This paper examines the condition of women in both Israel and Islamic countries, specifically their freedom to leave a marriage, and compares respective models. First, the study analyses the peculiar relationship between secular and religious law in Israel and Islamic countries. Second, it studies the nature of marriage as a contract in these legal systems, comparing a totally private approach and a mixed, public–private approach. Third, it analyses the possibilities of dissolution of marriage in such legal systems, indentifying some aspects of gender disparity. Finally it discusses some juridical tools offered in these legal contexts, which are intended to rebalance the exercise of a woman's freedom to leave a marital relationship and its conditions.