دراسة مقترحة للمقارنة بين قانون العقوبات الفرنسية والكويتي وبين العقوبات في الشريعة الإسلامية

Criminal laws differ based on country. Most countries have found French criminal law a source for developing their own laws. However, Islamic criminal law differs from other criminal laws. Islamic criminal law divided crimes into three sections. Hadd (crimes “against God” whose punishment is specified in the Qur’an and hadiths), qisas (crimes against an individual or family whose punishment is equal vengeance in the Qur’an and hadiths) and ta’zir (crimes for which the Qur’an and hadiths do not stipulate punishment and are left to the discretion of the ruler or judge). In this study, a comparison between French criminal law as well as Kuwaiti criminal law with Islamic criminal law is conducted. Both laws are reviewed and compared with Islamic law. Similarities and differences will be highlighted. recommendations for law makers will be given based on the results of this research.