This paper explores the pivotal developments that have framed the DIFC Courts’ injunctive landscape over the past year. The DIFC Courts’ have now determined that the decision in Sandra Holding v Al Saleh was overruled in Carmon v Cuenda, which confirmed that the DIFC Courts had the power to issue freezing orders in support of pending foreign proceedings. This found statutory recognition in Law No. 2 of 2025. In recent decisions – Trafigura v Gupta and Techteryx v Aria Commodities – the DIFC Courts affirmed that Article 15(4) of Law No. 2 of 2025 permits the issuance of “suitable precautionary measures” to protect the integrity of an anticipated award or judgment enforceable within the DIFC.

Nevertheless, questions of jurisdictional importance are rarely straightforward. The DIFC Courts’ recent decision in Nashrah v Najem & Nex (although in the context of the earlier Law No. 10 of 2004) signals judicial hesitation to extend freestanding jurisdiction beyond asset-preservation measures ancillary to the DIFC Courts’ enforcement jurisdiction.

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.