Sharia laws, theories vary among world's Muslims

By Tom Heneghan, Religion Editor

PARIS (Reuters) - Sharia law is understood and applied in such varied ways across the Muslim world that it is difficult to say exactly what it is and how it could fit into a western legal context, according to experts on Islam.

Full Islamic criminal law, the harsh code most non-Muslims think of when they hear the word sharia, is applied in very few countries, such as Saudi Arabia. Islamic "personal law" for issues like marriage and inheritance is much more common.

Archbishop of Canterbury Rowan Williams sparked off a storm last week by suggesting Britain adopt some sharia law. British Muslims defending him stressed most of the Islamic world also rejected the ultra-orthodox model that he clearly ruled out.

"There are 57 Muslim countries in the world and only two or three of them impose full sharia criminal law. Why on earth would we want to have that here?" asked Sheikh Suhaib Hasan, secretary of the Islamic Sharia Council in Britain.

There are also widely differing interpretations of sharia, both within the four classical Sunni and one Shi'ite schools of jurisprudence and between traditional and modern thinkers.

"In the Muslim world these days, 'sharia' means a whole variety of different things," said John Voll, professor of Islamic history at Georgetown University in Washington.

Williams apparently had in mind a modern school of Muslim thinking that sees sharia as a system of essential Islamic values rather than a fixed code of harsh punishments, he said.