Regional & Middle East

The contract may be held there, but Malaysian Syariah Court permission is still required, and Indonesia itself requires the permission of the Pengadilan Agama (Religious Court). Malaysians who marry in Indonesia are subject to two systems at once: Indonesian law for the contract there, and the state Islamic family Enactment for recognition in Malaysia. In Malaysia, a married man must obtain the written permission of the Syariah Court before marrying again (Act 303 s.23 for the Federal Territories; equivalent state Enactments), and this requirement applies even if the contract is made abroad. In Indonesia, the Registrar is forbidden to record a second marriage without the court's permission (PP 9/1975 Article 44). The KUA usually asks for a status certificate from the home country through the Embassy of Malaysia in Jakarta or a consulate. The safe order: court permission first, then the contract, then registration. See Indonesia.

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It can be recognised and registered in Malaysia if the contract is valid under Syariah law and the registration procedure is followed, but a Thai certificate alone is not enough. The religious marriage certificate from the Provincial Islamic Committee is only proof of the contract, not Malaysian permission for polygyny. The certificate is usually endorsed at the Consulate General of Malaysia in Songkhla (or the Embassy in Bangkok), then registered at the Islamic religious affairs office of the state of residence within six months (Act 303 s.31; equivalent state Enactments). The religious affairs office or Syariah Court will check the wali, the witnesses, the accredited officiant and the status of the parties. If the wali is in doubt, the court may refuse to confirm the contract and the couple may need to renew the contract. If it is polygyny without permission, the husband is usually charged and fined first. See Thailand and recognition of marriages abroad.

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No. Saudi law does not require court permission and does not require the existing wife's consent to marry again, with a limit of four wives. The Personal Status Law 2022 (Royal Decree M/73, based on Hanbali fiqh) requires every akad, including a second marriage, to be registered like an ordinary akad (Article 8); the official text of the law contains no special polygyny procedure other than the duty of fairness (Article 42); the forms in the Najiz system have not been checked (check with the authorities of the country concerned). The husband must be just in the rotation and maintenance, but that justice is not examined before marriage; the wife can only claim it by complaining to the court. The wife's main protections are conditions in the akad and judicial dissolution (fasakh) for harm. However, for a Malaysian man, marrying again in Saudi Arabia without the permission of the Syariah Court is still an offence in Malaysia. See Saudi Arabia.

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If the akad was in Indonesia, register it again at the state Islamic religious affairs office or the Malaysian mission within six months, either before a Registrar abroad after the date of the marriage or before a Registrar in the state after first returning (Act 303 s.31; the other state enactments checked also set six months, including Sarawak s.29; Terengganu s.29 sets two months after first arriving in Malaysia, according to an unofficial copy of the 2017 text). The steps: obtain the official marriage book from the KUA, not merely a letter from the imam; verify the documents and have them translated if requested; then attend the district Islamic religious affairs office, which will check the wali, witnesses and status. If there is doubt, the case is referred to the Syariah Court for validation of the marriage. If the akad is in Malaysia instead, the foreign spouse needs status documents and the wali's permission from her country. Once registered, the wife may apply to the Immigration Department for a Long-Term Social Visit Pass for spouses of Malaysian citizens; according to the Immigration Department's official website (viewed 14 Oct 2026), the pass may be granted for up to five years, subject to approval — a Malaysian marriage certificate is required. If the husband is already married, polygyny permission must be obtained first. See cross-border marriage.

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ROMM (Registry of Muslim Marriages) is Singapore's registry of Muslim marriages, which administers the Kadis and Naib Kadis and receives polygyny applications. Under AMLA s.96(3) and rule 5 of the Muslim Marriage and Divorce Rules, a man who is still married may not be married to a new wife unless the Kadi has made an inquiry and is satisfied that there is no impediment under Shariah and the law. The husband submits an application to ROMM with financial documents and information about the existing wife. The Kadi may summon the applicant, the prospective wife and her wali, and the existing wife, and weighs the wife's views, financial means and the reasons for marrying again. As a result, polygyny was only 0.18% of Muslim marriages in 2020. See Singapore.

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In Brunei, marrying again without permission is an offence under s.123 Chapter 217: a fine of up to $2,000, imprisonment of up to 6 months, or both. Section 23(1) forbids a man from marrying another woman "in any place" while his marriage subsists except with the written permission of a Syar'ie Judge. If he marries without permission, the marriage may only be registered subject to s.123, that is, after action for the offence. Chapter 217 also makes a husband's failure to treat a wife justly according to Hukum Syara' an offence (s.129), and a false declaration to the Registrar is also an offence (s.126), each with the same maximum penalty. Marrying abroad to avoid the court process does not help. See Brunei.

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Yes, but only as an exception in "exceptional cases" and if the husband is able to be just. Art. 27 of the Code of Muslim Personal Laws (PD 1083) states that a Muslim man may have up to four wives at one time, but may not have more than one wife unless he can deal with them with equal companionship and just treatment as enjoined by Islamic law. The Supreme Court in Malaki v. People (2021) read it as: the general rule is that a married man may not marry again. The procedure under Art. 162: written notice to the Clerk of the Shari'a Circuit Court, a copy to the existing wife, and an Agama Arbitration Council if the wife objects. The Code does not explain what "exceptional cases" means. See Philippines.

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The official Arabic text of the 2024 law on the UAE legislation portal contains no provision requiring the existing wife to be told of a new marriage; article 41 only requires the contract to be documented in court. The UAE also does not require court permission. The law that applies to Muslims is Federal Decree-Law No. 41/2024 on Personal Status, in force from 15 April 2025. It sets a limit of four wives (article 32(4)) and requires the husband to be fair in treatment, turns and maintenance (article 49(6)). The wife's main protection is a condition in the contract (article 33): if a valid condition is broken, for example a condition that the husband will not marry again, she may apply to dissolve the contract within one year of learning of it. The condition must be written in the contract or acknowledged by the spouses. See Gulf States.

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The marriage certificate from the Provincial Islamic Committee is usually verified at the Consulate General of Malaysia in Songkhla (or the Malaysian Embassy in Bangkok) before being brought home; please check current requirements directly with the consulate. Only marriages solemnised by an accredited officiant under the relevant provincial Islamic Council are accepted for registration. Certificates from unaccredited "express marriage" agents may be rejected, or even be forgeries. Foreigners, including Malaysians, usually receive only a religious certificate from the Provincial Islamic Committee and do not register at the Thai district office. After verification, have a certified translation made if requested, then register at the state Islamic religious affairs office within six months (Act 303 s.31). See Thailand.

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Because polygamy without the Syariah Court’s permission is an offence, and the marriage can only be registered after the court is satisfied that it is valid according to Hukum Syarak, subject to the penalty section (Act 303 s.23(1A); Selangor s.23(2)). Usually the husband is charged and fined first (Act 303 s.123; Selangor s.124; Sarawak s.127), and then the marriage is registered if the contract is valid. The maximum penalty in most of the states checked is a fine of RM1,000 or imprisonment of 6 months or both; Terengganu up to RM2,000 or imprisonment of 1 year (s.126); Sarawak up to RM3,000 or imprisonment of 2 years (s.127). Under JKSM Practice Direction No. 9/2007, the affidavit for validation must state whether the marriage is polygamous, and if so it is referred to the Syariah High Court. See polygamy in Malaysia.

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For the Federal Territories, within six months (Act 303 s.31); the texts of the eleven other state enactments and the Sarawak Ordinance (s.29) that were checked also set six months, while Terengganu (s.29) sets two months after first arriving in Malaysia, according to an unofficial copy of the 2017 text. Muslims resident in Malaysia who marry abroad must register the marriage in the state where they reside. Registration can be done at the Islamic Religious Affairs Office/Registrar of Marriages, or at the Malaysian embassy/consulate in the country concerned. Late registration incurs a fine, and delay makes it harder to register the children's births, claim maintenance and inherit. Do not leave a marriage abroad unregistered. See recognition of marriages abroad.

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The husband must obtain the permission of the Pengadilan Agama (Religious Court), and permission is given only if there are the prescribed reasons and conditions. Indonesia follows the principle of open monogamy (UU 1/1974 Article 3). Reasons (Article 4; KHI Article 57): the wife cannot perform her duties, has a physical disability or incurable illness, or cannot bear children. Conditions (Article 5; KHI Article 58): the wife's consent, assurance that the husband can guarantee the living needs of his wives and children, and a guarantee that he will be fair. The court summons and hears the wife, and examines financial evidence such as payslips. KHI Article 55 limits it to four wives, and Article 56 states that a second marriage without the Pengadilan Agama's permission has no legal force. See Indonesia.

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In principle yes — the wife's consent is a condition under UU 1/1974 Article 5, but there are exceptions. Consent may be written or oral, and oral consent is affirmed before the court. It is not required if the wife cannot possibly be asked for consent, there has been no news of her for at least two years, or for other reasons assessed by the judge (Article 5 paragraph (2)). KHI Article 59 also allows the Religious Court to grant permission even if the wife refuses, after examining and hearing the wife; the wife may appeal (banding or kasasi). This differs from Malaysia, where the wife's consent is not a legal condition but her views must be stated. See Indonesia.

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Nikah siri is a marriage that is not recorded by the Office of Religious Affairs (KUA). Article 2 of the UU Perkawinan states that a marriage is valid when performed according to religious law, and every marriage is recorded according to statutory regulations. Without recording, the wife and children have no official proof and find it hard to claim maintenance, jointly acquired property and inheritance. The remedy is an application for itsbat nikah (marriage validation) at the Religious Court, but it is not a shortcut to avoid the conditions for polygyny. For a husband who is already married, an unrecorded marriage usually means bypassing the required court permission. Unrecorded polygyny also does not appear in official statistics. This site does not encourage unregistered marriages. See Indonesia.

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The new KUHP does not prohibit polygyny as such, but Article 402 criminalises a marriage conducted while there is a lawful impediment. The national KUHP (UU No. 1 of 2023) comes into force on 2 January 2026. Article 402 paragraph (1): maximum imprisonment of 4 years 6 months or a category IV fine; paragraph (2), if the existing marriage is concealed from the other party: maximum imprisonment of 6 years or a category IV fine. The chair of Commission III of the DPR explained in January 2026 that the target is, for example, marrying another man's wife. How far a second marriage without the permission of the Religious Court counts as a "lawful impediment" is still debated, and there is no settled prosecution practice yet. What is certain: concealing an existing wife is the most serious form. See Indonesia.

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It is possible with additional conditions: a male civil servant (PNS) must first obtain written permission from his office (superior), in addition to the permission of the Religious Court (Pengadilan Agama) (PP 10/1983 jo. PP 45/1990). A female civil servant, for her part, is not permitted to become a second, third or fourth wife, and a breach can bring heavy disciplinary penalties. An example of a regional regulation is Pergub DKI Jakarta No. 2 of 2025: according to a detikNews report, a male ASN may have more than one wife only if there is a reason, the wife's written consent, sufficient income, willingness to be just, no disruption to duties, and court permission. Governor Pramono Anung (February 2025) stated that he would not grant polygyny permission to Jakarta ASN during his administration. Members of the TNI/Polri are subject to their own internal regulations. See Indonesia.

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Yes. The first wife can raise her objection with ROMM during the Kadi's inquiry, and if the application is still approved, she can appeal to the Appeal Board. The Kadi may summon the existing wife and weigh her views together with the applicant's financial means and reasons for wishing to marry again. After the second marriage, the first wife may also apply for divorce on the ground of unequal treatment. Appeal Board decisions show that financial means and the wife's consent alone are not enough without a reasonable cause — for example Ja'afer bin Kassim [2010] 5 SSAR 179 was dismissed, while Saheeda Banu v Osman Mohamed Sabeer [1998] 5 SSAR 164 was allowed with undertakings on maintenance and a separate home. See Singapore.

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A marriage in Singapore through ROMM requires an applicant with Singpass: ROMM's official process chart provides a track for marriages between a Singapore citizen or permanent resident and a foreign national, and since April 2025 every application must include supporting documents. List of marital status documents for foreign nationals (please check on the ROMM website). A Malaysian husband who already has a wife needs the permission of his state Syariah Court in Malaysia; ROMM will also investigate his marital status. Do not hide an existing wife — that is deception and can be an offence in both countries. ROMM does not allow a person who declares that he is already married abroad to marry in Singapore until that foreign marriage is dissolved. After the akad, register the marriage within six months, either before a Registrar abroad after the date of the marriage or before a Registrar in the state after first returning (Act 303 s.31; the other state enactments checked also set six months, including Sarawak s.29; Terengganu s.29 sets two months after first arriving in Malaysia, according to an unofficial copy of the 2017 text). Marriage does not give an automatic right of residence. See Singapore.

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Yes. Under s.23 Chapter 217 (Emergency (Islamic Family Law) Order 1999), a man may not marry again anywhere except with the written permission of a Syar'ie Judge. The application is accompanied by a written declaration stating the grounds on which the marriage is just and necessary, present income, financial commitments and liabilities, the number of dependants including new ones, and whether the consent or views of the existing wife have been obtained. Unlike Malaysian state enactments, which list specific conditions in s.23(5), Brunei's s.23(3) gives the Syar'ie Judge a general discretion to approve if satisfied according to Hukum Syara'. Official statistics on Brunei polygyny applications were not found (consult the local authorities). See Brunei.

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The wife's consent is not an absolute condition in Brunei, but her views must be stated. The written declaration accompanying the application under s.23(2) Chapter 217 must state whether the consent or views of the existing wife have been obtained. The Syar'ie Judge then decides according to Hukum Syara' guided by the information in that declaration (s.23(3)). After marrying, a husband who fails to treat a wife justly according to Hukum Syara' may be fined up to $2,000, imprisoned for up to 6 months, or both (s.129). The wife may also claim her rights through the Syariah Court, including taʿliq divorce (s.45), judicial dissolution (fasakh) (s.46) or dissolution for harm recognised by Syariah law (darar syarie) (s.44). See Brunei.

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A Bruneian citizen or permanent resident who wishes to marry abroad must first obtain the Registrar's permission (s.18 Chapter 217), and register the marriage within 6 months of returning (s.29). Failing to appear for registration without reasonable excuse is an offence (s.33: a fine of up to B$1,000, imprisonment of up to 3 months, or both). A marriage to a foreigner or by a civil servant may require additional administrative approval (check with the embassy or the authorities of that country). On the Malaysian side, a husband who is already married still needs the permission of the state Syariah Court; one permission does not replace the other. People from Sabah and Sarawak are subject to their own state enactments/ordinances. See Brunei.

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It is a written notice that the husband must file with the Clerk of the Shari'a Circuit Court where his family resides, before marrying again (PD 1083 Art. 162). The Clerk serves a copy of the notice on the existing wife or wives. If any wife objects, an Agama Arbitration Council is constituted: each party nominates a representative, and the Clerk acts as chair. If the Council fails to obtain the wife's consent, the court decides whether to sustain the objection, subject to the conditions of Art. 27. Failure to comply with Art. 162 is punishable by arresto mayor (imprisonment of 1 month 1 day to 6 months) or a fine of ₱200–₱2,000, or both (Art. 183). In practice, this notice is often not filed. See Philippines.

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No. Embracing Islam merely to marry again while still bound by a civil marriage does not prevent prosecution for bigamy (Revised Penal Code Art. 349). Art. 180 of PD 1083 exempts persons married under this Code, but the Supreme Court has limited it. In Nollora v. People (2011), a man claiming to be a convert was convicted because his marriage was not solemnised under PD 1083. In Malaki v. People (2021), a party to a civil marriage who embraced Islam and then married again was still guilty, as was the new spouse; the first civil marriage remains under civil law. The court also stressed that the wife's consent, or the court's permission if the wife refuses, is a sine qua non. Islam itself does not allow religion to be used as a ruse to wrong a wife. See Philippines.

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A marriage contracted in Mindanao or Sulu where the couple live in Sabah must be registered at the Sabah Islamic religious affairs office under the Islamic Family Law Enactment 2004 (Sabah), s.25 and s.31, within six months. Obtain a marriage certificate from the Shari'a Circuit Registrar or a PSA copy, not just a letter from the imam. To be registered in Malaysia, the documents usually need to be authenticated by the Philippine Department of Foreign Affairs (DFA) and the Malaysian Embassy in Manila: the Philippines has been a party to the Apostille Convention since 14 May 2019, but Malaysia is not a party to that convention (HCCH status table), so a DFA apostille alone does not apply in Malaysia (check the current procedure at the Malaysian Embassy). A contract without official documents, or without a valid wali, makes registering the child's birth and the spouse pass difficult. If the husband already has a wife, Syariah Court permission is still required; if domiciled in the Philippines, notice under Art. 162 PD 1083 must also be filed. See Philippines.

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Only four provinces: Pattani, Narathiwat, Yala and Satun, under the Act on the Application of Islamic Law B.E. 2489 (1946). There, in civil cases on family and inheritance between Muslims, Islamic law applies in place of the Civil and Commercial Code (s.3). A Dato' Yutitham sits with the judge and his ruling on Islamic law is final (s.4). The Act does not create separate Syariah courts. Songkhla is not included even though some of its districts have large Muslim populations; Muslim family disputes there are decided under the monogamous Civil Code. Act 1946 also has no polygyny permission procedure or specific penalties. See Thailand.

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A Thai wali hakim is valid only if the kinship wali is absent, refuses without a valid religious reason ('adhal), or is more than two marhalah away according to the Shafi'i school. If the kinship wali exists and can be contacted, using a wali hakim across the border risks making the contract doubtful. "There is no marriage without a wali" (narrated by Abu Dawud 2085 and at-Tirmidhi 1101; sahih), and "The ruler is the wali of one who has no wali" (narrated by at-Tirmidhi 1102; hasan). Disputes about the wali are the main reason registration applications are rejected; the Syariah Court may refuse to validate the contract and the couple may need to remarry. The safer route: apply for a wali hakim order at the Syariah Court of your own state. See cross-border marriage.

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No. The district office will not register a second marriage of a man who already has a registered marriage. The Thai Civil and Commercial Code rests on the principle of monogamy: s.1452 (amended 2024) states that a person may not marry while still having a spouse, and a marriage in breach of it is void (s.1495). A civil marriage exists only once registered (s.1457). As a result, most polygynous marriages in Thailand have only a religious certificate from the Provincial Islamic Committee. In the four southern provinces, the courts can recognise it in family disputes between Muslims, but for other civil matters a wife without civil registration is in a weak position (please check current practice). See Thailand.

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Yes, and in Hanbali fiqh, on which Saudi law is based, such a condition is valid and binding; if it is breached, the wife may choose annulment (fasakh). Article 27 of the Personal Status Law 2022 binds the spouses to the conditions they agreed, but it grants the right of annulment only if the condition is written in the marriage contract document or acknowledged by both parties. Article 28: if the husband breaches the condition, annulment takes place without compensation from the wife. The proof is the hadith: "The conditions most deserving of fulfilment are those by which you make intimacy lawful" (Sahih al-Bukhari 2721; Sahih Muslim, Kitab an-Nikah). However, some Saudi scholars argue the condition can be voided under Article 29, and how far the courts enforce it after 2022 needs check with the authorities of the country concerned. Make sure the condition is written into the registered contract. See Saudi Arabia.

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The Saudi spouse must obtain special permission from the Ministry of Interior before marrying a foreigner; a ma'dhun may not solemnise a mixed marriage without that approval letter. The Ministry of Justice guideline is Ministerial Order no. 6874 (1422H). Usual conditions such as age limits and age gaps have been reported and amended from time to time (please check through Absher or the regional Emirate office). A Malaysian bride needs a valid wali, and must bring her birth certificate, a verified letter of single or divorced status, and a certified Arabic translation. A foreign wife's residence permit depends on the husband as sponsor. After the akad, register it again in Malaysia (Act 303 s.31). See Saudi Arabia.

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It is not needed. The Saudi Minister of Hajj and Umrah announced in October 2022 that women may perform Hajj and umrah without a mahram if accompanied by trustworthy women or a safe group (Arab News, citing SPA). Package conditions and Tabung Haji policy for Malaysian pilgrims (check with the authorities of the country concerned). Moreover, according to the majority of scholars including the Shafi'i and Hanbali schools, a marriage contract is invalid while in ihram (Sahih Muslim, Kitab an-Nikah). An umrah or tourist visa is also not a route to residence; a marriage without approval gives no residence permit, and such marriages often cannot be registered. An undocumented "under the table" marriage leaves the wife and children unprotected. See Saudi Arabia.

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Every contract must be registered (Article 8) and conducted by a ma'dhun (licensed marriage officiant) under the Ministry of Justice. Najiz (najiz.sa) is the ministry's e-services portal for booking a ma'dhun, obtaining an electronic contract, documenting talaq and filing family cases. The standard contract records the amount of the mahr and has space for conditions, and the wife has the right to receive a copy. After the contract, the marriage is recorded in the Ministry of Interior's civil status register; since the 2019 amendments a woman can register the marriage herself (check the details). Keep a copy of the contract from Najiz and any foreign marriage approval letter — they are needed for re-registration in Malaysia. See Saudi Arabia.

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Court permission is not needed, but the husband must document the talaq within 15 days. Article 77 defines talaq as the dissolution of the contract at the husband's will. Under Articles 90–91, the wife has the right to be notified; if the husband fails to register or notify, the wife is entitled to compensation of at least the equivalent of the maintenance owed. Triple talaq in one pronouncement: under the official text of Article 83, any talaq coupled with a number, or repeated in one sitting, counts as only one talaq. The wife, for her part, may apply for khulʿ (Articles 95–102) or fasakh (Articles 103–115). For a marriage registered in Malaysia, a talaq abroad must be confirmed in a Malaysian Syariah Court. See Saudi Arabia.

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A misyar marriage — where the wife waives her right to maintenance or housing — is recognised through fatwas and commonly practised, but is not mentioned in the Personal Status Law 2022 (Musawah 2022). The main problem arises when it is not documented: a marriage without registration, including an unregistered misyar, makes it hard for the wife to prove the child's lineage, claim maintenance and obtain residence permission. Every contract must be registered (Article 8). For domestic workers, an undocumented "under the table" or misyar marriage leaves the wife and children with no residence permit, no official lineage and at risk of deportation. This site does not encourage unregistered marriages. See Saudi Arabia.

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The current law is Federal Decree-Law No. 41/2024 on Personal Status, in force from 15 April 2025, replacing Federal Law 28/2005. It applies to Muslims; non-Muslims may choose Decree-Law 41/2022 on Civil Personal Status. Its provisions include: marriage age 18, below 18 only with court permission (article 19); a limit of four wives (article 32(4)); contract conditions are binding, with a right to dissolve if breached (article 33); fairness between wives in treatment, rotation and maintenance (article 49(6)); wives may be housed in the same building if each has almost complete independence (article 105(4)); and talaq must be documented in court within 15 days (article 58). See Gulf States.

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Yes. Under Article 14 of Qatar Family Law No. 22/2006, in all cases the existing wife is notified after the contract. If the husband's status indicates financial inability, the marriage officer must also make sure the prospective wife knows of it, but may not refuse registration if she still agrees. Qatar does not require court permission. This law is based on the Hanbali school: a limit of four wives (Article 25(2)), contract conditions including not marrying again are binding and their breach gives the right to seek fasakh (Article 53), and the husband must be just between his wives (Article 57(6)). According to MICS 2012, about 4% of marriages in Qatar are polygynous. See Gulf countries.

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Yes. Under Bahrain Family Law No. 19/2017, the husband must declare his marital status; if already married, the ma'dhun records the existing wife's name and residence in the akad (article 19; Minister of Justice Decision 1/2016 article 9(3)). Registration is mandatory (article 18) and the husband must be just in maintenance and the rotation (article 39(d)). The wife may also put a condition in the akad that he will not marry again. This law unifies Sunni and Ja'fari provisions. Ministry of Justice data for 2020 show about 5.7% of Bahraini citizens' marriage contracts were polygynous, stable between 5.5% and 6.5% for 2015–2020. See Gulf states.

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No. A mutʿah marriage in Iran is not recognised by Islamic family law in Malaysia and is rejected by the Shafi'i school. Iran's Civil Code recognises temporary marriage according to Ja'fari fiqh, but all four Sunni schools consider it abrogated and void (Sahih Muslim, Kitab an-Nikah). Offers of a "contract" or fixed-term marriage are also a warning sign of marriage syndicates. For permanent marriage, remarriage in Iran falls within the Family Court's jurisdiction (Family Protection Law 2013, article 4); the first wife's consent requirement comes from the 1975 law, and its current application is check with the authorities of the country concerned. The Family Protection Law 2013 requires registration of permanent marriages, divorces and rujuk. See Iran.

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Yes. Under article 11 bis of Law 25/1929 (amended by Law 100/1985), the husband must state his marital status in the marriage contract, along with the name and address of each existing wife, and the ma'dhun must inform the existing wife by registered letter. The wife may seek divorce if she suffers material or moral harm making it impossible to live together, even if there is no condition in the contract; this right lapses one year from the date she learned of the marriage, or earlier if she consents. Polygyny is not considered harm in itself — harm must be proven. A new wife who did not know her husband was already married may also seek divorce. Giving false information can be punished with a fine and imprisonment (article 23 bis). See Middle East.

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In Jordan, the judge must check before conducting the akad of a man who is already married (Personal Status Law No. 15/2019, article 13). The judge must ensure that the husband is able to pay the prospective wife's mahr, able to provide maintenance for all his dependants, and that the prospective wife is informed that the man is already married. After the akad, the court informs the existing wife. The first wife's consent is not required. Article 79 requires the husband to be just in the rotation and maintenance. The akad must be documented by a judge or his deputy (article 36); an akad outside the court is punishable with a fine of up to JOD 200. In 2022, 7% of grooms in Jordan were already married (HPC/UNFPA 2023). See Middle East.

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Yes, it is among the strictest of the laws that still permit polygyny. Under the Moudawana 2004 (based on Maliki fiqh), polygyny is prohibited where injustice is feared, and prohibited if the wife stipulated in the contract that her husband would not marry again (article 40). The court does not permit it without an exceptional and objective justification, or if the husband cannot support two families (article 41). The husband applies with a financial statement (article 42), the existing wife is summoned (article 43), and the prospective wife must be informed and state her consent (article 46). If the first wife chooses divorce, her entitlements must be paid within 7 days or the application is deemed withdrawn (article 45). In 2020 there were only 658 cases, or 0.3% of contracts. See Middle East.

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No — both countries make polygyny a crime. In Tunisia (CSP 1956 article 18), a man who marries before his previous marriage is dissolved can be imprisoned for one year and/or fined, and a woman who knowingly marries him faces the same penalty. In Turkey, the Civil Code 4721 makes a marriage absolutely void if either party is already married (article 145(1)), and the Penal Code 5237 article 230 punishes it with imprisonment of 6 months to 2 years. An imam's contract (imam nikahı) in Turkey has no legal effect; such a wife has no right to maintenance, matrimonial property or inheritance. For Malaysians: a polygynous contract there is a crime and invalid — never do it. See Middle East.

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An 'urfi marriage is an unregistered marriage, and it undermines the wife's rights and the confirmation of the child's lineage — do not get involved. In Egypt, the official contract is concluded by a ma'dhun under the Ministry of Justice, and for a married man, the ma'dhun must notify the existing wife (article 11 bis of Law 25/1929). Avoiding this process with an unregistered marriage makes it hard for the wife to claim maintenance and other rights. On the Malaysian side, a marriage abroad by a Muslim domiciled in Malaysia must be registered in their state within the period set by the Enactment, and documents must be endorsed through the Malaysian Embassy. A contract without a valid wali also risks not being recognised. See Middle East and cross-border marriage.

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It is your choice, but across the GCC, a condition in the marriage contract is the most effective tool for a wife who does not want a co-wife. No GCC country requires court permission before a husband marries again. In the UAE (article 33) and Qatar (article 53), breach of a valid condition gives the right to seek dissolution or fasakh; in Bahrain a wife may stipulate that her husband will not marry again. Write the condition clearly in the contract and keep a registered copy — verbal agreement is hard to prove. Other conditions such as working, studying or a separate home can also be stated. Make sure the contract is concluded by a licensed officer and re-registered in Malaysia. See Gulf states.

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A wali (guardian) by kinship who lives far away may delegate (tawkil) in writing to the marriage officiant in the country of the contract, and this is safer than going straight to a wali hakim. A wali hakim is used only when the kinship wali is absent, refuses without a valid religious reason ('adhal, which a court must decide), or is more than two marhalah away and cannot be contacted. "There is no marriage without a wali" (narrated by Abu Dawud 2085 and at-Tirmidhi 1101; sahih). A foreign spouse also needs documents of status and the wali's consent from their own country; foreign documents usually need to be certified by the home country's foreign ministry and embassy, and translated if necessary. A contract in Malaysia has the advantage of direct registration by the state religious affairs office. See cross-border marriage.

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Yes. A talaq or divorce order abroad must be registered or confirmed at the Syariah Court in Malaysia before you can remarry in Malaysia, and the ʿiddah is counted from the date of the actual talaq. For marriages registered in Malaysia, a talaq pronounced in Thailand must be confirmed and registered at the state Syariah Court. In the Philippines, the talaq must be notified (PD 1083 Art. 161) and then confirmed in Malaysia. In Saudi Arabia and the UAE, the talaq must be documented within 15 days there — keep the documents. Claims for maintenance, mutʿah (consolatory gift) and harta sepencarian are easier to make in the country where the husband has assets; foreign court orders are not necessarily enforceable automatically. See cross-border marriage.

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Register the birth at the Malaysian Embassy/Consulate within the set period (usually one year) so that the child's citizenship is recorded under the Federal Constitution, Second Schedule. The amendment to the Federal Constitution passed by the Dewan Rakyat in October 2024 will allow a child born abroad to a Malaysian citizen mother to acquire citizenship by operation of law. According to a Bernama report (14 Nov 2025), the amendment was not yet in force and was targeted for mid-2026; please check the gazette for its commencement date. An unregistered marriage may mean the birth certificate does not record the father's name, and the child may be treated as illegitimate for citizenship purposes until the marriage is validated. Under the Shariah, a child born at least six lunar months after a valid akad is attributed to the father (Surah al-Ahqaf 46:15; Surah Luqman 31:14). Malaysia does not allow dual citizenship for adults. See recognition.

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The foreign spouse of a Malaysian citizen may apply for a Long-Term Social Visit Pass through the Immigration Department. According to the Immigration Department's official website (viewed 14 Oct 2026), the pass may be granted for up to five years, subject to approval, and the holder may work or run a business with permission endorsed in the passport. Conditions for permanent residence (consult the local authorities). The application requires a Malaysian marriage certificate — one more reason to register a marriage abroad promptly at the state Islamic religious affairs office. A marriage that cannot be registered, for example because the wali is in doubt or an unauthorised polygynous marriage has not been resolved, makes the spouse pass, the child's birth registration and maintenance claims difficult. Do not marry on a visa that does not allow it, such as an umrah or tourist visa in a country that requires approval. See cross-border marriage.

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Yes. The permission of a Malaysian Syariah Court is still required even if the country of the contract allows polygyny without permission. The domicile law of a Malaysian man still applies (Act 303 s.23; state Enactments). A polygynous contract in the Gulf without that permission may lead to action under the state Islamic family law when it is registered in Malaysia. In the Gulf, the contract must be concluded by a licensed officer or court; in Bahrain the marital status and the name of the existing wife are recorded in the contract, while in Qatar the existing wife is notified after the contract. Expatriate workers usually need status documents and embassy confirmation (check with the embassy or the authorities of that country). An unregistered contract affects visas, residence and the children's lineage. See Gulf countries.

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There is no official Malaysian figure; there are only statements by Thai religious authorities, the consulate and state executive councillors, and these figures cannot be added together. The Malaysian Consulate in Songkhla (Feb 2024) cited nearly 300 Malaysian couples a month, about 60% of them polygynous. Kedah recorded 799 cases in 2018, up from 566 in 2017. The Narathiwat Islamic Council (2022) stated that more than half the men who came for polygyny held the title "Datuk". After the illegal routes were closed from 1 December 2024, marriages in Narathiwat fell by about 40%. The Songkhla Islamic Committee recorded 4,500 couples in 2015. The consulate verifies documents but does not publish a data series. See polygyny in Malaysia.

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A marriage in Thailand causes the existing wife to lose the right to be heard by the court before the polygamous marriage and the right to claim division of harta sepencarian at that stage — but Malaysian law still protects you. A man who marries without permission must immediately pay all the mas kahwin and pemberian owed to the existing wife (Act 303 s.23(7); Selangor s.23(8)), and the husband may be prosecuted (Act 303 s.123; Selangor s.124). A wife who is not treated fairly may apply for fasakh, for example under Selangor 2003 s.53(1)(h)(vi), and failure to give proper justice is also an offence (Selangor and Kedah s.129). Refer to the Syariah Court or the religious office of your state. See polygamy in Malaysia.

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Muslim divorces in Singapore are handled by the Syariah Court of Singapore under the Administration of Muslim Law Act (AMLA); a talak pronounced outside court must be brought to the court for registration.
The forms of divorce handled include talak, khulʿ, fasakh and taʿliq divorce, and parties usually have to go through a counselling or support programme before the case proceeds. Singapore's Syariah Court can decide mut'ah, ʿiddah maintenance, custody and the division of matrimonial assets. For Malaysians whose marriage is registered in Malaysia, the divorce must also be registered or confirmed in their home state so that Malaysian records are updated. Allah tells us to part in a good way (al-Baqarah 2:229); follow the process in both countries. Check current requirements on the Syariah Court of Singapore's website. See Singapore.

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Permission only opens the door; after the contract, each wife is entitled to adequate maintenance and housing and a fair turn, and need not live with her co-wife without her consent.
Allah makes justice a condition (an-Nisa' 4:3) and forbids inclining wholly to one wife (an-Nisa' 4:129). The Prophet ﷺ warned that a man with two wives who inclines to one will come on the Day of Resurrection with one side of his body leaning (Sunan Abu Dawud 2133). A wife may give her turn to her co-wife, as Sauda r.a. did for ʿAisha r.a. (Sahih al-Bukhari 5212). If these rights are neglected, a wife may take her claim to Singapore's Syariah Court, including maintenance and fasakh. See Singapore.

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Not automatically. A foreign spouse of a Singaporean citizen needs a long-term pass applied for separately, and the marriage must also be registered in Malaysia.
A contract in Singapore usually requires at least one party to be resident or to meet the conditions of the Registrar of Muslim Marriages (ROMM), and a foreigner needs certified marital-status documents from their home country. A Malaysian husband who is already married needs permission from the Syariah Court of his state in Malaysia, and hiding an existing wife can be an offence in both countries. After marrying, register the marriage with the state religious office or the Malaysian High Commission in Singapore within the set period. Allah tells us to record important matters (al-Baqarah 2:282). Check current immigration requirements before planning where to live. See Singapore.

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Muslim divorces in Brunei go through the Syariah Court, and pronouncing talak outside court without permission is an offence under Brunei's Islamic family law.
Chapter 217 provides for a divorce application with reconciliation attempted first (s.42), syiqaq with arbiters (s.43), dissolution for syarie harm (s.44), taʿliq divorce (s.45), fasakh (s.46), khulʿ (s.48) and liʿan (s.49), while talak outside court without permission is an offence (s.124). Mutʿah, ʿiddah maintenance, custody and jointly acquired property are claimed at the Syariah Court. This approach is in line with Allah's command to reconcile couples through arbiters before they part (an-Nisa' 4:35). Malaysians married or living in Brunei must also make sure the divorce is registered in Malaysia. See Brunei.

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Follow Brunei's process for the contract, obtain the Malaysian permissions required (including polygamy permission if already married), and register the marriage in Malaysia afterwards; one permission does not replace another.
A Malaysian husband who is already married needs the Syariah Court's permission in Malaysia, and if the contract is in Brunei, he must also meet Brunei's process (Islamic Family Law Act, Chapter 217, s.23). The marriage must be registered with the state religious office or the Malaysian High Commission in Bandar Seri Begawan within the period set by the state enactment. Sabahans and Sarawakians marrying in Brunei are subject to their own state's Islamic family enactment or ordinance. Allah tells us to record important matters (al-Baqarah 2:282); keep the original documents and certified copies. See Brunei.

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No. In Indonesia, divorce can only take place before a court hearing after reconciliation fails; a talak outside the Religious Court is not registered and does not change official status.
Law (UU) No. 1 of 1974, Article 39 sets this principle. For Muslims, the husband applies to the Religious Court for permission to pronounce talak (cerai talak), while the wife files a divorce suit (cerai gugat), including khulʿ or for breach of the taʿliq. The grounds for divorce are set out in Government Regulation (PP) No. 9 of 1975, Article 19 and the Compilation of Islamic Law (KHI), Article 116. After the judgment, the parties receive a divorce certificate, and ʿiddah, mutʿah, child maintenance and custody are decided. Cross-border couples must make sure the divorce is recognised in both countries; consult a lawyer in Malaysia and an advocate in Indonesia. See Indonesia.

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Not for the civil record: a marriage also registered civilly in Thailand must be dissolved civilly too, either by registering a divorce by consent at the district office or by court order.
In the four southern provinces that apply Islamic family law, talak, khulʿ and fasakh follow Islamic law, and disputed cases are decided by the court sitting with a Dato' Yutitham. But if the civil record is not updated, the couple remain recorded as married under Thai civil law (the Civil and Commercial Code). For Malaysians, a talak pronounced in Thailand for a marriage registered in Malaysia must be confirmed and registered at the state Syariah Court. Allah commands parting in a good way, with witnesses (at-Talaq 65:2). See Thailand.

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Not as before. Republic Act 11596 (2021) makes the marriage of anyone under 18, including under custom or religion, a prohibited child marriage that is void from the start.
Art. 16 of PD 1083 once allowed Muslim men to marry at 15 and women on reaching puberty, and even earlier by court order. RA 11596 makes arranging, solemnising or cohabiting with a child a crime, and its repealing clause amends conflicting provisions, including Art. 16 to the extent of the conflict. For Muslims and indigenous peoples, certain penalties were suspended for a year as a transition. Islam requires marriages that protect welfare and cause no harm (Sunan Ibn Majah 2340). Malaysians, especially in Sabah, should not take part in marrying children in the Philippines. See The Philippines.

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PD 1083 Art. 45 defines divorce as a dissolution granted only after all efforts at reconciliation have failed, and recognises forms such as talak, ilaʾ, zihar, liʿan, khulʿ, tafwid and fasakh.
Muslims are the only group in the Philippines who can lawfully divorce within the country. Talak under Art. 46 is a single pronouncement during a period of purity without intercourse, and several pronouncements within one period of purity count as one; reconciliation may take place within the ʿiddah without a new contract. Ilaʾ (Art. 47) lets a wife obtain a divorce order if the husband swears not to be intimate with her for at least four months. Divorces must be registered with the Shariʿa registrar. These principles match the Quran's call for reconciliation through arbiters (an-Nisa' 4:35) and gradual talak (al-Baqarah 2:229). Malaysians who divorce in the Philippines must register it in Malaysia. See The Philippines.

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No. Kuwait's Personal Status Law of 1984 does not require court permission or any duty to inform the wife; the limit set is not marrying a fifth wife until one of the marriages is dissolved and its ʿiddah has ended (Article 21).
This differs from Malaysia, where Syariah Court permission is required (Act 303 s.23). Malaysians working in Kuwait remain bound by Malaysian law: marrying again in Kuwait without court permission in Malaysia can be an offence on return, and the marriage must be registered. Kuwait also has family courts that handle judicial divorce on grounds such as maintenance and harm. Allah still makes justice a condition in every country (an-Nisa' 4:3). See The Gulf & Iran.

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Kuwaiti courts do not hear claims about a marriage that has not been officially documented (Article 92), so a wife may lose the route to claim maintenance, custody and her other rights.
The provision shows how important registration is, in line with Allah's command that important matters be written and witnessed (al-Baqarah 2:282). Malaysians who marry in Kuwait, or anywhere in the Gulf, should make sure the contract goes through a recognised authority and the documents are certified, then register the marriage in Malaysia within the set period. Do not rely on a "religious only" contract with no record; if a dispute or death occurs, the rights of the wife and children are hard to prove in either country. See The Gulf & Iran and Unofficial marriages.

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Not without the wife's consent. Oman's Personal Status Law (Royal Decree 32/97) Article 59 forbids a husband to house a wife with her co-wife in the same home without her consent.
Oman does not require court permission or notice to the wife for polygamy, but sets the limit of four wives (Article 35(2)) and the duty of fairness (Article 37(6)), requires marriages to be officially documented (Article 6) and talak to be registered within 30 days. The principle of separate homes matches the Shafi'i view that a wife need not live with her co-wife without consent, based on the duty to provide housing (at-Talaq 65:6). Malaysians in Oman still need the Malaysian Syariah Court's permission to take another wife. See The Gulf & Iran.

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Most Gulf states have family courts that allow a wife to seek khulʿ, divorce for harm, and fasakh for breach of conditions in the contract; a husband's talak must be documented within a set period.
For example, the UAE allows fasakh for breach of conditions (Article 33) and requires talak to be documented within 15 days (Article 58), while Qatar allows fasakh for breach of conditions and divorce for harm caused by polygamy (Article 53). So conditions written into the contract in these countries have real effect. Allah tells couples who cannot reconcile to part in a good way (al-Baqarah 2:229). Besides the process there, the divorce must be registered in Malaysia, and custody and the children's travel should be planned with lawyers in both countries. Contact the Malaysian embassy if help is needed. See The Gulf & Iran.

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