The Dubai International Financial Centre Court of Appeal recently held, in the case of DNB Bank ASA v Gulf Eyadah [CA-007-2015] (25 February 2016), that

“ a foreign judgment, when granted recognition in the DIFC Courts becomes a local judgment of the DIFC Courts and should therefore be treated as such by the Dubai Courts ”

This represents an important and landmark decision in relation to the jurisdiction of the DIFC Courts and is a positive step in recognising the international nature of the DIFC Courts.

      I.          Background

After obtaining judgment by the English Commercial Court requiring Gulf Eyadah Corporation & Gulf Navigation Holding PJSC (Defendants/Respondents) to pay US$8.7 million plus costs under various contracts, the Claimant/Appellant (DNB Bank ASA) sought the enforcement of the said judgment in the DIFC Courts.

The Defendants contested the jurisdiction of the DIFC Courts, inter alia , on the grounds that:

· there was no immediate nexus with the DIFC- the Defendants' assets were located onshore; and