Real Estate Laws and Regulations: A Comparative Analysis between India, US, UK and UAE

Abstract

In this article, the author aims to delve into the regulations, rules and applicable laws dealing with real estate and property ownership in countries such as India, United States (“US”), United Kingdom (“UK”) and United Arab Emirates (“UAE”). Furthermore, while establishing certain laws in the following countries, the article also will provide a comparative analysis of the same. In India, the laws that deal with ownership and trade of lands in particular are the Contracts Act, Transfer of Property Act and Real Estate Regulation Act, 2016. In the UK, the Law of Property Act, 1925 (“LA”) and the Land registration Act, 2005 governs primarily with the real estate regulations. In the US, there are three types of laws which are federal, state and local regulations and in this paper, we’ll be analyzing the Real Estate Settlement Procedures Act, 1974 (“RESPA”) for the purposes of the paper. Finally, in UAE, for the purposes of this paper and limitations, we will analyze the Dubai Real Estate Regulatory Authority (“DRERA”), 2007, which also solidified the legislation and jurisprudence of real estate issues. This article will attempt to put a clear picture on the laws stated above and a contrast among them with different sections and jurisprudence.