In their paper Classical Islamic Law and Modern Bankruptcy (2010), U.S. editor Abed Awad and his co-author Robert E. Michael compares bankruptcy in classical Islamic law to American bankruptcy pre and post the enactment of Chapter 11. Bankruptcy in classical Islamic law is “strongly analogous to the traditional civil and common law treatment of bankrupts prior to the enactment of Chapter 11,” as the latter turned the purpose of bankruptcy law from repayment to business rehabilitation. They go on to conclude that it is possible for this same change to happen in a sharīʿa-compliant way. Read more.
Awad, Abed and Michael, Robert E. “Iflas and Chapter 11: Classical Islamic Law and Modern Bankruptcy.” The International Lawyer, Vol. 44, No. 3 (FALL 2010), pp. 975-1000