In every society where family affairs are regulated according to instructions derived from the Shariah or Islamic law, women are disadvantaged. The injustices these women are exposed to in the name of Islam vary from extreme cruelty (forced marriages; imprisonment or death after rape) to grossly unfair treatment in matters of marriage, divorce and inheritance.

Muslim women across the world are caught in a terrible predicament. They aspire to live by their faith as best they can, but their faith robs them of their rights. Some women have found a way out of this dilemma in the principle of separation of organized religion and state affairs. They fight an uphill battle to achieve and hold on to their basic rights. Two cases demonstrate just how difficult that struggle can be, in the context of new as well as established democracies.

The first is the draft constitution of Iraq, now due next week. Iraqi women like Naghem Khadim, demonstrating on the streets of Najaf, are fighting to prevent an article from being put in the constitution that would establish that the legislature may make no laws that contradict Shariah edicts. The second case is the province of Ontario, in Canada. There, Muslim women led by Homa Arjomand, an activist of Iranian origin, are fighting--using the Canadian Charter of Rights--to keep Shariah from being applied as family law through a so-called Arbitration Act passed as law in Ontario in 1992...