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Arab countries apply Islamic law rules to inheritance matters and domestic relations.

Many Arab countries grant a mother the right to transmit citizenship to her children; however, some countries, such as Libya, the United Arab Emirates (UAE), and Bahrain make it conditional. Other countries, such as Jordan, Qatar, and Lebanon have no provisions allowing a mother to transmit citizenship to her child.

Many Arab countries set the minimum age for women to marry at 18 years of age. Nevertheless, those countries have a provision in their family law allowing a religious court to grant women younger than 18 the right to marry. Yemen has abolished its minimum age for marriage.

Most Arab countries include a provision in their constitutions promoting the principle of gender equality. Some countries, such as Kuwait, Jordan, and the UAE, however, do not include the term “gender” in the equality provision.

Many Arab countries have adopted legislation to combat the problem of domestic violence. However, countries such as Egypt, Qatar, Oman, and Yemen lack anti-domestic violence laws.

It is important to note that even in those cases where constitutions or laws guarantee certain rights, court cases illustrating that those rights are enforced are lacking in some of the jurisdictions covered. 

I. Inheritance

Arab countries apply Islamic law rules to inheritance matters. Verse 11 of Surat An-Nisaa of the Qur’an states that a woman’s share of an inheritance is half that of a man.

Recently, attempts to change the general rule of inheritance have occurred in two Arab countries. The cabinet of Tunisia approved a bill on November 22, 2019, which, for the first time in the nation’s history, would require that male and female heirs receive equal inheritance shares. If enacted, Tunisia would be the first among the Arab countries to adopt such a law. The cabinet referred the bill to the Tunisian Parliament for debate and voting.[1] It is not yet a law.[2]

On November 25, 2019, the Cairo Court of Appeal granted an Egyptian Christian woman a share of her late father’s estate equal to the share of each of her brothers. The plaintiff had argued that, as a Coptic Christian, she should not be subject to Islamic law in matters related to inheritance. She pointed out that article 3 of the 2014 Egyptian Constitution grants the right to Egyptian Christians to apply their religious laws regarding matters related to personal status and family law.[3]

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II. Citizenship

A. Algeria

Law No. 01-05 of 2005 allows a child of an Algerian mother to acquire Algerian citizenship.[4]

B. Bahrain

Article 4(c) of the Bahraini citizenship law allows the child of a Bahraini woman who is born in Bahrain or abroad to acquire Bahraini citizenship, provided that his or her father is unknown or stateless.[5]

C. Egypt

Article 1 of Law No. 154 of 2004 allows those who were born outside Egypt of Egyptian mothers married to foreign husbands to acquire Egyptian citizenship. Article 1 defines “Egyptian citizens” as anyone born of an Egyptian father or an Egyptian mother, and anyone born in Egypt from unknown parents.[6] 

D. Iraq

Article 3 of Law No. 26 of 2006 states that a person will be considered Iraqi if he or she was born to an Iraqi father or an Iraqi mother.[7]

E. Jordan

Jordan has no provision in its citizenship law allowing a mother to transmit citizenship.[8]

F. Kuwait

Article 3 of the Royal Decree on Citizenship allows the child of a Kuwaiti woman who is born in Kuwait or abroad to acquire Kuwaiti citizenship, provided that his or her father is unknown.[9]

G. Lebanon

Lebanon has no provision in its citizenship law allowing a mother to transmit citizenship.[10]

H. Libya

Law No. 47 of 1976 allows a child born in Libya by a Libyan woman to acquire Libyan citizenship, provided that his or her father is unknown or stateless.[11]

I. Morocco

Law No. 62-06 of 2007 allows a Moroccan mother’s child to acquire Moroccan citizenship.[12] 

J. Oman

< p>Article 11 of the Omani law on citizenship grants an Omani woman’s child Omani citizenship whether the child was born in Oman or abroad.[13]

K. Qatar

Qatar has no provision allowing a Qatari mother to transmit Qatari citizenship.[14]

L. Saudi Arabia

Article 7 of Resolution No. 4 allows those who are born inside or outside the Kingdom by a Saudi mother and an unknown father to acquire Saudi citizenship.[15]

Article 8 imposes conditions for citizenship on individuals who are born inside Saudi Arabia to a Saudi mother and non-Saudi father. It stipulates that the Minister of Interior may grant Saudi citizenship to such an individual if the person

  • has a permanent Resident Permit (Iqama) upon reaching legal age (18 years of age),
  • has good behavior with no record of a criminal judgment or imprisonment for more than six months,
  • is fluent in Arabic, and
  • applies for citizenship within one year of reaching legal age.[16]

M. Syria

Law No. 276 of 1969 provides that anyone born in Syria to a Syrian mother and an unknown father may acquire Syrian citizenship.[17] 

N. Tunisia

Under Law No. 55 of 2010, a child born to a Tunisian mother is considered a Tunisian citizen.[18]

O. United Arab Emirates

Article 2 of Federal Law No. 10 of 1975 on citizenship stipulates that a person who is born in the UAE to an Emirati mother and an unknown or stateless father may acquire Emirati citizenship.[19]

Under article 10 (bis) of Law No. 16 of 2017, the children of an Emirati woman who is married to a foreign citizen have the right to acquire Emirati citizenship subject to a waiting period of at least six years after their birth.[20]

P. Yemen

Under article 3 of Law No. 6 of 1990, as amended by article 1 of Law No. 25 of 2010, individuals must be considered Yemeni citizens by birth if they are (1) born to a Yemeni father or mother in Yemen or abroad, or (2) born to a Yemeni mother and a foreign father.[21]

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III. Legal Age of Marriage

A. Algeria

Males and females must be 19 years of age to marry. Individuals interested in marrying before that age must obtain approval from the family law court.[22]

B. Bahrain

The minimum age of marriage for females is 16. If the female’s guardian wants her to get married earlier, he must obtain the permission of the religious court.[23] For males, the minimum marriage age is 18.[24]

C. Egypt

Females must be at least 16 years of age and males at least 18 years of age to marry.[25]

D. Iraq

The minimum age for marriage in Iraq is 18 years of age for both men and women.[26] Law No. 188 of 1959 grants judges the right to permit the marriage of individuals between the ages of 15 and 18 if the legal guardian of the bride or the groom does not object to the marriage. If the guardian abstains from giving an opinion, the judge may set a deadline for him to express his view.[27]

A judge has the power to authorize the marriage of a 15-year-old person (or either sex) if the judge sees an “urgent necessity” for the marriage. Giving such authorization is also conditional upon the attainment of legal puberty and the “physical ability to marry.”[28]

E. Jordan

The minimum age for marriage is 18 years of age for both men and women.[29] The Shari‛a Courts have the right to permit the marriage of an individual of either sex between the ages of 15 and 18 years.[30]

F. Kuwait

The minimum age of marriage is 15 for females and 17 for males.[31]

G. Lebanon

In October 2014, the Legal Research Directorate of the Lebanese Parliament issued a study identifying the minimum age of marriage set by Lebanese religious sects.[32]

Catholic Christians set the minimum age of marriage at 16 for boys and 14 for girls.[33] However, Catholic religious leaders have discretion to raise the minimum age of marriage from 14 to any age.[34]

Orthodox Christians have determined the minimum age of marriage as 18 for both men and women. The Orthodox Christian religious leaders have the right to reduce the minimum age of marriage to 17 for boys and 15 for girls.[35]

Protestant Christians consider the age of puberty as the minimum age of marriage, and define the age of puberty for men as 18 and for women as 16.[36]

With respect to the Muslim Sunni sect, religious leaders have the right to allow a marriage to take place at the age of puberty. They consider the age of puberty as between nine and 13 for girls. The child’s guardian must approve the marriage.[37] Some other Sunni leaders set the age of marriage at 18 for boys and 17 for girls.[38] Likewise, the religious leaders of the Muslim Shi‛a sect consider the age of puberty as the minimum age of marriage. They identify the age of puberty as nine to 13 for girls,[39] but as 15 for boys.[40] The guardian of the child or teen must approve the marriage.[41]

Concerning the Druze sect, the religious leaders identify the minimum age of marriage as 18 for men and 17 for women.[42] A Druze woman needs her male guardian’s permission to marry if she is under the age of 21.[43] Druze leaders have the power to reduce the minimum age of marriage to 16 for boys and 15 for girls.[44]

H. Libya

Both males and females must be at least 20 years of age to marry in Libya.[45]

I. Morocco

The minimum age for marriage in Morocco is 18 for both men and women.[46] The religious courts have the power to authorize the marriage of a person under 18 years of age (of either sex) if a court finds marriage is in “the best interest of the couple.” Giving such authorization is also conditional upon the “physical ability to marry.”[47]

J. Oman

The minimum age for marriage in Oman is 18 for both males and females.[48] The religious courts have the power to authorize the marriage of a person under 18 years of age (of either sex) if a court finds marriage is in “the best interest of the couple.”[49]

K. Qatar

The minimum age for marriage in Qatar is 18 for males and 16 for females. The religious courts have the power to authorize the marriage of males under 18 and females under 16.[50]

L. Saudi Arabia

The minimum age for marriage is 17. Persons under 17 years of age must obtain court permission to get married.[51]

M. Syria

According to article 16 of Law No. 4 of 2019 amending Law No. 59 of 1953 on Personal Status, the minimum age for marriage in Syria is 18 years for both men and women.[52]

Article 18 of Law No. 4 of 2019 grants a judge the right to permit the marriage of an individual of either gender between the ages of 15 and 18 years.[53] Before the judge permits the marriage, the judge must obtain the approval of the minor’s guardian.[54]

N. Tunisia

The minimum age of marriage in Tunisia is 18 for both males and females. The religious court has the power to authorize the marriage of a person under 18 years of age of either gender if the court finds marriage is in “the best interest of the couple.”[55]

O. United Arab Emirates

The minimum age for marriage for both females and males is 18. The religious court has the power to authorize the marriage of a person under 18 years of age of either sex.[56]

P. Yemen

Article 15 of the Presidential Decree promulgating the Personal Status Law No. 20 of 1992 previously set the minimum age of marriage at 15 years for both genders.[57] However, Law No. 24 of 1999 amended article 15 by abolishing the minimum age of marriage for females. The Law currently states that the marriage contract of a young girl is valid. However, marriage cannot be consummated if the girl has not reached the age of puberty and is not physically able to have sexual intercourse.[58] Article 127 of Law No. 20 of 1992 identifies the age of puberty for females as nine years old and above.[59]

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IV. Constitutional Provisions Addressing Equality

A. Algeria

“Citizens are equal before the law without any discrimination on the basis of birth, race, gender, opinion or any other personal or social condition or circumstances.”[60]

B. Bahrain

“People are equal in human dignity and citizens are equal before the law in public rights and duties. There is no discrimination among them on the basis of gender, origin, language, religion or creed.”[61]

C. Egypt

“Citizens are equal before the law, possess equal rights and public duties, and may not be discriminated against on the basis of religion, belief, gender, origin, race, color, language, disability, social class, political or geographical affiliation, or for any other reason.”[62]

D. Iraq

“Iraqis are equal before the law without discrimination based on gender, race, ethnicity, nationality, origin, color, religion, sect, belief or opinion, or economic or social status.”[63]

E. Jordan

“Jordanians shall be equal before the law with no discrimination between them in rights and duties even if they differ in race, language or religion.”[64]

F. Kuwait

“The people are peers in human dignity and have, in the eyes of the Law, equal public rights and obligations. There is no differentiation among them because of race, origin, language or religion.”[65]

G. Lebanon

“All Lebanese are equal before the law. They enjoy civil and political rights equally, and assume obligations and public duties without any distinction among them.”[66]

H. Libya

“The state must ensure equal opportunity and strive to guarantee a proper standard of living, the right to work, education, medical care, and social security to every citizen.”[67]

I. Morocco

“The man and the woman enjoy equal rights and freedoms of civil, political, economic, social, cultural and environmental character.”[68]

J. Oman

“Justice, equality, and equal opportunities among Omanis are pillars of the society guaranteed by the State.”[69]

K. Qatar

“People are equal before the law. There shall be no discrimination against them because of gender, race, language, or religion.”[70]

L. Saudi Arabia

“Governance in the Kingdom of Saudi Arabia is based on justice, Shura [consultation] and equality according to Islamic Shari‛a.”[71]

M. Syria

“Citizens shall be equal in rights and duties without discrimination among them on grounds of sex, origin, language, religion or creed.”[72]

N. Tunisia

“All citizens, male and female, have equal rights and duties, and are equal before the law without any discrimination.”[73]

O. United Arab Emirates

“All persons are equal in law. There is no distinction among the citizens of the UAE on the basis of race, nationality, faith or social status.”[74]

P. Yemen

“The State must guarantee equal opportunities for all citizens in the fields of political, economic, social and cultural activities and shall enact the necessary laws for the realization thereof.”[75]

“Women are the sisters of men. They have rights and duties, which are guaranteed and assigned by Islamic law.”[76]

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V. Legal Protection against Domestic Violence

A.  Algeria

Law No. 15-19 criminalizes physical assault against a spouse or ex-spouse with a term of imprisonment up to 20 years. If the assault results in death, the penalty will be increased to a life sentence.[77]

B.  Bahrain

Law No. 17 of 2015 protects wives from all forms of domestic abuse and violence. The Law creates the Department of Family Guidance, located in the Ministry of Social Affairs. The main function of the department is to provide legal assistance to individuals facing domestic violence. It also sets forth procedures to protect victims of domestic violence. Finally, it enhances the penalties for all forms of domestic violence and abuse.[78]

C.  Jordan

Law No. 15 of 2017 on combating domestic violence enhances the penalty for assaulting wives (verbally or physically). It also identifies legal measures adopted by the court to protect a wife from her attacker.[79]

D.  Lebanon

Law No. 293 of 2014 on combating domestic violence and the protection of women establishes legal safeguards to protect women facing domestic violence not only from their spouses but also from family members. It also enhances the penalties for verbal and physical assault of a wife, daughter, sister, or other female member of the family. Finally, the law identifies procedures that members of law enforcement must adopt when they receive a complaint of domestic violence.[80] 

E. Morocco

Law No. 103.13 of 2018 on combating violence against women criminalizes some acts of domestic violence but does not address marital rape. The Law introduces legal measures to protect victims of domestic violence. It also obligates public authorities to take preventive measures against domestic violence, such as creating public awareness campaigns to educate women on how to report domestic violence incidents.[81]

F.  Saudi Arabia

Royal Decree No. M/52 of 24/12/1434 (Hijri) corresponding to October 29, 2013, bans forms of domestic abuse. It makes sexual violence in the home and the workplace a punishable crime. Moreover, it mandates the creation of shelters for victims of domestic violence. It also requires law enforcement officers to follow up on reports of domestic violence or abuse. Finally, it imposes a sentence of imprisonment and fines against violators.[82]

G.  Tunisia

Law No. 58 of 2017 on eliminating all forms domestic violence provides women with the measures necessary to seek protection from acts of violence by their husbands and family members. The Law includes provisions that prevent violence against women by raising public awareness. It protects victims of domestic violence by creating shelters for abused victims. Finally, it directs that individuals who physically or verbally attack their spouses or female family members should be prosecuted.[83]

H.  United Arab Emirates

Decree Promulgating Law No. 10 of 2019 on the protection from domestic violence introduces an array of legal measures, including terms of imprisonment and restraining orders to protect victims of domestic violence. The law grants the court the right to order an abusive husband to remain a certain distance from an abused wife. Violating the court’s restraining order will result in a three-month jail sentence.[84] 

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Prepared by George Sadek
Foreign Law Specialist
February 2020


[1] Tunisia Becomes the First Arab Nation to Approve Gender Equality in Inheritance Law, Dhaka Trib. (Nov. 25, 2018), https://perma.cc/U7RW-EB83.

[2] Tunisia: New Parliament’s Rights Priorities, Hum. Rts. Watch (Nov. 13, 2019), https://perma.cc/R7LA-H7EX.

[3] George Sadek, Egypt: Court Grants Christian Woman Share of Father’s Estate Equal to Share of Her Two Brothers, Global Legal Monitor (Jan. 9, 2020), https://perma.cc/6YFW-RM3C.

[4] Law No. 01-05 of 2005, art. 6, al-Jarīdah al-Rasmīyah, vol. 15, 17 Feb. 2005.

[5] Law of 1963, al-Jarīdah al-Rasmīyah, vol. 8, 9 Sept. 1963.

[6] Law No. 154 of 2004, al-Jarīdah al-Rasmīyah, vol. 28 duplicate (a), 14 July 2004.

[7] Law No. 26 of 2006, al-Waqā’a‛ al-‛Iraqīyah, vol. 4019, 7 May 2006.

[8] Q&A: Status of Non-Citizen Children of Jordanian Mothers, Hum. Rts. Watch (May 1, 2018), https://perma.cc/CXE2-DQLQ.

[9] Law No. 40 of 1987 amending Royal Decree No. 15 of 1959, https://perma.cc/9ZJW-34RL.

[10] Lebanon: Discriminatory Nationality Law, Hum. Rts. Watch (Oct. 3, 2018), https://perma.cc/YSJ7-38SW.

[11] Law No. 47 of 1976 amending Law 17 of 1954, art. 3 (C), al-Jarīdah al-Rasmīyah, vol. 43, 29 July 1976.

[12] Law 62-06 of 2007, art. 6, al-Jarīdah al-Rasmīyah, vol. 5513, 2 Apr. 2007.

[13] Royal Decree No. 38 of 2014, al-Jarīdah al-Rasmīyah, vol. 1066, 12 Aug. 2014.

[14] Rothna Begum, Qatar’s Permanent Residency Law a Step Forward but Discrimination Remains, Hum. Rts. Watch (Sept. 11, 2018), https://perma.cc/CP5Y-K3YG.

[15] Royal Decree M/4 of 1405 (Hijri), issued on 24/05/1405 (Hijri) (corresponding to 15 Feb. 1985), art. 7.

[16] Id. art. 8, amended by Royal Decree M/4 of 1405 (Hijri), issued on 24 /05/ 1405 (Hijri) (corresponding to 15 Feb. 1985). Prior to this amendment, article 8 did not recognize individuals born to a Saudi mother and foreign father as Saudi citizens. The former provision read: “[A]ny person whose father is a foreigner and mother is a Saudi national may be treated as a foreigner.” The old provision granted those individuals the right to apply for Saudi citizenship if they reached legal age, resided permanently in Saudi Arabia, and renounced their father’s foreign citizenship.

[17] Law No. 276 of 1969, art. 3(a), Nov. 24, 1969, https://perma.cc/DNQ7-FSAL.

[18] Law No. 33 of 2010, art. 6 (1), al-Jarīdah al-Rasmīyah, vol. 097, 3 Dec. 2010.

[19] Federal Law No. 10 for 1975, al-Jarīdah al-Rasmīyah, vol. 32, 15 Nov. 1975. 

[20] Law No. 16 of 2017, al-Jarīdah al-Rasmīyah, vol. 622, 18 Sept. 2017. 

[21] Law No. 6 of 1990, art. 3, amended by Law No. 25 of 2010, art. 1, issued on Nov. 1, 2010, https://perma.cc/37Y8-RS2Y. Prior to the amendment, Law No. 6 of 1990 on citizenship did not recognize individuals born to a Yemeni mother and a foreign father as Yemeni citizens unless the father was stateless or absent.

[22] Law No. 11 of 1984, art. 7, al-Jarīdah al-Rasmīyah, vol. 24, 9 June 1984.

[23] Law No. 19 of 2017, art. 20, al-Jarīdah al-Rasmīyah, vol. 3323 (annex), 20 July 2017.

[24] Ministerial Decree No. 45 of 2007, al-Jarīdah al-Rasmīyah, vol. 2812, 11 Oct. 2007.

[25] Law No. 1 of 2000, art. 17, 29 Jan. 2000, https://perma.cc/AK5S-87PN.

[26] Law No. 188 of 1959, art. 7(1), al Waqā’a‛ al ‛Iraqīyah, vol. 280, 30 Dec. 1959.

[27] Id. art. 8(1).

[28] Id. art. 8(2).

[29] Law No. 36 of 2010, art. 10(a), al-Jarīdah al-Rasmīyah, vol. 5061, 10 Oct. 2010.

[30] Id. art. 10(b).

[31] Law No. 51 of 1984, art. 26, Al-Kuwait Al-Youm, 23 July 1984.

[32] Dep’t of Res., Gen. Directorate for Stud. & Info., Council of Rep., Republic of Leb., Draft Law Proposed to Set a Minimum Age of Marriage (Oct. 1, 2014), https://perma.cc/5WE3-CS9V.

[33] Id. at 2, para. 2.

[34] Id.

[35] Id. at 2, para. 3.

[36] Id. at 2, para. 4.

[37] Id. at 3, chart 2.

[38] Id. at 2, para. 5.

[39] Id. at 3, chart 1.

[40] Id. at 2, para. 6.

[41] Id. at 3, chart 1 (the approval of the guardian).

[42] Id. at 2, para. 6.

[43] Anna Louie Sussman, In Lebanon, a Tangle of Religious Laws Govern Life and Love, Atlantic (Sept. 29, 2011), https://perma.cc/HTU8-J2D5.

[44] Dep’t of Res., Draft Law Proposed to Set a Minimum Age of Marriage, supra note 32, at 2, para. 6.

[45] Law No. 10 of 1984, art. 20, Apr. 19, 1984, https://perma.cc/K63B-GNAV.

[46] Decree 1.04.22, executing Law 70.03, art. 19, al-Jarīdah al-Rasmīyah, vol. 5184, 3 Feb. 2004.

[47] Id. art. 20.

[48] Royal Decree No. 32 of 1997, art. 7, al-Jarīdah al-Rasmīyah, vol. 601, 4 June 1997.

[49] Id. art. 10(c).

[50] Law 22 of 2006, art. 17, al-Jarīdah al-Rasmīyah, vol. 8, 28 Aug. 2006.

[51] Gen. Dep’t of Media & Comm., Saudi Ministry of Just., Requirements for the Marriage of Females Who Are 17 and Under, https://perma.cc/3CUX-UP8W

[52]Law No. 4 of 2019, amending Law No. 59 of 1953, https://perma.cc/9KS9-3547

[53] Id. art. 18.

[54] Id. art. 18(2).

[55] Law No. 32 of 2007, art. 5, al-Jarīdah al-Rasmīyah, vol. 042, 14 May 2007.

[56] Law No. 28 of 2005, art. 30, al-Jarīdah al-Rasmīyah, vol. 439, 30 Nov. 2005.

[57] Personal Status Law No. 20 of 1992, art. 15, al-Jarīdah al-Rasmīyah, vol. 3/6, 29 Mar. 1992.

[58] Law No. 24 of 1999, 10 Apr. 1999, https://perma.cc/2LDA-MXDC.

[59] Law No. 20 of 1992, art. 127.

[60] Alg. Const. of 1989, art. 32.

[61] Bahr. Const. of 2002, art. 18 (amended 2017).

[62] Const. of Arab Rep. of Egypt of 2014, art. 53.

[63] Iraq Const. of 2005, art. 14.

[64] Jordan Const. of 1952, art. 6(1) (amended 2016).

[65] Kuwait Const. of 1962, art. 29 (amended 1992).

[66] Leb. Const. of 1926, art. 7 (amended 2004).

[67] Libya Const. of 2011, art. 8 (amended 2012).

[68] Morocco Const. of 2011, art. 19.

[69] Oman Const. of 1996, art. 12(1) (amended 2011).

[70] Qatar Const. of 2003, art. 35.

[71] Basic Law of 1992, art. 8.

[72] Syria Const. of 2012, art. 33.

[73] Tunis. Const. of 2012, art. 21.

[74] U.A.E. Const. of 1971, art. 25 (amended 2009).

[75] Yemen Const. of 1991, art. 24.

[76] Id. art. 31.

[77] Law No. 15-19 of 2015, al-Jarīdah al-Rasmīyah, vol. 71, 30 Dec. 2015. 

[78] Law No. 17-2015, al-Jarīdah al-Rasmīyah, vol. 3222, 13 Dec. 2015.

[79] Law No. 15 of 2017, al-Jarīdah al-Rasmīyah, vol. 5460, 16 May 2017.

[80] Law No. 293 of 2014, al-Jarīdah al-Rasmīyah, vol. 21, 15 May 2014.

[81] Law No. 103.13, al-Jarīdah al-Rasmīyah, vol. 6655, 12 Mar. 2018.

[82] Royal Decree No. M/52, https://perma.cc/W4RV-EAZ3

[83] Law No. 58 of 2017, al-Jarīdah al-Rasmīyah, vol. 065, 15 Aug. 2017.

[84] Decree Promulgating Law No. 10 of 2019, al-Jarīdah al-Rasmīyah, vol. 661 (annex 1), 29 Aug. 2019.

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Last Updated: 02/25/2020