Commercial, DIFC, and ADGM property sale and purchase agreements operate under legal frameworks that differ fundamentally from each other and from the off-plan residential regime. The remedies available on exit, and the conditions that must be met to exercise them, depend entirely on which framework applies to the transaction.
Part 2 of 3 | UAE SPA Exit Series: Part 1: Off-Plan Residential · Part 2: Commercial, DIFC & ADGM · Part 3: Resale (Secondary Market)
Why the Framework Matters
Part 1 of this series examined the off-plan residential regime in Dubai — a system dominated by mandatory statutory procedures, fixed forfeiture tiers, and RERA oversight. Commercial property SPAs, and those governed by the law of DIFC or ADGM are not subject to that regime. In each of these contexts, the legal framework for exit is different and in important respects, the positions of buyer and seller are materially less predictable than under the Dubai residential regime.
The distinction matters because the consequences of exit, such as deposit forfeiture, damages, specific performance, and the availability of termination without a court order are determined by a combination of the governing law of the SPA, the jurisdiction in which disputes will be resolved, and the specific wording of the contract itself. A party who assumes that the forfeiture protections from the off-plan residential framework carry across into commercial transactions, or vice versa, is likely to be wrong.
This article addresses three distinct contexts: onshore UAE commercial property SPAs governed by the UAE Civil Code; property transactions within the Dubai International Financial Centre (DIFC) under DIFC law; and property transactions within the Abu Dhabi Global Market (ADGM) under English common law. It then addresses cross-border buyer considerations that arise across all three.
This Article is a Part of our Legal & Regulatory Framework in UAE Real Estate Blogpost.
Onshore UAE Commercial Property SPAs
Commercial property transactions in onshore UAE are governed primarily by the UAE Civil Code (Federal Law No. 5 of 1985) and, for Dubai transactions, by Law No. 7 of 2006 on Real Property Registration and the requirements of the Dubai Land Department (DLD). Unlike the off-plan residential market, there is no equivalent of Law No. 13 of 2008’s mandatory forfeiture tiers or the Article 11 public-policy procedure. The terms of the SPA itself carry considerably more weight.
DLD registration. All commercial property transactions in Dubai must be registered with the DLD. An SPA that is not registered does not transfer a real property right. Instead, it creates a personal contractual obligation between the parties. This distinction is commercially significant: a buyer whose SPA is unregistered has a weaker enforcement position than a registered owner, particularly if the seller subsequently deals with the property.1
Termination and the court order requirement. Under the UAE Civil Code, a contract cannot ordinarily be unilaterally terminated by one party, even following a breach, without a court order. Article 272 provides that in bilateral contracts, the court may order termination with or without damages, after considering the circumstances.2 The critical exception is an express termination clause (sometimes called a faskh clause or an ipso facto clause) that grants one or both parties the right to terminate upon specified events without recourse to the courts. Such clauses are enforceable in UAE law and are increasingly standard in commercial SPAs. If a party assumes a breach gives them the right to terminate without a court order when no such clause exists, their action could itself amount to a breach.
Deposit forfeiture – no statutory cap. For commercial property transactions, the UAE Civil Code does not prescribe statutory limits on the amount a seller may forfeit from a buyer’s deposit on default. The position is governed entirely by the SPA. In practice, a 10% deposit is standard in the Dubai commercial market, and SPAs typically specify that the seller may retain the deposit if the buyer fails to complete. Dubai courts have upheld the seller’s right to retain the full deposit where the buyer failed to fulfil a clear SPA obligation, for instance by not securing mortgage finance within the agreed period, even if the buyer claimed hardship.3
Liquidated damages and judicial adjustment. Where an SPA specifies a fixed penalty for non-performance beyond the forfeiture of the deposit, Article 390(2) of the UAE Civil Code gives UAE courts the power to reduce a penalty clause to match actual loss if the specified sum is found to be excessive. The court will assess the actual harm caused, not merely the contractual figure. This is an important backstop for defaulting buyers facing disproportionate penalty provisions, but it is a judicial remedy requiring litigation, not a self-executing protection.
Specific performance. Specific performance, which means compelling the other party to complete the transaction is a remedy available under UAE law and is particularly relevant where the property is unique and monetary compensation would not adequately restore the innocent party. Article 380 of the UAE Civil Code provides that a debtor may be compelled to perform in kind where the obligation is one capable of performance. UAE courts have ordered specific performance in commercial real estate disputes, though they retain discretion and will not order it where performance has become impossible or where damages are an adequate remedy.
DIFC Property Transactions
The Dubai International Financial Centre operates as an independent jurisdiction within the UAE, applying common law principles to all civil and commercial matters. Real property within the DIFC is governed by DIFC Real Property Law No. 10 of 2018 (as amended), and contractual relations are governed by DIFC Contract Law No. 6 of 2004. An amendment to DIFC Law No. 3 of 2004 on the Application of Civil and Commercial Laws, enacted in November 2024, now explicitly provides that DIFC law is supplemented by the common law of England and Wales and other established common law jurisdictions.4
DIFC off-plan property — the Disclosure Statement. Part 23 of the DIFC Real Property Law (Articles 155–164) sets out the framework for off-plan sales within the DIFC. A developer must register each off-plan sale in the Off-Plan Register within 30 days of executing the agreement. Critically, the developer must provide a Disclosure Statement to the buyer before the off-plan sales agreement is entered into. The Disclosure Statement covers service charges, community amenities, and the specification of the unit. Where a developer fails to provide a Disclosure Statement, the buyer has a right to terminate the off-plan agreement.5 An escrow account is required for off-plan sales, and warranties for construction defects apply: one year for non-structural defects and ten years for structural defects.6
Termination for fundamental non-performance. Under DIFC Contract Law No. 6 of 2004, termination of an SPA requires careful compliance with the law’s procedural framework. Article 77 defines non-performance broadly to include defective and late performance. The threshold for immediate termination is fundamental non-performance (Article 86): a breach that substantially deprives the innocent party of what it was entitled to expect under the contract.7
For non-fundamental non-performance, the innocent party must first allow a reasonable additional period for cure. The aggrieved party may include an automatic termination trigger in its notice (Article 81), but must otherwise serve a further notice at the expiry of the cure period if it wishes to terminate. The DIFC Courts have emphasised that parties must be clear and deliberate in communicating termination. Equivocal or ambiguous communications may not be effective for the purpose of termination.8
Liquidated damages in the DIFC. Under DIFC Law No. 7 of 2005 (Law of Damages and Remedies), Article 21, a liquidated damages clause specifying a sum payable on non-performance is enforceable, and the aggrieved party is entitled to that sum irrespective of actual loss. The only ground for reduction is that the specified sum is manifestly disproportionate to the foreseeable harm. This is a higher threshold than the UAE Civil Code’s ‘excessive’ standard, meaning that pre-agreed liquidated damages carry more commercial weight in the DIFC.9
DIFC Courts: direct access. There is no mandatory mediation or regulatory committee stage for commercial property disputes in the DIFC. Parties may proceed directly to the DIFC Courts or to arbitration if the SPA so provides. The DIFC Courts apply strict common law procedural standards and their judgments are enforceable across the UAE under the Dubai Judicial Authority Law.
ADGM Property Transactions
The Abu Dhabi Global Market serves as Abu Dhabi’s international financial centre, covering areas such as Al Maryah Island and Al Reem Island. Its courts apply English common law directly, pursuant to the Application of English Law Regulations 2015, except where ADGM has enacted its own legislation on a specific topic.10
ADGM off-plan framework. The ADGM Off-Plan Development Regulations 2024 establish a registration and oversight framework for off-plan property sales within ADGM, broadly comparable in purpose to the DIFC regime. Developers must be registered, projects must be approved, and escrow accounts are required. Disputes arising from off-plan transactions within ADGM fall within the jurisdiction of the ADGM Courts.
Contract termination under English common law. In the ADGM, the test for termination follows English common law principles. A breach gives rise to a right to terminate if it is repudiatory, that is, if it goes to the root of the contract and substantially deprives the innocent party of the whole benefit the parties intended. Where the breach is of a condition (a term the parties agreed was of essential importance), termination is available regardless of actual consequences. Where the term breached is a warranty, only damages are available, not termination.
The ADGM Contract Law, which is closely modelled on the DIFC Contract Law, also provides for termination on fundamental breach with prior notice to cure where appropriate. Under Article 86 of the ADGM Contract Law, a party may terminate if the other side’s non-performance constitutes a fundamental breach causing substantial detriment, having given the requisite notice.11
ADGM Courts: direct access. Like the DIFC, there is no mandatory pre-litigation stage for commercial property disputes in the ADGM. Parties may proceed directly to the ADGM Courts or to arbitration. The ADGM Courts apply English procedural standards and have concurrent jurisdiction with the DIFC Courts for certain categories of commercial dispute. Default interest on judgment debts is 5% per annum in the absence of an agreed rate.
Jurisdiction Comparison at a Glance
The table below summarises the key differences across the three frameworks relevant to an SPA exit.
| Feature | Onshore UAE (Civil Code) | DIFC | ADGM |
|---|---|---|---|
| Governing law | UAE Civil Code (Federal Law No. 5 of 1985) | DIFC Contract Law No. 6 of 2004; English common law supplementary | English common law (Application of English Law Regulations 2015) |
| Termination without court order | Only if express ipso facto / faskh clause in SPA | Yes — on fundamental non-performance under Article 86, with notice | Yes — on fundamental breach under common law, with notice |
| Deposit forfeiture | Governed entirely by SPA terms; no statutory cap for commercial property | Governed by SPA terms; DIFC courts apply manifestly disproportionate test | Governed by SPA terms; English law penalty clause rules apply |
| Specific performance | Available; court has discretion; primarily ordered for unique property | Available under DIFC Law No. 7 of 2005; courts have discretion | Available under English common law; courts have discretion |
| Liquidated damages | SPA terms; UAE Civil Code Art. 390 allows judicial reduction if excessive | DIFC Law No. 7 of 2005, Art. 21 — reduction if manifestly disproportionate | English common law penalty rules; reduction if penalty, not genuine pre-estimate |
| Dispute resolution first step | UAE courts or arbitration (no mandatory mediation for commercial) | DIFC Courts directly, or arbitration | ADGM Courts directly, or arbitration |
| Off-plan specific statutory regime | Dubai DLD/RERA framework (Law No. 13 of 2008 and amendments) | DIFC Real Property Law No. 10 of 2018, Part 23 | ADGM Off-Plan Development Regulations 2024 |
The Deposit: What Happens Across Jurisdictions
The deposit is almost always the central commercial battleground in a contested SPA exit. The governing regime determines how much of it can be retained, on what conditions, and whether a court must be involved.
In onshore UAE commercial transactions, the SPA determines the outcome. Courts have consistently upheld deposit forfeiture provisions where the defaulting party’s breach was clear and the clause was unambiguous. The court retains power under Article 390(2) of the UAE Civil Code to reduce excessive penalties, but will not do so simply because the defaulting party suffered financial difficulty or changed their mind.
In the DIFC, deposit forfeiture clauses are treated as liquidated damages and are assessed under the manifestly disproportionate standard. A standard 10% deposit forfeiture on buyer default will almost always survive challenge, since 10% of a commercial property price is well within the range of a genuine pre-estimate of the seller’s likely loss from a failed transaction. A clause that allow retaining significantly more, especially if the seller resells quickly at a similar or better price, face greater risk of challenge.
In the ADGM, the English common law rules on penalty clauses apply. A deposit forfeiture clause is enforceable if it represents a genuine pre-estimate of loss, or if it serves a legitimate commercial interest proportionate to the breach. If it is found to be a penalty designed to punish rather than compensate. it will not be enforced beyond the level of actual loss. Given the commercial sophistication of most ADGM transactions, however, penalty clause challenges rarely succeed in standard commercial property contexts.
Specific Performance: When Completion Can Be Compelled
A seller who defaults on a completed property transaction, for example by refusing to transfer title, failing to discharge encumbrances, or purporting to resell to a third party, may face a specific performance claim compelling completion of the original transaction. This remedy exists because every piece of real property is unique by nature, and damages alone may not adequately substitute for the specific property the buyer contracted to acquire.
Across all three frameworks, onshore UAE Civil Code, DIFC, and ADGM, specific performance is available but discretionary. Courts in all three jurisdictions will decline to order it if performance has become impossible, the delay in seeking the remedy has been excessive, or the balance of convenience strongly favours compensation over compelled performance. In DIFC and ADGM proceedings, buyers can also seek injunctions at an early stage to stop a defaulting seller from dealing with the property while the dispute is ongoing. These interim orders often provide quicker practical protection.
Material Adverse Change Clauses and Geopolitical Risk
Some commercial property SPAs, especially those involving large-scale transactions, institutional sellers, or cross-border financing include a Material Adverse Change (MAC) clause. A MAC clause allows a party (usually the buyer) to exit the transaction if a material adverse change occurs in specified conditions such as the value of the property, the counterparty’s financial position, or defined market conditions between signing and completion.
MAC clauses are distinct from force majeure. Force majeure addresses impossibility of performance. A MAC clause addresses a significant deterioration in the underlying economics of the deal, even where performance remains technically possible. Not all SPAs include MAC clauses, and in the UAE commercial market they are more common in acquisition finance transactions and large commercial deals than in standard property purchases.
When a MAC clause is included, its exact drafting is very critical. Courts in DIFC and ADGM will apply a strict common law approach: the triggering event must fall within the precise language of the clause, and the buyer bears the burden of proving that a material adverse change, as defined, has actually occurred. Geopolitical uncertainty, regional tensions, and market price movements will not satisfy a MAC clause unless they are expressly within its scope or have caused a measurable deterioration in the defined metrics.12
For onshore UAE commercial SPAs, MAC clauses are interpreted by reference to the UAE Civil Code’s principles of contractual interpretation (Articles 258–265). Where the clause is genuinely ambiguous, it will be read against the party that drafted it. In practice, MAC clauses are increasingly narrowly drafted in the UAE market following litigation in other jurisdictions that has shown how difficult they are to invoke successfully.
Frustration of Contract and Impossibility of Performance
In times of geopolitical tension or unforeseen regional events, some parties may seek to exit commercial property SPAs by arguing that the contract has been frustrated. This doctrine addresses situations where a supervening event, without fault of either party, fundamentally alters or renders impossible the performance of the contract.
Under the UAE Civil Code, the concept operates through Article 273. In contracts binding on both parties, if a force majeure event makes performance of an obligation impossible, the corresponding obligation is extinguished and the contract is automatically cancelled by operation of Article 273(1). Where only part of the contract becomes impossible, that portion may be extinguished while the rest continues, although the innocent party may elect to cancel the entire agreement upon notice under Article 273(2). 13
In the DIFC, the Contract Law under Article 82 provides a statutory excuse for non-performance due to an impediment beyond a party’s control that could not reasonably have been foreseen or overcome at the time of the conclusion of the contract. It is important to note that the key exception to this clause is in respect of an obligation to pay.
In the ADGM, which applies English common law principles directly, the doctrine of frustration remains available when the SPA contains no force majeure clause or when the clause fails to cover the relevant event. Under this doctrine, a contract may be discharged only if a supervening event without fault on either side makes performance impossible or illegal, or renders it radically different from what the parties originally contemplated when signing the agreement. The threshold for this is in fact very high. Ordinary changes in economic conditions, increased costs, or mere commercial hardship will not qualify. If frustration is successfully established, the contract ends automatically, releasing both parties from any further obligations.14
Cross-Border Buyer Considerations
A significant proportion of commercial and DIFC/ADGM property transactions in the UAE involve buyers who are not resident in the UAE, do not have a local banking relationship, and may be dealing in a currency other than AED. Several issues specific to cross-border buyers arise in the context of SPA exit.
Governing law and jurisdiction. A cross-border buyer who has signed an SPA governed by DIFC or ADGM law, with disputes referred to the DIFC or ADGM Courts or to arbitration, has a clear and internationally respected dispute resolution pathway. An SPA governed by the onshore UAE Civil Code, with disputes referred to the Dubai or Abu Dhabi courts, involves civil law proceedings conducted primarily in Arabic, which may present practical challenges for non-Arabic-speaking buyers and sellers.
Non-admitted insurance. Cross-border buyers who have placed insurance on their UAE property with a foreign insurer not licensed by the CBUAE risk holding a policy that is unenforceable under UAE law. The same principle applies to financial guarantees structured outside the UAE regulatory perimeter.
Enforcement of judgments. DIFC and ADGM judgments benefit from clear enforcement mechanisms within the UAE and in foreign jurisdictions through applicable treaties and common law recognition rules. Onshore UAE court judgments require enforcement through the local execution courts — a process that is generally reliable but procedurally distinct from enforcement in common law jurisdictions.
Currency and financing risks. A buyer funding a UAE commercial property acquisition with financing denominated in a foreign currency faces exchange rate risk between signing and completion. Most UAE commercial SPAs do not contain express currency adjustment provisions. A buyer whose financing falls away due to market movements — whether currency, interest rate, or geopolitical — will generally not find that this constitutes force majeure or MAC under the contract, absent a specific clause providing for it.
Practical Steps
A party considering exit from a commercial, DIFC, or ADGM property SPA should address the following.
Practical Checklist
- Identify the governing law first. The consequences of exit — including deposit forfeiture, the availability of termination without a court order, and the remedies available — differ significantly between onshore UAE Civil Code, DIFC law, and ADGM English common law. This is not a minor technicality; it is the threshold question.
- Read the termination clause carefully. Check whether the SPA contains an express ipso facto or faskh clause (onshore) or a fundamental breach termination provision (DIFC/ADGM). If no such clause exists, termination without a court order risks itself being a breach.
- Assess the deposit forfeiture position. Identify what the SPA says about deposit retention on default by each party. Note whether a judicial reduction mechanism applies (Article 390(2) onshore; manifestly disproportionate test in DIFC; penalty clause rules in ADGM) and whether that provides any meaningful protection on the specific facts.
- Check for a MAC clause. Review the SPA for any Material Adverse Change provisions. If one exists, assess whether the triggering conditions have been met in terms of the exact contractual language — not in terms of general market sentiment.
- Preserve your enforcement options. If the other party is in default, serve a formal written notice immediately specifying the breach and the required cure period (where applicable). Delay in giving notice can affect both the availability of termination and the calculation of damages.
- Consider interim relief. In DIFC and ADGM proceedings, injunctions and interim orders preventing a defaulting seller from dealing with the property are available on short notice and should be considered as an urgent first step in any dispute involving real property.
- Obtain advice on the specific SPA. Commercial, DIFC, and ADGM property SPAs are bespoke documents. The analysis of exit rights depends on the exact drafting of the individual agreement, not the general framework.
Conclusion
Exiting a commercial property SPA in the UAE requires a threshold assessment of the governing legal framework before any other analysis is possible. The same conduct — stopping payment, refusing to complete, or citing changed circumstances — produces different legal consequences depending on whether the transaction is governed by the UAE Civil Code, DIFC law, or ADGM common law.
Across all three frameworks, the SPA wording carries more weight in commercial transactions than in the off-plan residential context. There is no equivalent of the Article 11 public-policy procedure that overrides unfavourable SPA terms. A well-drafted commercial SPA can confer rights that the law would not otherwise provide; a poorly drafted one can deprive a party of protections they assumed they had.
For cross-border buyers and for transactions involving significant amounts, the choice of governing law and dispute resolution forum should be a deliberate decision at the drafting stage — not an afterthought discovered when a dispute arises.
Related Articles
UAE SPA Exit Series: Part 1: Off-Plan Residential · Part 2: Commercial, DIFC & ADGM (this article) · Part 3: Resale (Secondary Market)
Other ATB Legal articles: Force Majeure in UAE and DIFC/ADGM Contracts
Footnotes…………………………………………………………………..
- All real property transactions in Dubai must be registered with the Dubai Land Department under Law No. 7 of 2006 Concerning Real Property Registration in the Emirate of Dubai. An unregistered sale is a personal contractual obligation, not a property right, and affords significantly weaker protection against third-party dealings by the seller: see Fakher & Co, ‘Real Estate Sale Agreements in the UAE: Legal Pitfalls’, available at: fakhernco.com.
- UAE Civil Code (Federal Law No. 5 of 1985), Article 272: ‘In contracts binding on both parties, if one of the contracting parties does not fulfil what is imposed upon him by the contract, the other party may, after serving notice upon him, demand fulfilment of the contract or its rescission.’ The court may order termination with or without damages and may grant the debtor a period of time to perform in appropriate circumstances. Termination is generally a judicial remedy under the Civil Code: see Fakher & Co, ‘Breach of Contract in the UAE’, available at: fakhernco.com.
- Dubai courts have upheld a seller’s right to terminate an SPA and retain the buyer’s deposit where the buyer failed to obtain mortgage finance within the contractually agreed period and no reason beyond the buyer’s control was established: see Motei & Associates, ‘Court Approved Seller’s Right to Terminate the Sales and Purchase Agreement and Retain the Buyer’s Deposit’, available at: motei.com. The court-appointed expert confirmed that the buyer’s failure was not beyond his control, entitling the seller to the deposit under the SPA’s express terms.
- DIFC Law No. 3 of 2004 on Application of Civil and Commercial Laws in the DIFC, as amended by Amendment Law enacted 14 November 2024, effective 21 November 2024. New Article 8A provides that DIFC law is determined first by DIFC statutes and court judgments, supplemented by English common law and equity and the laws of other common law jurisdictions. See DIFC Authority announcement, available at: difc.com; and Lexis Middle East analysis, available at: lexismiddleeast.com.
- DIFC Real Property Law No. 10 of 2018, Article 160: the developer must provide a Disclosure Statement before an off-plan sales agreement is entered into. Article 160(6) as amended: where a Disclosure Statement is provided after the agreement is signed, the buyer has 60 days to review it and a further 20 days within which to terminate if the Disclosure Statement does not accurately reflect the off-plan development. See Trowers & Hamlins, ‘DIFC proposes changes to the Real Property Law’, available at: trowers.com; and Al Tamimi & Company, ‘Changes to the DIFC Real Property Laws’, available at: tamimi.com.
- DIFC Real Property Law No. 10 of 2018, Articles 162 (Escrow Account) and 163 (Construction Defect Rectification). The one-year warranty covers non-structural defects; the ten-year warranty covers structural defects. An escrow amount is retained for 12 months following building completion as security for defect rectification obligations: see Al Tamimi & Company, ibid (note 5).
- DIFC Contract Law No. 6 of 2004, Article 86: a party may terminate the contract where the other party’s non-performance amounts to fundamental non-performance — i.e., non-performance that substantially deprives the aggrieved party of what it was entitled to expect under the contract — provided notice is given and the defaulting party has not cured. For detailed analysis of the DIFC termination framework: Taylor Wessing, ‘Contract Termination in Dubai: The Formalities and Potential Pitfalls’, available at: taylorwessing.com.
- DIFC Contract Law No. 6 of 2004, Articles 77–87. A non-performing party may propose to cure its non-performance (Article 80). Where cure is not offered, the aggrieved party may serve a notice allowing additional time to perform (Article 81). For non-fundamental non-performance, automatic termination is only triggered if the notice expressly states that the contract will terminate on expiry of the period (Article 81(3)); otherwise a further notice is required. Parties must communicate termination clearly — equivocal communications may not be effective: Taylor Wessing, ibid (note 7).
- DIFC Law No. 7 of 2005 (Law of Damages and Remedies), Article 21: liquidated damages are enforceable irrespective of actual harm, but may be reduced to a reasonable amount if manifestly disproportionate. The threshold is higher than the UAE Civil Code’s ‘excessive’ standard. See Al Tamimi & Company, ‘Liquidated Damages in the DIFC Courts’, available at: tamimi.com. As of the date of this article, no DIFC Court precedent has definitively fixed the boundary of ‘manifestly disproportionate’ in the real estate context.
- ADGM Application of English Law Regulations 2015 establish that English common law principles and rules of equity apply in the ADGM, supplemented by ADGM’s own enacted legislation. ADGM Courts apply these principles directly and refer to English case law as authoritative precedent. For contract law, see Mondaq, ‘Top 10 Questions Answered About Contracts in the UAE’, available at: mondaq.com.
- ADGM Contract Law, Article 86: a party may terminate the contract where the other party’s non-performance constitutes a fundamental breach causing substantial detriment, provided the aggrieved party gives notice requiring remedy within a reasonable period. Article 88 provides for anticipatory termination where it becomes clear that a fundamental breach will occur before performance is due. Article 82 provides for termination on force majeure impossibility: Mondaq, ibid (note 10).
- MAC clauses in commercial property SPAs are interpreted strictly against the party seeking to rely on them in both DIFC and ADGM proceedings. A buyer invoking a MAC clause must demonstrate that the triggering conditions, as precisely defined in the agreement, have been met — not merely that market conditions have worsened or that the transaction has become less financially attractive. For the distinction between MAC clauses and force majeure in UAE contracts, see ATB Legal Consultancy, ‘Force Majeure in UAE and DIFC/ADGM Contracts’, available at: atblegal.com.
- 13.Navigating Force Majeure, Impossibility and Frustration under UAE Law During the Current Crisis,last accessed on 25 March 2026.
- 14.The Middle East conflict: Key legal issues for commercial entities under UAE, ADGM and DIFC law byNorton Rose Fulbright, last accessed on 27 March 2026
Edited by Benoy P Jacob
