Enforcing Foreign Judgements in U.A.E.: A Successful Case Study

In today’s interconnected world, legal obligations often transcend borders.  Recently, a significant case demonstrated how an American judgment was successfully enforced in the United Arab Emirates (UAE), showcasing the UAE’s legal system’s adaptability and adherence to international legal principles.



The case began when an American state court issued a judgment against an individual who subsequently relocated to Dubai and became a resident.  Seeking justice and repayment, the claimant initiated proceedings in Dubai Courts to enforce the American judgment.



The client filed the case at the Court of First Instance in Dubai, but the court rejected the enforcement claim.  The primary reason for this rejection was the absence of a bilateral treaty between the United States and the UAE concerning the mutual recognition and enforcement of judgments.  This decision highlighted a common challenge in international law: enforcing foreign judgments without a specific treaty in place.



Undeterred by the initial setback, the client appealed the decision, relying on Article 222 of the UAE Civil Procedures Law.  This article provides a pathway for recognizing and enforcing foreign judgments even in the absence of a bilateral treaty.  According to Article 222, the UAE can enforce foreign judgments if certain conditions are met, including:

1.      The foreign judgment must be final and binding.

2.      The judgment should not contradict UAE public policy or Islamic Sharia law.

3.      The foreign court must have had proper jurisdiction over the case.



The client’s appeal was based on the argument that the judgment fulfilled all the criteria outlined in Article 222.  The appellate court reviewed the case thoroughly, focusing on:

  • Finality and Binding Nature. The American judgment was final and had no pending appeals.
  • Public Policy.  The judgment did not violate any UAE public policy or principles of Islamic Sharia law.
  • Jurisdiction.  The original court in the United States had proper jurisdiction over the matter.

The Dubai Court of Appeal agreed with the client, overturning the initial rejection.  The appellate court clarified that a bilateral treaty is not mandatory for enforcing foreign judgments in the UAE and that Article 222 of the UAE Civil Procedures Law applies in the absence of such a treaty.


The case eventually reached the Cassation Court, the highest judicial authority in the UAE.  The Cassation Court affirmed the appellate court’s decision, confirming that the absence of a treaty does not preclude the enforcement of foreign judgments.  The Dubai Courts emphasized that the UAE Civil Procedures Law provides sufficient legal grounds for such enforcement.


With the Cassation Court’s ruling, the client successfully enforced and collected on the American judgment in Dubai.  This outcome not only brought justice to the claimant but also set a significant legal precedent for future cases involving the enforcement of foreign judgments in the UAE.


1. Persistence Pays Off.  Despite initial setbacks, persistence and a solid understanding of local laws can lead to successful enforcement of foreign judgments.

2. Article 222.  This provision is crucial for enforcing foreign judgments in the UAE, providing a legal framework even in the absence of bilateral treaties.

3. Judicial Adaptability.  The UAE judiciary’s willingness to apply international legal principles ensures justice is served across borders.


The successful enforcement of an American judgment in the UAE highlights the country’s commitment to upholding international legal standards.  This case serves as a guiding light for individuals and entities seeking to enforce foreign judgments in the UAE, demonstrating that with the right legal strategy and a thorough understanding of local laws, justice can indeed be achieved across borders.

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