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Islamic Contract Law – Bargain Theory (English Law) Comparison


1. What is Bargain Theory? (English Law)
  • A contract is based on a bargain (exchange) between parties
  • Each party must:
    • Give something
    • Receive something in return
👉 This “something” is called consideration


Simple Example
  • A sells a laptop to B for RM1000
  • A gives: laptop
  • B gives: RM1000
👉 This exchange = bargain → valid contract


2. Key Features of Bargain Theory
  • Focus on:
    • Exchange of value
  • Requires:
    • Consideration
  • Principle:
    • “No consideration = no contract”
  • Law is concerned with:
    • What is exchanged, not morality


3. Examples of Bargain Theory
a. Sale Contract
  • Goods exchanged for money
  • Profit comes from:
    • Price difference


b. Service Contract
  • Work/services exchanged for payment


c. Debt Agreement
  • Loan given → repayment promised


4. What is NOT a Bargain (in English Law)
  • Pure promise:
    • “I will give you RM1000” ❌
  • No exchange → no consideration
👉 Not a valid contract (unless formalised as a deed)


5. Comparison with Islamic Contract Law
A. Core Foundation
  • Bargain Theory (English Law)
    • Based on:
      • Exchange (consideration)
  • Islamic Contract Law
    • Based on:
      • Fulfilment of obligations
      • Moral + legal duty


B. Role of Consideration
  • English Law
    • Essential requirement
  • Islamic Contract Law
    • Not required in the same strict sense
    • Focus is on:
      • Consent
      • Lawful subject matter


C. Treatment of Promises
  • English Law
    • Not binding without consideration
  • Islamic Contract Law
    • Can be binding:
      • Morally
      • Sometimes legally


D. Focus of the System
  • English Law
    • Economic exchange
    • Legal enforceability
  • Islamic Contract Law
    • Ethical responsibility
    • Justice and fairness


6. Key Difference (Very Important)
  • Bargain Theory
    • Contract = exchange of value
  • Islamic Contract Law
    • Contract = binding obligation that must be fulfilled


Final Summary
  • Bargain theory explains contracts as:
    • Mutual exchange (consideration-based)
  • Islamic contract law is broader:
    • Includes:
      • Exchange-based contracts
      • Non-exchange obligations (promises, covenants, oaths)


One-Line Comparison
  • Bargain theory = “You give something, I give something”
  • Islamic contract law = “Once you commit, you must fulfil”


If you want, we can move next to will theory—it’s another key comparison often asked in exams.

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