<![CDATA[Introduction to the Problem: Polygamy presents a profound challenge in private international law because national legal systems classify it differently. While some jurisdictions recognize it as a conditional marital arrangement under religious or customary law, others categorically prohibit it as a violation of public order (ordre public). This legal fragmentation generates significant conflict in cross-border family disputes concerning marital status, inheritance, and social security. Purpose/Study Objectives: This article moves beyond the reductive Islamic-Western dichotomy by proposing a nuanced four-tier classification of legal systems based on their regulatory tolerance toward polygamy. It examines how public order functions not as a rigid barrier but as a dynamic, context-sensitive filter that balances state sovereignty with the protection of individual rights acquired abroad. Design/Methodology/Approach: The study employs a comparative legal methodology grounded in doctrinal analysis and case-law synthesis. Twelve jurisdictions were initially screened to map regulatory patterns, with four representative systems (France, Morocco, Canada, and Saudi Arabia) analyzed in depth alongside illustrative examples from Indonesia, Tunisia, the Netherlands, and the United Kingdom. Primary sources include statutory texts, landmark judicial decisions, and peer-reviewed literature. The analytical framework proceeds through four stages: (1) mapping domestic status, (2) identifying conflict-of-laws rules, (3) assessing public-order exceptions, and (4) evaluating the recognition of civil effects. Findings: The analysis reveals four regulatory models: (1) fully prohibited systems (e.g., France and Tunisia), although France may recognize limited effects in particular cases; (2) systems permitting polygamy under strict judicial control (e.g., Morocco and Indonesia), where domestic permission may face non-recognition abroad; (3) systems permitting polygamy with minimal restrictions (e.g., Saudi Arabia and Sudan), which integrate it into local public order; and (4) partially tolerant or effects-based systems (e.g., Canada, the Netherlands, and the United Kingdom), which restrict domestic formation but may recognize maintenance, pension, or inheritance consequences. This typology shows that public order operates as a calibrated filter rather than a monolithic prohibition. Paper Type: Research Article]]>
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