A comparative study of divorce in Iranian and Egyptian lawsZahra

A wife's refusal to pay her husband's rights in the matter of enjoyment, which has juridical and legal effects. A comparative study of the laws of Egypt and Iran regarding divorce shows some differences in the conditions of divorce and its effects. This article examines this issue with descriptive-analytical method and library research. Iranian jurists have divided obedience into two categories, general and special, and they consider divorce as not complying with these two obediences. Although Egyptian jurists have not used the term subjugation and its divisions, but the examination of the examples mentioned for Neshuz shows that there is no difference between the examples of Neshuz and Iranian law. What has caused the difference is the conditions for the realization of Nashush and also the consequences of Nashush. The Islamic reasons for leaving the house without the husband's permission are less in Egyptian law than in Iranian law, so the possibility of the wife being considered unmarried in Egyptian law is higher, on the other hand, the consequences of unmarried in Iranian law are greater than in Egyptian law, and this makes it a deterrent to Neshouz is more in Iran than in Egypt.