In this book, the author questions the impact of migration from countries with a predominantly Muslim population on European family law codes. She not only maps out the problems of a multicultural society but also proffers solutions to such perceived tensions, in particular solutions to the threat that Islamic family law may become entrenched in the legal systems of European counties. While she does accept that a possible shortcoming in the solutions proffered are that they are biased towards theory rather than practice, the book itself is aimed at academics rather than practitioners and therefore serves its readership well. These solutions appear in the final chapter of the book and are titled: ‘Seven theses to sum up and conclude’, one being ‘Inclusion or exclusion of alien family law’, in which it is argued that Islamic law has a part to play in the application of the law in European countries because private international law refers to it.

There is a useful summary of classical Islamic law (p 10) that encompasses the salient aspects of a broad topic. It would have been further helpful to readers to understand the relationship between religious and cultural identity, albeit in summary form, as the book quickly moves from Islamic law to cultural and religious identity without a link between the two. Not all culture is Islamic and not all Islamic practices are cultural. While Buchler is careful to point out at the beginning of the book that even the Muslim community in Europe is diverse (p 23), the fact that she considers cultural identify alongside religious identity but fails to differentiate between the two is a glaring deficiency.

Chapter 2, on ‘Real and virtual legal spaces: the scope and limitations of conflict-of-laws rules’, presents challenging questions and scenarios in which conflict of laws rules would be invoked. For most European countries, nationality is the key factor when making a decision that may involve two conflicting jurisdictions and, rightfully, the author attributes useful discussion to this topic (p 28). In particular, there is a comparison between the legal systems of Switzerland and England on residence or domicile being a determining factor of nationality. Thus, in Switzerland, the applicable law when determining disputes in family law is based on a person's domicile or habitual residence (except for Iranian nationals, in which case the Swiss courts would apply the law of a person's primary nationality, in other words, Iranian law). The author compares this approach to that of the English courts, in which there is a more strict approach in determining domicile and there is no dual right to domicile: ‘everyone has a domicile, and no one has either several or none’ (p 37).

An important aspect of family law is child custody (or ‘residence’, as it is now known in the British courts) and Buchler provides a helpful comparison between the approach of sharia law and that of family law in Europe (p 61). The information on adoption (p 62) is simplistic and perhaps misleading in that, for some Muslims, adoption is not considered to be a prohibited act and certainly there is nothing in the Qur'an that explicitly forbids adoption; rather the act of stating that an adopted son is biologically yours is forbidden and therefore the verse has been misinterpreted by the author, with potential grave consequences. Adoption itself is a difficult area within Islamic family law and it is not surprising that Buchler has represented the most simplistic and, for some Muslims, incorrect stance. However, she goes on to provide a comparison between the various European countries of accommodating Islamic family law within adoption for Muslim couples. Further, the author makes an assumption that Muslims have both a nikah and civil wedding owing to distrust: ‘The refusal to have recourse to English law can be seen not only as a reassertion of religious and cultural identity, but also as evidence of lack of trust in official law’ (p 77). In fact, it is well known that Muslims regard only the nikah as a religiously binding marriage contract and any other form of marriage ceremony, while legally valid, would not bind their conscience. The issue is not one of trust; it is one of religious values.

Despite some of its shortcomings, the book is unique in that it provides the reader with a general insight into how the courts in European countries such as Germany, Switzerland, France, England and Spain have dealt with culture and religious identity in family law cases; most previous works have dealt with court decisions from one legal system or country alone. The comparison is most helpful, especially when proffering guidance and solutions, as Buchler has done in the final chapter of her book.