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Find out moreReal estate, construction, and hospitality are at the forefront of transformation across the Middle East – reshaping cities, driving investment, and demanding increasingly sophisticated legal frameworks.
In the June edition of Law Update, we take a closer look at the legal shifts influencing the sector – from Dubai’s new Real Estate Investment Funds Law and major reforms in Qatar, to Bahrain’s push toward digitalisation in property and timeshare regulation. We also explore practical issues around strata, zoning, joint ventures, and hotel management agreements that are critical to navigating today’s market.
As the landscape becomes more complex, understanding the legal dynamics behind these developments is key to making informed, strategic decisions.
2025 is set to be a game-changer for the MENA region, with legal and regulatory shifts from 2024 continuing to reshape its economic landscape. Saudi Arabia, the UAE, Egypt, Iraq, Qatar, and Bahrain are all implementing groundbreaking reforms in sustainable financing, investment laws, labor regulations, and dispute resolution. As the region positions itself for deeper global integration, businesses must adapt to a rapidly evolving legal environment.
Our Eyes on 2025 publication provides essential insights and practical guidance on the key legal updates shaping the year ahead—equipping you with the knowledge to stay ahead in this dynamic market.
On June 26, 2025, the Dubai Court of Cassation issued an important judgment in Civil Appeal No. 276 of 2025. The case dealt with the enforcement of a foreign judgment issued by the Court of Appeal in Riyadh, Saudi Arabia, within the United Arab Emirates. The judgment is significant as it clarifies the application of judicial cooperation agreements among the Gulf Cooperation Council (GCC) countries and addresses the issue of parallel enforcement procedures across member states.
Facts and Procedural History
The case originated when the appellant obtained a judgment from the Riyadh Court of Appeal ordering the respondent to pay a sum of money. The appellant then applied to the Dubai Execution Judge to have the Saudi judgment declared enforceable. An enforcement order was issued by the Execution Judge (the “Enforcement Order”) and an execution file was registered in the Dubai Execution Court to enforce the Saudi judgment. However, the respondent appealed the order, and the Dubai court of appeal decided to revoke the Enforcement Order on the grounds that enforcement procedures had already begun in Saudi Arabia and therefore, according to the appeal judgment, no parallel enforcement proceedings should be initiated in another jurisdiction concerning the same judgment.
Grounds of Appeal and Legal Arguments
The judgment creditor appealed to the Court of Cassation, arguing that neither the 1995 GCC Convention for the Execution of Judgments nor the 1983 Riyadh Arab Convention for Judicial Cooperation prohibits the enforcement of a judgment in more than one member state, as long as the judgment amount has not yet been recovered. The judgment creditor therefore argued that parallel execution efforts is permitted until the judgment amount is actually recovered, especially if the judgment debtor had moved asset to different jurisdictions to evade enforcement.
Reasoning of the Cassation Court
The Court of Cassation affirmed its settled position that international treaties ratified by the UAE form part of domestic law and take precedence over general provisions in civil procedure law. It further clarified that the 1995 GCC Convention is the more specific treaty in this context, taking precedence over the broader Riyadh Convention, to which both the UAE and the KSA are members.
The Court also emphasized that the GCC Convention does not prohibit parallel enforcement proceedings in more than one member state unless the judgment debt has already been satisfied. The focus should be on whether the creditor has actually received the amount awarded by the judgment in question, rather than on the mere existence of multiple enforcement proceedings t. Additionally, the court underlined that the role of the enforcing court is limited to verifying that formal requirements are met, without reviewing the merits of the original judgment.
Significance and Practical Implications
This judgment carries substantial legal significance in several respects:
Conclusion
This judgment serves as a key precedent in the enforcement of foreign judgments within the GCC, demonstrating the judiciary’s commitment to upholding international agreements in a way that furthers justice and prevents procedural abuse. It guides national courts to adhere strictly to treaty provisions and avoid imposing extra conditions, thereby strengthening legal certainty and fostering a reliable environment for individuals and businesses across the Gulf region.
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