On 13 September 2022, the UAE Ministry of Justice called upon the Dubai Courts to enforce judgments of the English Courts in the UAE. Judge Abdul Rahman Murad Al-Blooshi, Director of the International Cooperation Department of the Ministry of Justice, issued an official communication to His Excellency Tarish Eid Al-Mansoori, Director General of the Dubai Courts, confirming the enforcement of judgments in the UAE issued by English Courts based on the principle of reciprocity.

In the past, English Courts were historically reluctant to enforce UAE-issued judgments, and the UAE courts had for decades not applied the principle of reciprocity to the enforcement of English judgments. 

The English High Court’s recent decision in Lenkor Energy Trading DMCC v Puri (2020) EWHC 75 (QB), was an appreciated development. 

In this ground-breaking case, the High Court enforced a ‘bounced cheque’ judgment of the Dubai Court of Cassation. The High Court ruled that the Dubai judgment was a final and conclusive judgment of a court of competent jurisdiction and did not offend English public policy.

This important development assures creditors looking to enforce English Court judgments in the UAE. It is an encouraging development in terms of the ongoing judicial cooperation between the English and Dubai courts.

This will also open additional avenues for the enforcement of arbitral awards. Creditors of London-seated arbitral awards may now consider proceeding directly to the Dubai courts after enforcing their awards at the seat of the arbitration under section 66 of the Arbitration Act. 

In conclusion, the Dubai Courts will now recognize and enforce the London-seated arbitral awards in Dubai.

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