THE LAST 365 DAYS IN THE DIFC COURTS

I. INTRODUCTION

  1. The DIFC stands at the forefront of Dubai’s transformation into a global nexus for finance, innovation, and professional services. Over the last two decades, it has built an ecosystem that blends regulatory certainty with commercial agility – an equilibrium that has made it a model for emerging financial centres worldwide. Today, the DIFC is home to more than 8,000 active registered companies, and its banks and capital market institutions manage approximately US$ 240 billion in assets.[i] With Dubai ranked 11th globally in the Global Financial Centres Index 2025,[ii] the DIFC continues to cement Dubai’s reputation as a leading centre of international commerce.
  2. At the same time, the DIFC Courts continue to anchor themselves at the intersection of modern dispute resolution. The DIFC Courts have not only kept pace with global judicial standards but have also actively defined new benchmarks for procedural innovation and cross-border enforcement. The past 365 days reflect a jurisdiction in motion, marked by legislative reform, evolving jurisprudence, and visible maturity in advocacy and judicial reasoning. The momentum is mirrored in performance, with case values exceeding AED 17.5 billion (as of October 2025), underscoring the Courts’ growing global relevance and user confidence.[iii]
  3. The DIFC Courts also saw a renewal of leadership. Justice Wayne Stewart Martin (formerly the Chief Justice of Western Australia) took over as Chief Justice of the DIFC Courts, marking a seamless transition that combines continuity with a fresh, international perspective.[iv] Soon after, Justices Thomas Bathurst (Australia), Sapna Jhangiani KC (Singapore), and Roger Stewart KC (England and Wales) joined the bench, adding further depth of global experience and common law expertise.[v]
  4. This edition of the Litigation Framework in the DIFC - The Last 365 Days by Singularity Legal builds on the foundations laid in earlier publications and comprises of a five-part series reflecting on the major developments and trends that have shaped the Courts’ jurisprudence and practice over the past year.[vi] Together, these papers offer a forward-looking perspective on how legislative and judicial developments have reshaped litigation and arbitration practice in the DIFC and what they signal for practitioners, businesses, and other stakeholders engaging with one of the world’s most dynamic commercial court systems.
  5. In the paragraphs that follow, I walk through some of the key updates covered in this year’s series, spanning legislative and institutional reforms, evolving jurisdictional boundaries, landmark enforcement decisions, and the Courts’ growing body of jurisprudence on remedies and judicial conduct, each reflecting the DIFC’s steady evolution as a mature and globally oriented judicial forum.

II. THE LEGAL ARCHITECTURE: NEW LAWS AND INSTITUTIONAL REFORMS

  1. The past year’s legislative and institutional reforms mark more than procedural evolution. They signal a conscious recalibration of the DIFC Courts’ role within Dubai’s broader judicial landscape. Each reform, from statutory codification to digital modernisation, reflects a system aimed at embedding clarity, accessibility, and innovation at every level of its operation.
  2. Perhaps the most defining development of the year has been the enactment of the New Judicial Authority Law (Law No. 2 of 2025) (“New JAL”) – a piece of legislation that redefined the very architecture of the DIFC judicial system. Over the years, the Courts have been celebrated for their agility and pragmatic approach. The New JAL takes that accumulated judicial wisdom and commits it to statute. It expands the jurisdictional gateways that have long anchored the DIFC’s international reach and, importantly, in Article 14(7), retains and broadens the “any written law” gateway, now extending to legislation in force across Dubai and to international treaties to which the UAE is a party.[vii] Equally significant is the revamped enforcement framework, which introduces the role of the Enforcement Judge[viii] and consolidates all enforceable instruments within a single concept – the Enforcement Writ.[ix] These are not just cosmetic changes; they speak of a maturing system that is as focused on clarity and coherence as it is on efficiency. These reforms are discussed in detail along with their structural implications in the chapter titled “JAL 2.0 – The DIFC Courts Reboot.”
  3. Complementing these reforms is the launch of the DIFC Courts’ Mediation Centre, a new forum designed to give parties a structured and cost-effective path to settlement before entering litigation.[x] The Mediation Centre aligns with international best practice, providing a confidential and court-supervised environment for mediation. Under the New JAL, signed settlement agreements approved by the Mediation Centre and the settlement agreements ratified by the DIFC Courts in the course of proceedings are recognised as Enforcement Writs.[xi] The initiative reinforces the DIFC’s role as a holistic dispute-resolution hub – one that values resolution as much as adjudication and continues to evolve toward a more efficient, settlement-oriented judicial framework.
  4. Running parallel to these reforms is the introduction of Practice Direction 1 of 2025 – Access to Justice in Employment Disputes, which reflects the same institutional philosophy: that a modern court must be accessible and proportionate. It takes aim at some long-standing disincentives that made employment litigation in the DIFC daunting for individuals – the risk of adverse costs, the public nature of hearings, and non-anonymised judgments, which raised concerns about the future employability of the employees involved in the proceedings. The new PD changes that dynamic. It introduces a default rule that each party bears its own costs, allows proceedings to be conducted in private by default, and provides for anonymised judgments. The balance is carefully drawn: employees are spared the chilling effect of potential costs orders, while employers still have limited grounds to recover costs, where justified. The shift may not satisfy every purist of open justice, but it recognises the human reality of employment disputes in a close-knit jurisdiction like the DIFC. Above all, it’s a practical reform – one that lowers barriers to access and reflects a court that is willing to evolve with the community it serves.[xii] 
  5. This growing commitment to accessibility is also reflected in the DIFC’s litigation-funding landscape. The recent successful conclusion of a funded claim ([2023] CFI 081) backed by Lexolent Litigation Fund I SP ACH[xiii] underscores how funding mechanisms can expand access to justice while operating within the DIFC’s transparent ethical regime.
  6. Even as the DIFC continues to strengthen its legal infrastructure, it has not lost sight of innovation. In a forward-looking step, the DIFC Courts have rolled out an AI-enabled Case Management System, equipped with an intelligent conversational assistant designed to modernise legal workflows and improve access to case data.[xiv] This emphasis on technology is further reflected in the Courts’ expanding suite of digital services. At GITEX Global 2024, the DIFC Courts launched the “Digital Assets Will”, empowering individuals to distribute their digital holdings, including ETH, BTC, MATIC, USDC, and USDT, through a secure, non-custodial DIFC Courts wallet. The platform allows users to reallocate assets freely during their lifetime, with final distributions made as specific gifts. These digital wills can also be stored within Tejouri.[xvi] 
  7. Building on this digital trajectory, the DIFC Courts have also launched a Notary Service, providing three options for users – an automated self-service, a live virtual system, and an in-person service. The service will notarise English language documents only and is the first-of-its-kind service in the UAE.[xvii]

III. PUSHING BOUNDARIES: JURISPRUDENTIAL DEVELOPMENTS IN THE DIFC

  1. Alongside structural reforms, the DIFC Courts’ jurisprudence over the past year has continued to test and refine the boundaries of their jurisdiction. The resulting body of case law, spanning issues of conflict of laws, inter-court comity, and the limits of sovereign and judicial power, illustrates a maturing court system increasingly confident in balancing autonomy with cooperation across jurisdictions.
  2. A key example of this evolution came in Korek Telecom,[xviii] where the DIFC Court of Appeal formally recognised that the Act of State (“AOS”) doctrine forms part of the DIFC law. Building on the decisions in Fal Oil v SEWA[xix] and Pearl Petroleum,[xx] which had confirmed that sovereign immunity was part of the DIFC law through English common law principles, the Court affirmed that the AOS doctrine likewise applies within the DIFC. The Court applied the doctrine in a manner consistent with international public policy and the pro-enforcement ethos of the DIFC Arbitration Law, holding that the doctrine could not shield corrupt conduct from scrutiny. In doing so, the Court drew on the U.S. law derived Kirkpatrick exception, not because of its origin but because of its conceptual coherence and normative fit with the UAE public policy and the DIFC’s institutional role. Importantly, the Court foreshadowed the operation of the 2024 amendment to the DIFC Application Law that expands the DIFC’s reference point from English to transnational common law. While not applicable retrospectively, the Court recognised its significance as signalling a decisive shift from derivative reliance on English law toward the development of a comparative, homegrown common law framework. The chapter titled “The Act of State Doctrine and the DIFC’s Turn Toward Transnational Common Law,” explores this decision in detail, which marks a pivotal moment in defining how international doctrines will evolve within the DIFC’s distinct legal identity.
  3. This growing jurisprudential maturity is equally visible in cases testing the interface between the DIFC and onshore courts, where issues of concurrent jurisdiction and comity have continued to evolve. The chapter titled “Untangling Conflict between DIFC and Onshore Courts”, discusses how Dubai’s move from the old Joint Judicial Committee (“JJC”) to the new Conflict of Jurisdictions Tribunal (“CJT”) has changed the playbook. No more automatic stays on a mere referral; the CJT first decides competence and works to 30-day timelines, with decisions that now operate as binding precedent across both court systems – a notable shift toward coherence in a mixed civil/common-law environment. Its remit is broader than the JJC, and early outcomes show a more balanced, supervisory-seat-first approach: DIFC, where the seat is DIFC; Dubai, where the seat is Dubai; and no “conflict” just because parties pursue parallel enforcement of the same judgment. The CJT has also affirmed that the DIFC Courts can grant supportive interim relief (e.g., freezing orders) for non-DIFC-seated arbitrations without straying into the merits.
  4. Running alongside, Article 14(C) of the New JAL now codifies comity inside the DIFC’s own statute: even where a gateway is satisfied, the Court may step back if there’s an agreed forum or a final onshore judgment capable of execution in the DIFC (see, Union Insurance v IPMR).[xxi] But that restraint is not a surrender of inherent tools: the DIFC Court of Appeal has stressed that CJT references are for genuine, same-parties/same-subject conflicts, while observing that mere reference to CJT does not preclude the DIFC Courts’ ability to issue anti-suit or other protective orders where appropriate.[xxii] Net effect: a steadier equilibrium – coordination when duplication looms, assertion when party autonomy or the supervisory seat demands it.
  5. That same spirit of interpretive clarity was also evident in Ashok Amir Chand v Zurich International,[xxiii] wherein the claimant tried to anchor the dispute in the DIFC by pointing to a clause saying that the company submitted to the “non-exclusive jurisdiction of any competent legal authority in the UAE”. The defendant pushed back, arguing that this wording did not go far enough to bring the case within the DIFC’s reach. The Court took a step back and looked at earlier decisions like Investment Group[xxiv] and Goel v Credit Suisse,[xxv] where phrases such as “Courts of the UAE” had been read broadly enough to include the DIFC Courts. But it drew an important distinction here – the clause used the words “competent legal authority”, which, the Court held, denotes a court that already has jurisdiction under the law, not one that becomes competent just because the parties say so. However, since the DIFC gateways were not met, the Court dismissed the claim for want of jurisdiction.
  6. A similar sense of jurisdictional precision came in Oswin v Otila,[xxvi] the DIFC Court held that the law of the seat governs the arbitration agreement, not the governing law of the underlying contract — a position also reflected in the amended English Arbitration Act. The joint venture agreement in question provided for arbitration under the DIFC-LCIA Rules with the seat in the DIFC, while another clause conferred exclusive jurisdiction on the Abu Dhabi Courts. The Court held that DIFC law governed the arbitration agreement and that choosing the DIFC as the seat allows the DIFC Courts to exercise it supervisory and interim jurisdiction. Importantly, it found that the Abu Dhabi clause, being expressly subject to the arbitration provisions, did not oust those powers.

IV. TURNING POINTS IN ENFORCEMENT: KEY DECISIONS FROM THE YEAR

  1. The DIFC Courts are widely recognised for their robust pro-enforcement stance, supporting both foreign and domestic judgments and awards. In particular, the past year has seen considerable expansion in the DIFC Courts’ enforcement jurisprudence. These are welcome developments and cement the international commercial character of the DIFC Courts in the region and globally.
  2. In keeping up with its reputation as an arbitration-friendly jurisdiction, the DIFC has dismissed attempts to set aside DIFC-issued recognition orders made in respect of foreign-seated arbitral awards. In an unpublished decision issued in Naqid v Najam,[xxvii] the CFI held that an award issued by an India-seated tribunal was executable in the DIFC on the basis of the India-UAE Judicial Cooperation Agreement for the mutual recognition and enforcement of judgments and awards. The CFI refused to set aside the recognition and enforcement order previously granted, despite the defendant’s insistence that such an order contravened Article 44 of the DIFC Arbitration Law. In doing so, the CFI confirmed that the defendant could only rely on set-aside grounds contained in the India-UAE Judicial Cooperation Agreement, and not on the DIFC Arbitration Law, following Article 24(2) of the DIFC Court Law No. 10 of 2004 (“Old Court Law”), which required the CFI to comply with the terms of applicable treaties entered into between the UAE and other foreign states. 
  3. The DIFC Courts’ pro-enforcement instincts were also on display in Standard Chartered PLC v Standard Chartered Bank,[xxviii] a decision by Deputy Chief Justice Ali Al Madhani that has quietly reshaped how recognition and enforcement actions begin in the DIFC. Traditionally, parties would commence with a Part 7 or Part 8 claim before seeking any enforcement order. But in this case, the Court took a more pragmatic path. Referring to earlier unreported rulings by former Chief Justice Hwang and Justice Wayne Martin, Justice Al Madhani confirmed that a foreign disclosure order issued under Article 31(4) of the New JAL could be recognised and enforced directly under Part 45 of the DIFC Rules as an ENF claim, without the extra procedural layers. The decision might seem technical, but its message is clear: the DIFC is prepared to prioritise substance over form when it comes to enforcement. It is another example of a court system that understands the urgency of commercial reality – and is willing to adapt its procedures to meet it.
  4. In the same pro-enforcement vein, Oaklen v Obadiah[xxix] turned the spotlight on how far the DIFC Courts are willing to go to make sure judgments are not only won, but actually enforced. The case raised a fascinating question – could the Courts compel foreign officers of a corporate judgment debtor to come before them under RDC Part 50 for an Examination of Judgment Debtor (“EJD”)? The officers pushed back, pointing to Masri v Consolidated Contractors[xxx] in the UK and the ADGM’s Rosewood Hotel v Skelmore Hospitality,[xxxi] both of which suggested such powers should stop at the jurisdiction’s borders. The DIFC Court took a different view. It found that the only thing that truly matters is whether the person qualifies as an “officer” under RDC 50.2(2)[xxxii] – not where they happen to live. It was a characteristically practical, pro-enforcement decision that reaffirmed the DIFC’s global outlook. But the story is not over yet. A renewed application for permission to appeal was granted in July, with the Court of Appeal deciding that recent guidance from the highest court in England and Wales makes this a question worth revisiting.[xxxiii] For now, the EJD order against one of the officers has been paused – but whichever way the appeal goes, the case has already cemented the DIFC’s willingness to test the limits in aid of enforcement.

V. SHAPING REMEDIES AND JURISDICTIONAL STANDARDS

  1. The DIFC Courts have consistently affirmed their strong jurisdiction to grant interim and final measures. As discussed in “The Evolving Landscape of Freestanding Injunctions in the DIFC”, this year’s jurisprudence has been particularly significant in clarifying the contours of that jurisdiction, primarily in the context of freezing orders. What began as an ominous restriction of the DIFC Courts’ powers to issue injunctions in support of an anticipated foreign judgment without a demonstrated nexus to the DIFC in Sandra Holding v Fawzi Musaed Al Saleh[xxxiv] was soon corrected by Carmon v Cuenda,[xxxv] which overruled Sandra Holding and restored the Courts’ wider injunctive reach. This trajectory was later reinforced through the enactment of the promulgation of the New JAL and the recent pronouncements in Trafigura v Gupta[xxxvi] and Techteryx Ltd v Aria Commodities DMCC,[xxxvii] which confirmed that asset-preservation relief may be granted where the foreign judgment is potentially enforceable in the DIFC. Yet the momentum met a moment of judicial restraint in the unpublished Nashrah decision, where the Court of Appeal declined to extend its freestanding jurisdiction to anti-suit injunctions in aid of foreign proceedings. The Court distinguished between asset-protection measures seen as ancillary to enforcement, and anti-suit injunctions, which it characterised as interferences with another forum’s jurisdiction. This reasoning may sit uneasily – an anti-suit injunction protecting a potential arbitral award, arguably serves the same enforcement-supportive function as a freezing order by safeguarding the integrity of the adjudicatory process. Nevertheless, this step back, following a series of expansive decisions, highlights the Court’s deliberate calibration between innovation and restraint.
  2. The Court’s innovation, however, is matched by a strict insistence on procedural discipline. In EFG (Middle East) Ltd v Marj Holding Ltd,[xxxviii] the CFI set aside a worldwide freezing order (“WFO”) on the basis that it was obtained by material non-disclosure, including a failure to highlight potential jurisdictional difficulties to the CFI, and because it was not sought in the standard form provided for under DIFC law. The omission of a business-expenses carve-out and the absence of a bank guarantee proved to be decisive. The CFI found these procedural failures in procuring the WFO far outweighed the substantive merit of such relief and refused its re-imposition. Despite the dismissal of the WFO, the CFI remained cognisant that the defendant’s failure to provide information as required under the WFO was deliberate and amounted to contempt of the CFI’s order. Even in circumstances where the underlying order was ultimately set aside, the CFI nonetheless found a non-compliant defendant guilty of contempt and fined him accordingly. The judgment serves as a reminder that the DIFC Courts’ expansive injunctive jurisdiction operates hand-in-hand with a demand for candour and precision.
  3. In Innovative Production v Innovation Factory Royal,[xxxix] the DIFC Court reinforced the importance of procedural discipline under the RDC. The defendant had filed its Acknowledgement of Service well beyond the 14-day deadline without seeking an extension, and the Court made clear that such timelines are not optional. Non-compliance can invalidate subsequent applications. Yet, even as it dismissed the jurisdiction challenge on procedural grounds, the Court went on to consider the merits. It held that the DIFC Courts did have jurisdiction under Article 14(B) of the New JAL, finding that the governing law clause, which provided for DIFC law, reflected the parties’ clear and express intention to submit disputes to the DIFC Courts.
  4. This balance between flexibility and rigour also defines the Courts’ approach to contractual remedies. In 7Ci Technologies,[xl] Justice Sir Jeremy Cooke took a firm yet pragmatic view on compensation, awarding not only statutory interest under the DIFC Law of Damages and Remedies but also additional damages under Article 17(3), a rarely invoked provision allowing recovery for foreseeable losses beyond simple interest. The Court held that the defendant’s sustained non-payment caused measurable harm beyond ordinary delay, reinforcing the principle that contractual obligations in the DIFC are to be meaningfully enforced, not merely acknowledged.
  5. Another example of the DIFC Courts’ pragmatic approach to global enforcement and their refusal to let procedural boundaries get in the way of substance came in SKAT v FFA Bank.[xli] Decided under the Old Court Law, the case involved an application by Denmark’s tax authority for Norwich Pharmacal relief against a DIFC-based bank to trace funds linked to fraud perpetrated on the SKAT. The bank tried to argue based on English law that such orders could not be made in support of proceedings outside the UK and that any assistance should be sought through formal judicial channels under the UK–UAE Treaty on Judicial Assistance. The Court took a different view. It held that the Courts’ power is entirely statutory – grounded in RDC 30.65 r/w Articles 32 and 34 of the DIFC Courts Law and Article 38 of the Law of Damages and Remedies and not borrowed from English law. On that basis, it granted the disclosure order, underscoring the DIFC’s willingness to step in where justice and cross-border cooperation demand it.
  6. In the past year, the DIFC has quietly built one of the most coherent legal infrastructures for digital assets anywhere in the region. It began with the DIFC Court of Appeal’s landmark decision in Huobi v Tabarak,[xlii] where the Court confirmed that cryptocurrencies such as Bitcoin are a form of legal property capable of being owned, transferred, and held in custody like any other asset. Drawing heavily on the UK Law Commission’s Digital Assets: Final Report, the Court endorsed the view that digital assets represent a third class of property – neither a thing in possession nor a thing in action – thereby bringing blockchain-based assets within the scope of the DIFC’s Personal Property Law and Law of Obligations.
  7. That recognition soon found statutory footing in the DIFC Digital Assets Law 2024 (Law No. 2 of 2024),[xliii] which expressly defines digital assets as intangible property, clarifies the concept of “control” as the functional equivalent of possession, and allows such assets to be the subject of security, recovery, and enforcement actions. The shift is more than definitional: it bridges the once-perceived gap between the code and the law. The same traditional reliefs of injunctions, tracing orders, proprietary claims, or execution against assets, can now be pursued in respect of digital holdings, regardless of where the underlying blockchain data is located.
  8. These developments are in line with the other DIFC Courts’ development in the digital sphere. In 2021, the Digital Economy Court was established. A specialist division within the DIFC Courts was created to handle disputes arising out of cutting-edge technologies such as blockchain, fintech, and AI. Its dedicated procedural framework, set out under Part 58 of the RDC, introduces streamlined mechanisms for managing complex, tech-related disputes, allowing cases to be handled by judges and experts familiar with the digital economy.[xliv]
  9. The DIFC Digital Economy Court in Techteryx[xlv] issued its first WFO involving reserves backing a US dollar-pegged stablecoin, under the New JAL. The order illustrates that digital assets are now not only recognised as property in principle but also protected through the same equitable and enforcement remedies long available for traditional assets. What was once a question of technological uncertainty is fast becoming a question of procedural strategy: whether to litigate or enforce in the DIFC may soon be less about jurisdictional convenience and more about accessing a court system expressly built to bridge digital markets with enforceable rights in the real world.
  10. The DIFC’s engagement with blockchain is not new. As far back as 2018, the DIFC Courts partnered with Smart Dubai to launch the world’s first Court of the Blockchain. An initiative aimed at using distributed ledger technology to verify and share court judgments for cross-border enforcement. That early vision of a more connected, transparent, and technology-enabled judicial ecosystem has steadily evolved into the DIFC’s current digital asset framework, which now sits at the forefront of legal innovation in the region.[xlvi]

VI. CHARTING THE ROAD AHEAD

  1. The trajectory is unmistakable: the DIFC Courts are shaping not just the future of dispute resolution in Dubai, but a new paradigm for cross-border commercial justice. The chapters that follow examine how each reform – legislative, procedural, and technological – which contributes to that broader vision of a judiciary built for the digital and global economy.
  2. The first Insight “JAL 2.0: The DIFC Courts Reboot” discusses the new phase of the DIFC Courts’ evolution with the enactment of the long-awaited and widely discussed the New JAL. It codifies well-established judicial practices while introducing notable reforms aimed at strengthening the Courts’ institutional coherence and international legitimacy. This paper provides an overview of the key developments with particular focus on its structural reforms, jurisdictional clarifications, and their implications for enforcement and dispute resolution strategies within and beyond the DIFC.
  3. The second Insight “The Act of State Doctrine and the DIFC’s Turn Toward Transnational Common Law” examines the DIFC Court of Appeal’s landmark decision in Korek Telecom v Iraq Telecom, which affirmed that the AOS doctrine formed part of DIFC law. In recontextualising the AOS doctrine to normatively fit with the DIFC's status as an international court, the decision positions the DIFC as a transitional and integrative common law jurisdiction. Although the Court held that the 2024 amendment to the DIFC Application Law (broadening the applicable sources of law from the laws of England and Wales to common law in general) did not apply retrospectively, its reasoning underscored the DIFC’s evolution from derivative reliance on English law to the development of its own common law – one that draws from global jurisprudence while aligning with the UAE public policy.
  4. The third Insight “The Evolving Landscape of Freestanding Injunctions in the DIFC” explores the pivotal developments that have framed the DIFC Courts’ injunctive landscape over the past year. The DIFC Courts have now determined that the decision in Sandra Holding v Al Saleh was overruled in Carmon v Cuenda, which confirmed that the DIFC Courts had the power to issue freezing orders in support of pending foreign proceedings. This found statutory recognition in the New JAL. In recent decisions – Trafigura v Gupta and Techteryx v Aria Commodities – the DIFC Courts affirmed that Article 15(4) of the New JAL permits the issuance of “suitable precautionary measures” to protect the integrity of an anticipated award or judgment enforceable within the DIFC. Nevertheless, questions of jurisdictional importance are rarely straightforward. The DIFC Courts’ recent decision in Nashrah v Najem & Nex (although in the context of the earlier Old Court Law) signals judicial hesitation to extend freestanding jurisdiction beyond asset-preservation measures ancillary to the DIFC Courts’ enforcement jurisdiction.
  5. The fourth Insight “Conflict between DIFC and Onshore Courts” traces how Dubai’s dual-court system progressed toward judicial comity and coordination over the past year. A key step in transforming the jurisdictional conflict mechanism was the replacement of the JJC with the CJT. The tribunal’s early decisions already reflect a balanced approach, reconciling jurisdictional conflict with judicial restraint, and even confirming the DIFC Courts’ authority to grant protective measures in support of onshore proceedings. Complementing this institutional reform, Article 14(C) of the New JAL codifies judicial comity by empowering the DIFC Courts to decline jurisdiction where another UAE court has issued a final, enforceable judgment. This was applied for the first time in long-running litigation in Union Insurance v IPMR, where the DIFC Court granted an indefinite stay in deference to an onshore Sharjah judgment, despite having previously confirmed its own jurisdiction over the same dispute. Together, these developments reflect a judicial system increasingly defined not by conflict, but by coordination and comity.

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[i] Dubai advances position as Middle East, Africa and South Asia’s leading global financial centre (20 October 2025) (see here)

[ii] GFCI Ranking 38th Edition (see here)

[iii] Dubai advances position as Middle East, Africa and South Asia’s leading global financial centre (20 October 2025) (see here)

[iv] Decree No. 58 of 2024 (see here)

[v] Issuance of Decree No. 59 of 2024 – Govt. of Dubai, Media Office (1 October 2024) (see here)

[vi] See, Singularity’s Insights here, and specifically the predecessor to this book titled ‘Litigation Framework in the DIFC and its implications for global enforcement and recovery strategies’ (see here)

[vii] Article 14(7), New JAL

[viii] Article 29, New JAL

[ix] Article 30, New JAL

[x] Article 13, New JAL; Launch of the DIFC Court’s Mediation Service Centre (see here)

[xi] Article 30(B)(4) & (5), New JAL

[xii] Practice Direction No. 1 of 2025: Access to Justice in Employment Disputes (9 October 2025) (see here)

[xiii] The first litigation fund to be based out of UAE

[xiv] DIFC Courts 2024 Statistics, at p.17 (see here); Accubits: Legal AI Agent for DIFC Courts (see here)

[xv] DIFC Courts launches Digital Assets Will (15 October 2024) (see here)

[xvi] The DIFC Courts’ cloud-based digital vault launched in 2022, which uses Distributed Ledger Technology to preserve confidentiality and ensure seamless transmission of data to designated beneficiaries under strict zero-knowledge privacy principles.

 DIFC Courts launches Notary Service (see here)

[xviii] Korek Telecom Company LLC & Another v Iraq Telecom Limited [2024] DIFC CA 016 (16 June 2025)

[xix] FAL Oil Company v Sharjah Electricity and Water Authority [2019] DIFC ENF 221 (16 February 2021)

[xx] Pearl Petroleum Company Ltd v The Kurdistan Regional Government [2017] DIFC ARB 003 (20 August 2017)

[xxi] Union Insurance Company PJSC v International Precious Metals Refiners LLC [2022] CFI 064/2022 (12 May 2025)

[xxii] Ivankovich v KJM Marine [2024] DIFC CFI 068 (26 Mar 2025); Nael v Niamh Bank [2024] DIFC CA 015 (9 January 2025)

[xxiii] Atul Ashok Amir Chand Dhawan v Zurich International Life Limited [2025] DIFC CFI 019 (9 September 2025)

[xxiv] Investment Group Private Limited v Standard Chartered Bank [2015] DIFC CA 004 (19 November 2015)

[xxv] Goel v Credit Suisse (Switzerland) Ltd [2015] DIFC CA 002 (26 April 2021)

[xxvi] Oswin v. Otila & Ondray [2025] ARB 032 (16 September 2025)

[xxvii] [2024] DIFC ARB 004 (24 December 2024). Singularity represented the successful award holder.

[xxviii] [2025] DIFC ENF 053

[xxix] Oaklen v Obadiah and (1) Ozias (2) Ori (3) Octavio [2023] DIFC ENF 269 (29 April 2025)

[xxx] Masri v Consolidated Contractors (No. 4) [2010] 1 AC 90

[xxxi] Rosewood Hotel Abu Dhabi LLC v Skelmore Hospitality Group LTD [2020] ADGM CFI 002

[xxxii] As defined in the unreported decision of the Court of Appeal in Oskar [2024] DIFC CA 009, cited at [15], Oaklen v Obadiah.

[xxxiii] (1) Ozias (2) Ori (3) Octavio v (1) Obadiah (2) Oaklen [2023] DIFC CA 269 (1 July 2025). 

[xxxiv] [54], Sandra Holding Ltd v Fawzi Musaed Al Saleh [2023] DIFC CA 003 (6 September 2023); The Insight titled ‘Obtaining Worldwide Freezing Orders in the DIFC: Freestanding and in aid of Enforcement’ examined the challenging implications of the DIFC Court of Appeal’s decision in Sandra Holding which found that the DIFC Courts could not issue injunctions, specifically WFOs in support of an anticipated foreign judgment without a demonstrated nexus to the DIFC.

[xxxv]  [155], Carmon Reestrutura-engenharia E Serviços Técnios Especiais, (Su) LDA v Antonio Joao Catete Lopes Cuenda [2024] DIFC CA 003 (26 November 2024)

[xxxvi]Trafigura Pte Ltd & Trafigura India Pte Ltd v Prateek Gupta & Ginni Gupta [2025] DIFC CA 001 (22 September 2025)

[xxxvii] DEC-001-2025 (unreported judgment); See ATCO, “Digital Economy Court’s First Worldwide Freezing Order: Al Tamimi & Company secures landmark relief to protect digital asset reserves” (see here). 

[xxxviii] [2025] DIFC CFI 029 (27 August 2025)

[xxxix] [2025] DIFC CFI 054 (15 October 2025)

[xl] [2025] DIFC CFI 003 (11 July 2025)

[xli]SKATTEFORVALTNINGEN (the Danish Customs and Tax Administration) v. FFA Private Bank (Dubai) Ltd. [2024] DIFC CFI (25 July 2024)

[xlii] Gate Mena DMCC (Formerly Known as Huobi OTC DMCC) and Anr. v Tabrak Investment Capital Limited [2023] DIFC CA 002 (13 June 2024)

[xliii] DIFC Digital Assets Law (see here)

[xliv] DIFC RDC Part 58 (see here)

[xlv] DEC-001-2025 (unreported judgment); See ATCO, ‘Digital Economy Court’s First Worldwide Freezing Order: Al Tamimi & Company secures landmark relief to protect digital asset reserves’ (see here). 

[xlvi] Courts of the Future: Courts of the Blockchain (see here)