A reinsurance dispute rooted in the April 2024 Dubai floods has produced a ruling that redraws the procedural boundaries for multi-party litigation in the UAE, according to an analysis published by law firm Clyde & Co. On January 26, 2026, the Dubai Conflict of Jurisdiction Tribunal (CJT) determined that the Dubai International Financial Centre (DIFC) Courts had jurisdiction over the dispute, on the sole basis that one of the reinsurers in the proceedings was registered in the DIFC.
The case, Application No. 6/2025, arose from a high-value property insurance claim settled by a local Dubai insurer after the 2024 floods. Guy Carpenter estimated that insured losses across the UAE from the April 2024 event could reach as high as US$2.4 billion, with Dubai identified as the most affected emirate.
A group of local and international reinsurers, one of which was established in the DIFC, commenced proceedings in the DIFC Courts seeking declarations on their liability under the reinsurance agreements. Those agreements contained a dispute resolution clause conferring exclusive jurisdiction on the "competent" UAE Courts, language that left the precise court undefined.
Before those proceedings were served, the insurer filed a parallel action in the Dubai Courts. After service of the DIFC claim, the insurer challenged the DIFC Courts' jurisdiction and applied to the CJT. Its position was that the matter belonged in the Dubai Courts, not the DIFC.
The CJT rejected that argument, according to Clyde & Co, which represented the reinsurers in the proceedings. It applied Dubai Law No. 2 of 2025 (the DIFC Courts Law) rather than federal civil and commercial procedural rules, which do not apply within financial freezones such as the DIFC. The CJT confirmed that both court systems sit within the Emirate of Dubai, and the allocation of jurisdiction between them is a matter of Dubai law alone.
Article 14(a) of the DIFC Courts Law grants the DIFC Courts exclusive jurisdiction over civil and commercial claims involving DIFC establishments: entities licensed, registered or permitted to operate in or through the DIFC. The CJT found that gateway was satisfied because one of the reinsurers was a licensed entity conducting business solely within the DIFC. The insurer argued that the underlying policy had no substantive connection to the DIFC and that the insured losses did not occur there. The CJT found neither point altered the statutory position.
The principle that a single DIFC party confers DIFC jurisdiction was already settled in both court systems. What the CJT's decision adds is a procedural shift with direct consequences for how disputes are managed from the outset.
The CJT's usual threshold requires an actual, established conflict between two judicial bodies before it can intervene. Previously, that bar was difficult to clear at an early stage. Parties had routinely exploited the gap by opening parallel proceedings in both systems to preserve tactical options, at the cost of duplicated fees and delays, Clyde & Co noted. The CJT intervened here before that pattern took hold and issued a definitive determination at the start of the proceedings.
For reinsurers in the UAE, the practical implications are considerable, according to Clyde & Co. Multi-party reinsurance disputes routinely involve layered arrangements with participants seated both inside and outside the DIFC. The ruling confirms that once a single party qualifies as a DIFC establishment, the DIFC Courts hold exclusive jurisdiction over the entire dispute, regardless of where the insurer is based, where the losses arose or where performance of the reinsurance contract took place.
The decision also reinforces what the DIFC Courts offer that the onshore system does not. Onshore Dubai Courts do not readily grant declaratory relief, a remedy reinsurers frequently need to establish their position on liability before a cedant commences an affirmative claim, according to Clyde & Co. The CJT's willingness to act early preserves access to that remedy by cutting off the parallel proceedings that have historically delayed it.
