Civil Law and UAE: Mistake in Contract Formation

1. Introduction

Mistake in contract formation occurs when one or both contracting parties have an incorrect understanding of an essential fact, the subject matter, the identity of a contracting party, a material characteristic, or, in certain circumstances, the law applicable to the transaction.

Under the UAE civil-law system, mistake is treated as a defect affecting consent. The important question is not simply whether a person misunderstood something, but whether the mistake is sufficiently material or essential to justify annulment or another contractual remedy.

A major point for current UAE law is that Federal Decree-Law No. 25 of 2025 promulgating the Civil Transactions Law came into force on 1 June 2026. The current provisions on mistake are principally Articles 162–165. (UAE Legislation)

The basic structure is:

Mistake → Defective Consent → Annulment/Correction → Restitution or Other Consequences

2. Legal Meaning of Mistake

A mistake exists where the contracting party's understanding of the circumstances differs materially from reality.

Examples include:

believing one property is being purchased when another is actually identified;

believing the contract concerns one type of transaction when it concerns another;

misunderstanding an essential characteristic of the subject matter;

entering a contract because of an incorrect understanding of the identity of the other contracting party;

making a qualifying mistake concerning the law;

making a substantial calculation or drafting error.

However:

Not every mistake invalidates a contract.

The law distinguishes between material/essential mistakes and ordinary errors that do not justify avoidance.

3. Current UAE Statutory Framework

The current Civil Transactions Law contains the following important provisions.

Article 162 — Essential mistake

A contracting party who falls into an essential mistake may request annulment if the other contracting party:

made the same mistake;

was aware of the mistake; or

could easily have detected it.

For donation contracts, the law provides a special rule under which annulment may be requested without regard to the other party's knowledge or participation. (UAE Legislation)

Article 163 — Material mistake

A mistake is material where it is so serious that the party would have refrained from entering into the contract had the mistake not occurred.

The law specifically identifies mistakes concerning:

an essential desired characteristic of the thing; and

the identity or essential characteristic of the other contracting party where that identity/characteristic was the principal reason for contracting. (UAE Legislation)

Article 164 — Mistake of law

A party may seek annulment for a mistake concerning the law where the conditions for a qualifying factual mistake are satisfied, unless the law provides otherwise. (UAE Legislation)

Article 165 — Calculation or writing error

A mere error in:

calculation; or

writing

does not invalidate the contract.

Instead:

The error is corrected. (UAE Legislation)

4. Essential Mistake vs Ordinary Mistake

This distinction is fundamental.

Example

A buyer thinks he is purchasing Villa A, but the contract legally identifies Villa B.

This may constitute a serious mistake concerning the subject matter.

By contrast:

The contract says AED 1,000,000 instead of AED 1,000,001 because of a simple typographical error.

That may be a correctable writing/calculation error rather than a basis for invalidating the whole contract.

5. Mistake as a Defect of Consent

Contract formation requires genuine agreement between the parties.

The classical structure is:

Offer + Acceptance + Agreement on Essential Matters → Contract

But where consent is seriously defective:

Apparent Agreement → Defective Consent → Legal Challenge

Mistake therefore operates at the level of consent, rather than merely contractual performance.

6. Mistake Concerning the Identity of the Contract

A person may believe that they are entering one type of contract while legally entering another.

Example

A party believes that a document is merely a:

“non-binding memorandum of understanding”

when the document actually contains binding purchase obligations.

The court must examine:

wording;

circumstances;

conduct;

contractual structure;

communications;

objective legal effect.

A sufficiently fundamental mistake concerning the identity or nature of the transaction may affect validity.

7. Mistake Concerning the Subject Matter

This is one of the clearest categories.

Examples:

wrong property;

wrong shares;

wrong goods;

wrong parcel;

wrong quantity;

wrong asset;

wrong technical specification.

Example

A contract is intended to transfer Plot 101, but the documentation identifies Plot 110.

The legal consequences depend upon:

whether the error is genuinely material;

whether the parties shared the mistake;

whether one party knew;

whether the error can be objectively corrected;

the surrounding circumstances.

8. Mistake Concerning an Essential Characteristic

Article 163 recognizes a mistake concerning a desired attribute of the subject matter that is essential to the consideration of the parties, taking into account the circumstances and good faith. (UAE Legislation)

Example

A buyer purchases a machine believing it has a particular production capacity that is fundamental to the transaction.

If that characteristic was essential to the bargain, the mistake may be legally significant.

But a minor difference in colour or an incidental characteristic may not be sufficient.

9. Mistake Concerning Identity of the Other Contracting Party

Sometimes the identity of the contracting party is itself fundamental.

For example:

A collector intends to purchase an artwork directly from the artist but instead contracts with an unrelated person, where the artist's identity was the principal reason for the transaction.

If identity was fundamental to the contract, the mistake may become legally relevant.

The key question is:

Was the identity or characteristic of the other party a principal reason for entering into the contract?

10. Mistake of Law

Article 164 introduces an important rule concerning mistake as to law.

A party may seek annulment where the legal mistake satisfies the conditions applicable to a qualifying factual mistake, unless the law provides otherwise. (UAE Legislation)

This should not be confused with a simple argument:

“I did not know the law.”

Ordinary ignorance of law does not automatically allow a party to escape contractual obligations.

The statutory conditions remain important.

11. Calculation Error

Article 165 provides a specific rule:

A mere error in calculation or writing does not affect the validity of the contract; it is corrected. (UAE Legislation)

Example

The parties agree on:

1,000 units × AED 50 = AED 50,000

but the written document accidentally states:

AED 5,000

If the evidence clearly establishes that AED 50,000 was intended, the issue may be treated as a calculation/writing error rather than grounds to invalidate the entire contract.

This principle promotes contractual stability.

12. Mistake and Misrepresentation

Mistake must be distinguished from misrepresentation/deceit.

Mistake

The incorrect belief may arise without intentional deception.

Misrepresentation

One party causes or contributes to the other party's mistaken belief through misleading conduct.

The distinction matters because a contract may be challenged under different legal provisions depending upon how the mistaken belief arose.

13. Mistake and Fraud

Consider two situations.

Situation A — Innocent mistake

Seller honestly believes the machine has a capacity of 1,000 units per hour.

Buyer believes the same.

Later it is discovered that the capacity is only 600 units.

This may involve mistake.

Situation B — Fraudulent representation

Seller knows the machine only produces 600 units but deliberately tells the buyer it produces 1,000.

This may involve deceit/misrepresentation, not merely mistake.

Thus:

Mistake concerns incorrect belief; fraud involves wrongful deception producing the belief.

14. Mistake and Duress

Mistake is also different from duress.

Mistake

“I agreed because I misunderstood an essential fact.”

Duress

“I agreed because unlawful pressure compelled me.”

Both can affect consent, but their legal requirements differ.

15. Mistake and Exploitation

Mistake should also be distinguished from exploitation/gross unfairness concepts.

A person may:

misunderstand the transaction;

be deceived;

be pressured; or

enter an extremely unfair bargain.

The court must identify the correct legal doctrine rather than treating all defective consent as “mistake.”

16. Knowledge of the Other Party

A central feature of Article 162 is the position of the other contracting party.

Annulment for an essential mistake may be requested where the other party:

made the same mistake;

knew of the mistake; or

could easily have detected it. (UAE Legislation)

This prevents a party from easily escaping a contract based upon a purely private and insignificant misunderstanding.

Example

A buyer secretly misunderstands a technical specification that was clearly disclosed.

If the seller had no reason to know of the misunderstanding, the buyer's position is substantially different from a situation where the seller knew exactly what the buyer misunderstood.

17. Shared Mistake

A shared mistake occurs when both parties have the same incorrect understanding.

Example

Both parties believe that a particular licence is valid.

They conclude a business-transfer contract on that basis.

Later, they discover that the licence had already expired.

This may create a much stronger mistake argument than a purely unilateral misunderstanding.

18. Unilateral Mistake

A unilateral mistake occurs where:

One party is mistaken but the other is not.

The current UAE law does not make every unilateral mistake sufficient for annulment.

Article 162 specifically requires the relevant relationship between the mistake and the other party's:

mistake;

knowledge; or

ability to easily detect the mistake. (UAE Legislation)

Therefore:

Unilateral mistake + no relevant knowledge/detectability = much weaker case for annulment.

19. Gross Negligence and Risk Allocation

Modern contractual law generally prevents a party from using its own careless conduct to escape every contractual obligation.

This is especially visible in DIFC jurisprudence concerning mistake.

In Gjurd v Gizella (DIFC) Ltd [2016] DIFC SCT 081, the court considered whether the mistaken party had been grossly negligent and whether the risk of the mistake should have been borne by that party. The court found that relying on information supplied by the landlord was not, on the facts, gross negligence. (DIFC Courts)

This is DIFC jurisprudence rather than mainland precedent, but it provides a useful comparative illustration.

20. Mistake and Contractual Confirmation

A party who discovers a possible mistake does not necessarily have unlimited freedom to continue performing and later attempt to invalidate the agreement.

Conduct after discovery may be relevant.

For example:

continuing to accept benefits;

making payments;

affirming the agreement;

remaining silent for a substantial period;

performing contractual obligations.

These facts can affect the credibility and legal availability of a later challenge.

21. Mistake and Digital Contracts

Modern contracts may be formed through:

email;

electronic signatures;

online platforms;

click-wrap agreements;

digital wallets;

smart contracts.

A mistake can occur in any of these environments.

Example

A company representative clicks “accept” believing that the document is a quotation, but the electronic document actually contains a binding guarantee.

The legal issue becomes:

Was there a legally relevant mistake concerning the nature or essential terms of the contract?

Electronic evidence may be critical in answering this question.

22. Mistake in Automated/Smart Contracts

Smart contracts create additional problems.

Suppose the parties intend:

Transfer 100 tokens

but a coding or input error causes:

Transfer 10,000 tokens.

The technical transaction may execute automatically.

But:

Blockchain execution does not necessarily determine the underlying civil-law consequences.

The court may have to distinguish:

Code execution
from
legal intention

Evidence may include:

source code;

transaction records;

wallet records;

communications;

audit logs;

expert reports.

23. Mistake in M&A Transactions

Mistake can become especially important in mergers and acquisitions.

Examples:

incorrect valuation;

wrong ownership information;

mistaken debt amount;

mistaken regulatory status;

wrong asset identification;

incorrect shareholding percentage;

misunderstanding of consideration.

However, sophisticated M&A agreements often contain:

warranties;

representations;

indemnities;

disclosure schedules;

entire-agreement clauses;

risk-allocation clauses.

These provisions can affect whether a party can later rely on mistake.

24. Mistake in Real-Estate Contracts

Real-estate transactions are particularly susceptible to mistakes concerning:

plot numbers;

boundaries;

area;

title;

permitted use;

development rights;

property identity;

ownership.

The court may examine title records, plans, correspondence, valuation reports and expert evidence.

A mistake concerning the identity of the property itself can be substantially more serious than a minor clerical error.

25. Mistake in Banking and Finance

Financial contracts can involve:

interest calculations;

loan amounts;

guarantees;

collateral;

maturity dates;

payment schedules;

securities.

A calculation mistake does not automatically invalidate a financing agreement.

Article 165's principle concerning mere calculation/writing errors is therefore important. (UAE Legislation)

The court must distinguish:

mistake affecting consent

from:

clerical/calculation error capable of correction.

26. Mistake and Rectification

Rectification means correcting the written document so that it reflects the parties' actual agreement.

This is conceptually different from declaring the contract void or annulling it.

Three different possibilities

A. Contract valid + clerical error

→ Correct the error.

B. Fundamental mistake affecting consent

→ Annulment may be available.

C. Deception caused the consent

→ Misrepresentation/deceit remedies may arise.

The remedy must correspond to the legal defect.

27. Case Laws

Because mainland UAE reported judgments specifically devoted to mistake are comparatively limited and older judgments often refer to the former 1985 Civil Transactions Law, the most reliable approach is to distinguish:

UAE-law authorities dealing directly with mistake; and

DIFC/ADGM decisions applying or analysing UAE-law mistake principles.

DIFC and ADGM decisions are not binding mainland UAE precedents.

Case 1 — Khaled Salem Musabeh Humaid Al Mheiri v John Cameron

[2025] DIFC CA 008

This is one of the most useful recent authorities.

The dispute concerned an indemnity agreement and allegations that consent had been affected by deceit or mistake.

The Court of Appeal considered UAE Civil Code Articles 194 and 195, which under the former law dealt with:

fundamental mistakes concerning the identity of the contract, its conditions or subject matter; and

mistakes concerning non-essential characteristics. (DIFC Courts)

The Court ultimately focused on the deceit aspect and did not decide the mistake defence itself because the first-instance reasoning had resolved the case on deceit.

Importance

It nevertheless confirms the UAE-law structure distinguishing:

fundamental mistake → stronger contractual consequence

from:

mistake concerning a non-essential characteristic → different remedy.

28. Case 2 — Khaled Salem Musabeh Humaid Al Mheiri v El Araj & John Cameron

[2021] DIFC CFI 057

This first-instance decision directly considered UAE-law mistake.

The defendant argued that he had signed an indemnity agreement under mistaken beliefs concerning:

shares he expected to receive;

another person's participation in a similar agreement; and

payment of certain loans.

The court considered Articles 194 and 195 of the UAE Civil Code. (DIFC Courts)

Importance

The case demonstrates how the court examines whether the mistaken belief concerned matters sufficiently fundamental to affect consent.

Revision point

Mistake must be connected to a matter sufficiently important to the decision to contract.

29. Case 3 — NMC Healthcare Ltd (in Administration) v Dubai Islamic Bank PJSC

[2023] ADGM CFI 042

This case is particularly important because it directly analysed UAE-law mistake and rectification.

The court considered whether the parties' contractual documentation reflected their true agreement and discussed the UAE Civil Code rules concerning mistakes in the subject matter and characteristics of the contract. (ADGM)

The court noted the distinction between mistakes falling under the former Articles 194/195 and the separate issue of rectification.

Importance

It demonstrates:

A mistaken written document does not automatically mean that the contract should simply be rewritten.

The precise statutory remedy must be identified.

30. Case 4 — Gjurd v Gizella (DIFC) Limited

[2016] DIFC SCT 081

This is a direct DIFC mistake case.

The dispute concerned the mistaken identification of the location and size of leased premises.

The court applied Article 37 of the DIFC Contract Law and found that the mistake was sufficiently important that a reasonable person would not have entered the agreement had the true circumstances been known. The landlord had caused the mistake through incorrect identification. (DIFC Courts)

The court also considered whether the tenant's conduct amounted to gross negligence.

Importance

It provides a very clear example of:

mistake concerning the identity/essential characteristics of contractual subject matter.

31. Case 5 — Halston v Hazel (DIFC Branch)

[2017] DIFC SCT 086

This case concerned a calculation error in a compromise agreement.

The court applied Article 37 of the DIFC Contract Law and considered whether the mistaken calculation was sufficiently important to justify avoidance. The court concluded that the mistaken provision could be avoided because the circumstances satisfied the relevant requirements and the other party could not fairly rely on the error. (DIFC Courts)

Importance

It demonstrates that a calculation mistake can become legally significant where it is sufficiently fundamental and the statutory requirements for avoidance are satisfied.

Comparison with current UAE law

Under current UAE mainland law, however, Article 165 expressly provides that a mere calculation or writing error is corrected rather than treated as automatically invalidating the contract. (UAE Legislation)

Therefore, the DIFC case should not be mechanically transplanted into mainland UAE law.

32. Case 6 — Gjurd v Gizella: Remedy

The same Gjurd decision is particularly useful because the court addressed the consequence of mistake.

After finding the contract voidable/void for mistake under the DIFC Contract Law, the court considered restitution as the appropriate remedy. (DIFC Courts)

Importance

It demonstrates the broader principle:

When a contract is successfully avoided because of a qualifying defect in consent, the parties may have to be restored, as far as legally possible, to their pre-contractual position.

33. Case 7 — Ahmed Seddiq Mohamed Samea Almutawa v Mohamed Seddiq Mohamed Samea Al Mutawa

[2023] DIFC CFI 095

This case involved an alleged misunderstanding concerning the consideration payable for shares.

The defendant argued that he misunderstood the nature of the consideration.

The court rejected the argument because:

the contractual language was clear;

the consideration was expressly stated;

the entire-agreement clause was relevant;

subsequent conduct was inconsistent with the alleged misunderstanding; and

there was no sufficient evidence that the other party knew or should have known about the alleged mistake. (DIFC Courts)

Importance

This is an excellent illustration of why:

“I misunderstood the contract” is not by itself enough.

The court examines the document, surrounding circumstances, conduct and the statutory requirements for mistake.

34. Case 8 — Dimension B+ Ltd v Saleh Abdelkarim Hussain Abdelrahman Almaazmi

[2024] DIFC CFI 094

The court stated the general principle that a person who signs an integrated written agreement is normally bound by it even if the person did not read or understand it, unless a recognized vitiating factor such as:

fraud;

misrepresentation;

duress; or

fundamental mistake

is established. (DIFC Courts)

Importance

This case demonstrates the threshold for transforming:

non-reading/non-understanding

into:

legally recognized mistake.

Mere failure to read a contract is ordinarily not enough.

35. Case 9 — Amjad Hafeez v Damac Park Towers Company Ltd

[2014] DIFC CFI 002

This case involved allegations of misrepresentation and deceit concerning an apartment and contractual plans.

Although it was not ultimately a simple mistake case, it is relevant to defective consent because it demonstrates the importance of properly identifying and pleading the precise basis of the alleged defect. (DIFC Courts)

Importance

A claimant should distinguish between:

mistake;

misrepresentation;

fraud/deceit;

contractual breach.

Different legal requirements and remedies may apply.

36. Case 10 — Lals Holdings Ltd v Emirates Insurance Company & Siaci Insurance Brokers

[2024] DIFC CA 002

The DIFC Court of Appeal discussed the correction of contractual errors as part of contractual interpretation and emphasized that correction requires a sufficiently clear error and clarity about the correction needed. (DIFC Courts)

Importance

It is useful for distinguishing:

interpretive/drafting correction

from:

fundamental mistake affecting consent.

This distinction is particularly useful in complex commercial contracts.

37. Case-Law Table

38. Effect of Mistake on Contract

The consequence depends upon the type of mistake.

Fundamental/essential mistake

Potentially:

Annulment

Non-essential/material characteristic

Potentially:

Cancellation/annulment according to statutory requirements

Calculation/writing error

Generally:

Correction rather than invalidity

Fraud-induced mistake

Potentially:

Avoidance + other available remedies

Thus:

Classification determines remedy.

39. Mistake and Good Faith

Article 163 expressly refers to the circumstances and requirements of good faith when assessing whether a characteristic is essential. (UAE Legislation)

Good faith is therefore important in determining whether a purported mistake is genuinely material.

Example

A seller knows that the buyer's entire decision depends upon a particular characteristic but remains silent while the buyer contracts under a serious misunderstanding.

That fact can materially change the legal analysis.

40. Burden of Proof

A party alleging mistake generally needs to establish the factual foundation for the claim.

Evidence may include:

contract;

emails;

WhatsApp messages;

negotiations;

technical specifications;

expert reports;

property records;

valuation reports;

invoices;

witness testimony;

electronic signatures;

subsequent conduct.

The court does not ordinarily accept:

“I misunderstood.”

without evidence establishing what was misunderstood and why the mistake legally matters.

41. Entire Agreement Clauses

Commercial contracts often contain:

“This agreement constitutes the entire agreement between the parties.”

Such a clause may make reliance on previous communications more difficult, depending on the applicable law and the nature of the alleged defect.

The Almutawa decision demonstrates how an entire-agreement clause, clear contractual wording and subsequent conduct can undermine a later assertion of misunderstanding. (DIFC Courts)

However, such clauses should not automatically be treated as eliminating every statutory ground for invalidity.

42. Mistake and Professional Parties

Courts may examine the circumstances of sophisticated commercial parties differently from those of inexperienced consumers.

Relevant circumstances may include:

legal advice;

professional expertise;

negotiations;

due diligence;

disclosure;

contractual risk allocation.

This does not mean that sophisticated parties can never rely on mistake.

It means that the factual question of whether a mistake was genuinely material and legally protected may be more difficult to establish.

43. Practical Example

Facts

Company A agrees to purchase 40% of Company B.

The agreement states:

Purchase price = AED 40 million.

Company A later claims:

“We believed AED 40 million represented the total price for 40%, but we now understand that it was an additional payment.”

Analysis

Step 1 — Contract language

What does the agreement actually say?

Step 2 — Materiality

Was the alleged misunderstanding fundamental?

Step 3 — Knowledge

Did Company B know or should it easily have detected the mistake?

Step 4 — Conduct

Did Company A make instalment payments according to the disputed interpretation?

Step 5 — Entire agreement

Does the agreement contain an entire-agreement clause?

Step 6 — Evidence

What do negotiations and contemporaneous documents establish?

Step 7 — Remedy

Is this actually a qualifying mistake, or merely an attempt to reinterpret a clear bargain?

This closely resembles the reasoning illustrated by Almutawa v Almutawa. (DIFC Courts)

44. Practical Example: Real Estate

A buyer signs a contract believing the property is 1,500 square metres.

The actual registered property is 1,050 square metres.

Possible issues

Was area essential to the bargain?

Was the buyer's mistake material?

Did the seller know?

Could the buyer easily have discovered it?

Were official plans supplied?

Was the difference a clerical error?

Can the contract be corrected?

Should the contract be annulled?

This resembles the reasoning in Gjurd v Gizella, where location and size of leased premises were considered sufficiently important to constitute a relevant mistake under DIFC law. (DIFC Courts)

45. Mistake vs Interpretation

These concepts must be separated.

Interpretation

“What does the contract mean?”

Mistake

“Did my consent become legally defective because I misunderstood an essential matter?”

Rectification/correction

“Does the written document contain an error that should be corrected to reflect the legally relevant agreement?”

A court should not automatically convert a disagreement about contractual meaning into a mistake claim.

46. Mistake in Contract Formation: Decision Tree

A useful examination decision tree is:

Was a contract apparently concluded?

↓ Yes

Was there a mistake?

↓ Yes

Was it essential/material?

↓ Yes

Would the party have refused to contract if the truth were known?

↓ Yes

Did the other party share the mistake, know it, or easily detect it?

↓ Yes

Does any statutory exclusion apply?

↓ No

Possible annulment

If the mistake is merely:

writing/calculation error

→ Correction under Article 165

47. Key Differences

48. Important Examination Principles

Mistake is a defect of consent.

Not every mistake invalidates a contract.

Article 162 concerns essential mistake.

Article 163 defines material mistake.

Article 164 deals with qualifying mistake of law.

Article 165 deals with calculation and writing errors.

A material mistake must be sufficiently serious that the party would not have contracted if the truth had been known.

Knowledge or easy detectability by the other party is important.

Identity can be material when it was the principal reason for contracting.

An essential characteristic of the subject matter can constitute a material mistake.

Mere failure to read a contract normally does not establish fundamental mistake.

Subsequent conduct can be important evidence.

Mistake must be distinguished from fraud, misrepresentation, duress and contractual breach.

Mistake and rectification are different legal concepts.

DIFC/ADGM cases are persuasive/comparative only for mainland UAE disputes unless the relevant jurisdiction's law applies.

49. Short Exam Answer

Mistake in contract formation under UAE civil law is a defect of consent arising when a contracting party has an incorrect understanding of an essential aspect of the transaction. Under the current Civil Transactions Law, Federal Decree-Law No. 25 of 2025, Articles 162–165 regulate essential mistake, material mistake, mistake of law and errors in calculation or writing. An essential mistake may justify annulment where the other party shared the mistake, knew of it or could easily have detected it. A mistake is material where the party would have refrained from contracting had the truth been known. Mistakes concerning an essential characteristic of the subject matter or the identity of the contracting party can be significant. A mere calculation or writing error normally results in correction rather than invalidity. (UAE Legislation)

Important authorities include Al Mheiri v Cameron [2025] DIFC CA 008, Al Mheiri v El Araj & Cameron [2021] DIFC CFI 057, NMC Healthcare v Dubai Islamic Bank [2023] ADGM CFI 042, Gjurd v Gizella [2016] DIFC SCT 081, Halston v Hazel [2017] DIFC SCT 086, Almutawa v Almutawa [2023] DIFC CFI 095, and Dimension B+ v Almaazmi [2024] DIFC CFI 094. These authorities illustrate the importance of materiality, the other party's knowledge, contractual wording, subsequent conduct, and the distinction between fundamental mistake and simple drafting or calculation error.

50. Final Revision Formula

Mistake in UAE Contract Formation = Incorrect Belief + Materiality + Causal Importance to Consent + Relevant Knowledge/Detectability + Proof → Appropriate Statutory Remedy

And remember:

Fundamental mistake → possible annulment
Material mistake → possible annulment subject to statutory conditions
Mere calculation/writing error → correction
Fraud-induced mistake → analyse under misrepresentation/deceit provisions as well

Most important current-law point: For contracts governed by UAE mainland law today, use Articles 162–165 of the 2025 Civil Transactions Law rather than automatically quoting the old Articles 193–197 of the repealed 1985 Civil Code. Older cases remain useful for jurisprudential reasoning, but their statutory references must be translated into the current 2026 framework.