What is the difference between a religious marriage in Toronto and a marriage in the United Arab Emirates?

Kanafani v. Abdalla, 2010 ONSC 3651, 89 R.F.L. (6th) 189, is similarly distinguishable from Alspector and the present case on its facts. In 2004, the parties were married in Toronto under Sharia law by an Islamic religious leader. They never obtained a marriage licence or registered the marriage. They subsequently attended before a judge in the United Arab Emirates (“UAE”). The focus of the motion for summary judgement was on the subsequent UAE ceremony, which the wife asserted resulted in a valid civil marriage. The motion judge found there was no intention to comply with Ontario law and concluded that “on the undisputed facts” the religious marriage was not valid under the Marriage Act. She held that the certificate issued by the judge in the UAE did not suggest a new valid marriage ceremony had occurred. Her conclusion was supported by the wife’s contradictory assertions about whether the UAE ceremony created a new marriage or merely registered the Toronto marriage.