Wholesale Instant Transplants Through Transnational Legislative Dialogue?^*

This article argues that the SEZ (Special Economic Zone) ‘Abu Dhabi General Markets’ (ADGM), with its introduction of the English legal system as its own legal system, has entered into a grand experiment of transplants where private and constitutional law is largely indistinguishable. This is the first time in history where an entire legal system is transplanted without coercion. As it cannot survive on its own, the ADGM is in the process of what this author calls ‘transnational legislative dialogue’. Hence, along with the legal transplant itself it has, the ADGM has equally transplanted the institutions that sustain English law, including a synergy with private stakeholders, such as an extensive body of English-speaking legal professionals. It is argued that although the aim of the ADGM is to transplant English statutory law, the medium of communication between the speaker (English legal system) and the listener (fledgling ADGM legal system) is the common law. The constitutional relationship between the ADGM and its corporate citizens cannot but be predicated on norms that are as liberal and as flexible as the private laws that permeate the life of the ADGM. As a result, while this transplant seemingly only involves private law, it indirectly also encompasses constitutional norms of a liberal character.