How did Muslim women’s property rights differ from those under traditional English common law?

Under traditional English common law, the doctrine of coverture dictated that a woman’s legal existence was suspended upon marriage, effectively merging her identity into that of her husband. Consequently, married women were stripped of control over their real and personal property, and husbands acquired extensive rights to administer and own their wives' assets, including earnings from employment, without any obligation to account for them.12

In contrast, traditional Islamic law maintained a distinct legal personality for women regarding property. Upon marriage, a husband is required to pay his wife a dower, which becomes her exclusive property. Furthermore, Islamic law provides specific, albeit often unequal, inheritance rights to women as daughters, wives, mothers, or sisters, which they hold independently of their husbands. While traditional Islamic law is patriarchal—often granting male relatives greater shares or guardianship over minor children's property—it does not impose the total legal erasure of a woman's property rights seen under the common law system of coverture.34