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Islamic Contract – Bay’ al-Istisnā‘: Late Delivery Charge Clause in Istisnā‘ Contracts
Q1: Why are the terms
gharamah
and
ta‘wīd
not commonly used in istisnā‘ late delivery clauses?
Answer
The terms:
  • gharamah (penalty); and
  • ta‘wīd (compensation)
are more commonly used in:
debt-based contracts such as murābahah financing.
This is because murābahah primarily creates:
  • a debt obligation owed by the customer to the bank.
Late payment in murābahah therefore concerns:
  • delayed settlement of debt.
Hence:
  • ta‘wīd compensates actual losses from delayed payment;
  • gharamah acts as a deterrent penalty against intentional default.


Why Istisnā‘ Is Different
In istisnā‘:
  • the issue is not late payment of debt;
  • the issue is:
delay in completing or delivering a manufactured/construction asset.
Therefore, the late delivery clause in istisnā‘ is usually treated as:
a contractual performance penalty clause (shart jazā’ī)
rather than:
  • debt compensation (ta‘wīd); or
  • debt penalty (gharamah).
This is because:
  • the purchaser suffers loss due to construction or manufacturing delay,
  • not due to unpaid debt.


Q2: What is the AAOIFI position regarding late delivery charges?
Answer
According to AAOIFI Shariah Standard (Para 6/6):
  • a fair penalty clause may be included in the istisnā‘ contract to compensate the purchaser if the manufacturer delays delivery.
However:
  • force majeure situations are excluded.
Examples of force majeure:
  • floods;
  • earthquakes;
  • war;
  • government restrictions.
The compensation must be:
  • fair;
  • proportionate; and
  • linked to actual contractual delay.


Q3: What is the BNM position regarding late delivery charges?
Answer
According to the BNM Policy Document on Istisnā‘ (Para 27.4):
  • the contracting parties may include:
a punitive clause (shart jazā’ī)
against the seller for late delivery.
Unlike murābahah:
  • the penalty amount may be recognised as income by the purchaser.
This is because:
  • the purchaser may suffer genuine commercial losses from project delay.


Q4: What is
shart jazā’ī
?
Answer
Shart jazā’ī means:
a contractual penalty clause agreed upon in advance for breach or delay in performance obligations.
In istisnā‘:
  • it applies when the seller/manufacturer:
    • fails to complete;
    • delays construction;
    • or delivers late.


Comparison Between Murābahah and Istisnā‘ Late Charges
Murābahah
Nature of Issue
Late payment of debt.
Terms Used
  • ta‘wīd
  • gharamah
Reason
Customer delays repayment obligation.


Istisnā‘
Nature of Issue
Late delivery or late construction.
Term Used
  • shart jazā’ī
Reason
Manufacturer delays contractual performance.


Case Study 1: Murābahah Late Payment (Ta‘wīd and Gharamah)
An Islamic bank provides murābahah vehicle financing.
Financing Details
  • Selling price: RM120,000
  • Monthly instalment: RM2,000
The customer delays payment for:
  • 5 months.
Analysis
This concerns:
  • delayed debt repayment.
Thus:
  • ta‘wīd and gharamah may apply.


Case Study 2: Istisnā‘ Late Delivery (
Shart Jazā’ī
)
A contractor agrees to construct a warehouse.
Contract Details
  • Construction price: RM10,000,000
  • Completion date: 1 January 2029
The contract states:
“Contractor shall pay RM15,000 per week for unjustified delay.”
The contractor delays completion by:
  • 6 weeks.


Penalty Calculation
15,000 times 6 = 90,000

Result
  • Contractor pays RM90,000 to purchaser.
Analysis
This is:
  • not ta‘wīd for debt delay;
  • not gharamah for late payment.
Instead:
  • it is a contractual performance penalty (shart jazā’ī)
    for delayed completion of construction.


Case Study 3: Force Majeure Situation
A construction company builds a factory under istisnā‘.
Contract Details
  • Factory value: RM30,000,000
During construction:
  • severe earthquake damages site.
Completion delayed by:
  • 4 months.
Analysis
Delay caused by:
  • force majeure beyond contractor’s control.
Therefore:
  • penalty clause should not apply.
Result
✅ No shart jazā’ī imposed.


Important Principle
Murābahah
Late charges relate to:
debt repayment obligations.
Thus:
  • ta‘wīd and gharamah apply.


Istisnā‘
Late charges relate to:
failure to complete or deliver manufactured asset on time.
Thus:
  • shart jazā’ī applies instead.
The distinction exists because:
  • the legal nature of the obligation is different.




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