The value of English common law for new “special zones”: a case study of two contrasting examples

Abstract

Abstract The UK legal system, and in particular the legal method of the common law, is in use in numerous countries around the world. (The Scots law approach, which is uncodified, is in many ways similar to that of the common law, but has been used less internationally.) The UK's approach contrasts with the code-based civil law method, the other major legal technique, in use in most other countries and which derives from the codifications in Europe of the nineteenth century. In recent years, various countries have sought to benefit from the UK’s methods, particularly in commercial matters, by setting up free zones in which new laws can apply. Dubai and Abu Dhabi, two of the United Arab Emirates, are prominent examples. However, they have chosen different means by which to adopt elements of the UK’s legal system. This article explores what each has done, and some of the distinctions between their two approaches.