Navigating Judicial Conflict amidst Jurisdictional Expansion: Common Law Commercial Courts in Arab Civil Law Countries

In recent decades, jurisdictionally separate common law commercial courts have emerged alongside existing civil judicial systems, particularly in the Middle East. Although these unique outposts are creating complex jurisdictional dynamics with their local counterparts, existence is also inspiring innovative structural solutions and cultural interactions. Recent cases Dubai Qatar reveal that originally intended limited jurisdiction of expanding beyond what Michael Hwang once famously termed ‘common lakes oceans’. One ways which remit bounds financial centre ‘lakes’ by making it easier for litigants to ‘opt in’ jurisdiction. Increasingly, an identity crisis has gripped some as they now regularly accept identify themselves ‘State courts’. From perspective institutional credibility, State court designation positive growth acceptance. Being a allows capture litigation where contractual language employed forum election clauses. This article explores expansion international consequent or potential tensions structures. Delicately managed, ‘outposts’ can contribute legal synthesis influencing both cultures, including broader systems host States. The experience two jurisdictions explored this instructive future design similar instrumentalities projects other emerging economies.