Abstract
In this paper, I will explore a specific aspect of the contract of sale, namely the obligations that sale places on the parties involved. The paper will compare the treatment of these obligations in both Islamic law and common law, bringing to light the points of similarity and difference. Exploring the obligations of parties provides specific insight into the acceptable and moreover expected norms of behavior when parties own a duty to one another. The exploring of two different legal systems in this paper will help to expose the instances in which a contractual obligation may be circumscribed by Islamic law though permitted in the common law. By comparing the various obligations in these two systems, a picture begins to form, which reveals the strong ethical dimension of the sale obligations in Islamic law as compared to emphasis on the autonomy of the parties present in the common law.
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