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The parties were married on 2 February 1994 and had two children. They had lived harmoniously as husband and wife for 21 years, however, in 2000, the respondent fell ill. This had compromised her ability to be physically intimate with the applicant for approximately the past four years. Concerned that he would commit adultery (zina), in December 2014, the applicant requested the respondent's permission to marry again. The respondent granted him permission. The woman the applicant proposed to marry was fit and proper in that she did not breach any shari'a or civil legislative requirements: she was not a blood relative of the applicant or respondent, nor had they shared a wet nurse; she was a divorcee and not engaged to another man; and her marriage guardian was prepared to marry them. The applicant also told the court that he believed he was capable of having more than one wife as his monthly salary was IDR 5 million, he had promised to be fair to both wives as well as his children, and the respondent had prepared a written statement in support of the applicant. The applicant also told the court that he and the respondent were prepared to separate their joint assets if the applicant were granted judicial permission to marry again.

The court counselled the applicant on the consequences and risks of polygamy, advising him not to go ahead with the second marriage. Its advice, however, went unheeded. With this in mind, the court cited verse 3 of Surat Annisa from the Qur'an, which does not prohibit polygamy but places the onus on the man to prove he will treat both wives fairly, as enunciated in art 55(2) of the Compilation of Islamic Laws. The court was of the opinion that the applicant would treat his wives and children fairly, and, as required by art 5(1.b) of Law No. 1 of 1974 on Marriage, and art 58(1.b) of the Compilation of Islamic Laws, could financially afford to care for them. After the applicant signed a statement attesting to do so, meeting the requirements of art 5(1)(a), (b) and (c) of Law No. 1 of 1974, as well as art 41(b) and (c) of Government Regulation No. 9 of 1975. The court acceded to the applicant's request and stipulated the items acquired by the parties as a married couple as their joint assets.

The parties were married on 10 February 2008. They lived together and had two children (aged 6 and 2). Initially, the marriage had been harmonious. By August 2014, however, the parties had begun to quarrel regularly. The plaintiff submitted that:

1. the defendant would often not come home from work, providing no reason or explanation;
2. the defendant often pawned the parties’ household items, including her parents' car, providing no reason or explanation;
3. the defendant, since October 2014, had ceased to financially support the plaintiff;
4. the defendant had sold the title to the plaintiff’s parents' property solely for his own benefit; and
5. while the plaintiff had often financially supported the defendant in the hope he would change, he had not.

In January 2015, the plaintiff left the defendant. The plaintiff claimed that the aforementioned circumstances had caused the marriage to deteriorate irreparably, and requested that the Court grant her an irrevocable divorce (talak satu ba’in shughra). The plaintiff also requested that the court grant her custody of the parties' child, and order the defendant to pay to her IDR 1,000,000 per month in child support.

While the plaintiff cooperated with the court, the defendant failed to attend the proceeding, despite having been summonsed. The court found that the marriage was irreparable and could no longer fulfil the purposes of art 1 of Law No. 1 of 1974, and art 3 of the Compilation of Islamic Laws, and that the plaintiff’s claim satisfied the requirements of art 39(2) of Law No. 1 of 1974, in conjunction with art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws, in that the parties' differences were indeed irreconcilable. The court, however, did not consider the plaintiff’s claims for custody or child support because she subsequently withdrew that part of her claim. The court ordered the plaintiff to pay all court costs (IDR 316,000).

The parties were married on 25 April 1997 and had four children (aged 16, 12, 7 and 4). The parties' marriage had been harmonious for approximately three years before becoming quarrelsome by the beginning of 2002. The applicant submitted that the respondent:

1. was not transparent with her finances;
2. would ignore the applicant’s advice and did not care about the troublesome situation at home; and
3. provided her own family with financial assistance (by selling the gold jewellery the applicant had purchased for her, unbeknownst to the applicant), but did not contribute to her own immediate family.

In 2014, these problems escalated and the parties separated (although the court stated that the parties separated on 8 November 2012).

On 13 November 2014, the applicant filed for a revocable divorce (talak satu raj'i) in the Kuala Simpang Shari'a Court. In response to the applicant’s submissions, the respondent submitted that the applicant had already married another woman without the respondent’s permission, which the applicant conceded. The applicant also agreed to pay to the respondent IDR 1 million for iddah (100-day period after divorce has been granted) and mut’ah (divorce compensation), in the form of a prayer instrument.

The court acceded to the applicant's request, finding that the parties could no longer fulfil the purpose of marriage as envisaged by art 1 of Law No. 1 of 1974 on Marriage, and art 3 of the Compilation of Islamic Laws. The court, pursuant to art 39(2) of Law No. 1 of 1974, art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws, granted the applicant a revocable divorce (talak satu raj'i) on the grounds of ongoing conflict, while also ordering the applicant pay to the respondent IDR 1 million for iddah, the aforementioned prayer instrument for mut'ah, as well as court costs (IDR 191,000).

The parties were married on 13 February 2012 and had one child, born on 17 May 2013. The applicant submitted that the parties' marriage had been harmonious until the end of 2013. After that time, however, it had become quarrelsome because the respondent had been disobedient towards the applicant, would become excessively jealous and suspicious of the applicant, and if the applicant ever counselled the respondent the parties would quarrel. On one such occasion, the applicant orally divorced the respondent, after which time the parties separated.

In response to the applicant’s submissions, the respondent requested IDR 5 million per month in retrospective maintenance (nafkah) back dated to June 2014. The respondent also requested IDR 20 million for iddah (100-day period after divorce has been granted) and mut’ah (divorce compensation) in the form of a 24 karat gold bracelet, IDR 10 million for maskan (accommodation), IDR 10 million for kiswah (clothing), custody of the parties' child, IDR 2 million per month in child maintenance, and that the parties' vehicle be seized to prevent the applicant from transferring the ownership thereof. The respondent then withdrew her request regarding the parties' vehicle.

The court acceded to the applicant's request, finding that the parties could no longer fulfil the purpose of marriage as envisaged by art 1 of Law No. 1 of 1974 on Marriage, and art 3 of the Compilation of Islamic Laws. The court, pursuant to art 39(2) of Law No. 1 of 1974, art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws, granted the applicant a revocable divorce (talak satu raj'i) on the grounds of ongoing conflict. The court also acknowledged that the applicant's monthly wage was IDR 7 million. Accordingly, he would only be able to afford the following:

1. IDR 5 million for iddah;
2. a 6.6 gram gold ring as mut'ah;
3. IDR 1 million for kiswah; and
4. IDR 1.5 million per month in child maintenance (the court awarded custody of the parties' child to the respondent).

The parties were married on 9 September 1996 and had two children. The plaintiff submitted that the parties' marriage had become quarrelsome early on for reasons unbeknownst to the plaintiff. The defendant would often become intoxicated and physically beat the plaintiff, as well as leave the parties' home for days on end. In February 2006, the defendant finally left the plaintiff and their two children. As a result, the plaintiff requested that the court grant her an irrevocable divorce (talak satu ba'in sughra).

The defendant responded to the plaintiff's submissions, submitting that the plaintiff had already married another man in July 2010, and questioning whether or not Islamic law permitted a woman to marry another man before her husband had first divorced her. The defendant conceded that the parties quarrelled frequently but reasoned that it was common for married couples to do so. Moreover, that the reason the parties quarrelled as frequently as they did was that the plaintiff would often leave the parties' home, leaving behind their two children for days on end. The defendant also conceded that he had physically beaten the plaintiff when in an intoxicated state but justified it on the grounds that the plaintiff would frequently leave the parties' home to fraternise with other men.

In response to the plaintiff's submission that the defendant had left the plaintiff and their children in mid-February 2006, the defendant responded that he had commenced work in West Seram regency on 1 February 2000, and that every time he had returned home on a weekend the plaintiff was never there. In actual fact, the defendant submitted, it was the plaintiff who had left the parties' home from mid-2008 until 31 January 2011, evidenced by the fact the plaintiff had been renting a room in Ambon with the man she subsequently married. Moreover, the parties' children had been living with the defendant's parents. The defendant submitted that he was surprised to learn, when he returned home on 1 Feburary 2011, that the plaintiff had filed for divorce. He also submitted that it was unfeasible for the plaintiff to expect the defendant to maintain his spousal obligations to the plaintiff when she had been carrying on extra-marital affairs with other men before re-marrying.

The court acknowledged that the parties' marriage was in an irreparable state and no longer constituted a joyful and everlasting domestic life, per art 1 of Law No. 1 of 1974 on Marriage, or a peaceful, hopeful and loving domestic life, per art 3 of the Compilation of Islamic Laws. Pursuant to art 39(2) of Law No. 1 of 1974 on Marriage, art 19(b) and (f) of Government Regulation No. 9 of 1975, and art 116(b) and (f) of the Compilation of Islamic Laws, it acceded to the plaintiff's request on the grounds that the parties had been separated for more than two consecutive years, and ongoing conflict.

The parties were married on 21 January 1994 and had four children (aged 19, 17, 12 and 7). Initially, their marriage was harmonious; however, by December 2010, it had become quarrelsome. The cassation respondent had claimed that:

1. the parties could not reconcile their differences;
2. the cassation applicant could not commit to Islam (despite having converted to Islam from Christianity to marry the cassation respondent, he then, in 2006, reverted to Christianity, only to convert to Islam again in 2011);
3. the cassation applicant had not provided her with financial support for the last three years.

Problems escalated and, in April 2011, the parties separated. The cassation applicant, in the first instance, requested the local religious court grant her an irrevocable divorce (talak satu ba’in Shughro). In Decision 1048/Pdt.G/2013/PA.Kab.Kdr (18 September 2013), the lower court, pursuant to art 19(f) of Government Regulation No. 9 of 1975, in conjunction with art 116(f) of the Compilation of Islamic Laws, granted her an irrevocable divorce (talak satu ba’in sughra) on the grounds of ongoing conflict, and ordered her to pay IDR 691,000 in court costs.

The cassation applicant then lodged an appeal with the Surabaya High Religious Court (3427/Pdt.G/2013/PT.Sby), which upheld the judgment of the Kediri Religious Court.

On 11 February 2014, the cassation applicant submitted a request for cassation to the Supreme Court based on the following grounds:

1. that the Surabaya High Religious Court had applied the law incorrectly, granting a divorce despite the cassation respondent's claim for divorce not being established with any legitimate evidence;
2. that the aforementioned evidence was inadequate because the marriage was actually stable and harmonious; and
3. that the cassation respondent's true motive for divorce was to be with her boyfriend, while the interests of the parties' children were not adequately considered by the court.

Pursuant to art 30 of Law No. 14 of 1985 on the Supreme Court, as amended by Law No. 5 of 2004 and Law No. 3 of 2009, the court upheld the decision of the Surabaya High Religious Court, dismissing the defendant’s reasons for cassation, and ordering him to pay court costs (IDR 500,000).

The plaintiff's claim stated that, after the parties were married on 1 October 2010 before a marriage registry official from the local Office of Religious Affairs, work commitments had necessitated their living apart. The plaintiff worked at the Sungai Garinggiang Public Health Centre, and lived at the Health Centre's service house, while the defendant lived with his parents in Padang. Once every three days the plaintiff returned to her parents' home until the parties separated. The parties had one child.

The plaintiff submitted that, since the beginning of the marriage, she and the defendant had quarrelled continuously. This was because:

1. the defendant did not dedicate enough time to the plaintiff; and
2. the plaintiff had heard from family friends that the defendant had had an extra-marital affair, and, while the defendant had denied the allegation, the plaintiff's own investigation revealed that the defendant had indeed had an affair with his previous girlfriend.

Problems escalated in mid-October 2012, as the defendant was still in contact with his previous girlfriend. While the defendant denied these allegations again, the ensuing argument caused him to leave the plaintiff's parents' home. The parties had remained separated since then, and the defendant had not provided the plaintiff with any financial support. In August 2013, the plaintiff was informed by friends of the defendant that the defendant had married his previous girlfriend.

The court noted that its advice to the parties that they reconcile had been to no avail. Moreover, the defendant had no objections to the plaintiff's request for a divorce. Accordingly, the court, pursuant to art 39(2) of Law No. 1 of 1974 on Marriage, in conjunction with art 19(f) of Government Regulation No. 9 of 1975, and art 116 of the Compilation of Islamic Laws, granted the plaintiff an irrevocable divorce (talak satu ba'in shugra) on the grounds of ongoing conflict.

The parties were married on 4 September 2000 and had three children. They had lived together with one of the defendant's uncles in Samarinda for approximately three years, before moving to live with another of the defendant's uncles in West Java for four years. From there they loved to Simoro village, where they had lived up until the time of the proceeding. Initially, the marriage had been harmonious, however, by February 2006, the parties had begun to quarrel regularly. The plaintiff submitted that the defendant:

1. had debts of which the plaintiff was unaware;
2. would drink excessively and sometimes even slap the plaintiff;
3. had been having an extra-marital affair since the birth of the parties' third child; and
4. had failed to provide for the plaintiff since the birth of the parties' third child.

When problems escalated the defendant left the matrimonial home. 

The court found that a sufficient reason to grant an irrevocable divorce, as required by art 119(2)(c) of the Compilation of Islamic Laws, that being ongoing conflict, existed. Therefore, it acceded to the plaintiff's request, pursuant to art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws.

The parties were married on 6 February 2012, after which time they had lived together with the plaintiff's parents. The parties had no children. The plaintiff submitted that by February 2013 the marriage had become quarrelsome because the defendant:

1. would not provide for the plaintiff due to his own jealousy;
2. could not be physically intimate with the plaintiff due to his own sexual impotence; and
3. had failed to provide for the plaintiff for one year and nine months.

When problems escalated in February 2013 the defendant left the matrimonial home.

The court found that a sufficient reason to grant an irrevocable divorce, as required by art 119(2)(c) of the Compilation of Islamic Laws, that being ongoing conflict, existed. Therefore, it acceded to the plaintiff's request, pursuant to art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws.

The parties were married on 8 February 2010 and had a child who passed away at the age of 3. By the end of 2011 they had begun to quarrel regularly because the respondent intended to move to Malaysia to work, despite the applicant's reluctance to give her his blessing, and that upon the respondent's return to Indonesia in July 2014, she had chosen to stay with her parents rather than return to the applicant. 

The applicant submitted that the parties' differences were irreconcilable and, accordingly, requested a revocable divorce (talak satu raj'i). The court acknowledged that the purpose of marriage, as contained in the Qur'an, Surah Al Rum, verse 21, as well as art 1 of Law No. 1 of 1974, and art 3 of the Compilation of Islamic Laws, being a peaceful, hopeful and loving home, was no longer feasible. Therefore, pursuant to the elucidation of art 39(2) of Law No. 1 of 1974, art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws, the court granted a divorce on the grounds of ongoing conflict.

The parties were married on 24 May 2009. They lived together happily with the applicant's parents for five years and four months, but had no children. Since October 2010, however, the parties had begun to quarrel because, due to a cervical tumor, the respondent was unable to fall pregnant. The applicant submitted that this caused him to suffer greatly, and to feel that the parties could no longer remain married. Moreover, the parties had been separated since September 2014, during which time, they had shared no physical intimacy.

The applicant submitted that the parties' differences were irreconcilable and, accordingly, requested a revocable divorce (talak satu raj'i). The court acknowledged that the purpose of marriage, as contained in the Qur'an, Surah Al Rum, verse 21, as well as art 1 of Law No. 1 of 1974, and art 3 of the Compilation of Islamic Laws, being a peaceful, hopeful and loving home, was no longer feasible. Therefore, pursuant to the elucidation of art 37 of Law No. 1 of 1974, art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws, the court granted a divorce on the grounds of ongoing conflict.

The parties were married on 5 May 2002. Since May 2006, however, the marriage had become disharmonious. The plaintiff submitted that this was because the defendant:

1. had frequently become emotional and angry and would utter obscenities, even physically assaulting the plaintiff;
2. was never transparent with the plaintiff as to his finances and salary; and
3. had stopped providing the plaintiff with emotional and financial support since May 2006.

Despite these issues, the parties had remained under the one roof.

In the defendant's absence, the court found that the parties no longer loved each other as husband and wife, as envisaged by art 77(2) of the Compilation of Islamic Laws. Moreover, ongoing conflict between the parties enabled the court, pursuant to art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws, to grant the plaintiff an irrevocable divorce (talak satu ba'in shugra).

The parties were married on 8 February 2009. On 17 July 2009 they had their first and only child and, after two years, relocated to Denpasar, Bali. Since July 2010, however, the parties had begun to quarrel regularly. The plaintiff submitted that this was because:

1. the defendant's temperamental nature would often result in discussions turning into arguments where the defendant would slap, hit and shove the plaintiff; and
2. the defendant had not provided the plaintiff with financial or emotional support since March 2011.

Indeed, in March 2011, problems escalated, resulting in the defendant leaving the matrimonial home. The plaintiff asserted that the parties' differences were irreconcilable and that the court should find sufficient reason to grant her an irrevocable divorce (talak satu ba'in sughro), pursuant to Law No. 1 of 1974 on Marriage, and art 19 of Government Regulation No. 9 of 1975, and art 116 of the Compilation of Islamic Laws. The court concurred, finding that ongoing conflict between the parties satisfied the legitimate reason requirement to grant a divorce, per art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws.

The parties were married on 29 September 2003 and had two children. Since 2013, however, the parties had begun to quarrel regularly after the respondent had had an extra-marital affair and then married the other man. Problems escalated and, on 24 September 2014, the respondent left the parties' matrimonial home. As a result, the applicant believed divorce was the only feasible option.

Despite having been summonsed, pursuant to art 26 of Government Regulation No. 9 of 1975, and art 138 of the Compilation of Islamic Laws, the respondent failed to attend court. Citing Surat Al-Baqarah verse 227 from the Qur'an, as well as art 39 of Law No. 1 of 1974 on Marriage, art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws, the court acceded to the applicant's request for a revocable divorce (talak satu raj'i) on the grounds of ongoing conflict between the parties.

The parties were married on 29 May 2010 and had one child. By 2011, however, the parties had begun to quarrel regularly. The plaintiff submitted that this was the result of the defendant:

1. directing profane language at the plaintiff;
2. often damaging items in the home; and
3. sometimes physically assaulting the plaintiff.

Problems escalated and, by the beginning of 2013, the plaintiff had left the defendant. As time passed, the plaintiff believed that divorce was the only feasible option.

Despite having been summonsed, pursuant to art 26 of Government Regulation No. 9 of 1975, and art 138 of the Compilation of Islamic Laws, the defendant failed to attend court. Citing Surat Al-Baqarah verse 227 from the Qur'an, as well as art 39 of Law No. 1 of 1974 on Marriage, art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws, the court acceded to the plaintiff's request for an irrevocable divorce (talak satu ba'in shughra) on the grounds of ongoing conflict between the parties. The court also ordered the plaintiff to pay court costs (IDR 301,000).

The parties were married on 15 May 2014, after which they had lived with the plaintiff's parents for three months before moving to their own accommodation. The plaintiff submitted that, since 2014, the parties had frequently quarrelled because the defendant:

1. had not permitted the plaintiff to adhere to a family planning program;
2. had not permitted the plaintiff to see her family; and
3. had forced the plaintiff to leave their accommodation when they would argue, even disposing of the plaintiff's clothes.

Consequently, the plaintiff had been living with her parents, while the defendant had remained in the parties' accommodation. It followed that the plaintiff sought an irrevocable divorce (talak satu ba'in sughra).

In the defendant's absence, the Court acknowledged that the parties' marriage had deterioriated and no longer represented that envisaged by art 1 of Law No. 1 of 1974, art 3 of the Compilation of Islamic Laws, and the Qur'an in surat Ar-Rum, verse 21. It acceded to the plaintiff's request on the grounds of ongoing conflict, per art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws.

The parties were married on 24 December 1995, after which they had lived with the plaintiff's parents for three days, before departing for Irian Jaya, where they lived for three years, before then returning to Atambua. The parties had four children. The plaintiff submitted that, since October 2005, the parties had frequently quarrelled because the defendant:

1. gambled frequently, ignoring the plaintiff's advice to stop;
2. would ignore the plaintiff's suggestions; and
3. had repudiated his responsibilities towards his children and the plaintiff as a financial provider.

The parties had been separated for the past 10 years and the plaintiff requested that the Court grant her an irrevocable divorce (talak satu ba'in sughra).

The Court acknowledged that the parties' marriage had deterioriated and no longer represented that envisaged by art 1 of Law No. 1 of 1974, art 3 of the Compilation of Islamic Laws, and the Qur'an in surat Ar-Rum, verse 21. It acceded to the plaintiff's request on the grounds of ongoing conflict, per art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws. While not part of the plaintiff's submissions, it also found that the quarrelling between the parties was akin to domestic violence and, pursuant to arts 5(d) and 9 of Law No. 23 of 2004 on the Abolition of Domestic Violence, had to be stopped immediately.

The parties were married on 6 April 1980 and had two children. The applicant submitted that the parties had been happily married for 30 years. By June 2011, however, the marriage had become quarrelsome after the respondent had had an extra-marital affair with another man, whose identity the respondent had kept concealed from the applicant. The applicant also submitted that the respondent would return home in the middle of the night, flout or ignore the applicant's advice, become angry with the applicant, use profane language with the applicant, and had even requested that the applicant divorce her as quickly as possible before a religious court. As a result, the parties had been sleeping in separate beds since 18 February 2012. The applicant submitted that the information with which he had provided the court was sufficient to be granted a divorce (talak satu raj'i), pursuant to art 116(f) of the Compilation of Islamic Laws.

The court acceded to the applicant's request, granting him a revocable divorce on the grounds of ongoing conflict, pursuant to art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws.

In preambular statement (a), this regional regulation states that Gorontalo province is a customary law region (Daerah Hukum Adat), whose culture is based on the philosophy of 'Adat bersendikan Syara, Syara bersendikan Kitabullah' ('custom found upon Islamic law, Islamic law found upon the Qur'an'), which needs to be maintained. Accordingly, it seeks to regulate and prohibit immoral behaviour that damages the societal fabric of Gorontalo, and which contradicts religious norms, morality and customs (art 2(1)). The regulation prohibits:

1. sexual relations out of wedlock, including adultery and prostitution (zina) (arts 3 and 4);
2. illegitimate marriage (art 5);
3. rape and sexual abuse (art 6);
4. pornoaction and pornography (art 7);
5. gambling (art 8);
6. alcohol consumption in non-designated areas (art 9(1));
7. being intoxicated in a public place (art 9(2)); and
8. narcotics distribution and abuse (art 10).

Contravention of arts 3-8 and 9(2) carries a maximum penalty of six months' imprisonment or a fine of IDR 5 million (art 14(1)), while contravention of art 10 carries a maximum penalty of IDR 5 million or a loss of trading licence (art 14(2)).

The parties were married on 28 October 2011 and had one child aged three years. The applicant submitted that the parties' marriage had always been disharmonious because the respondent:

1. had always been dissatisfied with what he had provided her financially;
2. would not deliberate with the applicant;
3. was unwarrantedly suspicious of the applicant;
4. was aggressive and harsh towards the applicant;
5. would prioritise her family's needs over his; and
6. would frequently request a divorce.

Problems escalated in November 2013 resulting in the respondent leaving the applicant and returning to her parents' home in Langsa. The parties had remained separated since and the applicant submitted that he believed a revocable divorce (talak satu raj'i) was the only feasible option available to the parties.

The court, pursuant to art 19(f) of Government Regulation No. 9 of 1975, and art 116(f) of the Compilation of Islamic Laws, acceded to the applicant's request on the grounds of ongoing conflict. It also acknowledged that revocable divorce is regulated in art 118 of the Compilation of Islamic Laws.