Middle East countries have approached the problem of reforming civil and commercial laws by adopting laws which purportedly suit the needs of a modern, industrial society. This note will examine the countries of the Arabian peninsula, particularly Kuwait, Bahrain, Qatar, the United Arab Emirates, and Saudi Arabia, while making passing references to Jordan, Syria, Iraq, and Egypt. The thesis of the paper is that Egypt exercised and still continues to exercise a predominant position, practically, legislatively, and jurisprudentially in the Middle East, and particularly the Arabian peninsula. Consequently, the development and reform of civil and commercial law in the Middle East (at least in the countries mentioned above) is based on a mixture of European civil law and Shari'a, with little common law.
Ian Edge, Comparative Commercial Law of Egypt and the Arabian Gulf, 34 Clev. St. L. Rev. 129 (1985-1986)