Federal Properties Ltd - Sole Proprietorship LLC v Ibrahim [2026] ADGMCFI 0009 (03 March 2026)

Federal Properties Ltd - Sole Proprietorship LLC v Ibrahim [2026] ADGMCFI 0009 (03 March 2026)

Where a registered owner holds property as a constructive trustee for another, and the Register is therefore incorrect, the Registrar must correct the Register under section 144 of the ADGM Real Property Regulations 2024 to substitute the true owners, provided no prejudice is caused to the registered owner or third parties, especially where the registered owner had actual or constructive knowledge of the error.

Citation
[2026] ADGMCFI 0009
Parties
Claimant/first Counterdefendant/counterdefendant: Federal Properties Limited - Sole Proprietorship LLC (also known as Federal Properties Limited); Defendant/first Counterclaimant: Rawafid H Jazairi Ibrahim; Second Counterclaimant: Ausama Ahmed Ibrahim; Second Counterdefendant: Department of Municipalities and Transport - Abu Dhabi (DMT); Defendant/counterclaimant: Amir Sadik Ali Al Samarraie
Jurisdiction
United Arab Emirates
Judgment Date
03 March 2026
Procedural Posture
Civil Real Property / Post Trial Judgment and Directions on Implementation
Outcome
Orders granted for correction of the Register and issue of new title deeds to the Unit Owners; no order as to costs unless application made by 17 March 2026.
Legal Topics
Constructive Trust, Correction of Land Register, Indefeasibility of Title, Registrar's Powers, Transfer of Property Title
Real Property Law Trusts Law Constructive Trust Correction of Land Register Indefeasibility of Title Registrar's Powers Transfer of Property Title

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Parties

Federal Properties Limited - Sole Proprietorship LLC (also known as Federal Properties Limited)

Claimant/first Counterdefendant/counterdefendant

Rawafid H Jazairi Ibrahim

Defendant/first Counterclaimant

Ausama Ahmed Ibrahim

Second Counterclaimant

Department of Municipalities and Transport - Abu Dhabi (DMT)

Second Counterdefendant

Amir Sadik Ali Al Samarraie

Defendant/counterclaimant

Procedural Posture

Civil Real Property / Post Trial Judgment and Directions on Implementation

Legal Issues

  1. 1 Whether the Register should be corrected to reflect the true beneficial owners of the units held by a constructive trustee
  2. 2 Whether the Registrar has power under section 144 of the ADGM Real Property Regulations 2024 to correct the Register in these circumstances
  3. 3 Whether correction of the Register would prejudice the rights of the registered owner or any other person

Ratio Decidendi

Where a registered owner holds property as a constructive trustee for another, and the Register is therefore incorrect, the Registrar must correct the Register under section 144 of the ADGM Real Property Regulations 2024 to substitute the true owners, provided no prejudice is caused to the registered owner or third parties, especially where the registered owner had actual or constructive knowledge of the error.

Court Disposition

Orders granted for correction of the Register and issue of new title deeds to the Unit Owners; no order as to costs unless application made by 17 March 2026.

Orders

  • Paragraphs 4 to 7 of the Order of 4 July 2025 and paragraphs 1 to 5 of the Order of 24 December 2025 vacated and replaced.
  • Within 7 days, Claimant to pay applicable fees to ADGM RA to correct the Register and issue new title deeds for Units 2701, 1307, and 1315.