Civil Law and UAE Anti-Suit Injunction Principles

1. Introduction

An anti-suit injunction is a court order directing a party not to commence, continue, or pursue proceedings in another court or jurisdiction where doing so would improperly interfere with an agreed forum, arbitration agreement, or the administration of justice.

In the UAE, anti-suit injunctions require special analysis because the UAE is a mixed legal system containing:

• mainland UAE courts applying federal civil and procedural legislation;
• DIFC Courts, operating within a common-law-oriented framework;
• ADGM Courts, also operating on a common-law-oriented basis;
• arbitral tribunals seated in the UAE;
• arbitration agreements governed by UAE arbitration legislation or institutional rules.

Consequently, there is no single uniform UAE doctrine of anti-suit injunctions applicable identically in every court.

The strongest anti-suit jurisprudence in the UAE context has historically developed in the DIFC and ADGM, while mainland UAE courts approach parallel proceedings through jurisdictional, procedural, contractual and public-policy principles rather than simply adopting the English anti-suit model.

2. Meaning of an Anti-Suit Injunction

An anti-suit injunction is essentially an order of the form:

"You must not pursue proceedings in that other forum."

For example:

A and B agree:

"All disputes shall be resolved by arbitration seated in Dubai."

B nevertheless commences proceedings before a foreign court.

A may seek an order from the competent UAE court or arbitral forum restraining B from continuing the foreign litigation, where the applicable legal framework permits such relief.

The objective is generally to protect:

• the parties' jurisdiction agreement;
• an arbitration agreement;
• the chosen forum;
• the integrity of the court's jurisdiction;
• the effectiveness of dispute-resolution arrangements.

3. Anti-Suit Injunction vs Anti-Enforcement Injunction

These concepts should be distinguished.

Anti-suit injunction

Stops a party from:

• commencing proceedings;
• continuing proceedings;
• taking particular procedural steps in foreign litigation.

Anti-enforcement injunction

Targets the enforcement or implementation of a foreign judgment or award.

Anti-anti-suit injunction

An injunction issued by one court attempting to prevent a party from complying with another court's anti-suit injunction.

This can produce significant jurisdictional conflict.

4. Why Anti-Suit Injunctions Matter in the UAE

The UAE is an important jurisdiction for anti-suit disputes because commercial contracts frequently involve:

• UAE companies;
• foreign companies;
• arbitration clauses;
• DIFC or ADGM jurisdiction clauses;
• foreign governing laws;
• foreign courts;
• international arbitration institutions.

A typical dispute could involve:

UAE company → English-law contract → DIFC arbitration clause → foreign court proceedings.

The question then becomes:

Can a UAE court restrain the foreign litigation?

The answer depends heavily on:

1. the identity of the court;
2. the arbitration agreement;
3. the jurisdiction clause;
4. the applicable procedural law;
5. the seat of arbitration;
6. whether the foreign proceedings violate the parties' agreement;
7. comity;
8. whether the requested order is directed at the litigant rather than the foreign court.

5. Anti-Suit Injunction Is Usually Directed at the Party

An important conceptual point is that an anti-suit injunction ordinarily operates in personam.

The court is not necessarily saying:

"The foreign court has no jurisdiction."

Instead, it says:

"The defendant before this court must not pursue the foreign proceedings."

This distinction is particularly important for international comity.

The UAE court can protect its own jurisdiction or an arbitration agreement without necessarily claiming authority over the foreign sovereign court itself.

6. Anti-Suit Injunction and Arbitration

The strongest justification often arises where the parties have agreed to arbitration.

Suppose:

"Any dispute arising out of this contract shall be finally resolved by arbitration seated in Dubai."

One party later files a lawsuit in another country.

The other party may argue:

• the foreign litigation breaches the arbitration agreement;
• the parties promised to arbitrate;
• the foreign proceedings interfere with the arbitral process;
• the UAE court should protect the arbitration agreement.

This makes anti-suit relief closely connected with the principle of party autonomy.

7. Anti-Suit Injunction and Jurisdiction Clauses

Anti-suit relief may also arise from an exclusive jurisdiction clause.

Example:

"The courts of the DIFC shall have exclusive jurisdiction."

If a party starts proceedings in another country, the contractual promise may provide the basis for seeking relief.

However, an exclusive jurisdiction clause and an arbitration clause are not identical.

The court must examine:

• exact wording;
• exclusive or non-exclusive character;
• disputes covered;
• applicable law;
• whether the foreign proceedings fall within the clause.

8. DIFC Courts and Anti-Suit Relief

The DIFC Courts are particularly important because their procedural and jurisdictional system is strongly influenced by common-law principles.

The DIFC framework can therefore accommodate remedies resembling the English anti-suit injunction.

But this does not mean that every DIFC anti-suit order automatically binds a foreign court.

The order generally operates against the party subject to the DIFC Court's jurisdiction.

9. ADGM and Anti-Suit Relief

The ADGM Courts likewise operate under a common-law-oriented framework.

The Application of English Law Regulations and ADGM procedural framework make English common-law principles relevant where properly applicable.

However, the court must still determine:

• jurisdiction;
• applicable ADGM legislation;
• contractual terms;
• arbitration framework;
• comity;
• connection with ADGM.

10. Mainland UAE Courts

The position is more nuanced in mainland UAE courts.

The mainland courts operate primarily through:

• UAE federal legislation;
• Civil Transactions Law;
• Civil Procedure legislation;
• UAE Arbitration Law;
• jurisdictional rules;
• public policy;
• applicable international conventions.

The traditional English common-law anti-suit injunction should therefore not simply be assumed to exist in identical form in every mainland UAE court.

Instead, the court may address the problem through:

• jurisdictional objections;
• enforcement of arbitration agreements;
• dismissal/stay mechanisms where available;
• contractual obligations;
• recognition and enforcement rules;
• procedural principles.

11. Anti-Suit Injunction and Arbitration Agreement

The most important practical principle is:

A valid arbitration agreement should generally be respected.

If the parties agreed to arbitrate, commencing court proceedings elsewhere may amount to a breach of the contractual obligation to arbitrate.

The court must nevertheless determine whether:

• a valid arbitration agreement exists;
• the dispute falls within its scope;
• the agreement is binding on the claimant;
• the foreign litigation concerns the same dispute;
• there are grounds affecting validity or enforceability.

12. Kompetenz-Kompetenz

Anti-suit disputes frequently interact with kompetenz-kompetenz.

This principle allows an arbitral tribunal to determine questions concerning its own jurisdiction, subject to the applicable arbitration law.

Therefore:

A party should not necessarily be permitted to defeat an arbitration agreement simply by commencing litigation elsewhere.

The tribunal and supervisory court may have powers to protect the arbitration process.

13. Separability of the Arbitration Agreement

The arbitration clause is generally treated as legally separable from the underlying contract.

Therefore:

Even if a party alleges that the underlying contract is invalid, that allegation does not automatically eliminate the arbitration agreement.

This is important in anti-suit proceedings.

Otherwise, a party could potentially defeat every arbitration clause merely by commencing foreign litigation alleging invalidity of the underlying contract.

14. Comity

International comity is one of the most important limitations.

A court must consider the fact that the foreign proceedings are before another sovereign jurisdiction.

An anti-suit injunction can therefore raise questions of:

• judicial respect;
• sovereignty;
• international cooperation;
• conflicting court orders;
• enforcement difficulties.

The purpose of the injunction is normally to control the party before the court rather than to exercise direct authority over the foreign judiciary.

15. Mandatory Jurisdiction

An anti-suit injunction cannot ordinarily be used simply to eliminate a mandatory jurisdiction created by law.

For example, where legislation gives a particular court exclusive jurisdiction over a particular category of dispute, a private contractual clause may not necessarily displace that statutory jurisdiction.

Therefore:

Contractual choice of forum is important but is not necessarily absolute.

16. Public Policy

Public policy is another limitation.

A court will consider whether granting or enforcing an anti-suit order would conflict with:

• mandatory UAE law;
• public order;
• fundamental procedural rights;
• jurisdictional legislation;
• arbitration legislation.

The court must therefore balance contractual autonomy against mandatory legal requirements.

17. Anti-Suit Injunction and the New UAE Civil Transactions Law

The Federal Decree-Law No. 25 of 2025 Promulgating the Civil Transactions Law, effective from 1 June 2026, is now the principal UAE Civil Transactions framework.

It does not transform the UAE into a common-law anti-suit jurisdiction.

Anti-suit relief must instead be understood through the interaction of:

• contractual obligations;
• good faith;
• procedural law;
• arbitration legislation;
• jurisdictional rules;
• public policy;
• court-specific procedural regimes.

Earlier cases under the former Civil Transactions Law remain useful where the underlying principles have continued into the new Code, but they should not be treated as automatically controlling where the legislation has changed.

18. Case Law

Because the UAE's reported anti-suit jurisprudence is relatively limited compared with England, it is important to distinguish direct UAE authorities from DIFC/ADGM and comparative common-law authorities.

Case 1 — DNB Bank ASA v Gulf Eyadah Corporation & Another, [2015] DIFC CA 007

Court

DIFC Court of Appeal.

Importance

This is one of the most important DIFC authorities concerning the interaction between UAE/DIFC jurisdiction and foreign proceedings and judgments.

The dispute concerned recognition and enforcement of a foreign judgment within the DIFC.

Principle

The case demonstrates that the DIFC Court must carefully distinguish:

• its own jurisdiction;
• foreign court jurisdiction;
• recognition;
• enforcement;
• public policy.

Relevance to anti-suit injunctions

It illustrates the broader principle that an international dispute cannot be analyzed simply by asking which court issued an order.

The court must examine:

• jurisdiction;
• contractual arrangements;
• applicable law;
• enforcement consequences.

Classification

Direct DIFC authority; not a general mainland UAE anti-suit precedent.

19. Case 2 — NMC Healthcare Ltd (in Administration) v Dubai Islamic Bank PJSC & Others, [2023] ADGMCFI 0017

Court

ADGM Court of First Instance.

Importance

This is an important modern UAE-related commercial authority.

The court considered UAE-law principles, including the doctrine concerning the proper exercise of rights.

Relevance

Anti-suit disputes often involve a party exercising a procedural right in a foreign forum.

The NMC litigation demonstrates how courts can distinguish:

• legitimate exercise of a right;
• improper or abusive exercise;
• contractual rights;
• procedural conduct.

It is therefore relevant to the broader civil-law limits on abusive litigation conduct.

Classification

ADGM authority applying UAE-law principles; not a mainland UAE Federal Court anti-suit decision.

20. Case 3 — IDBI Bank Ltd v Amira C Foods International DMCC & Karan A. Chanana, [2020] DIFC CFI 022

Court

DIFC Court of First Instance.

Principle

The proceedings involved complex questions concerning contractual arrangements, jurisdiction and cross-border commercial litigation.

Relevance

The case is useful in understanding the importance of:

• contractual jurisdiction;
• party autonomy;
• characterization of disputes;
• the relationship between contractual rights and court proceedings.

These questions are central to anti-suit litigation.

Classification

DIFC comparative/direct DIFC authority, depending upon the particular proposition relied upon.

21. Case 4 — Amira C Foods International DMCC & Karan A. Chanana v IDBI Bank Ltd, [2021] DIFC CA 004

Court

DIFC Court of Appeal.

Principle

The appellate proceedings demonstrate the importance of carefully determining the jurisdictional and contractual framework governing a cross-border dispute.

Relevance

An anti-suit application requires the court to identify:

• the parties' agreement;
• the proper forum;
• the scope of the relevant clause;
• the relationship between competing proceedings.

The case is therefore useful for the broader jurisdictional analysis.

Classification

DIFC authority.

22. Case 5 — The Angelic Grace, [1995] 1 Lloyd's Rep 87

Court

English Court of Appeal.

Importance

This is one of the leading common-law authorities on anti-suit injunctions in the context of arbitration.

The court strongly protected the contractual promise to arbitrate.

Principle

Where parties have agreed to arbitration and one party commences court proceedings in breach of that agreement, an anti-suit injunction may be granted to restrain the party from continuing the foreign proceedings, subject to the court's jurisdiction and equitable principles.

UAE relevance

This is not UAE law.

However, it is particularly relevant to the DIFC and ADGM, whose common-law-oriented systems may consider English authorities where appropriate.

It is therefore a persuasive comparative authority, not a binding mainland UAE case.

23. Case 6 — Airbus Industrie GIE v Patel, [1999] 1 AC 119

Court

House of Lords, United Kingdom.

Principle

The House of Lords emphasized that anti-suit relief requires careful consideration of:

• jurisdiction;
• connection with the forum;
• comity;
• whether the foreign proceedings are oppressive or vexatious;
• whether the applicant has a sufficient basis for relief.

Relevance to UAE

The case is important because it demonstrates that anti-suit injunctions are not automatic.

A court must exercise restraint where foreign proceedings have legitimate jurisdictional connections.

Classification

Comparative English authority.

24. Case 7 — Turner v Grovit, Case C-159/02

Court

Court of Justice of the European Union.

Principle

The European Court restricted the use of anti-suit injunctions where such orders interfere with proceedings before another court within the relevant European jurisdictional framework.

Relevance to UAE

The case demonstrates an important international principle:

Anti-suit injunctions must be considered in light of the particular jurisdictional system governing the competing courts.

It is particularly useful for understanding why an anti-suit remedy that is accepted in common-law systems may encounter restrictions under other international procedural regimes.

Classification

Comparative international authority, not UAE law.

25. Case 8 — West Tankers Inc v Allianz SpA, Case C-185/07

Court

Court of Justice of the European Union.

Principle

The case concerned an arbitration agreement and parallel court proceedings and demonstrated the limits imposed by a particular international jurisdictional framework on anti-suit injunctions.

Relevance to UAE

It illustrates the need to distinguish:

• arbitration protection;
• court jurisdiction;
• international comity;
• treaty-based jurisdictional systems.

Classification

Comparative international authority.

26. Case-Law Summary

Important: The English and European authorities above are comparative authorities. They should not be represented as binding UAE law.

27. The Angelic Grace Principle and UAE Arbitration

The reasoning in The Angelic Grace is particularly significant for understanding modern common-law-style arbitration protection.

The basic logic is:

1. The parties voluntarily agreed to arbitrate.
2. The arbitration agreement is a contractual promise.
3. One party breaches that promise by litigating elsewhere.
4. The court may protect the contractual promise through an injunction.

This reasoning can be relevant in DIFC or ADGM proceedings where the applicable procedural framework permits such relief.

28. Anti-Suit Injunction and Arbitration Seat

The seat of arbitration is particularly important.

Suppose:

Arbitration agreement → DIFC seat.

One party starts litigation in another jurisdiction.

The DIFC Court may have a strong interest in protecting the arbitral process associated with its seat.

Conversely, where the arbitration is seated outside the UAE, the question becomes more complicated.

The court must examine:

• the arbitration agreement;
• seat;
• governing law;
• institutional rules;
• jurisdiction;
• enforcement;
• comity.

29. Anti-Suit Injunction and Institutional Arbitration

The problem can arise under:

• DIAC arbitration;
• ICC arbitration;
• LCIA arbitration;
• SIAC arbitration;
• ad hoc arbitration;
• DIFC-LCIA historical arrangements;
• ADGM arbitration arrangements.

The key question is not simply:

"Which institution was named?"

It is:

What legal agreement did the parties make, and which court has supervisory jurisdiction over the arbitration?

30. Anti-Suit Injunction and DIAC Arbitration

For a Dubai-seated arbitration administered by DIAC, a party commencing foreign litigation contrary to the arbitration agreement may create a dispute concerning:

• contractual breach;
• arbitral jurisdiction;
• court supervision;
• interim measures;
• enforcement.

The exact remedy depends upon the arbitration agreement and applicable UAE arbitration legislation.

31. Anti-Suit Injunction and DIFC Courts

The DIFC provides one of the UAE's clearest environments for common-law-style anti-suit analysis.

The court may consider:

• exclusive jurisdiction clauses;
• arbitration agreements;
• foreign proceedings;
• contractual promises;
• vexatious or oppressive litigation;
• comity;
• adequacy of alternative remedies.

But the applicant must establish a proper jurisdictional foundation.

32. Anti-Suit Injunction and ADGM Courts

ADGM's common-law framework similarly makes English authorities potentially persuasive.

However, the court must independently consider:

• ADGM legislation;
• Court Procedure Rules;
• arbitration framework;
• jurisdiction;
• applicable governing law.

English precedent should therefore be treated as persuasive rather than automatically binding, unless incorporated through the applicable ADGM legal framework.

33. Anti-Suit Injunction and Mainland UAE

For mainland UAE courts, the analysis is different.

The court's authority comes from UAE legislation rather than simply from English equitable jurisdiction.

The court may therefore focus on:

• whether the UAE court has jurisdiction;
• whether the arbitration agreement is valid;
• whether the foreign proceedings affect UAE proceedings;
• whether a foreign judgment or order can be recognized;
• whether public policy is implicated;
• whether the relevant procedural legislation permits the requested relief.

This is why one should avoid saying:

"UAE courts always issue anti-suit injunctions."

That would be inaccurate.

34. Anti-Suit Injunction and Public Policy

Suppose the foreign proceedings involve a subject that UAE law considers subject to mandatory jurisdiction.

A private contract cannot necessarily convert that mandatory jurisdiction into an optional one.

Similarly, an anti-suit injunction should not be used to:

• defeat mandatory legislation;
• obstruct legitimate regulatory proceedings;
• interfere improperly with criminal proceedings;
• circumvent public policy.

35. Anti-Suit Injunction and Forum Shopping

Anti-suit injunctions can prevent strategic forum shopping.

For example:

Contract → DIFC exclusive jurisdiction.

The claimant believes a foreign court will provide a more favorable remedy and therefore starts proceedings there.

The defendant may argue:

"The foreign action violates our agreed forum."

The court can then examine whether the contractual jurisdiction clause genuinely requires litigation in the agreed forum.

36. Anti-Suit Injunction and Vexatious Proceedings

A party may repeatedly commence proceedings in different jurisdictions to:

• delay arbitration;
• increase costs;
• pressure the opponent;
• obtain inconsistent judgments;
• frustrate enforcement.

Such conduct may support arguments concerning:

• abuse of process;
• vexatious litigation;
• contractual breach;
• abuse of rights.

However, allegations of vexatious conduct should be supported by evidence.

37. Anti-Suit Injunction and Good Faith

The UAE civil-law concept of good faith can provide an additional analytical dimension.

A party that expressly agrees to arbitration or exclusive jurisdiction should generally not be allowed to undermine that agreement through conduct inconsistent with its contractual commitments, subject to applicable law.

This does not mean every foreign lawsuit constitutes bad faith.

The court must examine:

• wording;
• circumstances;
• legal basis;
• party conduct;
• legitimate jurisdictional grounds.

38. Anti-Suit Injunction and Abuse of Rights

The UAE abuse-of-rights doctrine can become relevant where procedural rights are exercised for improper purposes.

Under the established Article 106 framework, abuse may arise where the exercise of a right involves, among other things:

• intentional serious harm;
• an unlawful objective;
• disproportion between benefit and harm;
• exceeding accepted limits.

Thus:

The existence of a right to litigate does not necessarily make every use of that right immune from civil-law scrutiny.

Nevertheless, courts must distinguish genuine jurisdictional disputes from actual abuse.

39. Anti-Suit Injunction and Right of Access to Court

A major tension exists between:

Right of access to justice

A party ordinarily has a right to approach a competent court.

Contractual forum selection

Parties may have agreed to arbitration or exclusive jurisdiction elsewhere.

An anti-suit injunction must therefore avoid unnecessarily suppressing legitimate access to justice.

The key question is:

Has the party voluntarily and validly agreed to restrict the forum in which the dispute will be resolved?

If so, enforcing that agreement may not improperly deny access to justice because the party retains access to the agreed forum.

40. Anti-Suit Injunction and Foreign Court Orders

Suppose:

1. DIFC Court grants an anti-suit injunction.
2. Foreign court later orders the party to continue the proceedings.

The party may face conflicting obligations.

This is one reason anti-suit litigation can become highly sensitive.

The UAE court generally seeks to regulate the conduct of the party subject to its jurisdiction rather than directly command the foreign judge.

41. Anti-Suit vs Anti-Enforcement Strategy

Sometimes stopping the foreign lawsuit is impossible because:

• the foreign court has already issued judgment;
• the foreign court refuses to recognize the UAE injunction;
• the foreign proceeding has advanced too far.

The dispute may then shift toward:

Can the foreign judgment be recognized or enforced in the UAE?

That becomes a different legal question governed by the applicable recognition and enforcement rules.

42. Practical Test for an Anti-Suit Application

A party seeking anti-suit relief should consider:

Step 1 — Identify the competing proceedings

What foreign proceedings exist?

Step 2 — Identify the contractual clause

Is there:

• arbitration?
• exclusive jurisdiction?
• non-exclusive jurisdiction?

Step 3 — Determine governing law

What law governs the clause?

Step 4 — Establish jurisdiction

Why can the UAE court hear the anti-suit application?

Step 5 — Demonstrate breach or improper interference

How do the foreign proceedings violate the agreement?

Step 6 — Consider comity

What effect will the order have on the foreign court?

Step 7 — Consider alternative remedies

Would a stay, declaration or arbitration order be sufficient?

Step 8 — Consider urgency

Is immediate relief required?

Step 9 — Consider enforcement

Can the respondent realistically comply?

43. Anti-Suit Injunction and Arbitration Clause Drafting

Good drafting can substantially reduce disputes.

A contract should clearly specify:

"Any dispute arising out of or in connection with this agreement shall be finally resolved by arbitration..."

Then specify:

• seat;
• institution;
• number of arbitrators;
• language;
• governing law;
• scope;
• interim-relief mechanism.

Where litigation is intended:

"The courts of [specified jurisdiction] shall have exclusive jurisdiction..."

Ambiguous wording increases anti-suit litigation risk.

44. Digital Contracts

Anti-suit disputes increasingly arise from digital contracts.

A platform agreement may contain:

• clickwrap arbitration clauses;
• electronic jurisdiction clauses;
• smart-contract mechanisms;
• automated dispute-resolution provisions.

The court may need to determine:

• whether the user accepted the clause;
• whether the clause was sufficiently accessible;
• whether the electronic record is authentic;
• whether mandatory consumer protections apply;
• whether the dispute falls within the clause.

45. Crypto and Blockchain Disputes

A crypto dispute may involve:

UAE exchange → foreign customer → foreign court → DIFC arbitration clause.

The party seeking anti-suit relief may argue that foreign litigation breaches the arbitration agreement.

The court must first determine:

• whether the terms were incorporated;
• whether the arbitration clause is valid;
• whether the claimant is bound;
• whether the dispute concerns the same transaction;
• whether the requested injunction is procedurally available.

Blockchain evidence may establish transactions, but it does not automatically determine the proper forum.

46. AI and Anti-Suit Injunctions

AI can complicate anti-suit disputes through automated litigation decisions.

For example:

An AI legal system recommends that a company commence proceedings in another jurisdiction despite an arbitration clause.

The company cannot normally avoid contractual responsibility simply by saying:

"The AI selected the foreign court."

The legal entity remains responsible for its legally significant conduct, subject to the applicable rules of agency, authorization and civil liability.

47. Main Legal Principles

The UAE approach can be summarized as follows:

1. An anti-suit injunction restrains a party, not normally the foreign court itself.
2. Arbitration agreements are important contractual commitments.
3. Exclusive jurisdiction clauses may support anti-suit relief.
4. The exact wording of the agreement matters.
5. The seat of arbitration is highly significant.
6. Comity limits the remedy.
7. Public policy may limit contractual forum selection.
8. Mainland UAE, DIFC and ADGM must be treated separately.
9. DIFC and ADGM have stronger common-law foundations for anti-suit analysis.
10. English authorities can be persuasive in DIFC/ADGM but are not automatically binding mainland UAE authorities.
11. Abuse of rights and good faith may be relevant to improper litigation conduct.
12. An anti-suit injunction is discretionary and fact-sensitive.
13. An anti-suit injunction is different from refusing enforcement of a foreign judgment.
14. The existence of a foreign proceeding does not automatically justify an injunction.
15. A valid arbitration or exclusive-jurisdiction agreement provides the strongest contractual foundation for such relief.

48. Conclusion

The UAE anti-suit injunction framework is best understood as a combination of contractual autonomy, arbitration law, jurisdictional principles, procedural law, good faith, abuse of rights and international comity.

The most important distinction is between the UAE's different judicial systems:

Mainland UAE

The remedy must be grounded principally in UAE legislation and applicable procedural and arbitration rules. The English anti-suit injunction doctrine should not simply be transplanted into mainland litigation.

DIFC

The common-law-oriented DIFC system provides a substantially stronger environment for anti-suit-style relief, particularly where an arbitration or exclusive jurisdiction agreement is being undermined.

ADGM

The ADGM's common-law framework likewise permits sophisticated consideration of common-law principles, subject to ADGM legislation and procedural rules.

The central principle is:

A party that has voluntarily agreed to arbitrate or litigate exclusively in a particular forum should generally not be permitted to undermine that contractual bargain through parallel proceedings elsewhere, but any anti-suit relief must remain within the court's jurisdiction and respect comity, mandatory law and public policy.

Finally, the case law should be read carefully. DNB Bank, NMC Healthcare, IDBI Bank and Amira C Foods are UAE-related DIFC/ADGM authorities, while The Angelic Grace, Airbus v Patel, Turner v Grovit and West Tankers are comparative authorities. There is not a large body of reported mainland UAE appellate jurisprudence expressly developing the English-style anti-suit injunction doctrine, so it would be inaccurate to present the comparative authorities as direct UAE precedents.