UAE Law and Practice Contributed by: Mohammed Alsuwaidi, Ali Alraeesi, Rajiv Suri and Merline Dsouza, Alsuwaidi & Company
which the public is able to access. However, the docu - ments involved in the cases and the documents of the parties are not disclosed. All judgments, decisions or orders of public cases can also be accessed through the DIFC Courts’ website. ADGM Courts The public can access cases if they know details such as the case number or the parties’ names. The ADGM Courts’ online list shows the start date of the case, but no other information. However, a copy of the judgment can be downloaded upon the closure of the case. 3. Foreign Judgments 3.1 Legal Issues Concerning Enforcement of The UAE is a signatory to several multilateral and bilat - eral treaties facilitating the reciprocal recognition and enforcement of foreign judgments. These include the Riyadh Arab Agreement for Judicial Co-operation, the GCC Convention on the Execution of Judgments, and bilateral treaties with France, India, China, Kazakhstan and the United Kingdom. In 2020, India formally recognised the UAE as a recip - rocating territory for civil judgments, covering both onshore and free zone courts. Foreign Judgments Before Onshore Courts Interestingly, in a recent judgment, which was deliv - ered on 17 March 2026 by the Telangana High Court in India in Civil Revision Petition No 480 of 2026, namely, Sri Naralasetty Pavan Chandra Nagoor v Sri Ravi Kumar Meruva, it was held that a money decree passed by the Sharjah Federal Court is fully enforce - able in India, and that an Indian judgment debtor can - not use the excuse that he “was not present” in the foreign court to wriggle out of paying up. While laying emphasis on the treaty signed with UAE, the Court upheld the order of the Sharjah Court on merits and directed the attachment and sale of the judgment debtor’s property in India[MD1.1][RS1.2]. Further, although the UAE-UK treaty initially excluded enforcement, a 2022 UAE Ministry of Justice memo confirmed that UK judgments are now enforceable
in the UAE under the principle of reciprocity, follow - ing the English High Court’s decision in Lenkor Ener - gy Trading DMCC v Puri. This case concerned the enforcement in England of a Dubai Court judgment arising from dishonoured cheques linked to oil trad - ing transactions, thus strengthening legal reciprocity between the UK and UAE. Thus, these treaties form a robust cross-border frame - work for the enforcement of judgments within as well The DIFC Courts have signed bilateral memoranda of guidance on enforcement with several foreign courts, including the High Court of England and Wales, the High Court of Hong Kong, the Supreme Court of Sin - gapore and the Federal Court of Malaysia to promote mutual understanding and co-operation in the recog - nition and enforcement of money judgments. The DIFC is bound by the treaties ratified by the UAE. Accordingly, the DIFC Courts conform to such trea - ties and enforce any such foreign judgments, orders or awards. In order to ensure enforcement of a foreign judgment, the following factors are to be considered: • the judgment must be final and conclusive, even though it is subject to appeal; • the DIFC Courts will not enforce certain types of foreign judgments (eg, judgments ordering the pay - ment of taxes, fines or penalties); and • the foreign court must have had jurisdiction to as outside of the UAE. Before Offshore Courts DIFC Courts determine the dispute, according to the DIFC Rules on the Conflict of Laws – the DIFC Courts will gen - erally consider the foreign court to have had the required jurisdiction only where the person against whom the judgment was given: (a) was present in the jurisdiction at the time when the proceedings commenced; (b) was the claimant or counterclaimant in the proceedings; (c) submitted to the jurisdiction of the foreign court; or (d) agreed to submit to the jurisdiction of the for - eign court before commencement in respect of the subject matter of the proceedings.
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