This paper continues our five-part series on the litigation framework in the DIFC over the last 365 days, in the run up to the Dubai Arbitration Week 2025.

This paper examines the DIFC Court of Appeal’s landmark decision in Korek Telecom v Iraq Telecom Limited , which affirmed that the Act of State doctrine formed part of DIFC law. In recontextualising the AOS doctrine to normatively fit with the DIFC’s status as an international court, the decision positions the DIFC as a transitional and integrative common law jurisdiction. Although the Court held that the 2024 amendment to the DIFC Application Law (broadening the applicable sources of law from the laws of England and Wales to common law in general) did not apply retrospectively, its reasoning underscored the DIFC’s evolution from derivative reliance on English law to the development of its own common law – one that draws from global jurisprudence while aligning with UAE public policy.

To find out more, please register for the panel discussion on The Litigation Framework in the DIFC- The Last 365 Days on 10 November 2025, the opening day of the Dubai Arbitration Week 2025.