28/11/2025

DIFC Courts post landmark decision limiting DIFC enforcement powers in support of Dubai Court judgments

In a landmark judgment handed down on 25 November 2025, the Dubai International Financial Centre (DIFC) Court has found that its enforcement jurisdiction under article 31(4) of the New DIFC Law, Dubai Law No. 2 of 2025, is limited to assets situated in the DIFC.

Dubai Law No. 2 of 2025 came into force earlier this year, introducing extensive changes to the judicial, administrative and jurisdictional mandate of the DIFC Courts.

In its latest judgment, ENF 185/2025, the court examined art 31(4) of the New DIFC Law, which sets out its jurisdiction to enforce judgments, orders and awards of local or foreign courts and arbitral tribunals.

The court rejected the judgment creditor’s argument that its enforcement jurisdiction under art 31(4) did not require the judgment debtor’s assets to be situated within the DIFC. Instead, it ruled that, while the DIFC Courts have jurisdiction to enforce Dubai Court judgments under art 31(4), the phrase “inside the DIFC” should be construed such that its enforcement jurisdiction “is limited to the subject matter being in the DIFC” and to “assets within the DIFC”.

Kevin Lee acted for the successful party, instructed by Sadique Mohd and Lee Li Wei from Al Aidarous.