Enforcement of English Court Judgments in Civil Proceedings

Overview

This Practice Note addresses the recognition and enforcement of English Court judgments in the DIFC Court as well as the “conduit” jurisdiction of the DIFC Court in facilitating the enforcement of an English Court judgment before the onshore Dubai Court, including developments in the case law of the Joint Judicial Committee.

Practical Guidance

The DIFC is an autonomous financial freezone created under Federal Law No. 8/2004 and exists as a separate jurisdiction within the UAE. Its jurisdiction extends to civil and commercial matters. The DIFC has its own laws in relation to issues including contract, tort, real property and employment, and has its basis in the English common law. It is an independent court with its own freestanding rules of civil procedure.

Enforcement of English court judgments at the DIFC

The DIFC Court has general jurisdiction to enforce foreign court judgments pursuant to article 7(6) of Dubai Law No. 12/2014 (the Judicial Authority Law) and article 24(1)(a) of DIFC Law No. 10/2004 (the DIFC Court Law).