ABSTRACT
Investigation into the relationship between cultural diversity and family law in Europe principally centres on conflict-of-laws rules, the rules determining which law applies in family disputes involving foreign nationals. Law has a cultural dimension. People's legal convictions can be greatly at odds with the legal rules in their country, as is evidenced by marriages performed by imams in Turkey or by forced marriages in some South Asian cultures, both being invalid under the law of the countries concerned. If private international law requires that Muslim residents in European countries have to be judged according to the law of their foreign nationality, they will then not be permitted to benefit from the possibly more favourable provisions of the European code. The EU legal framework in family-law matters currently in place under the Brussels IIa Regulation governs only matters of international judicial jurisdiction in divorce issues and the recognition of member states' decisions in marital matters.
