A ministry or public body may issue a decision that directly affects you, such as refusing a licence, terminating an employee's service or imposing a disciplinary penalty. In these cases the law allows challenging an administrative decision in Qatar before the administrative courts, provided you respect short deadlines and set procedures.
The rules are set out in Law No. 7 of 2007 on the settlement of administrative disputes, as amended by Law No. 12 of 2013 and Law No. 15 of 2019. This guide explains which decisions can be challenged, the grievance and filing deadlines, and the administrative appeal stages.
Which administrative decisions can be challenged in Qatar?
Under the law, administrative bodies are ministries, other government agencies, and public authorities and institutions. A final administrative decision is one issued by an administrative body that the law empowers to decide a matter without approval from a higher authority, as well as decisions of the approving authority.
One or more Administrative Circuits, each of three judges, sit within the Court of First Instance and have exclusive jurisdiction over:
- Disputes over salaries, pensions, bonuses and allowances due to employees or their heirs, whatever their grade.
- Applications to cancel final administrative decisions on the promotion of employees at grade one and below or equivalent, on termination of their service, and disciplinary decisions concerning them.
- Applications by individuals and legal entities to cancel final administrative decisions, except those the law excludes.
- Compensation claims for the decisions in items 2 and 3, whether brought on their own or alongside a cancellation claim.
- Administrative contract disputes.
An administrative body's refusal or failure to take a decision it is required to take under laws and regulations is treated as an administrative decision.
Which decisions cannot be challenged before the Administrative Circuit?
The law excludes the following from cancellation applications brought by individuals and companies:
- Emiri orders, decisions and decrees.
- Decisions issued under Law No. 17 of 2002 on the protection of society.
- Decisions issued under laws on political asylum, permanent residency, and the entry, exit, residence and deportation of expatriates.
- Decisions on associations and private institutions, religious centres, printing and publishing, and newspaper and magazine licences.
- Licences for weapons, ammunition and explosives, and expropriation for public benefit.
- Decisions determining a voter's permanent address, and decisions on titles and affiliation to tribes and families.
On what grounds can an administrative decision be cancelled?
A cancellation application must be based on one of the following grounds:
- Lack of competence.
- A defect of form.
- Breach of laws and regulations, or error in applying or interpreting them.
- Abuse of power.
Applications by persons without a direct personal interest are inadmissible, as are requests to suspend a decision that are not combined with a request to cancel it.
What is the deadline to challenge an administrative decision in Qatar?
A cancellation claim must be filed within sixty days of the decision's publication in the Official Gazette or in bulletins issued by the administrative body, of its notification to the person concerned, or of proof that the person had actual knowledge of it.
A grievance to the administrative body interrupts this deadline. The body must decide the grievance within sixty days, and any rejection must give reasons. If sixty days pass without a reply, the grievance is treated as rejected, and the filing deadline runs from the date of the express or implied rejection.
- Cancellation claim
- Sixty days from publication, notification or actual knowledge
- Effect of a grievance
- Interrupts the filing deadline
- Time to decide a grievance
- Sixty days from submission; silence after that is an implied rejection
- Appeal against an Administrative Circuit judgment
- Sixty days from the date of judgment
- Cassation appeal
- Sixty days under Law No. 12 of 2005
A worked example
If you are notified of a decision and file a grievance before sixty days have passed, the deadline is interrupted. If the body does not reply within sixty days of the grievance, a new filing period starts from the date of that implied rejection. If an express rejection arrives earlier, the period runs from the date of the express rejection.
Is a grievance mandatory before filing a cancellation claim in Qatar?
A grievance is a condition of admissibility for decisions on the promotion of employees at grade one and below, on termination of their service, and on discipline. Claims to cancel those decisions are not accepted until a grievance has been made and the period for deciding it has expired. The grievance procedure is set by a decision of the Prime Minister.
Grievance procedures and deadlines laid down in other laws also apply, and a decision covered by them is not final and challengeable until those grievance stages are exhausted. In other cases a grievance is still useful, because it interrupts the deadline and may resolve the matter without litigation.
Does filing a claim suspend the administrative decision?
A cancellation claim does not automatically suspend the decision. If requested in the statement of claim, the Administrative Circuit may:
- Suspend the decision if the grounds appear serious enough to make cancellation likely and the consequences of enforcement may be irreversible, in cancellation claims brought by individuals and companies.
- Order all or part of the salary to continue to be paid until it rules on a claim to cancel a termination decision, if the circumstances justify it.
What is the Appellate Administrative Circuit in Qatar?
The Court of Appeal has an Appellate Administrative Circuit of three judges. It hears appeals against Administrative Circuit judgments, challenges to decisions on Shura Council and Central Municipal Council elections, and claims to cancel or seek compensation for decisions of disciplinary boards and administrative bodies with judicial functions.
Administrative Circuit judgments must be appealed within sixty days of the date of judgment. Where Law No. 7 of 2007 is silent, the Civil and Commercial Procedures Law and the law on cassation appeals in non-criminal matters apply. Judgments cancelling a decision are binding on everyone.
Steps to challenge an administrative decision in Qatar
- Obtain a copy of the decision or proof of the date of publication, notification or your actual knowledge.
- Check jurisdiction: is the decision final, and is it one of the excluded categories?
- Review the specific law under which the decision was issued for any grievance or committee stage you must go through first.
- Submit a written, reasoned grievance within the deadline and keep proof of the submission date.
- Track the sixty-day period for a response and record the date of any express or implied rejection.
- File the claim with the Administrative Circuit within sixty days of the rejection, including a request for suspension in the statement of claim if needed.
- Appeal within sixty days of the date of judgment if the ruling goes against you.
How we can help
Al Murqab Law Office can assess the administrative decision, calculate the deadlines, draft the grievance, and bring and pursue cancellation or compensation claims as part of our administrative law services. To see where administrative litigation fits in the wider system, read our guide to the Qatar court system, or book a legal consultation before your deadline expires.