One of the more notable features of Indonesian Islamic law is
its recognition of the concept of jointly owned marital property
which bears a striking similarity to the community property
system in California. In both systems the marital estate
consists of property acquired during the marriage through the
efforts of either of the spouses. Islamic inheritance law has
long been a source of controversy in Indonesia. The controversy
has generally been framed in terms of a supposed conflict
between Islamic inheritance doctrines and the customary law or
adat of the country's many ethnic communities. This article
argues that recent developments in Indonesian Islamic
inheritance law have narrowed the differences between Islamic
and customary approaches to the distribution of property on
death. Indonesia the largest Muslim country in the world, has
witnessed what may be interpreted as a continued Islamisation of
its Family Law, including the absorption & subsumption of
prevalent practices into a logic of codification a