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Polygyny laws around the world
The Shariah permits a man to marry up to four wives on the strict condition of justice — and commands only one if he fears he will not be just (4:3) — but each country regulates it differently, from court permission to criminal prohibition. This page compares more than 20 jurisdictions.
- Understand the four legal models of polygyny: permission, notice, unrestricted, prohibition
- Know the law of the country where you live or will marry
- Know the consequences of polygyny without permission in the main countries
- Understand the wife's right to set conditions in the marriage contract in some countries
Key point: Surah an-Nisa' 4:3 gives conditional permission, not a command, and most countries regulate it through the courts, notice to the wife or a criminal prohibition. Follow the law of the place where you live and register every marriage so that the wife and children are protected.
- Find your country in the matrix and read the relevant country page
- If you live, or will marry, abroad, check the recognition of foreign marriages in Malaysia
- Discuss with your spouse whether to include conditions or an additional taʿliq (conditional divorce) in the marriage contract
At a glance
23 jurisdictions in the comparison matrix
How states regulate polygyny
1How to read this comparison
The Shariah basis for polygyny is Surah an-Nisa' 4:3: a man may marry two, three or four, but "if you fear that you will not be able to deal justly, then (marry) only one". This verse gives conditional permission, not a command. For this reason, many modern Muslim countries do not prohibit polygyny but regulate its practice — usually through court permission, notice to the existing wife, or a check of financial means.
In the table and sections below, countries are classified into four models:
- Permitted with permission — a court or official body must approve first (Malaysia, Indonesia, Pakistan, Morocco).
- Permitted with notice/registration — no prior approval, but the wife is notified and may seek judicial dissolution (fasakh) (Egypt, Jordan).
- Permitted with almost no statutory restriction — subject to Shariah rulings and registration (Saudi Arabia, northern Nigeria).
- Prohibited / criminal bigamy — Tunisia, Turkey and almost all Western countries.
2World comparison matrix
A summary of 34 rows of jurisdictions, aligned with each country's page (click a country name for details and sources). The "Penalty" column refers to the consequences if a husband takes another wife without permission or breaches a prohibition.
| Country | Status of polygyny | Conditions / authority | Penalty without permission | Main law |
|---|---|---|---|---|
| Malaysia | Permitted for Muslims; prohibited for non-Muslims | Written permission of the Syariah Court (usually the Syariah High Court); the court assesses whether it is just and necessary, means, justice and harm; the existing wife is summoned | Most states: fine ≤ RM1,000 or imprisonment ≤ 6 months or both (FT s.123; Selangor etc. s.124); Sarawak: fine ≤ RM3,000 or imprisonment ≤ 2 years (s.127) | Act 303 s.23 & s.123 (FT); state Islamic family enactments (Sarawak: Ordinance 2001 s.21); Act 164 for non-Muslims |
| Indonesia | Permitted with consent (open monogamy principle) | Permission of the Religious Court (Pengadilan Agama): one of the grounds in Article 4, the wife's consent, means and an assurance of justice (Article 5); civil servants (PNS) need their office's permission | A marriage without permission has no legal force (KHI Art. 56); administrative fine (PP 9/1975 Art. 45); KUHP 2023 Art. 402: imprisonment ≤ 4 years 6 months, or ≤ 6 years if the existing marriage was concealed — whether this applies to polygyny without permission is still debated | UU 1/1974 Art. 3–5; PP 9/1975 Art. 40–45; KHI Art. 55–59; PP 10/1983 jo. PP 45/1990 (civil servants); KUHP (UU 1/2023) Art. 402 |
| Brunei | Permitted with permission | Written permission of a Syarie Judge of the Syariah Court (s.23); a declaration of just and necessary grounds, finances, dependants and the existing wife's views | Fine ≤ $2,000, imprisonment ≤ 6 months, or both (s.123) | Emergency Order (Islamic Family Law) 1999 — now Chapter 217, s.23 & s.123 |
| Singapore | Permitted for Muslims with approval | The Kadi, through ROMM, after an inquiry (AMLA s.96(3); MMDR r.5); the existing wife may be summoned, may object and may appeal to the Appeal Board | The marriage contract cannot be solemnised without the Kadi's approval; solemnising or registering a marriage unlawfully is an offence (AMLA s.133) | Administration of Muslim Law Act 1966 (AMLA) s.96; Women's Charter (non-Muslims, monogamy) |
| Thailand (south) | Recognised for Muslims in Pattani, Narathiwat, Yala and Satun | No permission procedure; disputes are decided by the court together with the Dato' Yutitham; administration by the Provincial Islamic Council | No specific penalty in the Act 1946; in other provinces a second registered marriage is void (Civil and Commercial Code s.1452, s.1495) | Act on the Application of Islamic Law in Pattani, Narathiwat, Yala and Satun B.E. 2489 (1946); Administration of Islamic Organisations Act B.E. 2540 (1997) |
| Philippines | Permitted for Muslims, only in exceptional circumstances | Ability to be just; notice to the Shari'a Circuit Court; the existing wife may object through the Agama Arbitration Council (Art. 162) | Non-compliance with Art. 162: arresto mayor (1 month 1 days to 6 months) or a fine of ₱200–₱2,000, or both (Art. 183) | PD 1083 (Code of Muslim Personal Laws 1977) Art. 27, 162, 183; Revised Penal Code Art. 349 (bigamy — not applicable to marriages under PD 1083) |
| Myanmar, Cambodia & Vietnam | Myanmar: restricted; Cambodia and Vietnam: prohibited | No Shariah courts; Myanmar applies Islamic law in the civil courts, while Cambodia and Vietnam apply civil law to everyone | Myanmar: Monogamy Law 2015 refers to Penal Code s.494 (≤ 7 years' imprisonment and a fine); Cambodia and Vietnam: a second marriage cannot be registered (criminal penalties: see the country page) | Monogamy Law 2015 (Myanmar); Constitution of Cambodia Article 45; Law on Marriage and Family of Vietnam 52/2014/QH13 |
| Pakistan | Permitted with permission | Prior written permission of the Arbitration Council; the existing wife may object | The existing wife's mahr (dower) must be paid immediately; simple imprisonment ≤ 1 year and/or a fine (text 1961: ≤ Rs 5,000); the wife may apply for dissolution (DMMA 1939) | Muslim Family Laws Ordinance 1961 s.6 |
| Bangladesh | Permitted with permission | Permission of the Arbitration Council (MFLO s.6); the first wife's consent is not an absolute requirement (High Court, 2025) | The existing wife's mahr (dower) must be paid immediately; imprisonment ≤ 1 year, or a fine ≤ 10,000 taka, or both (s.6(5)(b), amended 1982) | Muslim Family Laws Ordinance 1961 s.6; Muslim Marriages and Divorces (Registration) Act 1974 |
| India | Permitted for Muslims under personal law; prohibited for non-Muslims and in states that have enacted a Uniform Civil Code | No statutory permission for Muslims; Uttarakhand (in force 27 Jan 2025) prohibits it for all residents; Gujarat, Assam and Madhya Pradesh are following (enforcement status to be verified) | Bigamy is a crime for non-Muslims (BNS 2023 s.82; formerly IPC s.494) — not applicable to Muslim men under personal law; separate penalties under state UCCs | Muslim Personal Law (Shariat) Application Act 1937; Hindu Marriage Act 1955; Uniform Civil Code of Uttarakhand Act 2024 |
| Sri Lanka | Permitted for Muslims | 30 days' notice to the Quazi only (s.24); no financial test, and the wife's views are not required | No penalty on the husband; only a registrar who breaches the Act (s.82) | Muslim Marriage and Divorce Act 1951 (MMDA) s.24 |
| Maldives | Permitted with approval | Approval of the Registrar of Marriages at the Family Court after financial means are assessed (s.12; income threshold MVR 15,000 a month) | Fine of MVR 5,000 (s.65); a woman who knows the man is still married is also guilty | Family Act 4/2000 s.12, s.65 |
| Saudi Arabia | Permitted | No court permission or consent of the existing wife; the marriage contract is registered (Article 8; Ministry of Justice/Najiz); the wife may set conditions in the contract | No statutory penalty; the wife may seek judicial dissolution (fasakh) if the contract's conditions are breached or she is harmed (Article 103–115) | Personal Status Law 2022 (Royal Decree M/73) |
| UAE | Permitted for Muslims | No court permission; a limit of four and justice between wives (article 49(6)); conditions in the contract are binding (article 33) | No prior screening; the wife may apply for dissolution if the contract's conditions are breached (article 33) | Federal Decree-Law 41/2024 (in force 15 Apr 2025), replacing Federal Law 28/2005 |
| Kuwait, Qatar, Oman & Bahrain | Permitted | No court permission; control through registration of the contract — Qatar notifies the existing wife (article 14), Bahrain records the husband's status in the contract, Oman forbids housing wives together without consent (article 59) | No prior screening; the wife may apply for divorce on grounds of harm or breach of conditions (e.g. Qatar article 53) | Kuwait 51/1984; Qatar 22/2006; Oman Royal Decree 32/97; Bahrain 19/2017 |
| Iran | Permitted with permission | Family court permission; the first wife's consent except for specific reasons (to be verified) | The wife is entitled to divorce if the husband marries again without her consent; failure to register is fined (article number to be verified) | Civil Code (Ja'fari fiqh); Family Protection Law 2013 (1391 SH) |
| Egypt | Permitted | The husband declares his status in the marriage contract; the ma'dhun notifies the existing wife; the wife may seek divorce on grounds of harm within 1 year | Fines and imprisonment for false information about marital status or the wife's address (article 23 bis) | Law 25/1929 article 11 bis & 23 bis (amended by Law 100/1985) |
| Jordan | Permitted | The judge ensures the ability to pay mahr (dower) and maintenance (nafkah) and that the prospective wife is informed before the contract; the court notifies the existing wife (article 13) | No specific penalty for polygyny; a marriage contract concluded outside the court is punishable under the Penal Code with a fine ≤ JOD 200 (article 36) | Personal Status Law No. 15/2019 article 13 |
| Morocco | Permitted by exception | Court permission; exceptional objective grounds and sufficient finances; the wife may stipulate no polygyny (article 40) | Application refused; the wife may seek divorce | Moudawana 2004 article 40–46 |
| Iraq | Permitted with permission | Judge's permission: means, a lawful interest and no fear of injustice (article 3); Kurdistan: the first wife's consent | Imprisonment and/or a fine; the wife may apply for divorce (article 40(5)) | Personal Status Law No. 188/1959 article 3 |
| Syria | Permitted with permission | The judge may refuse if there are no valid grounds or the husband lacks the means; the existing wife need not be notified | No specific penalty stated; the wife may stipulate a right of divorce in the contract | Personal Status Law 1953 (No. 59) article 17, amended by Law 4/2019 |
| Lebanon | Permitted | Follows the Sunni or Ja'fari Shariah courts; a Sunni wife may stipulate a ban on polygyny in the contract | No statutory penalty | The law of each religious court; no civil family law |
| Tunisia | Prohibited since 1956 | — | Imprisonment of 1 years and/or a fine; a woman who knowingly marries a married man is punished likewise | Code du statut personnel 1956 article 18 |
| Turkey | Prohibited since 1926 | Only civil marriages are recognised; a second marriage is absolutely void (Civil Code article 145(1)) | Imprisonment of 6 months to 2 years (Penal Code 5237 article 230) | Turkish Civil Code 2001 (No. 4721); Penal Code No. 5237 article 230 |
| Afghanistan | Permitted with conditions (the 1977 framework); the situation after 2021 has changed | Conditions in the Civil Code (article 86–89) | EVAW law 2009 article 37 (Republic era) | Civil Code 1977 article 86–89 |
| Central Asia (former Soviet) | Uzbekistan, Kyrgyzstan, Tajikistan, Turkmenistan: criminalised; Kazakhstan, Azerbaijan: not registered | Only civil marriages are registered | Uzbekistan ≤ 3 years' imprisonment; Tajikistan ≤ 5 years; Kyrgyzstan a fine of 50,000–100,000 som; Turkmenistan ≤ 2 years' correctional labour or a fine; Kazakhstan and Azerbaijan: no criminal penalty | Criminal Code of Uzbekistan article 126, Kyrgyzstan 176, Tajikistan 170; Family Code of Azerbaijan 1999 article 12 |
| China, Japan, South Korea, Taiwan & Hong Kong | Prohibited — civil monogamy for all | Only registered marriages are valid | Bigamy is a crime: China ≤ 2 years; Japan ≤ 2 years; Taiwan ≤ 5 years; Hong Kong ≤ 7 years; South Korea not a crime (the second marriage may be annulled) | Civil Code of China 2020 article 1041–1042; Civil Code of Japan article 732; Korean Civil Act article 810; Civil Code of Taiwan article 985; Cap. 178 Hong Kong |
| Nigeria (north) | Permitted for Islamic and customary marriages | Shariah rulings (Maliki school) in the Shariah courts of 12 northern states | None for Islamic marriages; bigamy is a crime if the first marriage was under the Marriage Act (statutory) | State Shariah law (12 northern states); Marriage Act (civil, monogamous) |
| Kenya | Permitted for Islamic and customary marriages | Quazi Courts (recognised by the Constitution 2010) | — | Marriage Act 2014 |
| United Kingdom | Prohibited — bigamy is a crime | Polygynous marriages validly contracted abroad are recognised for limited purposes | Imprisonment ≤ 7 years | Offences Against the Person Act 1861 s.57; Matrimonial Causes Act 1973 s.11(d) |
| United States | Prohibited in all states | — | A crime under state law; Utah reduced it to a minor offence (2020) | State law; Reynolds v. United States (1878) |
| Canada | Prohibited | — | Crime: bigamy and polygamy | Criminal Code s.290 (bigamy), s.293 (polygamy) |
| Australia | Prohibited | Polygynous marriages validly contracted abroad are recognised for the purposes of the Family Law Act | Imprisonment ≤ 5 years | Marriage Act 1961 s.94; Family Law Act 1975 s.6 |
| European Union | Prohibited in all member states | No single EU family law; each country has its own | Bigamy is a crime (e.g. France Code pénal Art. 433-20; Germany StGB §172) | Family Reunification Directive 2003/86/EC Art. 4(4) |
3Southeast Asia: the court-permission model
The Nusantara region shares one model: polygyny is permitted for Muslims, but must first go through the religious authorities.
- Malaysia — under the Islamic Family Law (Federal Territories) Act 1984 (Act 303) s.23 and the equivalent state enactments, the court considers whether the marriage is just and necessary, the husband's financial means, his ability to be just, and the harm to the existing wife. Marrying without permission is an offence (Act 303 s.123), although the marriage may be registrable later after penalty. See Polygyny in Malaysia.
- Indonesia — UU Perkawinan 1974 is based on monogamy (Article 3), but the Religious Court (Pengadilan Agama) may grant permission if the wife cannot fulfil her duties, has an incurable disability/illness, or cannot bear children (Article 4), with the wife's consent and proof of means (Article 5).
- Brunei and Singapore — Brunei follows the Syariah court model; Singapore channels applications through ROMM, which interviews both parties.
- Southern Thailand and the Philippines — Islamic family law applies as minority personal law. Southern Thailand is a common destination for Malaysian couples who marry without permission — this is discussed in Marriage abroad.
4South Asia: Arbitration Councils and personal law
Pakistan and Bangladesh still use the Muslim Family Laws Ordinance 1961 s.6: the husband applies to the Chairman of the Arbitration Council, stating his reasons and whether the existing wife consents. The Council — made up of representatives of the husband and wife — decides whether the new marriage is necessary and just. If the husband marries without permission, he must immediately pay the existing wife's entire deferred mahr (dower) and may be imprisoned for up to one year and/or fined; the wife also has grounds to dissolve the marriage.
India is different: Muslims are governed by personal law (Shariat Application Act 1937) with no requirement for statutory permission, while Hindus, Christians and Parsis are bound by monogamy. The state of Uttarakhand enacted a Uniform Civil Code 2024 that prohibits polygyny for all residents, including Muslims; the national debate continues.
5Middle East and North Africa: from notice to prohibition
Arab countries show the widest spectrum:
6Sub-Saharan Africa: dual systems
Many African countries operate a dual legal system: statutory (civil) marriage is monogamous, while customary and Islamic marriages may be polygynous. In Nigeria, 12 northern states have extended Shariah jurisdiction since 1999–2000; Islamic marriages there may be polygynous and are handled by Shariah courts. But a person already married under the Marriage Act (civil) cannot marry again — that is bigamy. Couples need to know the type of marriage they register, because it determines inheritance and divorce rights.
7Western countries: bigamy is a crime
In the UK, US, Canada, Australia and throughout the EU, marrying while still in a valid marriage is the crime of bigamy. There are, however, important differences:
- Limited recognition — the UK and Australia recognise a polygynous marriage that was valid where it was contracted (if the parties were domiciled in a country that permits it) for purposes such as maintenance and divorce, but do not allow new polygynous marriages within the country.
- Immigration — EU Directive 2003/86/EC Art. 4(4) allows only one wife to be reunited; the UK and US have similar restrictions.
- Religious marriage without registration — not counted as a legally valid civil marriage; the wife receives no protection of property or inheritance.
Full explanation: Muslim minorities in the West.
8Lessons for Muslim couples
- Follow the law of the place where you live. The majority of scholars stress the obligation to honour agreements and to obey regulations that do not command sin (Surah al-Ma'idah 5:1; Surah al-Isra' 17:34). Laws that regulate polygyny do not forbid what is lawful — they set out a procedure.
- Register every marriage. Registration protects the wife and children; a secret or unregistered marriage runs contrary to the objectives of the Shariah (maqasid) of preserving lineage and property.
- Use conditions in the marriage contract. The Hanbali school and the laws of Morocco, Jordan and Saudi Arabia allow the wife to stipulate that the husband will not take another wife; the Prophet ﷺ said the conditions most deserving of fulfilment are those by which marriage is made lawful (Sahih al-Bukhari 2721; Sahih Muslim, Kitab an-Nikah). The Shafi'i, Hanafi and Maliki schools, however, hold that such a condition is not binding, although the contract remains valid.
- Get local advice before marrying in another country — see recognition of foreign marriages.
Sources & references
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