In 2011 the Dubai Court of Cassation confirmed that in order for a domestic arbitral award to be enforced, it must contain an operative part (i.e. a section which sufficiently particularises what has been decided and who is to pay what). Without this section the award is incomplete and unenforceable.

The Court of Cassation Decision 

In Real Estate Appeal No. 315 of 2011, the Dubai Court of Cassation confirmed a Court of Appeal decision to overturn the affirmation by the Court of First Instance of a domestic arbitration award. The Court of Appeal found that the Court of First Instance overlooked serious defects in the award, particularly the fact that the award did not include an operative part. The type of arbitration involved meant it was not possible for the Tribunal, having issued the Final Award, to explain or revise the award to include the operative part.