KANUN: JURNAL ILMU HUKUM
Vol. 28 No. 2: August 2026: Constitutional Law and Global Development

CONSTITUTIONAL MODEL OF RELIGIOUS RECOGNITION: A COMPARISON OF INDONESIA, AMERICA, GERMANY, MALAYSIA, IRAN, AND SAUDI ARABIA

Iman Pasu Marganda Hadiarto Purba (Universitas Negeri Surabaya)
Thohir Luth (Fakultas Hukum Universitas Brawijaya)
Tunggul Anshari Setia Negara (Fakultas Hukum Universitas Brawijaya)
Nur Chanifah (Unknown)



Article Info

Publish Date
02 Aug 2026

Abstract

The recognition of religion by the state has prompted constitutional questions across diverse jurisdictions. This article analyzes the constitutional model of religious recognition in six countries, i.e. Indonesia, Germany, Malaysia, the United States, Iran, and Saudi Arabia. It adopts conceptual analysis and comparative constitutional law to conduct normative legal research. The primary materials consist of constitutions, laws, and regulations that govern state–religion relations. A functional comparative technique is employed to qualitatively examine the legal elements and their interconnections. The study’s findings show that models of religious recognition are shaped by the character of state–religion relations and by the legal systems each country adopts. No country presents an identical model of religious recognition, reflecting inherent structural differences in constitutional design. Constitutional forms of religious recognition are influenced by each country’s pattern of state–religion interaction, constitutional ideology, and legal tradition. There is no universal constitutional model of religious recognition that fits all contexts. Instead, each framework demonstrates how state ideology, legal culture, constitutional design, and the historical relationship between religion and the state converge to produce unique regimes.

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Journal Info

Abbrev

KJIH

Publisher

Subject

Description

Kanun: Jurnal Ilmu Hukum (KJIH), the Indonesian Journal of Autonomy Law, is an international journal dedicated to the study of autonomy law within the framework of national and international legal systems. Published thrice annually (April, August, December), KJIH provides valuable insights for ...