Turkiye as a nation that has led the Islamic world for seven hundred years, from the early

13th century until the fall of the Ottoman Caliphate in the early 20th century. The phenomenon
of the life of the Turkish people became interesting when the Turkish state was founded in 1923
and declared a secular state, where Islam, which has worked as a religion and a system of social
and state life for more than seven centuries, was removed from its role and explained by the
Western system. 

Turkiye at the time of Mustafa Kemal Attaturk in 1923 wanted to give up everything
related to Islamic elements in Turkiye. Mustafa Kemal Ataturk erased all elements of the
Ottoman Era, except the splendor of the past, and renewed it with Westernization and
secularism. Then of course it will have an effect on family law, previously Turkiye was the first
country to implement reforms in the field of Muslim family law, at which time the existing
family law in Turkiye was adapted to several schools of thought and legalized for use by the
Turkish people. 

In Indonesia, the legislation that is used as a guideline for family law is the Compilation
of Islamic Law (KHI) which is a transformation of Law no. 1 of 1974 concerning marriage with
several changes and additions to articles. In KHI, the share of inheritance for men and women is
one of them regulated in Article 176 which reads: "A daughter if only one person gets a share, if
two or more people they get together two parts, and if a daughter together with son, the share of
the son is two to one with the daughter." Thus, it can be said that "one for men and half for
women. This means that if the heirs consist of only one man , the share of a son is twice the
share of a woman. This is based on the verse described above.     

In contrast to Indonesia, Turkiye is one of the countries that stipulates an equal share of
inheritance between men and women in addition to other countries such as Somalia. The Turkish
Family Law Act (The Civil Code 1926) stipulates that the male and female inheritance shares are
1:1. 

One of the most important things offered by the Turkish Family Law Act is the principles
between men and women relating to inheritance by the same. This means that the share between
men and women in Turkish legislation is 1:1. This is clearly the opposite of what has been
regulated in fiqh rules and Indonesian laws and regulations. Even though the two countries are
Islamic countries, the percentage of inheritance differs between men and women in the
application of inheritance.     

 Therefore, the author is interested in further researching the factors that caused the two
countries to apply the regulation, especially Turkiye.