Legal Insights | Episode 1 | UAE Legal Systems: Common Law vs Civil Law

[MUSIC] Welcome to another episode of Legal Insight, focusing on onshore litigation proceedings in the UAE. My name is Shereef Meher, I'm a partner, having the onshore litigation practice of Clydenkoe in the UAE. In this episode, we will be discussing the general characteristics of the UAE legal system, a system that is often described as unique. Not only in the region, but internationally also. It is unique in that it has two different legal systems operating in parallel and has lawyers from different backgrounds and jurisdictions, acting as legal consultants with both UAE lawyers and international law firms working hand in hand to serve clients in the legal market. The UAE is fundamentally a civil law jurisdiction heavily influenced by Egyptian legal codification, which itself is inspired from the French legal system and to some extent from the principles of Islamic Sharia. These frameworks sit side by side with civil law governing private and commercial matters, and Sharia retaining a central role in areas such as family law, inheritance, and personal status. At the same time, the UAE also hosts common law courts in the DFC and the ADGM, which apply common law principles. So we have within one country or one jurisdiction two parallel systems, the civil law and the common law system, each with its own judiciary, procedure, language of proceedings, and judicial culture. Today, we are joined by practitioners from the slide and code to buy work across the system. Some trained in civil law jurisdiction, some in common law jurisdiction, and some qualified in both jurisdictions. We'll be exploring how the systems interact where they diverge, and what this means in practice for clients and disputes. I would like to welcome what has today, Ty Scott, senior associate in Clyde and Co, and the commercial arbitration and litigation team, Mohmyn Eilwen, an associate in Clyde and Co, Dubai, and Abdel Mejid, Al Salus, a litigation specialist in Clyde and Co, Dubai. After Mugid, I know you have a number of questions to Ty, Mohmyn, and myself. I'll let you go ahead with all your questions. Yes, Sharif, thank you so much. Actually, since you touched on how the UAA system blends on so many influences, I'll start the first question by addressing it to you. Can you walk us through how the civil law system is structured, especially when it comes to the federal and the local courts? Yes, absolutely. So the UAA is a unique system, and that it has two separate systems, the federal judicial system, which is controlled by the federal supreme court, and the local judicial system at the local government level. The UAA Constitution allows each Emirate to have its own judicial authority, and the Emirates of Sharja Fugera, Umil Khwein, and Ajman remain part of the federal judicial authority, but the Emirates of Abu Dhabi, Dubai, Sharja, and Rathul Khaym, I have set up their own judicial authority. The Constitution provides that there are some disputes that must be heard at the federal level and not at the local level, and other disputes can be heard at the local level. So the articles 99 and 102 of the constitution determines what must be necessarily heard by the federal court. So I mentioned there are two systems, the local courts, so the local unsure courts handle the vast majority of cases in the Emirates, and they operate at three, at a three tiered level. So there is first the court of first instance, which has jurisdiction over all civil, commercial, administrative, labor, and personal status cases. Then there is the court of appeal at the local level, which is the second stage of the proceeding and which reconsideres the case in facts, but also in law. Finally, the highest degree of appeal is before the court of castration, which only considers legal arguments. So the court of castration does not reconsider the fact. It considers whether the lower court, so the court of its instance and the court of appeal, have correctly applied the law to the facts of the case. Next to the local unsure courts, there are the federal courts. So the UAE federal court system has jurisdiction over disputes involving the federal government and individuals, as well crimes and personal status action that arise in the federal capital. And also similar to the unsure, the local unsure courts, if there are three different degrees. So first, there is the federal court of first instance, there is then the federal court of appeal, which is the second tier of the second stage of the proceedings. And finally, there is the federal supreme court, which is the highest judicial authority at the federal level with a final and binding judgments. It's also, it's important to note that the federal supreme court also handles disputes between Emirates and constitutional challenges. I would also add that within the court structures themselves, there is the administrative division, which is the circuits within the courts. So you have the courts within the courts, there is the administration division where the different circuit would consider a person's status matters, another would consider criminal matters, another civil matters, and another one would consider, for example, the administrative matters. And I think this is common to the region and it's made in one way or another to ensure that the judges, which are being assertive disputes, are specialists in this type of dispute. Well, actually, that's quite interesting, which is also, Sharjah now has its own jurisdiction, even though it used to fall under the federal court system previously. But at the same time, we can still see that they are still operate within one broader judicial framework alongside with each other. Sharif, now the UAE legal framework didn't develop in isolation. It was influenced by several civil law jurisdictions, especially Egypt. Could you let us know how significant is the influence of the Egyptian civil code and broader European civil law traditions on the UAE legislation? Yes, absolutely. The inference of the Egyptian civil code on UAE legislation in general is highly significant. When the UAE was developing its legal framework in the 70s, it was inspired from the Egyptian system because at the time Egypt had already produced a modern, codified legal system that successfully blended European civil law principle, particularly civil French law, with Islamic legal concepts. So many of the drafters of the UAE civil code at the time were in fact Egyptian jurists and scholars invited to assist in the legislative process. So as a result of that, much of the structure, terminology, and legal reasoning in the UAE civil code mirrors the Egyptian civil code. But Egypt itself was influenced by the continental European system, especially the French Napoleonic code. So the UAE effectively inherited a European civil law tradition filtered through the Egyptian legal experience. And we can see the influence in several areas. So for example, in contract law, which stresses on codified obligation and the general principle rather than case-based rules. We see also the influence in tort and liability, where the concept of wrongful act liability is very similar to the provisions of the Egyptian civil code. And finally, in property and commercial right, which are codified and very also very similar to the Egyptian civil code provision. The system is however not purely European and the UAE incorporates Sharia-based provision, particularly in personal status, inheritance, and in some instances in commercial moral obligation. So the result is really a hybrid civil law system, which is European in structure, Egyptian in spirit, and in language, and doctrine, and grounded in Islamic legal values when relevant. Actually, interesting. And especially when you came across the Sharia point, one of the unique aspects of the UAE system is the integration of the Sharia principle within the civil framework. Movement and practice, where do Sharia principles most directly influence legal outcomes today? Yeah, so Sharia, as you know, is a principle source of law in the UAE legal system. So in article one of the civil code, it through apply Sharia in absence of an expressed provision of law. And if you look at the civil code from article 29 to 70, the section itself is titled "Princivils from Elfak" which is Sharia, Sharia. And those principles are mostly taken from a Megal al-Adlayah, which is the op-man codified law of the Sharia. But now a day Sharia is as much more limited, it's more of a limited application in the UAE. And we see it mostly in frist status matter, inheritance, which Sharia is when it's made so so so far. You still see it in criminal law, although the stoning and flogging was where it moved entirely from the penal code, but you still have a daya or blood money, which is a Sharia principle. In terms of the commissary transactions, there is a general provision of exploitation, which is taken from a Sharia. And you have it codified in the abuse of rights law. And you have it in the abuse of rights principle. And you have the general principle in Sharia where transaction should be further between the parties. And this is also in the good-faced principles of the civil code. There are some some principles which still apply as well. You have the provision of of Mysir or Gamling. You have the provision of the contractual outcomes which are based on lack of knowledge which is to Elgarar, which is like the feature contracts. Although the feature contracts are regulated in the context of trading. You have the the issue of the charging of interest. So according to Sharia, money is not a commodity. So it cannot be traded nor it does it does have a value over time if left unused. So principle of the provision of interest is still there. However, this is the changing and the courts now are starting to permit interest for banks and for drippments at a fixed rate. So what mean would you would you say that the Sharia principle still still have a strong influence on cost decision nowadays? So I would say like it's not like explicitly like having a strong influence but it is still in the coded sense like the general principle. So they have the the principle which is like for example something like Estopelo which is a common octopus. It's still in Sharia and you can find it in the civil code as well. So in some instance, yeah, it does influence but the strong Sharia like the perception of like the strong Sharia or the vlogging, stoning and like the provision of alcohol and all of these things. This is not clearly existing nowadays. Thank you, moment. Now moving from the substantive side of the law to its procedures, the UAE civil courts have their own unique way of handling cases. Sharia, I'll come back to you as well about if you could please let us know what are some procedural elements of the unsure UAE civil law system? Yes. So there are several characteristics about the UAE civil system. So first of all, one of the most important characteristics is that the proceedings are inviting. So the UAE as we've discussed is a civil law system. So the procedures rely largely on written submissions rather than oral advocacy. Hearing sent to be brief focused on submitting documents rather than lengthy courtroom arguments as is the case in common law system. The second characteristic I would say that there are judges not juries. So cases are decided by a panel of judges, judges take an active inquisitorial role they can ask questions to the parties direct the parties to provide additional documents, appoint experts and guide generally the the progression of the case. Also another characteristic is a codified law over over presidents and that's something that we discuss so courts primarily rely on statutory provisions of the civil code and other legislations. And judicial precedents can be persuasive but they're indefinitely not abiding and maybe used for guidance but the text of the law will have priority and will remain binding. Another characteristic is the the limited role of the oral advocacy. So lawyers typically do not cross examine witnesses in open court and evidence is usually presented in documentary form with factual dispute often being resolved through court appointed expert rather than adversarial examination. So we've mentioned court appointed expert that's usually central in court proceedings in the UAE. So in technical, financial or complex commercial matters court usually and frequently appoints independent expert to investigate facts review evidence and provide reports to the judge. The experts finding are not binding to the court but they are highly influential in the court's final decision. Another important characteristic is generally the procedural time frame. So hearings before the onshore UAE courts often occur in short intervals and cases progress through multiple short hearings rather than one single hearing. Then the another characteristic is obviously the language of the proceedings. So in onshore courts proceedings and documents are usually conducted in Arabic although the Abu W. courts in specific circumstances now allow the proceedings to be conducted in English but generally the principle is that the proceedings are conducted in Arabic and in such cases the parties must translate the contracts, submissions and evidence into Arabic through certified legal and translation. The last point I would say in relation to the characteristics of the UAE proceedings is the appeal. So there is a possibility to appeal both in fact and in law before the court of appeal. So there is a retrial of the case before the court of appeal and then a final appeal before the court of castration which is sort of the the guardian of the law and the the court that makes sure that ensures that the lower courts have correctly applied the law to the facts of the case. And applied from your perspective how do these procedures compare with those typically followed in common those jurisdictions? Abdul Majid they are similar. We have a adversarial system where as Shariaf has mentioned evidence is investigated not by the court through an expert but through the parties. They then place evidence before the court and test that evidence using an adversarial process either through argument or cross examination. We also do have typically provisions for an appeal and there's also in some jurisdictions, distinctions between appeals as a matter of fact as well as appeals as a matter of law with some of the higher apex sports any dealing with legal issues. If we look beyond the UAE many of our listeners are very familiar with the common law model use in the other countries. Moment since you are qualified in both jurisdiction the civil and the common law. How do proceedings and decision making processes in the UAE court compare to those in common laws or jurisdictions? Thank you Abdul Majid I mean I assume when you say your courts you mean onshore courts because the ADGM and the FC courts are both unit courts. So on on this assumption I will try to beef up like a very big comparison between the proceedings. So as truth said like the proceedings before their onshore courts are memorial style and the judge would depend mainly on the written submissions and the documents presented to the court. And the order advocacy is very limited and examination and cross examination is simply inexistent and only the judge can direct questions with us. So unlike the common law system the judges role in onshore courts is equatorial so the judge has an active role in the proceedings and does not only act as an arbitrator between the parties argument. And of course like we have seen cases where the judge would make a different analysis from the case argued to the parties as long as the judge doesn't issue a judgment for something that none of the parties have asked for. Before the onshore courts disclosure is very limited so the parties are not expected to disclose the documents that might harm their case unlike in common law system although the judge can still order a party to disclose the certain documents. And the main feature of the onshore court system is the coast allocation so the coasts that are awaited to any of the parties are minimum and do not cover the act record. And other than the procedures in terms of the law the UE has a codified legal system and the presence of the court although an influence of judge is not by or not binding and unlike the common law courts the onshore courts can read a different conclusion for treaty judgments. So yeah in terms of the influence that the common law principles had on onshore courts there are many examples that you can see for example the parties now tactically in the onshore court proceedings rely more on private expert reports just like in common law proceedings. And of course while there is no binding precedent in the civil law system and the onshore courts there is a newly introduced reconsideration procedure for judgments that are issued by the court of causation. And this can be a first step for setting a system of binding precedent or if the court of causation issue adjudgment contradicts the adjudgment from the notification principles circuit this can be reconsidered. And even in the arbitration procedures like the UE onshore arbitration law adopts many more unilateral model of concepts which are like something like due process, tribunal powers and the issuance of partial awards which is a blend of civil and common law influences. In the procedure there is doubt for example the management process where the the procedure of the case management process before the case is referred to succumbent court. This is purely a common law concept and it is now working in the UE and it's very unique to the UE compared to the other jurisdictions in the region. And even the for example in terms of like if you look at the mediation now in some cases the parties are required to mediate before the case is being placed before the court. And mediation has been in the CPR in the UK for a while now and it's very common and common law systems but it's very uncommon in civil law systems. Over the last few years we've seen several legal reforms and updates across the UAE. Sheriff's sense I believe you've been practicing in Dubai for more than 15 years. What would you say are the most significant recent changes in the UAE laws and what procedures? Absolutely I mean you you correct dimension it there has been significant legal reforms in the UAE and specifically starting from 2021 with the introduction and the amendment of more than 30 legislation. The most significant ones are the civil procedure code, the commercial code, the data protection law, the bankruptcy law, commercial agency law, corporate tax law and more recently the central bank law. So the intention of all these reform is to modernize the legal system and obviously attract foreign investors by making it easier for them to enter the market and to have the necessary protections to protect their investment. We've seen also next to those reform or in parallel to those reformed significant changes before the courts which facilitate the proceedings before the courts. So one of those important changes is the digitalization of the courts or the courts have implemented advanced digital systems which has drastically reduced the timeline of court proceedings and what used to take months or years can now be completed and sometimes weeks are just a few months. There is also the possibility to have remote hearings. Most of the hearings before the courts are now conducted remotely which is obviously faster and more efficient. The important change before the court as well is the really in general the pro arbitration trend of the courts in the UAE which recognize and enforce both domestic and international arbitration award. Finally, Mormon has mentioned the role of the experts, the court appointed experts, an important change that has happened recently is that international experts such as for example members of international auditing companies can now be registered as court appointed expert which raises the standard that is expected from court appointed experts. And actually, should you just add a quick point for my side as well. It's interesting also to see how Abu Dhabi courts are now accepting submissions and English instead of the Arabic only. Absolutely, you're absolutely right and that's obviously another step that's taken to accommodate investors who are not necessarily familiar with the Arabic language and where the documents or contracts are concluded in English. So it actually limits the cost of the proceedings if you're submitting documents in the original language in which documents were produced. Thanks, Fyrif. And finally before we move to that to discuss on the common law system, I'd like just to ask about the practical side of working here in UAE. What are the challenges in working in jurisdictions such as the UAE from your perspective? So I think we mentioned in general, so the UAE is a civil law jurisdiction inspired from the Egyptian system which for me as an Egyptian qualified lawyer makes it easier. However, as we will discuss in this post-calf, and as I mentioned at the beginning, the UAE has a dual legal system, the onshore legal system before the onshore local courts, but also the offshore system before the DFC and ADGM which follows common law system. So although my practice focuses on civil law and the onshore proceedings, there are sometimes interactions between the offshore and the onshore proceedings which requires a clear understanding of common law concepts. And this is where someone like Motman who is a Julie qualified in both civil and a common law jurisdiction and someone like Ty who's a common law lawyer brings their knowledge and expertise. Also sometimes working with clients who are familiar with common law concepts, but not necessarily familiar with civil law concepts, this means that you have to explain civil law concepts to to client, make sure they understand this concept, but you also have to address the common law concepts that are familiar with with with with the clients and identify whether or not similar concepts exist in the UAE civil system. Finally, one of the defining feature of the UAE legal system is that it is a modern system that adapts very quickly to new requirements and technologies, which means that the regulatory landscape evolves really quickly, faster than most jurisdictions. And that means that the lawyer, such as all of us, must continuously monitor newer forms and understand how those reform apply in practice when sometimes they haven't yet been tested by the courts. Yeah, I would say like lawyer practicing the UAE will have to stay updated weekly, but annually with the changes that are being made like regular basis. Yeah, so if I will turn now to the other side of the perspective, which is the common law jurisdiction that operates here in UAE, namely the DIFC and the ADGM courts, which bring a very different approach to the dispute resolution. Time to start us off on that front. What is the purpose of the DIFC and the ADGM courts? When do these courts have jurisdiction? Thanks Abdul Majid, who is very interesting to care everyone and learn a bit more about the civil law courts. In terms of the DIFC and the ADGM courts, they are independent common law courts that have been established to determine disputes. They form part of the sovereign structure of the Emirates of Dubai and Abu W. respectively, with the DIFC court being based in the Dubai International Financial Center and the ADGM court being based in the Abu W. Global Markers. Now, the jurisdiction of these courts is actually prescribed by law. So in the case with DIFC, you have Article 14 of Law 20 of 25, which sets out the jurisdiction of the DIFC courts. And it sets out a number of different matters such as civil, commercial employment claims and applications by or against the DIFC bodies or DIFC establishments. Now, in the case of the ADGM courts, you have Article 137 of the Abu W. Law 12 of 2020. And that provides that the ADGM court has jurisdiction over civil or commercial claims and disputes involving ADGM and ADGM authority or an ADGM licensed entity. Both of the laws also allow for parties to opt into the jurisdiction of these courts by way of an agreement. So this also known as a submission to jurisdiction. You can agree to have your dispute determined by those faults. But also both recognizes were a contract or a transaction is performed or concluded within the DIFC or the ADGM. This could also confirm a jurisdiction on these faults. But ultimately jurisdiction is a complex question and has to be determined by looking carefully at facts each case. And following up on it from that moment, how does the commulo system in DIFC and ADGM operate and parallel to the UAE's civil system? That's a very debatable and technical question. But so far both systems are operating in harmony and there are several initiatives and cooperation agreements between the own court and author court. However, of course there are principles in the UAE ligate system, which are purely seven that can influence the DIFC and ADGM as they are themselves squirts in the UAE and still subject to the Eocostution and certain UAE public policy principle. For example, while both courts like the ADGM and the FC are part of a harmonious system, given that they are still subject to the constitution, some of the tools available to the common law courts to resolve conflicts of jurisdiction might not apply. So if I in principle is like correspondence or to allow a court to decline jurisdiction, when it does have jurisdiction, it's not applicable in certain cases because it was previously found for example that it doesn't apply in the UAE because there are certain rules in the constitution to deal with the issue of conflict of jurisdiction in the Eocostution. We also previously have seen a question of interpretation of the DIFC law that was being referred to the Eocostution Court and that DIFC law was actually adjournment. So in one of the cases one of the parties requested the DIFC Court to refer one of its judgment or interpretation to the Federal Supreme Court on the basis that the DIFC Court has a binding precedent system and judgments become a defacto law. I mean if you look how it can develop, I mean in the future we can see one of the cases where one of the parties would challenge a particular DIFC or ADGM judgment to the Federal Supreme Court. On the basis for example that this judgment is contrary to the Constitution on the basis that these are precedent setting cases which can be actually considered a law. So it's quite interesting and very technical and I would say it's very debatable if they actually operate a harmony or there are some instances where the civil law system can directly influence the common law courts. So Ty are turned to you for this one. Both of these courts apply English common law principles but they are still operating within the UAE framework. How close did they follow traditional English common law and where do they differ due to the local factors? Thanks Abel Mijid. So the first point I think that needs to be made is that parties to a contract that is subject to the jurisdiction of the DIFC Court or the ADGM courts can choose the law to govern their contract so that doesn't have to be English law. They could for example choose the law of the UAE or Egypt but opt to have the DIFC Court or the ADGM Court be the jurisdiction or the forum that decides their dispute and applies that law. So assuming the parties have not made such a choice or that dispute is not a contractual matter then the DIFC will apply the law of the DIFC and the ADGM will apply the law of the ADGM. So historically the DIFC would apply English common law on matters where the DIFC law was silent. However the DIFC Court of Appeal has since helped that while English law is important or establishing the foundations of DIFC law it can't be assumed merely because there has been a common law development in English law that any such development will be transplanted into DIFC law. So DIFC law is determined by the statutes of the DIFC and the judgments of the DIFC courts and the DIFC courts for only apply English law where there is no inconsistency with DIFC laws and where the court agrees that it's appropriate to do so. So we've seen that the DIFC court moving away a little bit from English law and trying to establish its own set of laws and jurisprudence that it would follow primarily and then apply English law but not as a given where the court still has a measure of discretion. The ADGM by contrast directly applies English common law in terms of the application of English law regulations 2015. So unlike the DIFC court there's specific regulations in the ADGM that make the English common law including the rules and principles of equity directly applicable in the ADGM court. In addition a wide range of well-established English statutes on various civil laxas are also made directly applicable in the ADGM. Sheriff Arthur Anilimus on the kinds of the cases the common law courts come here for instance could they deal with personal status or criminal cases like the onshore UAE courts? There are restrictions and there are a few subject matters that cannot be heard by those jurisdictions. The DIFC courts or ADGM courts have a jurisdiction to hear criminal cases which fall exclusively within the the the onshore courts and also if you've mentioned family and personal status matters or when applying Sharia law that falls outside of the DIFC and ADGM there's also public law and administrative appeals that also falls outside the jurisdiction of the courts. There is matters that generally fall outside the jurisdiction of the the courts which for example real estate disputes that are that fall outside the the the free those free zones employment disputes where the employee is is not located in the DIFC and matters which fall within the jurisdiction of the the federal courts or I've mentioned in the beginning of the podcast that the constitution reserve certain matters to the federal courts for example disputes between different Emirates so that would necessarily fall outside the jurisdiction of the DIFC and ADGM courts. jurisdiction is another area that often raises complex questions. Moment how are the complex objection between onshore and offshore courts typically resolved? For example let's say in Dubai we've seen the establishment of the conflicts of jurisdiction tribune which is known as the CJT to handle the dispute between the onshore courts in Dubai and the DIFC courts. Both of the onshore courts and offshore courts should be functioning on the principle of coordination and mutual respect of jurisdiction but when you deal with the jurisdiction of issues it differs whether this court is in Dubai and the conflict is between the IFC and Dubai court or ADGM and Abu Dhabi court or a DIFC and the court of a different Emirates. For the relationship between the DIFC courts and the by courts as the right is that there is the ACT and this is to resolve the conflicts between the Dubai courts and the DIFC offshore courts and ADGM has a similar procedure where you have the Judicial Corporation Committee and this is to resolve conflict between the ADGM and Abu Dhabi courts. However when you go for the conflict of jurisdiction between an offshore court which is and an onshore court which is located in a different Emirates say like the IFC and Charger or courted at the ADGM and Razal Rehme then you have a different set of procedures because those will be considered a conflict of jurisdiction between a court of Emirates and a court of another Emirates and this will end up with the Federal Supreme Court. But because the UAE is unique you have the DIFC and ADGM courts which are an essence common local courts. So they have previously and they still issue anti-soot injunctions to prevent a party from pursuing a claim in onshore courts. More recently for example we had in one of our cases where the ADGM went further and considered a had jurisdiction to issue an anti-soot injunction for onshore courts proceedings where one of the parties resulted to the local courts when an arbitration agreement was set. But as you know like at the end the default rule is to either resort to the SCT or to the joint judicial corporation committee because the anti-soot injunctions and sometimes be permitted in onshore because they can be set to conflict directly with the right to litigate. So the safer option is to remain within the context of the rules set to cause due to resolve conflicts between the different words of the Emirates. Thanks moment. Taya I'd love to get your view on this as well. The UAE is mainly a civil law country but it's managed to deal with conflicts between the onshore and offshore courts quite well. How do you see this mix of system working together? I think it does work well in practice because jurisdiction is usually a black or white question. In practice just touching on what moment is mentioned around the interaction between different courts. As disputes lawyers were often approached by clients regarding how they should approach their cases and how they should establish jurisdiction. Now that choice has often been made in the contract by way of a dispute resolution clause or jurisdiction clause. However, given that we have these two forums there can be a number of strategic advantages for a client to consider approaching, for example, the DIFC or ADGM court before or rather than an onshore court because the DIFC or ADGM court have certain powers to grant particular relief that the onshore courts might not have. So moment mentioned an example of an anti-sutian junction but another example could be that the DIFC or ADGM courts can grant urgent, interim or precautionary relief to support onshore proceedings. So it clients who may have a claim in the onshore courts for repayment of monies but it's concerned that before this process can be finalised in the onshore court the data may try to restructure their business or dissipate assets to prevent the creditor from using these assets to satisfy the judgment debt. And in those situations as lawyers we could use the DIFC or ADGM court to obtain an interim relief such as a freezing order to protect the client's rights, pending the outcome of the proceedings on the onshore court. So that's a practical example of how the two courts can interact and the role that we as lawyers can play in that process. And as a last point to wrap up our discussion tie, from your experience as a common law lawyer qualified and staff Africa. What would you say are the main differences between practicing law and South Africa and practicing here in the UA? Look Abdul Rajira can obviously only speak to the common law courts and not the onshore courts but the common law courts are very similar in that they're staffed by judges in registrars. They use the adversarial system that we've talked about. The courts apply judicial precedent, judge made law and there's also a right to appeal or right to seek leave to appeal in the hands of an unsuccessful party. One thing that is different is that in South Africa applying for leave to appeal a judgment automatically suspends the judgment of a lower courts. Whereas here the common law courts do not suspend their judgment merely because you've made an application for leading to appeal. So I think this is a far better model because it avoids the appeal process to delay the enforcement of judgments. But one thing in South Africa are conducted in person while here the common law courts tend to have their hearings virtually and I think more in person hearings in the common law courts would be better because this is better for advocacy as practitioners to persuade the judge but also for collegiality with colleagues and the bench. It's nice to see people in calls and I think that's one suggestion I would make of that can change anything. Thank you so much everyone. Thank you Tariy, thank you, Motlin, thank you Sharif for this very helpful broadcast. Hopefully we can get more out of that in the future. Thank you. Thank you Abdimjeeh that has been very interesting and I hope our listeners will find it as interesting as it was for us to discuss it. you