ABSTRACT
Indonesia enjoys a pluralistic legal system, particularly in family law areas like divorce and inheritance. The reasons for this are formally the continuation of ethnically-based personal legal jurisdiction principles reaching back to Dutch colonial times. So we face under differing circumstances Islamic law, customary or ethnically-based adat law, and secular national law in inheritance matters. For our purposes, we can precisely trace the details of our “chicken or egg” question because the treatment of women in inheritance matters traditionally differs according to which legal approach is applied, but shows development in the practical overlap.
