A award creditor applied to the Dubai Courts Execution Judge to enforce an arbitral award which had been issued by the ICC in Paris.

The execution judge granted the exequatur and the award debtor appealed to the Dubai Court of Appeal which, in turn, upheld the execution judge's decision.

The Respondent appealed to the Dubai Court of Cassation on the grounds that the Court of Appeal judgment had erred by upholding the decision of the execution judge to grant the exequatur and argued that the Court of Appeal had relied on Article 88 of Cabinet Decision No. 57/2018 by deciding that international treaties ratified by the UAE were enforceable in respect of the enforcement of foreign judgments and arbitral awards even if conditions in Article 85 of Cabinet Decision No. 57/2018 were not met.