Introduction
In a landmark development for arbitration in the UAE, the Committee for the Unification of Federal and Local Judicial Principles at the Supreme Federal Court has resolved long-standing uncertainty surrounding arbitrators’ signatures on awards. By confirming that a signature on the final page is sufficient, the Committee has taken a decisive stance against rigid formalism and reaffirmed the UAE’s position as an arbitration-friendly jurisdiction. This ruling is more than a technical clarification, it enhances predictability, increases confidence in the arbitral process, and closes the door to opportunistic challenges based on form rather than substance.
Background: Divergence in Judicial Interpretations
Conflicting judicial approaches have created uncertainty for arbitration users. Some courts, including in Dubai, insisted that arbitrators must sign each page of the award, while others, such as in Ras Al Khaimah, accepted that a signature on the last page was sufficient. This divergence exposed parties to unnecessary risks, with otherwise valid awards vulnerable to challenge on purely procedural grounds. Recognizing the stakes, the Federal Attorney General petitioned the Committee to unify the principle and restore coherence across UAE courts.
The Committee’s Legal Mandate
The Committee for the Unification of Federal and Local Judicial Principles is entrusted with reviewing cases where conflicting judgments have emerged. Its functions include:
- Identifying Contradictions between rulings of federal and local courts.
- Issuing Binding Principles that courts across the UAE must follow.
The Committee’s work extends beyond resolving individual conflicts. It represents a mechanism for institutional dialogue between courts, ensuring the judiciary speaks with one coherent voice on matters of law.
Case Significance and Practical Application
The document in hand, which is petition no. 1 of 2025 dated 4th of August 2025, the Committee illustrates how the Committee addressed a dispute involving conflicting interpretations of key statutory provisions. In its reasoning, the Committee did not merely settle the dispute but also articulated guiding principles intended to govern future cases.
Such rulings serve two functions:
- Immediate Dispute Resolution – providing clarity and finality for the parties.
- Precedent-Setting Effect – establishing unified judicial principles that enhance predictability for businesses, investors, and individuals navigating the UAE legal landscape.
The Federal Attorney General submitted a petition to the Committee for the Unification of Federal and Local Judicial Principles at the Supreme Federal Court examined the procedural requirement concerning the signatures of arbitrators on arbitral awards.
The matter arose because of differing interpretations in judicial practice, some courts in some of their judgments as the Dubai Courts had rendered its judgments that an arbitral award must bear the arbitrators’ signatures on every page to be valid, while others adopted a more flexible approach as the Ras Al Khaimah Courts, accepting that a signature on the final page alone is sufficient. To harmonize these approaches, the Committee articulated a unified principle.
The Committee held that the signature requirement serves a functional and evidentiary purpose rather than a rigid formalistic one. The arbitrators’ signatures are intended to confirm that they have reviewed, deliberated, and adopted the award in its entirety. Once the arbitrators sign the concluding page of the award where the operative part and dispositive section are typically set out this signature signifies their collective endorsement of all the preceding content. Therefore, it is not legally necessary for the arbitrators to repeat their signatures on each individual page.
In its reasoning, the Committee emphasized that insisting on signatures on every page would amount to an unnecessary formality that does not advance the objectives of justice. The law seeks to ensure the authenticity and finality of arbitral decisions, not to impose unnecessary technical obstacles that could be exploited to undermine otherwise valid awards. Requiring multiple signatures across all pages would elevate form over substance, creating a potential ground for parties to challenge awards on purely procedural bases without affecting their substantive fairness or correctness.
By contrast, and as held by the committee, a signature on the last page only is sufficient and carries decisive legal effect without the need to sign every page of the award. It reflects the arbitrators’ approval of the award in its complete and final form. It also ensures certainty for the parties, the courts, and enforcement authorities that the award issued is indeed the one adopted by the tribunal. The Committee clarified that the absence of signatures on prior pages does not, and should not, constitute a defect that leads to nullity or non-enforceability.
The Committee has further confirmed in this regard that there is no basis to invoke Article V of the New York Convention of 1958 as grounds to object to or annul the arbitral award. The Committee emphasized that the reference to public policy under said Article must be interpreted narrowly, in line with the settled international practice regarding the enforcement of arbitral awards.
In this regard, the Committee clarified that the notion of public policy under the New York Convention is not meant to encompass procedural formalities or minor irregularities, such as whether each individual page of the award bears the arbitrators’ signatures. Rather, the concept is reserved for instances of a serious and grave violation that offends the most fundamental principles of justice and morality of the enforcing jurisdiction.
Furthermore, the Committee noted that the New York Convention itself does not prescribe the requirement of signing every page of the arbitral award. The essential condition, in line with internationally recognized practice, is that the award must be duly authenticated and bear the signatures of the arbitrators in a manner that sufficiently establishes its validity and integrity. Accordingly, the Committee adopted the internationally accepted approach i.e., that the absence of signatures on each individual page does not, by itself, render the award invalid or unenforceable.
Considering the above, the Committee concluded that reliance on Article V to resist recognition or to seek annulment of the award on such a formalistic ground is legally unfounded and contrary to the very purpose of the Convention, which aims to facilitate and uphold the enforcement of international arbitral awards.
Through this principle, the Committee has aligned arbitral practice with the broader objectives of efficiency, certainty, and the promotion of arbitration as a reliable dispute-resolution mechanism. It reflects a substance over form approach consistent with international arbitration norms, where what matters is that the arbitrators have duly signed and issued the final binding text of their decision.
What this means for arbitration users
As a result of this unification:
- Validity of Awards: Any arbitral award signed on the last page by the arbitrators is valid and enforceable in law, irrespective of whether the preceding pages are signed.
- Grounds of Challenge: A party cannot rely on the absence of signatures on every page as grounds for seeking annulment or resisting enforcement.
- Judicial Consistency: Courts across the UAE, both federal and local, must now apply this unified principle, thereby eliminating conflicting rulings on the matter.
Conclusion
The Committee’s decision is a welcome affirmation that arbitration in the UAE will not be derailed by unnecessary formalities. By prioritizing substance over form, the ruling eliminates a source of technical challenge that previously unsettled parties and practitioners alike. More importantly, it aligns the UAE’s judicial approach with international arbitration norms, reinforcing the country’s status as a credible, efficient, and arbitration-friendly jurisdiction. For users of arbitration, this clarity translates into greater confidence that their awards will be respected and enforced, without procedural technicalities overshadowing the merits of the case.
Disclaimer
This publication does not provide any legal advice, and it is for information purposes only. You should not rely upon the material or information in this publication as a basis for making any business, legal, or other decisions. Therefore, any reliance on such material is strictly at your own risk.
