. For example, in English law, Part II of the Family Law Act 1986 draws the distinction between a divorce obtained by "judicial or other proceedings" and the divorce obtained "otherwise than by means of proceedings". The Nikah form is recognized in UK if: