ABSTRACT
The possible reception of certain Islamic legal institutions in European legal systems – for instance polygamy – may clash with the fundamental rights and values enshrined in the European Convention on Human Rights. Two opposite interests are at stake here: on the one hand, protecting the legal and cultural identity of the Forum State and, on the other, respecting the diversity of other legal systems. This contribution clarifies whether and how it is possible to strike a balance between these opposite interests by means of private international law methods and techniques.
