Competing Models of Fatwa Authority: A Comparative Analysis of Indonesia and Türkiye in Addressing Contemporary Islamic Legal Challenges

This study explores the role of fatwā institutions in Indonesia and Türkiye in addressing contemporary legal challenges within Islamic jurisprudence. As Muslim-majority countries with distinct legal and political structures, both offer important comparative perspectives on how fatwās function as tools for religious interpretation and public guidance. The background of this research comes from the increasing complexity of modern issues, ranging from worship practices and social conduct to Islamic finance, halāl certification, bioethics, and governance that demand renewed ijtihad from authoritative bodies. In Indonesia, the Majelis Ulama Indonesia (MUI) serves as the primary national fatwā institution, issuing legal opinions that influence public discourse and religious life, despite lacking formal binding legal status. In contrast, Türkiye’s fatwās are centralised under the state-run Presidency of Religious Affairs (Diyanet), which operates with a unified, state-integrated model of religious authority. This research adopts a qualitative, comparative methodology through document analysis, focusing on fatwās issued by MUI and Diyanet between 2010 and 2023. The study also engages with legal and institutional texts to contextualise the frameworks in which these institutions operate. The findings suggest that while both institutions respond to similar contemporary challenges, they differ significantly in terms of their institutional independence, relationship with the state, and mechanisms of public influence. Fatwās, though not legally binding, continue to play a significant role in shaping religious norms, ethical behaviour, and Islamic legal development in both countries.