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Islamic Contract Law – Bargain Theory vs Will Theory vs Islamic Contract Law 


1. Core Foundation
  • Bargain Theory (English Law)
    • Contract based on exchange (consideration)
  • Will Theory (English Law)
    • Contract based on intention and free will
  • Islamic Contract Law
    • Contract based on:
      • Consent + obligation to fulfil + moral duty


2. Key Requirement
  • Bargain Theory
    • Must have:
      • Consideration (something in return)
  • Will Theory
    • Must have:
      • Mutual intention (meeting of minds)
  • Islamic Contract Law
    • Must have:
      • Offer + acceptance
      • Consent
      • Lawful subject matter


3. Role of Consideration
  • Bargain Theory
    • ✅ Essential
  • Will Theory
    • ⚠️ Important but not the main focus
  • Islamic Contract Law
    • ❌ Not required in strict sense


4. Role of Intention
  • Bargain Theory
    • Secondary to exchange
  • Will Theory
    • ✅ Central element
  • Islamic Contract Law
    • ✅ Important but combined with:
      • Legal + moral responsibility


5. Scope of Contract
  • Bargain Theory
    • Narrow:
      • Focus on economic exchange
  • Will Theory
    • Broader:
      • Focus on agreements generally
  • Islamic Contract Law
    • Broadest:
      • Includes:
        • Commercial contracts
        • Promises (ʿahd)
        • Oaths (yamīn)


6. Freedom of Contract
  • Bargain Theory
    • Recognised
  • Will Theory
    • Strongly emphasised
  • Islamic Contract Law
    • Allowed but:
      • Limited by Shariah rules


7. Moral Dimension
  • Bargain Theory
    • ❌ Minimal
  • Will Theory
    • ⚠️ Limited
  • Islamic Contract Law
    • ✅ Strong moral + religious element


8. Binding Nature
  • Bargain Theory
    • Binding due to:
      • Exchange
  • Will Theory
    • Binding due to:
      • Intention
  • Islamic Contract Law
    • Binding due to:
      • Agreement + duty to fulfil (religious + legal)


9. Simple Examples
  • Bargain Theory
    • Sell laptop → get money
  • Will Theory
    • Parties freely agree on contract terms
  • Islamic Contract Law
    • Sale, promise to donate, oath to perform act


Final Summary
  • Bargain Theory
    • Focus = exchange (consideration)
  • Will Theory
    • Focus = intention (free will)
  • Islamic Contract Law
    • Focus = obligation + morality + lawful agreement


One-Line Memory Trick
  • Bargain = Exchange
  • Will = Intention
  • Islamic law = Obligation + Ethics



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