Since the DIFC Courts opened in 2004, comparable courts have followed in Doha, Singapore, Abu Dhabi, Astana and Manama, with Oman’s yet to open. At first sight they have much in common: English-language proceedings, internationally experienced judges and familiar commercial procedures. Their differences lie deeper, in access to jurisdiction, relations with the national courts, interim relief and enforcement, and each reflects the purpose for which the court was built and the legal order it serves. This chapter compares the courts at each of these stages and considers what parties should weigh when choosing a forum. The DIFC Courts stand out for the breadth of their jurisdiction, though the right court ultimately depends on the parties’ circumstances. As these courts grow, each in its own way, they are together reshaping commercial law and giving cross-border disputes a home.

Authors: Prateek Bagaria, Natasha Kavalakkat and Sanchit Suri

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