The Dubai Court of Cassation recently issued a ruling that is considered significant in the UAE, addressing the issue of enforcing foreign bankruptcy judgments in light of the Gulf Cooperation Council (GCC) agreement on the execution of judgments, judicial delegations, and judicial notifications, as well as the Arab Riyadh Agreement for Judicial Cooperation. In this case, which involved a request to enforce a bankruptcy ruling issued in Saudi Arabia within the United Arab Emirates, the court upheld the decision of the lower courts to reject the enforcement.

The court found that, although the GCC agreement provides a general framework for the enforcement of judgments among member states, the Arab Riyadh Agreement, being a subsequent and more specific agreement in this regard, explicitly excludes bankruptcy judgments from its scope of application. Consequently, the Saudi bankruptcy judgment cannot be enforced in the UAE due to its conflict with the Riyadh Agreement. The court affirmed the principle that specific treaties take precedence over general treaties, and since the Riyadh Agreement is a specific agreement that explicitly excludes bankruptcy judgments, the general enforcement provisions of the GCC agreement do not apply in this case