Editing Waqf (section)

==Comparisons with trust law==
The ''waqf'' in [[Sharia|Islamic law]], which developed in the [[Islamic Golden Age|medieval Islamic world]] from the 7th to 9th centuries, bears a notable resemblance to the English [[trust law]].<ref>{{Harv|Gaudiosi|1988}}</ref> Every ''waqf'' was required to have a ''waqif'' (founder), ''mutawillis'' (trustee), ''[[qadi]]'' (judge) and beneficiaries.<ref>{{Harv|Gaudiosi|1988|pp=1237–40}}</ref> Under both a ''waqf'' and a trust, "property is reserved, and its [[usufruct]] appropriated, for the benefit of specific individuals, or for a general charitable purpose; the corpus becomes [[Inalienable rights|inalienable]]; [[Estate (law)|estates]] for life in favor of successive beneficiaries can be created" and "without regard to the law of [[inheritance]] or the rights of the heirs; and continuity is secured by the successive appointment of trustees or ''mutawillis''."<ref>{{Harv|Gaudiosi|1988|p=1246}}</ref>

The only significant distinction between the Islamic ''waqf'' and English trust was "the express or implied reversion of the ''waqf'' to charitable purposes when its specific object has ceased to exist",<ref>{{Harv|Gaudiosi|1988|pp=1246–7}}</ref> though this difference only applied to the ''waqf ahli'' (Islamic family trust) rather than the ''waqf khairi'' (devoted to a charitable purpose from its inception). Another difference was the English vesting of "legal estate" over the trust property in the trustee, though the "trustee was still bound to administer that property for the benefit of the beneficiaries." In this sense, the "role of the English trustee therefore does not differ significantly from that of the ''mutawalli''."<ref>{{Harv|Gaudiosi|1988|p=1247}}</ref>

Personal trust law developed in England at the time of the [[Crusades]], during the 12th and 13th centuries. The Court of Chancery, under the principles of equity, enforced the rights of absentee Crusaders who had made temporary assignments of their lands to caretakers.  It has been speculated that this development may have been influenced by the ''waqf'' institutions in the [[Middle East]].<ref>{{Harv|Hudson|2003|p=32}}</ref><ref>{{Harv|Gaudiosi|1988|pp=1244–5}}</ref>