Unlike the UAE onshore courts, the Dubai International Financial Centre (DIFC) courts easily grant anti-suit injunctions and can automatically enforce anti-suit injunctions issued by foreign courts. The DIFC courts present more opportunities to challenge arbitral jurisdiction than the UAE courts as their procedural rules tend to reflect those of the English courts. The DIFC courts have been developing a robust line of jurisprudence in this regard; for example, the decision of the DIFC Court of First Instance in Multiplex Constructions v Elemec Electromechanical Contracting (November 2020), established a precedent for the DIFC courts to grant anti-suit injunctions should a party commence litigation in breach of an arbitration agreement.