Answer: No, they cannot. Intent must be proven.
According to Article 217 of Federal Decree-Law No. 38 of 2022 on Criminal Procedure, every conviction must be based on proof of guilt, including credible evidence of criminal intent (القصد الجنائي).
The UAE Federal Supreme Court has emphasized that:
- Strict liability (e.g., based on a person’s position, such as a director) is not permissible unless expressly provided by law;
- Intent must be proven, not presumed — even if the person did in fact send the document.
Relevant case law:
Case No. 799 of 2024 / Federal Supreme Court / Criminal