The European Court of Justice stated that under EU law a declaration of divorce before a religious court is not covered by legislation. The agreement for divorce in a third country is not recognized and must be settled under the law of the member state.
Expert divorce lawyers in Thailand have successfully litigated hundreds of local and international divorce cases.
A Muslim couple who married in Syria, moved to Germany but had the marriage annulled in a Sharia court in Syria does not have their divorce legally acknowledged by Germany. This is because the couple had an “instant divorce” where a representative from the religious court repeats “talaq” three times. The EU does not recognize private divorces as a state authority was not involved.
However, the final ruling is not up to the ECJ but the court in Munich.
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