Which Law Applies to a Non-Muslim Expatriate's Will in the UAE?

Analysis

Wills and other matters relating to personal affairs, such as custody and divorce, are generally governed in the UAE by Federal Law 28 of 2005, known as the Law of Personal Status, which is based on Islamic Law.

In order to accommodate those residents of the UAE who ascribe to different religions, the Law of Personal Status permits a non-Muslim expatriate living in the UAE to elect to apply the law of his or her country to matters of personal affairs. Additionally Article 17 of the UAE Civil Code states that “inheritance shall be governed by the law of the testator at the time of his death”. This article considers a judgments issued by the Dubai Court of Cassation illustrating the applicability of these provisions.

Summary of the Facts