The Dubai Conflicts of Jurisdiction Tribunal Continues to Define the Boundaries of DIFC and Onshore Dubai Court Jurisdiction in Arbitral Award Recognition and Enforcement

On 20 April 2026, the Conflicts of Jurisdiction Tribunal (CJT) issued its ruling in Guangzhou Salvage v Global Marketing Systems DMCC (CJT Application No. 1 of 2026), confirming the distinction between procedures applying to recognition (or ratification) and enforcement and the respective allocation of the DIFC and Dubai Courts’ competence in relation to these stages.

Application No. 01/2026 concerned an arbitral award rendered under the rules of the Singapore Chamber of Maritime Arbitration (SCMA) in a Singapore-seated arbitration. The award creditor sought ratification and enforcement before the DIFC Courts (Case No. ARB-029-2025), while the award debtor filed annulment proceedings before the Dubai Courts (Case No. 13/2026). Both actions concerned the same award, the same parties, and the same legal basis.

The Guangzhou decision confirmed that award creditors can seek recognition and ratification of a foreign arbitral award in the DIFC Courts, even where there is no nexus to the DIFC and regardless of the applicable arbitral seat. The CJT reasoned that Article 42 of the DIFC Arbitration Law permits any arbitral award, irrespective of the jurisdiction in which it was rendered, to be recognised as binding within the DIFC without requiring any prior independent connection to the DIFC. The CJT relied on Article 14(A)(5) of DIFC Courts Law No. 2 of 2025, which confers exclusive jurisdiction on the DIFC Courts over applications for ratification or recognition of arbitral awards under the DIFC Arbitration Law, noting that this provision is expressed in general terms unrestricted by the seat of arbitration.

However, the CJT went on to hold that the DIFC Courts did not possess compulsory enforcement jurisdiction over the award in question as the award debtor had no assets in or connection to the DIFC (the award debtor’s assets were located in onshore Dubai). Under Article 31(3) of the DIFC Courts Law, the DIFC Execution Judge's jurisdiction is confined to cases where the enforcement falls upon an award debtor that is a DIFC body, establishment, or licensed entity, or any entity situated within the DIFC. The CJT therefore ruled that enforcement jurisdiction lay with the Dubai Courts as the competent execution authority outside of the DIFC.

In relation to the annulment action before the Dubai Courts, the CJT found that the Dubai Courts lacked jurisdiction to entertain the annulment claim because the parties agreed to arbitrate under SCMA rules, the underlying contract was governed by English law, the award was rendered in Singapore, and there was no evidence that the parties agreed to subject the arbitration to the UAE Federal Arbitration Law, which allowed no basis for the Dubai Courts to assert jurisdiction.

The Guangzhou decision builds on two other recent CJT decisions in Serene Resources DMCC v Energen DMCC (CJT Application No. 2 of 2025) and Ajay Sethi vs Power Pac Marketing Management (CJT Application No. 7 of 2025). In Serene, the CJT held that the onshore Dubai courts had “general jurisdiction” over a Dubai-seated Singapore International Arbitration Centre arbitration and was the “most suitable” forum to hear set-aside and enforcement applications relating to the award, thus finding that recognition and enforcement actions commenced by the award creditor in the DIFC could not proceed. In Sethi, which concerned a DIFC-seated arbitration, the CJT held that where the seat is the DIFC, the DIFC Courts are the courts with jurisdiction to hear the dispute and that ratification and enforcement proceedings that had been commenced in the Dubai Courts could not proceed.

For practitioners navigating Dubai’s dual-court system, the CJT rulings offer welcome guidance on the arbitral recognition and enforcement stages that occur regularly but which have at times felt uncertain. The CJT’s decision in Guangzhou may serve as a deterrent against use of delaying tactics by obstructive award debtors looking to frustrate enforcement by initiating parallel proceedings before multiple forums, which would be a welcome consequence.