Introduction

A recent landmark judgment from the UAE Federal Supreme Court (Appeals No. 141 and 146 of 2025 – Administrative Division) has established important legal principles regarding procedural aspects of civil litigation. The Court’s decision, issued on April 9, 2025, provides valuable guidance on determining case values, requirements for judicial reasoning, and the effect of overturning judgments on connected appeals. This blog examines these principles and their practical implications for litigants and legal practitioners in the UAE.

Background of the Case

The case originated from an employment dispute where an employee filed a lawsuit (No. 258/2024) against his employer, containing multiple claims, all arising from their employment relationship. The employee’s claims included:

1. Cancellation of a transfer decision dated April 5, 2024

2. Payment of business trip allowances

3. Overtime compensation for Ramadan work

4. Restoration of his previous job title and position

5. Provision of essential work requirements

6. Cancellation of various disciplinary warnings and penalties

7. Reconsideration of his 2023 performance evaluation

8. Cancellation of salary deductions and suspension of technical allowances

The Court of First Instance partially granted the claim, ordering the employer to pay for business trip allowances and canceling one disciplinary action while rejecting the remaining claims. Both parties appealed this decision.

The Court of Appeal overturned the first instance judgment and dismissed the case entirely on the grounds that it contained collective claims, imposing court fees on the appellant. This decision was subsequently challenged before the Federal Supreme Court.

Key Legal Principles Established

1. Valuation of Multiple Claims Arising from a Single Legal Cause

The Supreme Court emphasized that when a lawsuit contains multiple principal claims arising from a single legal cause, the case value must be calculated based on the total sum of all claims. This principle is established in Article 51(9) of Federal Decree-Law No. 42 of 2022 concerning Civil Procedures, which states:

“If the lawsuit includes claims arising from a single legal cause, the valuation shall be based on their total value. If they arise from different legal causes, the valuation shall be based on the value of each claim separately.”

The Court clarified that the “cause of action” refers to the fact or facts from which the plaintiff derives the right to make a claim. In this case, all claims arose from the employment relationship governed by the Human Resources Law.

2. Requirements for Proper Judicial Reasoning

The judgment reaffirmed that courts must include sufficient reasoning that demonstrates:

– Thorough examination of evidence and documents relevant to the case

– Comprehensive understanding of the factual reality of the dispute

– Responses to substantial defenses presented by the parties

– Clear reasoning that justifies the court’s conclusions

The Court held that when judgments fail to address these elements and rely on general statements that do not adequately support the conclusion, they suffer from deficient reasoning and violate the right to defense.

3. Effect of Overturning a Judgment on Connected Appeals

The Court established that when legal positions of appellants are interconnected in joined appeals, overturning the judgment completely for one party necessarily leads to overturning it for the other party as well. This principle ensures that the litigation and all parties return to their positions before the issuance of the overturned judgment.

The Court’s Analysis and Decision

The Supreme Court found that the Court of Appeal erred in treating each of the employee’s claims as independent and separate despite them all arising from a single legal cause—the employment relationship governed by Abu Dhabi’s Human Resources Law No. 6 of 2016 and its implementing regulations.

The Court determined that the appellate judgment suffered from:

– Flawed reasoning

– Insufficient justification

– Misapplication of the law

As a result, the Supreme Court overturned the Court of Appeal’s judgment in both appeals (141 and 146 of 2025) and remanded the case for reconsideration.

Practical Implications for Litigants

This judgment has several important implications for litigants in UAE courts:

1. Strategic Case Valuation: Litigants must properly calculate case values considering whether multiple claims arise from a single legal cause or different causes, as this affects court fees and jurisdictional thresholds.

2. Comprehensive Legal Arguments: Parties should present comprehensive legal arguments addressing all claims arising from the same legal relationship, as courts must consider them collectively when they share a common legal cause.

3. Challenging Insufficiently Reasoned Judgments: The decision provides grounds for appealing judgments that fail to adequately address substantial defenses or rely on generic statements without proper analysis.

4. Connected Appeals Strategy: In cases with multiple appellants challenging the same judgment, parties should consider the interconnection of their legal positions, as the success of one appeal may affect others.

Conclusion

This Federal Supreme Court judgment reinforces fundamental principles of procedural justice in UAE civil litigation. It emphasizes the importance of proper case valuation, comprehensive judicial reasoning, and the interconnection of appeals arising from the same judgment. Legal practitioners should carefully consider these principles when formulating litigation strategies and drafting appeals in cases involving multiple claims arising from a single legal relationship.

The Court’s decision serves as a reminder that procedural aspects of litigation can be just as crucial as substantive legal arguments in achieving favorable outcomes. By establishing clear standards for judicial reasoning and case valuation, the Federal Supreme Court continues to enhance the predictability and fairness of the UAE legal system.