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Islamic Contract Law – Will Theory (English Law) Comparison


1. What is Will Theory? (English Law)
  • Contract is based on the free will (intention) of the parties
  • Emphasises:
    • Freedom of contract
    • Parties are free to decide:
      • Whether to contract
      • Terms of the contract
👉 Key idea:
  • A contract is binding because parties intended it


Simple Example
  • A and B agree:
    • A sells a car for RM5,000
  • Both willingly agree
👉 Contract is valid because:
  • There is mutual intention (meeting of minds)


2. Key Features of Will Theory
  • Focus on:
    • Consent and intention
  • Emphasises:
    • Freedom
    • Autonomy of parties
  • Law respects:
    • What parties choose to agree on


3. Examples of Will Theory
a. Negotiated Contract
  • Parties freely negotiate terms
  • Example:
    • Price, delivery, conditions


b. Customised Agreements
  • Parties create their own terms
  • Law enforces:
    • Their chosen arrangement


c. Business Deals
  • Companies structure contracts based on:
    • Mutual consent and interests


4. Limitations of Will Theory
  • Freedom is not absolute
  • Law may restrict contracts involving:
    • Illegality
    • Fraud
    • Misrepresentation
    • Unfairness


5. Comparison with Islamic Contract Law
A. Core Foundation
  • Will Theory (English Law)
    • Contract based on:
      • Intention and consent
  • Islamic Contract Law
    • Based on:
      • Consent + obligation to fulfil
      • Moral and legal responsibility


B. Freedom of Contract
  • English Law
    • Strong emphasis on:
      • Freedom to contract
  • Islamic Contract Law
    • Freedom exists but is:
      • Limited by Shariah principles
    • Must avoid:
      • Riba (interest)
      • Gharar (excessive uncertainty)
      • Unlawful subject matter


C. Role of Morality
  • English Law
    • Focus on:
      • Legal validity
  • Islamic Contract Law
    • Combines:
      • Legal + ethical + religious values


D. Binding Nature
  • Will Theory
    • Binding because:
      • Parties intended it
  • Islamic Contract Law
    • Binding because:
      • Parties agreed
      • And must fulfil obligations as a duty


6. Key Difference (Very Important)
  • Will Theory
    • Contract = expression of free will
  • Islamic Contract Law
    • Contract = binding commitment governed by law and morality


Final Summary
  • Will theory focuses on:
    • Freedom and intention of parties
  • Islamic contract law:
    • Accepts intention
    • But adds:
      • Moral responsibility
      • Religious accountability
      • Substantive limits (Shariah rules)


One-Line Comparison
  • Will theory = “What parties intend becomes law”
  • Islamic contract law = “What parties agree must be lawful and fulfilled”

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