Annotation

The article analyzes the institution of appeal against judicial decisions in criminal procedure of Islamic legal systems. The hybrid nature of this institution, formed at the intersection of the religious-doctrinal logic of Sharia and borrowed secular procedural forms, is examined. Historical and doctrinal foundations, including the absence of the appeal institution in classical fiqh and the priority of doctrinal supervision, are considered. Special attention is paid to the influence of the classification of crimes (hudud, qisas, tazir) on the review procedure. Based on a comparative analysis of the models of Iran, Saudi Arabia, Pakistan and the United Arab Emirates, typological features and systemic problems of implementing the right to appeal are identified.