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Resolving disputes when contracts, assets or the other side are in another country. Led by a WONE Global Partner where one is named. Elsewhere, WONE Global confirms on request whether a vetted Associate firm can act.
Professional knowledge centre
When a cross-border contract goes wrong, the result depends less on who is right than on where the case is heard and whether the decision can be enforced where the other side's assets are. The choice is between national courts, international commercial courts such as the DIFC Courts, ADGM Courts and the SICC, arbitration under the New York Convention, and mediation. Recent changes have shifted the balance: the UK's Arbitration Act 2025 amendments took effect on 1 August 2025, the HCCH 2019 Judgments Convention entered into force for the UK on 1 July 2025, and the UAE acceded to the Singapore Convention on Mediation in October 2026 with effect from April 2027. India, the UAE, Saudi Arabia and Singapore are not parties to the 2019 Judgments Convention, so arbitration remains the most portable route across the main markets.
Source-checked research100% of statements checked against a source56 checked against an official source3 checked against a secondary sourceChecked 2026-10-19Not yet professionally reviewed
Dispute planning starts at signing. The dispute clause fixes the forum, the seat, the language and the procedural law, and each choice has consequences for interim relief, costs, time and enforcement. A judgment is enforceable abroad only through a treaty, a reciprocity regime or a fresh action, and these vary by pair of countries; an arbitral award can be enforced in all 172 New York Convention states, subject to narrow refusal grounds and any reciprocity or commercial reservations.
The modules below compare commercial courts, arbitration seats and enforcement under the New York Convention, enforcement of foreign judgments, mediation and the Singapore Convention, interim relief and asset preservation, and official costs and time limits. They cover India, the UAE (onshore, DIFC and ADGM), Saudi Arabia, Singapore, the UK, the US (federal and state), Germany and France. Only official figures are given for fees and time limits; where an institution's rules or fee schedule could not yet be checked, that is listed as a gap rather than estimated.
Several of the main markets now offer specialist commercial courts that work in English and apply common-law procedure, including the DIFC Courts and ADGM Courts in the UAE and the SICC in Singapore, alongside the long-established Commercial Court in London. India, Saudi Arabia, Germany and France have specialised commercial courts or chambers within their national systems. The choice of court matters because it fixes language, procedure and, above all, how far the judgment travels.
Questions on this topic
10 statements on commercial courts
Arbitration is the most portable form of dispute resolution across the main markets because all eight are parties to the New York Convention, which has 172 parties. The seat decides the supervising court and the law on challenges; the Convention governs enforcement elsewhere, with narrow refusal grounds. Reservations matter: India applies the Convention only to awards from notified reciprocating territories and commercial relationships, and Saudi Arabia only to awards made in other contracting states.
Questions on this topic
10 statements on arbitration and the new york convention
Court judgments travel less easily than arbitral awards. Within the EU they circulate almost automatically; the HCCH 2019 Judgments Convention now links the EU and the UK and a small number of other states, but not India, the UAE, Saudi Arabia, Singapore or the United States. Elsewhere enforcement depends on reciprocity statutes, bilateral arrangements or a fresh action, and Gulf courts add attestation and public policy requirements.
Questions on this topic
10 statements on enforcing foreign judgments
Mediation is becoming a required or court-encouraged step rather than an optional extra. India requires pre-institution mediation for most commercial suits, English courts can order ADR, and EU law makes mediated settlements enforceable and protects limitation periods during mediation. Cross-border enforcement of mediated settlements depends on the Singapore Convention: Saudi Arabia and Singapore are parties, the UAE joins from April 2027, and India, the UK and the US have signed but not ratified.
Questions on this topic
10 statements on mediation and the singapore convention
Interim relief protects assets and evidence before a final decision. English courts can grant worldwide freezing injunctions and support arbitrations seated abroad; Indian courts can grant interim measures in support of foreign-seated arbitrations unless excluded; UAE and German law let both courts and tribunals order interim measures. The UK's 2025 reforms extended court support to emergency arbitrators and non-parties. Speed and the right forum are everything.
Questions on this topic
9 statements on interim relief and asset preservation
Only figures published by courts and legislatures are given here. Court fees range from a percentage of the claim, as in London and the DIFC, to milestone fees in the SICC and a special contribution for large claimants in France's new economic activities courts. Statutory time limits shape arbitration too: India's twelve-month target for awards, short windows to challenge awards in England, India and the UAE, and a 60-day period for UAE enforcement orders.
Questions on this topic
10 statements on costs and time
Worked example, from official sources
An Indian manufacturer supplies a Dubai-based distributor under a contract negotiated by the manufacturer's UK subsidiary. Should the dispute clause choose the DIFC Courts, SIAC arbitration seated in Singapore or LCIA arbitration seated in London, and what does enforcement look like in India, the UAE and the UK?
| Forum | Enforcing in India | Enforcing in the UAE (onshore) | Enforcing in the UK | Key official figures |
|---|---|---|---|---|
| DIFC Courts (judgment) | DIFC lists a convention with India; Indian route not confirmed here | Execution judge after MOFA attestation (route for DIFC judgments onshore not confirmed) | DIFC lists reciprocal arrangement with London courts; UK 1933 Act only for designated countries | Filing fee 5% up to USD 500,000 (min USD 5,000); SCT up to AED 500,000 |
| SIAC, Singapore seat (award) | New York Convention; India enforces awards from notified territories; narrow public policy test | New York Convention, no UAE reservations shown | New York Convention; refusal only on s103 grounds | Singapore applies the Convention on reciprocity; 172 parties |
| LCIA, London seat (award) | New York Convention; notified territory check; s9 interim relief available | New York Convention, no UAE reservations shown | Domestic award; challenge within 28 days | 28-day challenge window; English law governs the arbitration agreement unless chosen otherwise |
Result on these facts
For a claimant needing to reach assets in onshore Dubai and possibly India, an arbitral award seated in Singapore or London travels on firmer, treaty-based ground than a DIFC Courts judgment: all three countries apply the New York Convention, the UAE without reservations, and India's public policy review is narrow. Between SIAC and LCIA the enforcement picture in India and the UAE is similar on the points researched; the difference lies in the seat's supervisory law (London brings the 2025 English reforms and a 28-day challenge window) and in institutional rules and fees not confirmed here. The DIFC Courts suit parties who want a court with published fees and Dubai proximity, but the route for their judgments into India and the UK should be confirmed before relying on it.
Confirm India's notified territories, the current SIAC and LCIA rules and fees, the onshore route for enforcing DIFC judgments and any UAE conditions for recognising foreign judgments, and take advice on the specific clause wording before signing.
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
The DIFC Courts state that their judgments can be enforced abroad through treaties such as the GCC Convention and the Riyadh Convention, conventions listed with China, India and France, and reciprocal arrangements with commercial courts including those in New York, Singapore, London and Hong Kong. DIFC Courts enforcement page; the page notes that these routes do not apply to the ratification or recognition of arbitral awards.
The page names the conventions with China, India and France without quoting them; how an Indian court treats a DIFC judgment was not confirmed on an Indian source.
To enforce a judgment issued abroad, the original judgment must be attested by the UAE Ministry of Foreign Affairs, and judgments are executed under the supervision of an execution judge at the Court of First Instance. Onshore courts; recognition conditions are in the Civil Procedure Code and were not reviewed.
Reused from ae-disputes-009.
Under the Foreign Judgments (Reciprocal Enforcement) Act 1933, money judgments of recognised courts in countries designated by Order in Council for reciprocity can be registered in the UK if final and conclusive, but not judgments for taxes, fines or penalties. Applies only to countries covered by an Order in Council; judgments from other countries generally require separate proceedings.
The list of designated countries, the Administration of Justice Act 1920 regime and common-law enforcement were not confirmed. Reused from gb-disputes-g17.
The DIFC Courts Court of First Instance filing fee for a money claim is 5% of the claim value up to USD 500,000 (minimum USD 5,000), with lower marginal rates above that, rising to a fixed USD 130,000 for claims over USD 50 million; an appeal notice costs USD 5,000. DIFC Courts Schedule of Fees (2023 edition); the filing fee is paid in three instalments (35%, 35%, 30%). Small Claims Tribunal: 5% of claim value, minimum USD 100 (2% for employment claims).
The DIFC Courts comprise a Small Claims Tribunal, a Court of First Instance with specialist divisions (including an Arbitration Division, a Technology and Construction Division and a Digital Economy Court) and a Court of Appeal whose decisions are final. DIFC Courts. The Small Claims Tribunal hears non-employment claims up to AED 500,000, and up to AED 1 million where all parties elect it in writing.
Reused from ae-disputes-g09.
The New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards has 172 parties. Count shown on the UNCITRAL status page when checked; all eight main markets are parties.
Saudi Arabia's entry carries only the reciprocity declaration; the UAE entry shows no declarations.
India signed the New York Convention on 10 June 1958, ratified it on 13 July 1960 and has applied it since 11 October 1960, with reservations limiting it to awards made in another contracting state and to differences arising from relationships considered commercial under Indian law. Convention on the Recognition and Enforcement of Foreign Arbitral Awards (1958); India's declarations correspond to footnotes (a) and (c) of the UNCITRAL status table.
Reused from in-disputes-001.
A foreign award under Indian law is an award on commercial differences made on or after 11 October 1960 under a written agreement to which the New York Convention applies, in a territory that the Central Government has declared by notification in the Official Gazette to be a territory to which the Convention applies. Section 44, Arbitration and Conciliation Act 1996 (Part II, Chapter I). Central law.
Consolidated text hosted by the IIAC; the cover reads 'Last update 12-3-2021' although the file name refers to 27.01.2023. India Code could not be fetched. Any amendment after March 2021 was not checked. The list of notified territories was not checked. Reused from in-disputes-g06.
An Indian court may refuse to enforce a foreign award as contrary to the public policy of India only where it was induced or affected by fraud or corruption, contravenes the fundamental policy of Indian law or conflicts with the most basic notions of morality or justice, and the test does not allow a review on the merits. Arbitration and Conciliation Act 1996, section 48(2)(b) and Explanations 1 and 2. Central law.
The UAE acceded to the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards on 21 August 2006, with entry into force on 19 November 2006, and the status table shows no declarations or reservations. Federal; applies to recognition and enforcement of foreign arbitral awards.
Reused from ae-disputes-g01.
In England, Wales and Northern Ireland, recognition or enforcement of a New York Convention award may be refused only on the listed grounds: incapacity, invalid arbitration agreement, lack of proper notice or inability to present the case, excess of jurisdiction, irregular composition or procedure, award not binding or set aside at the seat, non-arbitrability or public policy. Arbitration Act 1996, section 103(1) to (3). The resisting party must prove the section 103(2) grounds.
Singapore acceded to the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards on 21 August 1986, with entry into force on 19 November 1986, and applies it on the basis of reciprocity. Under the reciprocity declaration Singapore applies the Convention only to awards made in the territory of another contracting state.
The New York Convention contracting-states list also shows accession on 21 August 1986 and the reciprocity declaration. Reused from sg-disputes-004.
Part I of the Arbitration and Conciliation Act 1996 applies where the place of arbitration is in India, and, unless the parties agree otherwise, its provisions on interim measures by courts (section 9), court assistance in taking evidence (section 27) and related appeals also apply to international commercial arbitrations seated outside India. Section 2(2) and proviso. Central law.
Consolidated text hosted by the IIAC; the cover reads 'Last update 12-3-2021' although the file name refers to 27.01.2023. India Code could not be fetched. Any amendment after March 2021 was not checked. Reused from in-disputes-g01.
A court challenge to an award or appeal on a point of law under sections 67 to 69 of the Arbitration Act 1996 must be brought within 28 days of the applicable date, which is normally the date of the award or, where there was an arbitral appeal, review or material correction, the later date set out in the Act. Section 70(3) to (3B), as amended from 1 August 2025.
Under new section 6A of the Arbitration Act 1996, an arbitration agreement is governed by the law the parties expressly agree applies to it or, failing that, the law of the seat; choosing a law for the main contract is not by itself an express choice for the arbitration agreement. Does not apply to arbitration agreements arising from standing offers in treaties or non-UK legislation (investor-state cases).
Reused from gb-disputes-g07.
Parties with no DIFC connection may use the DIFC Courts if they agree in writing, before or after the dispute arises, through specific, clear and express provisions. DIFC Courts. Claims up to AED 500,000 can go to the Small Claims Tribunal.
Reused from ae-disputes-g08.
The HCCH 2019 Judgments Convention has 33 contracting parties, including the EU and its Member States (in force from 1 September 2023) and the United Kingdom (from 1 July 2025); India, the UAE, Saudi Arabia and Singapore are not listed, and the United States signed on 2 March 2022 without ratifying. Convention of 2 July 2019 on the Recognition and Enforcement of Foreign Judgments in Civil or Commercial Matters. Other parties include Ukraine, Uruguay, Albania, Montenegro and Andorra.
The status table showed a last-updated date of 13 May 2025 while listing later entry-into-force dates; recheck before relying on it.
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She is a lawyer, graduated from the Faculty of Law and Social Sciences of the University of Buenos Aires. She took his first steps in the nation's judiciary, in the National Labor Court, where he developed a rapid caree…
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Attorney at Law. Co-founder of the law firm. Provides litigation services to banks and advises corporate clients in international trade. Supervises the work of the Litigation Department and the International Desk. Chair…
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Kampala · UgandaWONE Global Partner · Uganda
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Lusaka · ZambiaWONE Global Partner · Zambia
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