LAW ET JUSTICIA LAW REVIEW
VOLUME 1 ISSUE 1
COMPARATIVE STUDY ON EFFECT OF CONVERSION ON MARRIAGE UNDER INDIAN LAW VIZ-A-VIZ MALAYSIAN LAW
Ms. SHREYA SHUKLA,
Faculty of Law, Jamia Milia Islamia, Delhi
Marriage is fundamentally considered as a union between man and woman and is accepted in the same form legally, all around the world but the nature of the marriage differs region wise. Roman Catholics consider the marriage as a sacrament whereas other western countries consider marriage as a contract. Early Hindus considered marriage as a sacrament too and believed it to be an indissoluble union. In India, the marriage is a personal affair which is majorly determined on the basis of religion and practices and there is no territorial law or uniform civil code that governs the personal matters of all religious communities. The importance and reliance on religion to determine the nature and form of marriage is a practice specific to India which is in absolute contradiction to the foreign patterns where the determinants of marriage related issues are governed by domicile or nationality as in England, or France and Germany respectively.