This extract, from an interesting article in the International Business Law Journal 2017, notes the existence of two distinct legal systems operating in rare proximity.
"[T]he most notable aspect for the legal practitioner is the creation of an autonomous court system at the heart of the financial centre. Based on English common law, the DIFC [Dubai International Financial Centre] Courts contrast with the civil law regime applicable throughout the rest of Dubai's territory.
In 2004 the Emirate of Dubai initiated a then-unique process: it established on its territory a common law jurisdiction meant to rule upon all civil and commercial disputes relating to the newly created financial free zone.
At its early stage, this very singular configuration was compared to a "Common Law island in a Civil Law ocean".
I.B.L.J. 2017, 4, 289-304
The image above illustrates the illuminating description made in the I.B.L.J. article of a "Common law island in a Civil law ocean". The DIFC is situated in Dubai in a special economic zone covering 100 hectares.
The recognition of particular benefits of the Common law in the context of commerce reflect Lord Neuberger's thoughts in a lecture given to the Faculty of Law, National University of Singapore Lord Neuberger 18 August 2016: