自古以來,伊斯蘭教在馬來世界的傳播具有一脈相承的特徵,直至近代隨著政治環境的改變,促使印度尼西亞與馬來西亞走向不同的伊斯蘭道路。兩國雖然皆擁有為數眾多的穆斯林人口,但伊斯蘭勢力在政治上的發展卻大不相同,在印度尼西亞,伊斯蘭政黨並不受到多數人口的青睞,在馬來西亞,各政黨爭相揮舉伊斯蘭大旗。 兩國政府態度雖然不一,但面對實施伊斯蘭法的司法議題卻有著相同曖昧不明的反應。世俗法律與審判制度仍然是主流,伊斯蘭法律與審判制度被侷限在私法領域裡。本論文將從歷史、政治與法律的角度,觀察兩國伊斯蘭法的過去、現在與未來。 Since ancient times, the spread of Islam in the Malay world shares same origin, until modern times as the political environment, to promote Indonesia and Malaysia to the different Islamic way. Although the two countries have a large number of Muslim population, but the Islamic forces in political development was very different. In Indonesia, the Islamic parties are not favored by the majority of the population. In Malaysia, main parties competed for leading power of Islamic issues. Although the two governments have different attitude, but in the face of Islamic law have the same legal issue is ambiguous reaction. Secular law and justice system is still the mainstream, Islamic law and the justice system was limited to private law field. This thesis will use historical, political and legal perspectives, observe Islamic law between past, present and future.