A significant development in the international financial markets in recent years has been the increasing importance of Islamic financing techniques*^[1]. In the international capital markets, a particular feature has been the development of the sukuk, or Islamic trust certificate, as a means of providing finance that meets the economic expectations of conventional capital markets investors in a manner that is consistent with Islamic principles.

The system of Islamic law that regulates Muslims' way of life is known as the Shari'a. It is derived from six sources:

• the Qur'an (the word of God as revealed to and written down by the Prophet);

• the Sunnah (the practices and traditions of the Prophet);

• the Hadith (accounts of the sayings and deeds of the Prophet);*^[2]

• qiyas (the application of accepted principles by analogy to new cases);

• ijma (the consensus of the Islamic community on a particular issue); and

• ijtihad (the opinion of Islamic jurists on a particular issue).

The Shari'a is therefore not a codified body of law, and is capable of development and interpretation*^[3]. When a new issue arises on which the position of the Shari'a is unknown, it may be necessary to seek a legal opinion (or fatwa ) from a religious leader (or mufti ). The opinions of different mufti may differ on the same issue depending on which Islamic school of thought they each belong to*^[3] and according to their individual interpretations of the Shari'a .