The Law of the Dubai International Financial Centre: Common Law Oasis or Mirage Within the UAE?

Development summary

This article considers the Dubai International Financial Centre (DIFC) as a parallel legal and judicial order based on common law and situated outside the Dubai and UAE federal systems. It addresses the requirement that DIFC decisions be deemed appropriate for enforcement outside the DIFC, the problems raised by references in DIFC law to Sharia-based national legislation and Sharia principles, and the likelihood that a commercially minded approach by the UAE Supreme Court would prevent DIFC legislation being struck down even if constitutionality were challenged.