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Journal of Islamic Law Review, Vol. 8, No. 1, June 2012, pp.

215-229

Mahr (dower; hereinafter mahr) is considered as an essential part of a Muslim


marriage. The husband gives it to his wife as a matter of her right, as it has
been mentioned in the Quran and accentuated by Hadith of the Prophet
Muhammad (s.a.w.); and it becomes her exclusive property. It is also given
as a mark of respect for her. If the mahr is not paid during the solemnisation
of the marriage, the right to mahr remains even after divorce except in certain
circumstances. The paper deliberates sheds light on the right of a woman to
mahr in Islamic law. In this paper, the differences of views of some Muslims
jurists pertaining to this matter have also been discussed. Legal provisions
and the practice of the Malaysian courts in entertaining this right of a woman
will be the focus of the paper. Thus, cases decided at the Shariah courts
relating to the claim of mahr has also been referred to study the practice of it
in Malaysia as well as problems problems pertaining to it. Comparison with
other jurisdictions on the practice of mahr is highlighted, especially the practice
in India. After analysing the contemporary legal provisions on mahr and its
practice, certain suggestions and recommendations are made for further
improvements in this area of law. Hence, the right of Muslim women to
mahr as enshrined in the Quran will be preserved.

In Islam, mahr is not a consideration for sale of a girl to a husband


unlike the African practice of giving a bride-price. It is also not similar
to the old European practice of dowry in which the father used to
give his daughter a heavy dowry at the time of her marriage. The
dowry given became the property of the husband and not the wife.
In India, fathers are required to pay very heavy dowries in order to
find suitable husbands for their daughters. It is given as compensation
to the husbands parents for the amount they had spent in educating
*

Associate Professor, AIKOL, IIUM, Malaysia, E-mail: ahnora@iium.edu.my

and upbringing their son. In Bangladesh, a study conducted in 2004


by Luciana Suran and others entitled Does Dowry Improve Life for
Brides? A Test of the Bequest Theory of Dowry in Rural Bangladesh
discovers that among Hindus in North India dowry sometimes can
amount to three or four times a familys total assets. The study shows
that the relation between dowry and abuse is highly level-specific in
which respondents who paid small dowries report much higher level
of abuse than those who paid large dowries.
It is observed that it is only in Islam that a woman has absolute
rights of getting mahr from her husband. Other nations require
women to pay dower to their husbands. Islam confers absolute rights
on the woman to demand as much dower from her husband, as she
desires to acquire it at her discretion and use and enjoy it according
to her wishes. The discussion in this paper focuses on the right of a
woman to mahr under the Shariah and the law of Malaysia. The
impact of mahr in the society is also deliberated in order to offer
necessary suggestions to the existing law and practice in Malaysia.

Mahr is a pre-requisite for a marriage and it is to be paid by the


husband to his wife. The amount of mahr should be equitable
however; both husband and wife can mutually make any adjustment
to the mahr. According to Ameer Ali, dower is a consideration for
wifes sole and exclusive use and benefit.1 Iqbal Siddiqi refers it as
either a sum of money or other property to which the wife is entitled
by marriage.2 The amount of mahr may be fixed either before or at
the time of marriage or after marriage and can be increased at any
time by mutual consent.3
In Islam, mahr is given to the wife as a reward for
submitting herself to the husband. It is to elevate the status of a
woman as the property becomes her exclusive property. It would be
a check on the arbitrary exercise of the power of divorce by the
husband.4
The authorities for mahr are laid down the Quran and the
practice of the Prophet Muhammad (s.a.w.) (Sunnah). In the Quran
it is mentioned to the effect that,

And give to the women (whom you marry) their Mahr (obligatory bridalmoney given by the husband to his wife at the time of marriage) with a
good heart; but if they, of their own good pleasure, remit any part of it to
you, take it, and enjoy it without fear of any harm.5

The above verse has referred to following three basic points: firstly,
mahr is referred to as sadaqah and sadaqah is derived from the root
sadaq. It is a token of the truthfulness and earnestness of the affection
of the man. Secondly, the pronoun hunna in the verse means that it
is ordained that the mahr belongs to the woman herself and not to
her parents. Mahr is not the wages for having brought her up, nursed
her and fed her. Thirdly, the word nihlatan makes it complete clear
that mahr has no other purpose apart from being an offer, a present,
or a gift.6
In another verse it is stated to the effect that,
give them their mahr as prescribed; but if after a mahr is prescribed,
you agree mutually (to give more) there is no sin on you.7

It is further mentioned in the Quran to the effect that,


There is no sin on you, if you divorce women while yet you have not
touched them, nor appointed unto them their mahr. But bestow on them,
the rich according to his means, and the poor according to his means, a gift
of reasonable amount is a duty on the doers of good.8

Allah (s.w.t.) explains in another verse to the effect that,


And if you divorce them before you have touched them, and you have
appointed unto them the mahr, and then pay half of that, unless they
agree to forego it, or he in whose hands is the marriage tie, agrees to forego
and give her full-appointed mahr.9

The above verse shows that if a Muslim man divorces his wife before
the marriage is consummated or before dower is fixed he is required
to give a suitable amount to the divorced woman according to his
own capacity. However, if mahr is fixed before the marriage and
divorce (talaq) is pronounced before the consummation of marriage,
the husband shall have to pay one half of the fixed mahr to the wife.
There are conditions for mahr to be validly given to the wife.
Firstly, there must be a valid marriage. Secondly, things that be given
as a mahr must be something that can be possessed and can be sold

and purchased. Thirdly, the items must be clean and pure or a kind
of beneficial service to the wife. Fourthly, mahr must be known of
its character and the amount. Lastly, it should be free from any fraud.
According to the Islamic law, there are two types of mahr, i.e.
specified mahr and proper mahr. Specified mahr is mahr that is
specified at the time of aqad.10 It is of two types prompt and deferred.
In the case of prompt mahr it is payable immediately after the marriage
and must be paid on demand.11 If the prompt mahr is not paid the
wife could refuse to stay with her husband and also can take legal
action. The court in Bangladesh, in the case of Nuruddin Ahmad v.
Masuda Khanam (PLD 1957, Dacca, p. 242) held that prompt dower
might be considered a debt always due and able to be demanded and
payable upon demand. The wife is under the Islamic law entitled to
refuse herself to her husband until and unless the prompt dower is
paid.12 It was also held in the case of Rahim Jan v Md. that the wife
can refuse to live with her husband if dower is not paid on her demand
and consummation does not affect this right of the wife.13 (Citation).
Deferred mahr becomes payable at the termination on the
dissolution of marriage either by death or divorce.14 If the marriage
is dissolved by divorce then mahr can be recovered by bringing legal
action in the Syariah (In Malaysia, Shariah is written as Syariah)
court. If by death the dower can be recovered from her husbands
estate. In the Malaysian Syariah court case of Shaari v Teh15 the wife
deserted the husband. She refused to resume cohabitation unless the
husband paid arrears of maintenance and deferred mahr of RM
300.00. It was held that the husband has to pay the deferred mahr.
In the case of Raman v Hasnah16 the respondent had claimed the
balance of the marriage expenses amounting to RM 100.00 from
the appellant. The appellant admitted that he had not paid the sum
due and judgment was given in favour of the respondent. The
appellant appealed to the Shariah Appeal Court, however the appeal
was dismissed.
In USA, New York court in Aziz v. Aziz (1985) enforced a
deferred mahr of $5,000 because the terms of contract complied with
New Yorks General obligation Law. The courts in USA treat mahr
as part of an ante-nuptial agreement. Thus, for it to be enforceable

the agreement must meet the standards of state law applying to all
ante-nuptial contracts.17 However, in Hosman Ibrahim Dajani v.
Dawn Lynell Dajani (2011, Court of Appeal Virginia), a Jordanian
wife was denied deferred mahr as the court heard expert testimony
that mahr is forfeited if the wife initiates the separation.18
Mahr mithli is mahr of a woman, which is determined by
comparing with the mahr settled upon other female members of her
family.19 It is determined by referring to the mahr received by female
members from the paternal side such as sisters, aunts and cousins. It
can also be determined by referring to the age, education, religion
and the status in the society.20
Under the Shariah, a woman is entitled to her full mahr
musamma (specified mahr) where there has been a valid marriage
that has been consummated, even when the marriage has been
dissolved by divorce or death.21 When there has been a valid marriage
that has not been consummated and has been dissolved by divorce
(where the dower has been fixed) she is entitled to half mahr
musamma.22
Concerning the amount of mahr, there is no specific rule under
the Sharah. It is normally given according to social status, wealth,
personal qualification and conditions of human society.23 It should
however, possess some value and it is recommended that it should
be less than 1,000 or more than 500 dirhams.24 Prophet Muhammad
(s.a.w.) paid varying amounts to his wives. In the case of Ummu
Habibah, she was paid 4,000 dirhams, while in case of the other
wives it was generally 500 dirhams.25 The lowest amount mentioned
in a hadith is an iron ring and the man who could not give anything
as a mahr was asked to teach his wife the surah from the Quran that
he memorised.26
Where there is no amount fixed for the mahr in the marriage
contract, the law gives the wife a right to the proper mahr
proportionate to her situation and position in life. In line with the
Shariah principles, it is submitted that the amount of mahr should
not be too expensive as it can cause burden to the husband.
Sometimes, it is observed that the brides family puts pressure on the
groom and his family for a large amount of mahr with the purpose

to show it off to the public and it is also not right to have a secret
arrangement in order to write in the paper a large amount of mahr
while in fact the girl will receive less than that.27 By doing this, no
one is deceived but himself or herself.
Fixing of excessive amount of mahr is being used in some
countries especially in Arab countries such Arab Saudi, UEA and
Kuwait. In South Africa, it is practised as a means to control and
check the husbands unilateral and unlimited power of divorce, as he
has to pay the full amount of mahr at the time of divorce.28 In some
countries, it becomes a common practice that the women use their
mahr to furnish their new homes. This practice does not contrary to
the Shariah as long as the wife agrees to it.29 However, it should not
be encouraged, as it is the duty of the husbands to prepare homes for
their wives.

In Malaysia, the practices of mahr among the Muslim Malays


represent a compromise between the Muslim law and the ancient
Malay custom. According to Ahmad Ibrahim, Islamic law recognizes
one payment that is the mahr whereas the Malay customary law insists
on a whole series of conventional presents/gifts beginning with the
betrothal and sometimes continuing till the birth of the first child or
even later.30
Under the Malay custom, the amount of mahr is fixed and
normally depends on the rank of the father of the woman.31 The
amount of mahr differs between a virgin or unmarried woman and a
previously married woman. The amount for previously married
woman is half of the amount for the unmarried woman. In Negeri
Sembilan, the amount of mahr must be the traditionally accepted
amount as fixed by the custom in the particular area. In the state of
Johor, the amount of mahr is fixed at RM22.50. In the state of
Selangor, the amount of mahr varies with the status of the bride
ranging from RM80.00 for the daughter of a commoner to RM2,
5000.00 for the daughter of the Ruler/King. Recently, the amount

of RM80.00 has been increased to RM300.00. This has made Selangor


being the highest state in fixing the amount of mahr in the country. In
the state of Malacca, the amount of mahr is RM40.00. Some states
such as Perlis, Terengganu, Kelantan and Kedah the amount of mahr
is not fixed by the states. In practice, it is given according to mutual
agreement between the parties involved. It is submitted that the rate
of mahr is not uniform from one state to another state which some
time may cause difficulty to the groom and his family.

Maskahwin/Mahr is defined in the Islamic Family Law Act, 1984 as


the obligatory payment due under Hukum Syara by the husband to
the wife at the time of aqad, whether in form of money actually
paid or acknowledged as a debt with or without security or in the
form of something that, according to hukum Syara is capable of being
valued in terms of money.
Section 21 of the Islamic Family Law Act, 1984 provides:
The mas kahwin shall ordinarily be paid by the man or his representative
to the woman or her representative in the presence of the person solemnising
the marriage and at least two other witnesses.

The registrar shall, in respect of every marriage to be registered by


him, ascertain and record:
(a) The value and other particulars of the mas kahwin;
(b) The value and other particulars of any pemberian;
(c) The value and other particulars of any part of the mas kahwin
or pemberian or both that was promised but not paid at the
time of the solemnisation of the marriage, and the promised
date of payment; and
(d) Particulars of any security given for the payment of any mas
kahwin or pemberian
Section 57 of the IFLA, 1984 provides:
Nothing contained in this Act shall affect any right that a married woman
may have under Hukum Syara to her mas kahwin and pemberian or any
part thereof on the dissolution of her marriage

In Malaysia, based on the above legal provision, the Syariah courts


allow the wife to claim for the payment of mahr if it still due after
divorce. In the case of Salma v Mat Akhir32 the wife claimed payment
of mahr of RM600.00. The husband claimed that the wife had
remitted the payment. The wife denied and called two witnesses.
She was asked to take an oath. The Qadi accepted the evidence of
the wife and ordered the husband to pay the mahr.
In Siti Zamrah v Majid33 the wife claimed for maskahwin and
pemberian. The husband claimed that the wife had agreed to give all
the property to him to facilitate the divorce. The husband called
only one witness. The Qadi asked the wife to take the oath to deny
any such agreement. The Qadi ordered the husband to pay a total of
RM770 to the wife.
In Janat v Sheikh Khuda Buksh34 the order of a Qadi for the
payment of maskahwin to a divorced wife was confirmed on appeal
by the Civil High Court. It was held that the husband must pay the
mahr in money. Only with wifes consent may he substitute articles
for money. If articles are given, they cannot be regarded as part of
the mahr in the absence of proof of such consent and the burden of
proof is on the husband.
The above cases show that if the husband is yet to pay mahr and
the marriage ends with divorce, the wife can claim the payment in
court. In the above-mentioned cases the court ordered the husband
to settle the payments which are still due to his wife.

Dowry as defined by the Law Commission of India means money or


other things estimable in terms of money demanded from the wife
or her parents or other relatives by the husband or his parents or
other relatives where such a demand is not properly referable to any
legally recognised claim and is related only to the wifes having married
into the husbands family. Arranged marriages are still widely practised
in India and a womans value to her husband and in-laws is enhanced
when she is accompanied by a substantial dowry.35 It is not a one
time payment, but is open ended in nature.36 As dowry is increasingly
given in cash, the husband and in-laws often misuse it. They also ask

the woman for additional dowry. Many young men in India see dowry
as a legitimate means of acquiring luxury items, clearing family debts
and moving up on the social status.37 In Bangladesh, dowry is used
by a bride and her family as a means to raise their status by marrying
the daughter into a higher status family.38
In South Asia, dowry deaths are common. In India, for example,
it was reported there were 4,215 dowry deaths in 1989, 4,836 in
1990 and 4,656 in 1991.39 Dowry was reported as the chief motive
in 5.6% and 6.9% of the cases of murder and culpable homicide in
the years 1988 and 1990 respectively.40 In Bangladesh, recent studies
suggest a link between domestic violence and dowry demands. Wife
abuse has been found to be higher when a husband or his family
believes dowry payments are inadequate.41 These deaths of women
are usually caused by the same persons who are legally and socially
supposed to protect them, i.e. their husband or in-laws.42
As regards to the legislation, India was first in South Asia to
make an attempt to control the dowry problem by passing the Dowry
Prohibition Act of 1961.43 Taslima Monsoor44 in her article states
that in Bangladesh the problems of dowry became so horrendous
after independence that activist women and some enlightened males
were demanding legislation to stamp out this social evil. She also
states that the commodisation of women was seen as neo-patriarchy,
which should not be tolerated any longer by the activists.
Consequently, the government under the pressure passed the Dowry
Prohibition Act of 1980.
According to Taslima45 the real need of women in Bangladesh is
to be protected from violence and economic deprivation. She explains
that dowry problems in Bangladesh involve both aspects of the need,
i.e. freedom from economic deprivation and violence. She also
observes that demands for reforms to control these problems were
already made earlier and thus, the Dowry Prohibition Act, 1980 and
the Cruelty to Women (Deterrent Punishment) Ordinance, 1983
were enacted in response to growing evidence of cruelty against
women.46 Recently in Bangladesh, a more comprehensive enactment
(the Repression Against Women and Children (Special Enactment)
Act xviii of 1995 has repealed the Cruelty to Women (Deterrent

Punishment) Ordinance, 1983 and enhanced the punishment.47 More


recently the Women and Children Repression Prevention (Special
Provision) Act 2000 exaggerated punishments in most cases up to
death penalty for crime against women and children.48

Under the Islamic law, mahr is the exclusive right of the wife in which
the father does not have the right to take even a small amount of it
without the consent of the woman. Woman has the full right to her
mahr, which is presented to her by her husband and is included in
the nuptial contract, and that such ownership does not transfer to
her father or her male relatives. The concept of mahr in Islam is
neither an actual nor symbolic price for the woman, as it is the case
in certain cultures, but rather it is a gift given to the wife. It is
connected with the womans modesty and chastity thus, she should
know that it is necessary for her honour and respect that she should
not give herself up freely to the authority of man but should give
herself worth.

It is recommended that the amount of dower in Malaysia should be


reviewed, as at present the rate of mahr in most of the states is relatively
low as compared to the high cost on living especially, in the big cities
such as Kuala Lumpur, Shah Alam, Petaling Jaya and Johor Bahru.
It was reported in July 2008 that the Muslims getting married in the
state of Selangor next year may have to pay more dowry following
the State Religious Departments proposal to review the rates.
Department Director, Datuk Mohamed Kushrin Munawi said the
current rates were RM80 for first-time brides and RM40 for divorcees
or widows. According to him the rates of mahr have not changed
since 1978.49 Thus, it is time for a review as many other states have
also increased their dowries.50 Zainunnisaa51 views that the current
rates are no longer reasonable and practical considering the rise of
prices in goods. She suggests for the increase amount of mahr in

order to overcoming the issue of extreme hantaran (marriage expenses)


which is seen as causing problems like delayed marriage among young
men, the phenomenon of spinsterhood, debts and even cheating.
However, in the State of Kelantan where the amount of mahr is not
fixed it has been announced recently that the State government is
considering lowering the rate of mahr to overcome the problem of
delayed marriage among the current young generation.52
Professor, Dr. Ahmad Atory Hussain from Universiti Utara
Malaysia (UUM) says it is cheaper for Malaysian men to marry
Indonesian women, as the dowry is lower.53 It is felt that the
Professor did not in his statement refer it to mahr but to the marriage
expenses (hantaran). This is because the rate of mahr in Malaysia is
not high in fact as stated above, it is very low. What is expensive is
the amount of marriage expenses. It is observed that the act of
demanding a large amount of marriage expenses and wedding gifts
which becomes the current trend among the Muslim Malays society
in Malaysia causes burden to the male party as there have been
cases of impersonation, cheating and debts in order to fulfil such
demands. 54
In Malaysia, it is submitted that the practice of mahr can be
improved further if the following suggestions are considered:
1. To uniform the amount of mahr in all States in Malaysia as
at present the amount varies from one State to another State.
This has created some problems in the society. For example,
in the state of Kelantan where the amount of mahr is not
fixed, the amount paid by the husband varies. As such, it
can be difficult for the family to decide on the proper amount
of mahr.
2. Zainunnisaa in her article proposes the new rate of mahr to
be fixed at RM900. She said the proposed amount is parallel
with the national minimum wage proposed by labour activist
for the private sector and also considering the newly increased
salaries for government servants.55
3. To legislate that it is an offence to take the mahr from the
wife as in Islam mahr is an exclusive right of a wife.

4. To organise workshop, talk, seminar on the significant of


mahr in marriage.
5. To educate the public about the concept of mahr in Islam
and moderation in spending for wedding ceremony. This is
important so as not to demand for higher amount of
marriage expenses from the husband.
6. To require the groom to pay mahr promptly during the aqad
and if he fails to do so the registrar of marriage is given the
authority to force him to sign a declaration that he will pay
the mahr within the first year of the marriage and failure of
which he will be prosecuted.
For India several proposals have been made by Prasad, B Devi56
in his research entitled Dowry related violence: A content analysis
of news in selected newspapers as follows:
1. Social workers and womens organizations can play an
important role in making the legal provision work and in
initiating and sustaining such new value and norms
favourable for ending dowry victimization.
2. Alternative role models, values and practices covering the areas
of marital interaction, gender roles and the custom of dowry
should be propagated by redefining roles of men and women.
3. There is the need for restructuring the social norms and
sanctions governing the expectations of the wife-takers and
the obligations of the wife-givers in the context of marriage.
As for Bangladesh, Taslima 57 proposes that remedies to the
problem of dowry can only be achieved by changes of attitude in
society. This can be attempted by legislation; however, will need to
be supported by education and legal awareness. She further suggests
for parents to safeguard their daughters from economic deprivation
and violence by educating them about their rights within marriage
such as the right to dowry.

1.

See, Syed Ameer Ali, Principles of Muhammadan Law, Allahabad, Law


Publishers, 1998.

2.

M. I. Siddiqi, The Family Laws of Islam, Lahore, PK, Kazi Publications,


1984, p. 79.

3.

Ibid.

4.

Ibid.; see, Abdul Rahman I. Doi, Shariah: The Islamic Law, Ta Ha


Publishers, London, 1997, pp. 161-162.

5.

Al-Quran: An-Nisa : 4.

6.

http://www.al-islam.org/rightsofwomeninislam/ viewed on 1/30/2007.

7.

An-Nisa : 24.

8.

Al-Baqarah: 236-237.

9.

An-Nisa: 19, 20, 21 and also refer to Al-Muntahinah: 10.

10. Wahbah al-Zuhaily, al-Fiqh al-Islami wa Adillatuhu, vol. VII, Trans,


Ahmad Shahbari Salamon et. al., DBP, Kuala Lumpur, 2001, pp. 348349.
11. Abdul Rahman I. Doi, Shariah: The Islamic Law, Ta Ha Publishers,
London, 1997, p. 161.
12. The case is quoted from Taslima Monsoor, Dower and Dowry: Its
Affect on the Empowerment of Muslim Women, at http://
www.thedailystar.net/law/200307/04/ (accessed on 12 June 2011).
13. Ibid.
14. Abdul Rahman I. Doi, Shariah: The Islamic Law, Ta Ha Publishers
London, 1997, p. 161.
15. (1983) 3 JH 107.
16. (1971) 3 JH 107.
17. The case is quoted from Zubair Fattani, Islamic Mahr, at http://
www.islamicacademy.org/html/Articles/english/IslamicMehr.htm
18. Ibid.
19. Wahbah al-Zuhaily, al-Fiqh al-Islami wa Adillatuhu, vol. VII, Trans,
Ahmad Shahbari Salamon et. al., DBP, Kuala Lumpur, 2001, pp. 349350.
20. Ibid.
21. An-Nisa: 4 and 24.
22. Al-Baqarah: 237.

23. Al-Baqarah: 236. See, M.I Siddiqi, The Family Laws of Islam, Lahore,
PK, Kazi Publications, 1984, p. 81.
24. M.I Siddiqi, The Family Laws of Islam, Lahore, PK, Kazi Publications,
1984, p. 81.
25. Ibid.
26. Asaf A.A. Fyzee, Outline of Muhammadan Law, Oxford University Press,
Delhi, 1974, p. 138; M.I Siddiqi, The Family Laws of Islam, Lahore,
PK, Kazi Publications, 1984, pp. 81-84; Abdul Rahman I. Doi, Shariah:
The Islamic Law, Ta Ha Publishers, London, 1997, pp. 165-166.
27. See, http://www.infad.kuim.edu.my/modules.php?op=modload&name=
News&file=article
28. Taslima Monsoor, Dower and Dowry: Its Affect on the Empowerment
of Muslim Women, at http://www.thedailystar.net/law/200307/04/
29. In surah an-Nisa; 4 Allah SWT says but if they, of their own good
pleasure, remit any part of it to you, take it and enjoy it with right
good cheer (as Allah has made it lawful).
30. Ahmad Ibrahim, Family Law in Malaysia, Third edn. Malayan Law
Journal Sdn Bhd, Kuala Lumpur, 1997, p. 209.
31. Ahmad Ibrahim, Family Law in Malaysia, Third Edn. Malayan Law
Journal Sdn Bhd, Kuala Lumpur, 1997, p. 210.
32. (1983) 5 JH 161.
33. (1986) 6 JH 130.
34. (1911) FMSLR 61.
35. Prasad, B Devi. Dowry-related violence: A content analysis of news
in selected newspapers, Journal of Comparative Family Studies. Calgary:
Spring 1994. Vol. 25, Iss. 1; p. 71.
36. Ibid.
37. Ibid.
38. Luciana Suran et. al., Does Dowry Improve Life for Brides? A Test of
the Bequest Theory Dowry in Rural Bangladesh, Population Council,
No. 195, 2004, p. 4.
39. National Crime Records Bureau, 1991.
40. Ibid.

41. Luciana Suran et al., Does Dowry Improve Life for Brides? A Test of
the Bequest Theory Dowry in Rural Bangladesh, Population Council,
No. 195, 2004, p. 5.
42. Taslima Monsoor, Dower and Dowry: Its affect on the Empowerment
of Muslim Women at http://www.thedailystar.net/law/200307/04/
index.htm
43. Ibid.
44. Ibid.
45. Ibid.
46. Ibid.
47. Ibid.
48. Ibid.
49. See, Mas Kahwin Selangor naik, Berita Harian Online, 08 July 2008,
see also at http://www.selangorkini.com.my/my/berita/1002
50. Recently, the State of Selangor has increased the rate of mahr to
RM300.00 from RM80.00.
51. Zainunnisaa Abdul Rahman, Mahar in Malaysia: the Law Revisited
[2007] 4 ShLR 1.
52. See, at http://persada.net/modules/news/article.php?storyid=173.
53. Wanita Indonesia menawan, mengoda, Utusan Online, 08 January
2008.
54. Zainunnisaa Abdul Rahman, Mahar in Malaysia: the Law Revisited,
[2007] 4 ShLR 1.
55. Zainunnisaa Abdul Rahman, Mahar in Malaysia: the Law Revisited,
[2007] 4 ShLR 1.
56. Prasad, B Devi. Dowry-related violence: A content analysis of news in
selected newspapers, Journal of Comparative Family Studies. Calgary:
Spring 1994. Vol. 25, Iss. 1; p. 71. The paper identifies theoretical
perspectives to understand the factors associated with dowry violence
and analyses the content of the dowry-related news stories.
57. Taslima Monsoor, Dower and Dowry: Its affect on the Empowerment
of Muslim Women at http://www.thedailystar.net/law/200307/04/
index.htm

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