이슬람 가치와 여성발전의 딜레마- 이집트, 모로코, 튀니지, 터키 4개국의 가족법 인식에 대한 비교 연구

Among the four countries above the most consensus is observed in regard of the positive correlation between women's social status and development of the society. However the change of women's status in the family law depends on the social value. In Egypt and Morocco islamic identity is more emphasized, whereas the strong influence of western family law is most obvious in Turkey. In interview the Egyptians tend to resist the western influence with strong defence of their islamic family value. They believe the reformation of family law should be based on the interpretation of their religious code, which can be varied. Most of the Moroccan interviewee regard the bill of reformed family law in 2004 brings the islamic identity and promotion of women's status together. While in Egypt and Morocco the western influence on family law is generally denied, it is more accepted even with their strong identity as Muslim in Tunisia. Especially it appears that Tunisian government supports this moderate adoption of modern family law. In contrast the westernization of the family law is the only way of modernization in Turkey. But the westernized family law in Turkey seems to have conflict in reality, particularly in respect of kinship, rural life, and ignorance of uneducated women. In islamic value the promotion of women's right is limited to protection of motherhood and control of women's sexuality within the community. Muslims consider that the individualism in western family results in irresponsible sexuality, which endangers the value of community. For Muslims the marriage is a holly contract, in which fairness is more important than equality of man and wife.