On 4 August 2025, the Federal-Local Judicial Principles Unification Authority decided on a procedural question related to Arbitration on whether an arbitral award is to be signed by all arbitrators on every page, or whether a signature on the final page is sufficient. Different judicial bodies, like the Ras Al Khaimah Court of Cassation and the Dubai Court of Cassation in the UAE, have given contradictory views on the matter. To unify the principles, the matter was referred to the Unification Authority by the Federal Public Prosecutor.
The Authority favored the decision of the Ras Al Khaimah Court of Cassation and decided that it was sufficient for arbitrators to sign only the last page of the arbitral award, and that they are not required to sign all of its pages in order to confirm that the decision was issued by them.
AUTHORITY FOR UNIFICATION OF LOCAL AND FEDERAL JUDICIAL PRINCIPLES
The UAE’s federal government has established a judicial body called the Authority for Unification of Local and Federal Judicial Principles (the Authority), concerned with unifying the conflicting judicial principles issued by two or more of the supreme courts in the State. The principles established by the Authority shall be binding on all the Federal or Local Judicial Authorities of the country.
ANALYSIS OF CONTRARY VIEWS
Article 41 of the Federal Arbitration Law No. 6 of 2018 requires the arbitrators to sign the award either electronically or manually. The law, however, does not make it clear whether it is required to sign each page of the award. The importance of a signature comes from the fact that it denotes the authorship of an arbitral award and its authenticity. It is important to note that even the New York Convention does not have any provision related to Article 41 of the Federal Law.
In light of the above, the Dubai Court of Cassation concluded that arbitrators are required to sign the operative part, the reasons, and all pages of the arbitral award; failing which the award shall be deemed null and void, such nullity being connected to public order.
In contrast, the Ras Al Khaimah Court of Cassation held that it is sufficient for arbitrators to sign only the last page of the arbitral award, and that they are not required to sign all of its pages in order to confirm that the decision was issued by them.
RULING OF THE AUTHORITY
The Authority sided with the view taken by the Ras Al Khaimah courts and stated that there was no statutory requirement for the signatures of all the arbitrators to appear on each individual page. Signatures of all arbitrators (or the majority, where applicable) on the final page of the written award were sufficient to consider it valid. Hence, failure cannot be a reason for annulment of the award and cannot constitute a breach of UAE public order within the meaning of Article 4 of the New York Convention.
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Thomas Paoletti
Francesca Romana Valeri
Fauzia Khan
“This article is for information purposes only and does not constitute legal or professional advice.“
