International Commercial Arbitration in the United Arab Emirates: A Look at Developments in Dubai, and Abroad
By Mahmoud Fadli
The United Arab Emirates has seen a massive economic boom in the past ten years, transforming the country from a sparsely inhabited desert to a modern concrete jungle. Surges in oil prices have allowed the nation to see unprecedented levels of growth, with the Emirate of Dubai seeing an almost relentless construction boom over the past ten years, helping the UAE become a regional business hub of the Middle East. This boom as attracted business from all over the world as they compete to establish distribution centers in the UAE to serve the region. With this boom comes its many challenges, one of which pertains to disputes between companies operating in Dubai. Many companies prefer arbitration as opposed to in-court litigation due to the lower costs, increased efficiency, and flexibility allotted to the parties in arbitration. This is especially true in the international business context where businesses are operating out of two different countries.
Given the nature of the growth in the United Arab Emirates, and the undeniable involvement of foreign investment that helped shape it, this paper will look briefly at Commercial Arbitration in the UAE as a whole. I will begin by giving the reader a brief historical overview of the United Arab Emirates, and then give a glimpse into the nation’s civil and Shari’a courts. The paper will then look at Arbitration in the two most powerful Emirates of the UAE: Dubai and Abu Dhabi, and will specifically look at the Dubai’s DIAC and DIFC-LCIA arbitration centers. Finally, the paper will analyze recent developments in the creation of the Takheem Sharjah International Arbitration Center in the Emirate of Sharjah, which began in 2009, and conclude with expectations for the future of the UAE in the realm of commercial arbitration.
The United Arab Emirates
To begin, it is important to know about the make up of the UAE. The United Arab Emirates consists of a federation of seven Sheikhdoms: Abu Dhabi, Dubai, Ajman, Al-Fujayrah, Sharjah, Ras Al-Khaimah, and Umm Al-Quwain. The Capital of the United Arab Emirates is Abu Dhabi, which is also geographically the largest sheikhdom in the Emirates. Consisting mainly of Muslims (96%), the UAE also has small minority Christian and Hindu populations, many of whom are foreign. The nation is bound by its constitution, which was first drafted in 1971, the same year the UAE was established.
The UAE signed and drafted a provisional constitution on July 18, 1971, with the constitution becoming final upon the passage of a constitutional amendment law in 1996. The UAE also joined the United Nations that same year. Allegedly modeled after the constitution of Kuwait, the Constitution of the United Arab Emirates establishes a “four-tiered constitutional monarchy,” lead by the Supreme Council of the Union (SCU). The SCU comprises of the seven Sheikhs (the leaders of each of the seven Emirates) who act as the final reviewers of proposed laws and amendments, and act to formally ratify laws. It is important to note that the chairman of the SCU is also the President of the United Arab Emirates. Below the SCU is the Council of Ministers, or the CoM. As the name implies, the CoM is, in essence, the cabinet of the UAE, and members of the CoM work with other councils to promulgate laws for the UAE’s Federal (or Union) Laws.
Below the CoM is the Federal National Assembly, or the FNA. The FNA comprises of a forty-member assembly and “performs an advisory function, undertaking non-binding reviews of bills tabled by the CoM.” Finally, there is the Judiciary, which is organized on three-levels and operates under the principles of both civil law and Shari’a law. As with a federation, there is the application of Federal Law (also called “Union Law”) and local law, and each Emirate has its own local court system that exercises “concurrent jurisdiction on matters outside the scope of federal law.” Of the seven Emirates, Dubai and Ra al-Khaimah are not yet part of the federal court system, and thus do not subscribe to the rulings of the federal courts. At the very top of the UAE judiciary is the Supreme Court of the Union, or SCU (hereinafter “UAESCU” to avoid confusion with the Supreme Union Council). Union laws and decrees emanate from the UAESCU and are binding upon the five fully subscribed Emirates of the UAE. In addition, where there is a conflict between Federal/Union law and local law, Federal/Union Law shall prevail.
Article 7 of the UAE Provisional Constitution declares Islam as the official state religion of the UAE and that Shari’a is the main source of law. Shari’a law, in essence, is law that is derived from the Islamic Holy Book, the Qur’an, and the examples in the life of the Prophet Mohammad, called Sunnah. Within Sunnah there is “hadith,” which is comprised of the sayings of the Prophet Mohammed. The Hadith is also considered a potential source of Shari’a, but this varies on the particular school of thought.
The Court System in Dubai: A Closer Look
A closer look at the Court System is Dubai is warranted before diving deep into the various arbitration mechanisms in place in the emirate. Dubai, the first emirate this paper will be focusing upon, has a “two-tiered court structure,” with the first tier being the Islamic, or Shari’a, Courts and the second being the civil courts. All commercial and financial matters, including all matters pertaining to banks, are within the jurisdiction of the civil court. Shari’a is thus subordinated to civil law in “the determination of civil matters.” This, however, does not mean that Shari’a is not considered by the civil courts when hearing matters. It is worth noting that Article 14 of the Dubai Courts Law of 1970 provides, inter alia, that a “judge of the civil court must exercise his power in accordance with… the provisions of the Sharia…”
While it is rare that a commercial dispute would ever, in the first instance, be brought before a Shari’a court, it is not impossible. If the laws of the emirate “were found to be silent (non liquet)” or if there were questions of public policy and order,” then there may be a chance that the matter would first arrive at a Shari’a court and not a civil court. A common example used to highlight this potential conflict is the concept of interest, known as “riba” in Shari’a. Many Islamic scholars believe, and as such Shari’a usually reflects, that interest on “sums lent or owed” is forbidden. If an arbitration award or a foreign judgment that contained interest was sought to be enforced in Dubai, problems of “public policy and order” may arise. This is important in the context of arbitration. With this brief overview of the court system, an overview of arbitration in Dubai and in the context of Shari’a is warranted.
Arbitration in Dubai
Arbitration in the Dubai is governed by the Federal Code of Civil Procedure, which was adopted in 1998. Despite amendments to the code in 2005, commentators noted that “the provisions that concern arbitration are not sufficient to prevent the default application of Shari’a principles by Dubai courts.” While Shari’a is open to arbitration, and by some accounts it actually encourages it, the requirements for arbitration under Shari’a law in Dubai are different than what is set forth in, for example, the UNCITRAL model rules.
For example, arbitrators under Shari’a must have the same qualifications as a judge, and must be an adult male Muslim and learned in Shari’a. Contrary to Western forms of arbitration, under Shari’a, the parties have limited powers to nominate arbitrators under Shari’a as it does not permit “party tailoring of the appointment process for arbitrators.” In addition, the powers of the arbitrator vary under Shari’a, which grants arbitrators broad powers to intervene in the course of the proceedings. Of the most concern is Shari’a only permitting arbitration agreements for disputes that are currently ongoing. While Shari’a is silent on agreements to arbitrate future disputes, many scholars have interpreted this silence as a prohibition. Thus, the practical implications of this are clear: Shari’a courts will not enforce contractual arbitration clauses that are meant to resolve future disputes. However, it is important to note that Shari’a nonetheless “treats agreements to arbitrate as being revocable until an award is rendered.” Whether this is a judicially created interpretation or simple practice is not clear.
Furthermore, choices of procedural law provisions are quite different under Shari’a. It is noted that “the same procedural and substantive laws applicable to Shari’a adjudication proper are mandatory in Shari’a arbitration.” This is at odds with Western theories and practices in arbitration that allow for the parties to have substantial say in whether they choose to apply foreign procedural and substantive laws to their dispute. Finally, some interpretations of Shari’a do not allow for arbitral rulings that affect third parties, which can be problematic. 
Arbitration in Dubai and the Federal Code of Civil Procedure
Despite the limitations in Shari’a law as compared to Western models of arbitration, the Federal Code of Civil Procedure, which is now in force in Dubai, does touch upon arbitration. The relevant code provisions are Articles 203 to 218. Under the Federal Code of Civil Procedure, an arbitration agreement must be in writing, evincing a “clear intention of the parties to submit any dispute arising out of their agreement…” to arbitrate. Moreover, UAE law does not recognize the authority of counsel to sign arbitration agreements on behalf of their clients; this has been often held to mean that “the parties must sign themselves if they are natural, or by the hand of their officers if they…” are corporate bodies. In addition, court orders compelling arbitration and stays are subject to appeal in the federal court system (through the Courts of Appeal) in both the UAE generally and in Dubai’s specifically oriented courts.
While the limitations above can be troublesome, the Federal Civil Procedure Code does allow for full party autonomy to appoint arbitrators. The failure of one party to appoint an arbitrator pursuant to an arbitration agreement will allow the other party to request the court to nominate for them or simply compel them to arbitrate. Furthermore, the code requires that arbitrators all be present at the hearings, sign hearing records and hear the arguments of the parties. Decisions are made by simple majority of the arbitrators.
Moreover, the code allows for court applications for removal of a particular arbitrator, usually on the grounds of bias, and the imposition of a six-month time limit on the granting of awards by the tribunal. This time can be extended by agreement of the parties. In addition, the powers of the arbitrator are conditioned upon the arbitration agreement itself, and thus the scope of the arbitrator’s powers is within the full discretion of the parties.
As with many civil law countries, UAE law “allows for limited discovery only,” though the parties are free to agree upon full discovery and “empower the arbitrator to make orders for the same…” With the arbitrator’s powers comes the ability to suspend proceedings until certain matters are determined by a local court. Such matters include document forgery, considered a criminal matter, or whether a “matter is capable of settlement through arbitration,” which may be a contractual issue (though sometimes, public policy considerations may play a part).
Disputes that can be Arbitrated and the Enforcement & Annulment of Awards
All awards that are handed down in the course of arbitration are subject to the Federal Civil Code. The requirements for a valid award are that it be signed by the arbitrator, state the facts of the dispute, the legal reasons for the decision, and that it must be dated and accompanied by the arbitration agreement itself. Moreover, the award and accompanying documents must be translated to Arabic if they were handed down in any other language.
An award may be annulled, however, only upon procedural grounds, which are listed in Articles 216 and 217 of the Federal Code. Reasons for annulment include awards that were made without an arbitration agreement, on the basis of an invalid arbitration agreement, where the arbitrator has exceed the terms of the agreement itself, where the appointment of the arbitrators was inconsistent with Federal Law, where the aware was made without a full panel of arbitrators, where a party lacked the capacity to execute the arbitration agreement, or where one or more of the arbitrators does not fulfill the legal requirements to hold the position. There are also vague grounds under Article 216(1)(C), stating that an award can be annulled if “something invalid in the ruling or in the procedures affecting the ruling” occurred during the arbitration. This has been known to cause considerable problems in ensuring the enforceability of awards handed down pursuant to valid arbitration clauses.
The common types of disputes typically arbitrated or send for alternative dispute resolution are put into a number of categories. There are ‘Time Disputes,’ which pertain to delays in construction projects which result in the imposition of liquidated damages and other compensatory measures. Moreover, ‘Quality Disputes,’ which pertain to the expected level of workmanship on certain projects, were commonly sent for ADR. Finally, payment disputes pertaining to compensation for work already completed were also commonly sent for ADR.
Foreign Judgments & Awards and their Enforcement
Before they can be enforced, awards rendered in the UAE must be “ratified,” offering the respondent an opportunity to “plead out its claim for annulment,” and show how the award offends the Federal Code. The same applies for foreign judgments, though an additional requirement is added: the dispute “must not have been within the jurisdiction of any UAE court at the time it arose.” If after review it appears that UAE courts did in fact have jurisdiction at the time that the dispute arose, foreign judgments will not be enforced. Even if the party can show that the dispute was not within the jurisdiction of any court in the UAE, the courts will still condition enforcement on proof of reciprocity. Moreover, the Federal Code prohibits contractual provisions that “conflict with the jurisdictional articles of the Federal Code,” meaning that any attempt to contract out of the jurisdictional requirement would be unenforceable.
As a result of these limitations, Dubai looked to alternative and creative solutions to ensure that arbitrations and their results are more predictable and in line with widely accept international standards. The solutions came in the form of the Dubai International Arbitration Center (DIAC) and the Dubai International Financial Centre’s partnership with the London Court of International Arbitration.
The Dubai International Arbitration Centre (DIAC)
First created in 1994, the DIAC was formed as “an independent arbitration institution with a Board of Trustees, the majority of whom are foreign and whose members are drawn from the ‘great and good’ of the international arbitration world.” The Centre boasts itself to be “an autonomous, permanent, non-profit institution” that “provides the regional and international business communities with an exclusive service at affordable rates.” The DIAC allows parties to settle national and international disputes under the DIAC Statute or in accordance to the rules agreed upon by the parties to the dispute. Moreover, Article 23(c) ensures that confidentiality is maintained throughout any and all arbitration proceedings.
By Decree No (11) in 2007, new rules were applied to the DIAC, and are considered to be “among the most modern and developed set of international arbitration rules due to their inclusion of best arbitration practices.” Institutions such as the International Chamber of Commerce (ICC) and the London Court of International Arbitration also follow similar rules, with the DIAC going further and incorporating examples from the UNCITRAL Model Law. Included is the authority for the arbitral tribunal to “make any temporary and urgent orders during an arbitration hearing when so requested by the parties,” which was considered a major development given that arbitrators did not have that ability in the past. Arbitrators are also given the ability to choose to conduct the arbitrations outside Dubai. Another advantage of the DIAC is that the arbitration is to be conducted in the language of the agreement unless provided for otherwise, and if the agreement itself is drafted in more than one language, the Executive Committee of the DIAC may select a language provided that the parties have not agreed otherwise.
These developments have made the DIAC an attractive venue for arbitration between local and international companies. Another key development in the Dubai with implications for the UAE as a whole is the Dubai International Financial Centre and its partnership with the London Court of International Arbitration. The DIFC-LCIA partnership will be reviewed in the next section.
The DIFC-LCIA Partnership
The DIFC was established in September of 2004 as “an on-shore international financial centre, occupying a 110-acre site in the heart of Dubai’s financial district.” The DIFC established its own legal and a regulatory framework as a result of it being independent of the UAE’s civil and commercial laws. The DIFC, essentially a free zone within the UAE, has a common-law-based legal system, making it an attractive venue for companies in the United States, the United Kingdom and other common-law countries. The rules are “based on a combination of civil and common law principles,” and are “tailored to meet the needs of dispute resolution at the DIFC.” Prospects of a reliable arbitration center in Dubai were further realized when the UAE ratified the New York Convention in 2006.
The DIFC boasts a “two-tiered” court system containing a Court of First Instance and a Court of Appeal. Judges are appointed by Decree of the Ruler of Dubai, and appeal’s court decisions are made by a simple majority. Unlike arbitration under the Federal Code, arbitration in the DIFC can occur without any physical connection to the DIFC. In other words, parties who wish to utilize DIFC arbitration services do not have to physically be in Dubai. However, to do so, the parties must specifically express their intention to arbitrate in the DIFC. For example, the DIFC Court of First Instance in 2009 considered “whether the seat of an arbitration was ‘onshore’ Dubai or the DIFC…” The arbitration clause of the contract in question stated that the applicable law was to be “the ‘laws of the Emirate of Dubai,’” and that the “’place’ of arbitration was ‘Dubai.’” The issue was whether the clause established the DIFC as the arbitral seat despite the fact that the very same clause stated that any dispute would be “resolved through arbitration conducted in accordance with ‘the DIFC-LCIA rules of arbitration…’”
Irrespective of the arguments presented by both sides, the Court of First Instance determined that the court must first determine the intention of the parties when the clause in question was drafted. After reviewing the clause and the evidence, the court determined that there was a connection between the clause and ‘onshore’ Dubai as opposed to the DIFC, and that any connection with the DIFC was minimal. The court also noted that the clause referred to “Dubai in several places, and in the dispute resolution clause referred specifically to the DIFC…” and that the parties were “not strangers to the idea of different jurisdictions within the Emirates and could have specified the DIFC as the seat had this been their intention.”
The important take away from this is while the DIFC-LCIA is an attractive venue for arbitration, it is best practice to explicitly state in the arbitration clause that the seat of the arbitration is to be the DIFC-LCIA. While it may be burdensome, the advantages of using the DIFC-LCIA are apparent. The partnership with the LCIA would allow for parties to choose from a list of highly reputable and certified arbitrators from both the DIFC and LCIA. With progressive rules, international partnerships with leading institutions, and the application of common-law within the boundaries of the DIFC, the DIFC-LCIA arbitration center will likely be a hub for arbitration between foreign companies in Dubai.
Abu Dhabi: The Abu Dhabi Commercial Conciliation and Arbitration Centre
The Abu Dhabi Commercial Conciliation and Arbitration Centre (ADCCAC) was established in 1993 by the Abu Dhabi Chamber of Commerce and Industry. Being a sub-branch of the Abu Dhabi Chamber of Commerce and Industry, the ADCCAC does not have its own arbitration law like the DIFC. Instead, the ADCCAC operates under the UAE Federal Code of Civil Procedure, and as a result suffers “significant drawbacks” in arbitral award enforcement. The Abu Dhabi Chamber of Commerce & Industry holds the responsibility of guaranteeing the “independence of its registered arbitrators in the performance of their duties.” The ADCCAC allows for arbitration clauses to be written prior to any dispute arising, with the rules stating that the “parties to a contract may agree to have disputes settled by arbitration under the ADCCAC Rules or hey may elect ADCCAC arbitration once a dispute has arisen,” which is advantageous over Shari’a, which does not permit such clauses.
Moreover, under the ADCCAC, the language of the proceedings is to be Arabic, unless the parties agree otherwise. However, even if the language is not specified, if one of the parties, or the arbitrators do not speak Arabic, another language will be selected. Unlike the DIFC, the ADCCAC Rules do not provide grounds for appeal, and instead limits resource to “applications for the annulment of an award under the UAE Law (civil Procedure Code).” While problematic, the ADCCAC is nonetheless been utilized by businesses belonging go the Abu Dhabi Chamber of Commerce for dispute resolution.
Tahkeem Sharjah International Arbitration Centre
In 2009, His Highness Dr. Sheikh Sultan bin Mohammed Al Wassimi, Ruler of Sharjah, issued Emiri Decree No. 6 establishing the Tahkeem Sharjah International Arbitration Centre. Like the ADCCAC, the Tahkeem Sharjah International Arbitration Center operates pursuant to the Federal Code of Civil Procedure. According to Article (26) of the TSICAC rules of arbitration, all arbitration proceedings are to be conducted in Arabic unless otherwise agreed to by the parties.
The stated objectives of the TSICAC are to resolve commercial disputes between natural or corporate persons through arbitration irrespective of membership in the Sharjah Chamber of Commerce, spread the culture of arbitration, and cooperate with local and international agencies and associations in arbitration related matters. As of August 2010, the centre had completed the third phase of its arbitrator-training program.
The United Arab Emirates is seeing growth on unprecedented levels. With more commercial interaction with international companies comes a greater potential for dispute. Given the benefits of arbitration in the international commercial context, the UAE over the past ten years has been working to “update” its mechanisms to enable foreign companies to feel comfortable arbitrating in the Middle East. The rapid growth of the country and the seemingly endless limits of the imaginations of its rulers have created magnificent cities and mega-projects that involve the cooperation of many international companies. The DIFC-LCIA partnership, the DIAC, ADCCAC and the TSICAC are all answers to the need to arbitrate instead of litigate, and to ensure that foreign investment and growth continue to be part of the UAE outlook.
 BBC News, “Dubai’s Relentless Construction Boom. “ <Available at: http://news.bbc.co.uk/2/hi/business/4506512.stm> (Viewed April 1, 2011).
 Karim J. Nassif, IBA Arbitration News, Country Development Africa and the middle East: Overview of Enforcement of Domestic and Foreign Arbitral Awards Under UAE Law, 15 No. 1. IBA Arb. News 77, 2010.
 Tom Pedreria, “Arbitration.” <Available at: http://alternative-dispute-resolution.lawyers.com/arbitration/Arbitration-and-Mediation.html> (Viewed April 3, 2011); (See also S.R. Luttrell, Choosing Dubai: A Comparative Study of Arbitration Under the UAE Federal Code of Civil Procedure and the Arbitration Law of the DIFC, 9 No. 3. Bus. L. Int’l. 254; stating “arbitration is now the preferred means of dispute resolution for international business.”)
 Shari’a literally means “the path,” and is used to refer to Islamic Law.
 United States Department of State, “The United Arab Emirates,” <Available at: http://www.state.gov/r/pa/ei/bgn/5444.htm> (Viewed March 29, 2011).
 BBC News, “Country Profile: The United Arab Emirates,” <Available at: http://news.bbc.co.uk/2/hi/middle_east/country_profiles/737620.stm> (Viewed April 3, 2011). The author also notes that you can practically fit all of the other emirates in the UAE in Abu Dhabi and have room to spare.
 United States Department of State, “The United Arab Emirates,” <Available at: http://www.state.gov/r/pa/ei/bgn/5444.htm> (Viewed March 29, 2011).
 S R Luttrell, “Choosing Dubai: A Comparative Study of Arbitration Under the UAE Federal Code of Civil Procedure and the Arbitration Law of the DIFC,” 9 No. 3 Bus. Int’l. 254, at 256 (September 2008).
 S R Luttrell at 257.
 Id. at 258.
 Id. at 260.
 Id. at 262.
 S R Luttrell at 262.
 Id at 263.
 S R. Luttrell at 264.
 S R Luttrell at 265.
 Id. S R Luttrell also notes that the code was amended in 2005 but that the draft Federal Arbitration law has yet to be adopted by the Union. Currently, The Federal Code of Civil Procedure as it was in 1992 remains in force as the lex arbitri in the UAE.
 Id. S R Luttrell notes that “UAE courts have refused to uphold arbitration clauses that were part o the fine print on general terms and conditions of contract, or on the back of invoices.”
 S R Luttrell at 267.
 Id., citing Article 204 of the Federal Code of Civil Procedure.
 Id. at 268.
 Id. at 269.
 Id. at 270.
 Id., citing Federal Code of Civil Procedure Article 212(i), (ii) and (iii).
 Id. at 272.
 Adrian Cole, “ADR Client Strategies in the Middle East and Africa: An Overview of Alternative Dispute Resolution in the United Arab Emirates,” 2009 WL 2966290 (September 2009).
 S R Luttrell at 272.
 S R Ruttell at 272.
 Id. S R Ruttell notes that the UAE “only has foreign civil judgments and enforcement agreements with its fellow GCC members, the states of the Arab League, India and France.”
 Id. at 273.
 Alec Emmerson, Christopher Mills, “IBA Arbitration Newsletter, The Changing Face of Arbitration in Dubai,” 13 No. 2. IBA Arb. Newsl. 44 (September 2008).
 DIAC, “About the DIAC,” <Available at http://www.diac.ae/idias/aboutus/.> (Last viewed April 10, 2011).
 Statute Rules of Dubai International Arbitration Centre, Article 3(2)(a).
 Hassan Arab, “IBA Arbitration News: The Road Ahead: The Future of Arbitration in the UAE,” 15 No. 1 IBA Arb. News 81 (March 2010).
 Id at 82.
 Id. at 83.
 Patrick Bourke, Dominic Hennessy, “IBA Arbitration Newsletter, Brighter Times – Developments in Arbitration in the United Arab Emirates,” 13 No. 2 IBA Arb. Newsl. 42 (September 2008).
 Id. at 43.
 Raid Abu-Manneh, “Dubai: A Regional Arbitration Centre?,” <Available at http://www.mayerbrown.com/internationalarbitration/article.asp?id=7383&nid=235> (Last Viewed April 12, 2011).
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 Hassan Arab, “IBA Arbitration News, The Road Ahead: The Future of Arbitration in the UAE,” 15 No. 1. IBA Arb. News 81, at 83.
 S R Luttrell, “Business Law International: Choosing Dubai: A Comparative Study of Arbitration Under the UAE Federal Code of Civil Procedure and the Arbitration Law of the DIFC,” 9 No. 3 Bus. L. Int’l 254, at 276.
 Id. at 277.
 Reza Mohtashami, “IBA Arbitration News, A Jurisdiction within a Jurisdiction: The DIFC as an Arbitral Seat,” 16 No. 1 Arb. News 129 (March 2011).
 Id. at 130.
 Mohtashami at 131.
 Hassan Arab at 84.
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 Al Bawaba News, “Sharjah International Commercial Arbitration Centre Completes third phase of training program for Sharjah arbitrators,” <Available at: http://www1.albawaba.com/news/sharjah-international-commercial-arbitration-centre-completes-third-phase-training-program-shar> (Last viewed April 13, 2011).