On 13 September 2022, the United Arab Emirates Ministry of Justice issued a letter, signed and sealed by the Director of the International Cooperation Department, to the Director General of the Dubai Courts which effectively directs the UAE courts to enforce judgments and orders rendered by the English courts (the Directive). The Directive confirms that the principle of reciprocity, historically being one of the most difficult hurdles for the enforcement of a foreign judgment in the UAE, has been established as between the UAE and the UK. The Directive follows a judgment the English High Court issued in the case of Lenkor Energy Trading DMCC v Puri (2020) EWHC 75 (QB), which enforced a debt judgment the Dubai courts rendered. The Directive concludes, “we kindly hope that, in the event of requests for the enforcement of judgments and orders rendered by the English courts, the requisite legal steps are taken in accordance with the laws in force in both countries, in order to consolidate the principle of reciprocity initiated by the English courts, and to ensure its continuity between English courts and UAE courts.”

While the Directive confirms that the principle of reciprocity has been established as between the UAE and UK, any judgment being enforced in the UAE must still comply with the other requirements provided for under UAE law (including, for example, that it must not conflict with any judgment or order already issued by a court in the UAE and must not include anything contrary to UAE public order or morals). The establishment of the principal of reciprocity between the UAE and UK is welcome news for parties (or potential parties) looking to enforce an English judgment against assets in the UAE.