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Indonesian Law (KHI)

08 — KHI vs Classical Fiqh: A Comparison

This chapter brings every difference together in one place, so the reader can see the full map and know exactly where the computed results can diverge.

Map of the differences

flowchart TB
  classDef same fill:#134e4a,stroke:#14b8a6,color:#ccfbf1
  classDef diff fill:#713f12,stroke:#ca8a04,color:#fef9c3

  subgraph SAMA["Mostly THE SAME"]
    S1["Furudh fractions (1/2, 1/4, 1/8, 2/3, 1/3, 1/6)"]:::same
    S2["Grounds: lineage & marriage"]:::same
    S3["'Aul & radd (basic mechanism)"]:::same
    S4["Bequest capped at 1/3"]:::same
  end
  subgraph BEDA["Points that DIFFER"]
    D1["Marital property separated first"]:::diff
    D2["Substitute heirs (grandchild steps up)"]:::diff
    D3["Wasiat wajibah for adopted child/parent"]:::diff
    D4["Impediment: needs a court ruling; + grave assault/slander"]:::diff
  end

Comprehensive comparison table

AspectClassical fiqh (the 4 other tracks)KHI (this track)Effect on the numbers
Marital propertyNo automatic concept; the entire estate of the deceased becomes tirkahThe surviving spouse takes 1/2 of the harta bersama first (Pasal 96), and only the remainder becomes tirkahLarge — the surviving spouse often receives far more
Grandchild (parent predeceased)Barred (mahjub) by a living child/uncleSteps up in place of the parent (Pasal 185), capped at no more than a same-level heirLarge — changes who is entitled
Adopted child/parentDoes not inherit; voluntary bequestWasiat wajibah of at most 1/3 (Pasal 209)Medium — carves off up to 1/3 before the inheritance
Criminal impedimentWrongful killing bars automaticallyRequires a final, binding court ruling; + grave assault & slanderSmall — different conditions, rarely changes the numbers
Difference of religionA firm impedimentFiltered through the “being Muslim” condition; some cases granted a wasiat wajibah through jurisprudenceSmall–Medium
Furudh fractionsQur’anic furudhSame (Pasal 176-180)None — identical
Grandfather & siblingsDetailed muqasamah system (al-Fauzan/ar-Rahabi) or “grandfather = father” (Ibn Uthaymin)Not spelled out; practice tends to have the grandfather bar the siblingsSmall–Medium
’Aul & raddPresent, with a disagreement over radd to the spousePresent (Pasal 190-193)Small
Amicable settlementPermitted (tasaluh) once rights are knownExplicitly recognized (Pasal 183)Small
Source of authorityThe soundness of the evidence (fiqh)Inpres 1991 (positive law)

When the result is the same, when it differs

  • Almost always the same when: there is no significant harta bersama, there is no grandchild from a predeceased child, and there is no adopted child/parent. The “husband + wife + biological children” case with no marital property usually yields identical numbers.
  • Can differ substantially when: there is a large amount of harta bersama (surviving spouse), or there is an orphaned grandchild whose parent predeceased, or there is an adopted child.

How to use this comparison

  1. First compute with a classical faraidh calculator (any track) to know the result according to the scholars.
  2. Check whether your case touches any of the points that differ in the table above.
  3. If it does, the court result (KHI) is likely to differ — and you now know why, rather than merely being caught off guard.

The aim of this comparison is not to judge which one “wins,” but to give an honest map: where state law aligns with the scholars, and where it takes its own path of ijtihad. Its shar’i weighing is in chapter 10.

Source: a summary drawn from chapters 03 through 07 of this bundle; KHI Book II. Details in chapter 12.