The Abu Dhabi Global Market and Its Transplant of English Private Law

Abstract

Abstract A grand experiment took place in the Abu Dhabi Global Market (ADGM). This relatively new special economic zone adopted English law as its operational law through a decision by which such a transplant would become instantly applicable. While such instant transplants have generally not fared well in the past, in the present instance, the ADGM experiment seems to have produced tangible outcomes. This is largely due to the fact that the introduction of English law was accompanied by the establishment of a court composed of judges with vast experience in the application of statutory and common law. In addition, both the court and its various stakeholders are in ‘dialogue’ with the courts and institutions of England, in the sense that English precedent is generally followed subject to the exigence of the ADGM. This species of transplant is viewed by the author as a successful model, albeit one suitable for a jurisdiction with significant financial resources.