ABSTRACT
The French and British legal models are generally seen as being antithetical. The former, "continental" model is based on the Roman tradition of civil law and codification in which the expression of the general will is the principal source of law and which relies on the notion of public order to protect society's values. On the contrary, under continental law, access to Islamic normativity is severely restricted by the supremacy of law and the imperative of public order, which rigorously frame contractual liberty a trait that is even more marked in France due to its traditions of lacit and centralization. Sharia councils emerge as religious institutions in the service of the Muslim community: exercising an advisory function on legal issues involving Islamic law; contributing to the establishment and authentication of legal acts of Islamic law; and resolving disputes between Muslims, primarily concerning family law.
