Choudhri obtained a Talaq divorce in Pakistan without Azhar’s knowledge; the Texas Supreme Court later rejected its recognition over lack of notice and due process
WASHINGTON DC: The Texas Supreme Court has rejected a Houston businessman’s attempt to secure recognition in Texas of a “secret” Sharia divorce obtained in Pakistan, holding that his estranged wife was not given adequate notice or a meaningful opportunity to participate before the divorce was finalised.
The ruling, issued on October 2, 2026, brings a major development in a nearly decade-long divorce dispute involving Mohammad Ali Choudhri and Hira Azhar, with more than $100 million in marital assets at stake.
According to court records, Choudhri obtained a divorce in Pakistan in 2013 while Azhar was there for visa-related matters. The divorce was conducted under a procedure described in the record as Talaq, associated with Islamic Sharia law.
Azhar has maintained that she did not know that the divorce had been initiated or completed and discovered it only about two years later. The dispute eventually moved into the Texas courts, where the question became whether the Pakistani divorce could be recognised despite the circumstances surrounding notice.
The Texas Supreme Court did not rule that foreign divorces or Islamic law-based proceedings can never be recognised in Texas. Instead, the justices focused on due process and whether Azhar had received sufficient notice of the Pakistani divorce proceeding. The court concluded that the circumstances did not provide her with the opportunity to be heard that Texas law requires before a foreign judgment can be given effect in the state.
The case has drawn attention because it involves the intersection of a foreign divorce, Talaq, Islamic Sharia law and Texas family law. The central issue was not simply the religious character of the divorce, but whether the manner in which the Talaq divorce was obtained satisfied the procedural standards required for recognition by a Texas court.
According to information cited in the case, Talaq can permit a husband to initiate divorce without requiring the wife’s consent. Descriptions of the Islamic law procedure cited in the dispute state that the husband makes declarations of his intention to divorce, followed by a waiting period before the divorce becomes final.
The precise requirements and practices surrounding Talaq can vary according to interpretation and jurisdiction, but the Texas Supreme Court focused on whether Azhar was actually informed about the proceeding.
Court records indicate that Choudhri’s documented effort to notify Azhar involved publication in a Pakistani newspaper for five days. Azhar said she did not see the notice and only learned about the divorce approximately two years later. The Texas Supreme Court found that publication in a single newspaper did not constitute sufficient notice under the circumstances.
The justices also questioned why other possible methods of communication were not used. The court referred to potential communication through telephone calls, text messages, email or mutual acquaintances. In its reasoning, the court warned against litigation strategies that could effectively prevent a defendant from discovering proceedings that could significantly affect her legal rights.
The ruling therefore places due process at the centre of the dispute rather than making a broad determination about Islam, Islamic law or Sharia itself. The court cited an earlier principle that international judgments should not be recognised when they are issued without due process or conflict with Texas public policy.
The dispute between Choudhri and Azhar dates back to their arranged marriage in Pakistan in 2008. Azhar was 18 and Choudhri was 28 when they married. Choudhri, a United States citizen who had lived in the Houston area since childhood, remained in the United States while Azhar worked through the visa process.
Azhar joined Choudhri in Houston in 2010. During their marriage, the couple accumulated more than $100 million in community assets, according to the court record. The substantial marital estate became a major component of the subsequent divorce litigation.
In 2013, Choudhri sent Azhar to Pakistan in connection with renewal of her visa. While she was there, he pursued the Talaq divorce, which was finalised in May 2013, according to the Texas Supreme Court opinion. Azhar later alleged that she had suffered physical and mental abuse during the marriage, allegations contained in the court record.
Azhar returned to Houston in 2015 and subsequently initiated divorce proceedings in Harris County. The Texas trial court recognised the Pakistani divorce and declined to award Azhar a division of the marital estate. The decision was later upheld by a Texas appeals court.
The lower-court decisions effectively gave legal effect in Texas to the Pakistani divorce and its consequences for the marital property dispute. The case therefore raised questions not only about recognition of a foreign divorce, but also about whether principles applied in the Pakistani proceeding could determine property rights that would otherwise be addressed under Texas law.
The Texas Supreme Court has now reversed those decisions. The justices determined that Azhar had not received proper notice and therefore had not been given a genuine opportunity to participate in the Pakistani proceeding.
The ruling comes amid a wider political debate in Texas over Sharia and the application of Islamic law in the United States. Texas Republican leaders have criticised what they describe as the implementation or recognition of Sharia law within the state. The supplied account states that 95 percent of voters participating in the March 2026 Republican primary supported a statewide prohibition.
The Choudhri-Azhar case, however, was decided on procedural grounds. The Texas Supreme Court did not base its decision simply on the fact that the divorce involved Talaq or Islamic Sharia law. Instead, it determined that the Pakistani judgment could not be recognised because Azhar lacked adequate notice and an opportunity to be heard.
The court stressed that a foreign judgment cannot automatically override fundamental requirements of Texas justice. It also indicated that Azhar should have the opportunity to pursue her divorce and related claims under Texas law rather than being denied access to those proceedings through recognition of a foreign divorce obtained without adequate notice.
For Azhar, the decision reopens the dispute over the couple’s marital estate and the legal consequences of the Pakistani divorce. For Texas courts, the case establishes the importance of due process when determining whether a foreign divorce, including one obtained through a Talaq procedure under Islamic Sharia law, should receive legal recognition.
