Theoretical Development of an Islamic Finance Dispute Resolution Framework for the African Market: Lessons from Nigerian Practice and Comparative Models

The rapid growth of Islamic finance in sub-Saharan Africa, led by Nigeria's non-interest banking sector, has outpaced the development of specialised Islamic finance dispute resolution mechanisms, creating a framework gap that limits investor confidence and constrains Islamic finance market development across the continent. This study develops an original theoretical framework for Islamic finance dispute resolution suited to the African market, drawing on Nigerian practice, comparative analysis of established Islamic finance dispute resolution systems, and original Islamic jurisprudential principles. A multi-source theoretical methodology is applied, combining Islamic Tahkim jurisprudence, comparative institutional analysis of Dubai's DIFC-LCIA, the UK's Islamic Finance Arbitration Tribunal, Malaysia's Kuala Lumpur Regional Centre for Arbitration, and an empirical analysis of forty Islamic finance disputes from Nigerian courts and arbitration proceedings from 2015 to 2023. Structured interviews with twenty Islamic finance dispute resolution practitioners across Nigeria, the UAE, and Malaysia inform the practical design dimensions. The theoretical framework introduces three original concepts: the West African Fiqh Margin (acknowledging legitimate regional doctrinal variation), the Multi-Madhab Arbitration Protocol (enabling party selection of governing juristic school), and the Maqasid Interpretation Principle for ambiguous Sharia finance contract terms. The framework addresses arbitrator qualification, Sharia supervisory integration, award enforcement, and multi-state recognition within an African institutional architecture. Keywords: Islamic finance dispute resolution, Africa, Tahkim, Nigerian practice, theoretical framework.