SOCIAL AND RELIGIOUS DIMENSIONS OF CHILDREN’S IN HERITANCE IN TURKEY, SAUDI ARABIA AND INDONESIA

Abstract

This paper explores the framework of inheritance provisions for biological children and adopted children in three different countries, namely Turkey, Saudi Arabia, and Indonesia. The reinterpretation of children’s inheritance rights in society today demonstrates the increasing response to social context vis a vis religious text. Turkey and Indonesia share an emphasis on social dimension in reinterpreting children’s inheritance rights for men and women portions. Saudi Arabia, however, is remained to adopt conservative approach in interpreting the religious texts wherein men’s share twice as much as women. This research is a normative (doctrinal) approach in comparing legal issues on inheritance exercised in three countries. The data are based on literature such as regulation, books, journals, and related articles. This paper argues that socio-cultural conditions, political dynamics and ideological mainstream shape the nature of law in each country.