ABSTRACT
The nature of modern Islamic legal practice first requires an appreciation of the extent to which, and the manner in which, laws of European origin came to be adopted in the various territories of Islam. European law—criminal and commercial—had a foothold in the nineteenth-century Ottoman empire through the system of Capitulations, by which the Western powers ensured that their citizens resident in the Middle East would be governed by their own laws. As a result of the steps taken during the Ottoman period, laws of European origin form a vital and integral part of the legal systems of most Middle Eastern countries. Criminal law and procedure are almost completely Westernised, have witnessed a movement away from the French Codes towards other sources. The same considerations, however, which had led to the adoption of modern Criminal Codes almost everywhere else in the Muslim world, applied also to Northern Nigeria, and the need for reform was felt more urgently as independence approached.
