The ECJ has called the Sharia divorce between a couple living in Germany a 'private divorce' and so EU law is not applicable.
In England and Wales the Sharia divorce Talaq is separate to a civil divorce, and a civil divorce is required for the divorce to be legally recognised. I often find my clients choose to have civil divorce proceedings through the English court and then at the conclusion complete their Islamic divorce.
The financial remedies available to the couple can be different under the two different systems so it is important to get experienced legal advice at an early stage.
A couple in Germany who divorced in a Sharia court in Syria cannot have their divorce validated under EU law, Europe's top court has ruled. The European Court of Justice said member states must decide for themselves whether to recognise "private divorces", such as those performed in Sharia courts.