The workers’ compensation Provision, originally included in the French Law of 1898 – which heavily influenced the labour Law in the UAE – once considered as a masterpiece of legal achievement , are now obsolete.

This is mainly due to the variations in the levels of the protection provided for in case of Civil accidents (such as traffic accidents) other than for injuries occurring in the scope of employment. In the first case, the victims are entitled to an expansive protection against the consequences of injuries, while injured workers have only the right to a lump sum compensation not exceeding a certain percentage of his wages.

The legislator – both inFranceand in the UAE- have attempted to improve the traditional system of workers’ compensation. But the fragmented solutions which have been introduced were not very successful.

The aim of this research is to expose the characteristics and the defects of the traditional system of workers’ compensation both in France and in the UAE, and to explore the possibilities of partial and comprehensive solutions