Been taking classes in Internationales Privatrecht, German-style conflict of laws. In the model of German conflict of laws, a divorce of two foreigners of the same nationality is to be divorced according to the law of their nationality, before a German court. My professor pointed out several times over that a marriage between two Muslim foreigners of the same nationality is divorced according to Muslim law, before a German judge. So, to divorce, the man says “Talaq, talaq, talaq”, and that’s it. The German judge must accept it. No separation year for Muslim foreigners, and also no right for women to divorce. I think the German judge formally did right by doing what the law says. But I think this law was made for diplomats or travellers temporarily living in Germany, and not for people who permanently reside here. It needs to be re-thought.
( http://en.wikipedia.org/wiki/Renvoi )]]>