This paper traces how Dubai’s dual-court system progression toward judicial comity and coordination over the past year. A key step in transforming the jurisdictional conflict mechanism was the replacement of the Joint Judicial Committee with the Conflict of Jurisdictions Tribunal. The Tribunal’s early decisions already reflect a balanced approach, reconciling jurisdictional conflict with judicial restraint, and even confirming the DIFC Courts’ authority to grant protective measures in support of onshore proceedings.

Complementing this institutional reform, Article 14(C) of the Law No. 2 of 2025 codifies judicial comity by empowering the DIFC Courts to decline jurisdiction where another UAE court has issued a final, enforceable judgment. This was applied for the first time in long running litigation in Union Insurance v IPMR, where the DIFC Court’s granted an indefinite stay in deference to an onshore Sharjah judgment, despite having previously confirmed their own jurisdiction over the same dispute. 

Together, these developments reflect a judicial system increasingly defined not by conflict, but by coordination and comity.

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.