A Landmark with Consequences: The CJT’s Latest Decision and Its Implications for Enforcement within the DIFC

On 2 September 2025, the Conflicts of Jurisdiction Tribunal (CJT) issued a landmark decision in Serene Resources DMCC v Energen DMCC, holding that the DIFC Courts lacked jurisdiction to enforce a Dubai-seated SIAC award while set aside proceedings were ongoing in the Dubai Courts. The ruling underscores the primacy of the Dubai Courts as the “holder of general jurisdiction” and signals a shift in the enforcement framework within the DIFC, with significant implications for award creditors seeking to rely on the DIFC as a conduit jurisdiction.