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.
International commercial courts in the Gulf and Singapore
The DIFC Courts, created by Dubai law in 2004, are an English-language common-law jurisdiction for civil and commercial matters. Parties with no DIFC connection can opt in by specific, clear and express written agreement, before or after a dispute. The structure includes a Small Claims Tribunal for claims up to AED 500,000 (AED 1 million by election), a Court of First Instance with specialist divisions and a Court of Appeal whose decisions are final. ADGM in Abu Dhabi applies English common law directly and runs an electronic court platform.
The SICC, established in 2015 as a division of Singapore's High Court, hears international commercial claims before a panel of international and local judges, and a written jurisdiction agreement raises a presumption that the case is international and commercial.12345
National commercial courts
The Commercial Court in London hears significant commercial disputes, most with an international element, and supports arbitrations seated in England and Wales. India's Commercial Courts Act applies to commercial disputes with a specified value of at least Rs 3 lakh. Saudi Arabia's Commercial Courts Law of 2020 governs specialised commercial courts, while disputes with government generally go to the Board of Grievances.
In Germany, regional courts can sit as chambers for commercial matters for listed disputes, such as claims between merchants and company law disputes. France has replaced commercial courts in twelve cities, including Paris and Lyon, with tribunaux des activités économiques for a four-year experiment from 1 January 2025.678910
| Market | Court | Key feature | Source |
|---|---|---|---|
| UAE (Dubai) | DIFC Courts | English-language common law; opt-in by express written agreement; SCT up to AED 500,000 | difccourts.ae |
| UAE (Abu Dhabi) | ADGM Courts | Direct application of English common law; electronic courts | adgm.com |
| Singapore | SICC (High Court division) | International and local judges; written jurisdiction agreement | judiciary.gov.sg |
| United Kingdom | Commercial Court, London | Mostly international commercial disputes; supports arbitration | judiciary.uk |
| India | Commercial Courts under the 2015 Act | Specified value of Rs 3 lakh or more | PRS India (Act text) |
| Saudi Arabia | Commercial courts (2020 law) | Government contract disputes generally to Board of Grievances | US State Department |
| Germany | Kammer für Handelssachen | Listed commercial matters at regional courts | § 95 GVG |
| France | Tribunaux des activités économiques | Twelve cities, experiment from 1 Jan 2025 | service-public.gouv.fr |
Decisions to make
- Does the clause expressly opt in to the DIFC Courts if neither party is in the DIFC?2Opt-in requires specific, clear and express written provisions.
- Where will the judgment need to be enforced?15A court is only as useful as the routes its judgments have into the countries where assets are.
- Is the counterparty a Saudi government body?8Government contract disputes generally go to the Board of Grievances rather than the commercial courts.
- Is the Indian claim within the commercial courts regime?7The Commercial Courts Act applies from a specified value of Rs 3 lakh and brings its own procedure, including pre-institution mediation.
Documents usually needed
- Jurisdiction clause using the court's recommended wording
- Written opt-in agreement for the DIFC or ADGM Courts where neither party is based there
- Statement of the claim's specified value for Indian commercial courts
- Certified translations where proceedings are not in the contract language
- Corporate authority to commence and defend proceedings
Common mistakes
- Naming 'the courts of Dubai' when the DIFC Courts were intended
- Choosing a court without checking how its judgments are enforced in the counterparty's country
- Assuming Saudi commercial courts hear disputes with government bodies
- Ignoring France's new economic activities courts and their claim contribution
- Filing an Indian commercial suit without pre-institution mediation where no urgent relief is sought
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- ADGM Courts' opt-in rules and fee schedule were not reviewed.
- The commercial divisions of Indian High Courts and their pecuniary thresholds by state were not compiled.
- US federal and state commercial divisions (for example business courts) were not researched beyond federal diversity jurisdiction.
- SICC rules on representation and transfer of cases from the General Division were not reviewed in this centre.
- The Paris international commercial chambers could not be confirmed on an official source.
Sources and review status
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 were established by Dubai Law No. 12 of 2004, as amended by Dubai Law No. 16 of 2011, and form an English-language common law jurisdiction with jurisdiction over civil and commercial matters only. Dubai International Financial Centre.
Reused from ae-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 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.
ADGM directly applies English common law, and its courts operate an end-to-end electronic courts platform. Abu Dhabi Global Market.
Reused from ae-disputes-g11.
The Singapore International Commercial Court (SICC), established in 2015, is a division of the General Division of the High Court that hears claims of an international and commercial nature before a panel of international and local judges. It can hear a case where the parties have submitted to its jurisdiction under a written jurisdiction agreement (which raises a rebuttable presumption that the case is international and commercial), or on transfer from the General Division. Registered foreign lawyers can generally act in offshore cases. SICC judgments are enforced like other Supreme Court judgments.
Jurisdiction, transfer, foreign-lawyer and enforcement points confirmed on the SICC FAQs page. Reused from sg-disputes-002.
The Commercial Court in London hears a wide range of significant commercial disputes, the majority of which have an international element, and supports arbitrations seated in England and Wales. Proceedings are governed by the Civil Procedure Rules and the Commercial Court Guide.
Reused from gb-disputes-g02.
A commercial dispute falls under the Commercial Courts Act 2015 where its specified value is not less than Rs 3 lakh, reduced from Rs 1 crore by the 2018 amendment, which is deemed to have come into force on 3 May 2018. Section 2(1)(i) of the Commercial Courts Act 2015 as amended by Act No. 28 of 2018. Central law.
Gazette of India Extraordinary, Part II, Section 1, No. 41 of 21 August 2018, hosted by PRS; India Code could not be fetched. Later amendments (including any consequential change made by the Mediation Act 2023) were not checked. Reused from in-disputes-g09.
The Commercial Courts Law of 2020 governs the specialised commercial courts, which hear commercial disputes, and the law encourages arbitration and mediation. Disputes between the government and private contractors generally go to the Board of Grievances.
Secondary (foreign government) source; the official Saudi text could not yet be checked run. Reused from sa-disputes-003.
Commercial matters before the regional courts (Landgerichte) can be heard by a chamber for commercial matters (Kammer für Handelssachen), covering for example claims against merchants from bilateral commercial transactions, company law disputes, trade name and trademark matters, and unfair competition claims. Statutory list in § 95 GVG; antitrust damages claims are excluded from § 95(2).
Reused from de-disputes-002.
Since 1 January 2025, twelve commercial or judicial courts have been replaced by tribunaux des activités économiques (TAE) for a four-year experiment: Paris, Marseille, Lyon, Nanterre, Limoges, Avignon, Auxerre, Saint-Brieuc, Le Havre, Nancy, Versailles and Le Mans. Experiment under the Justice orientation and programming law 2023-2027 (law no. 2023-1059) and an order of 5 July 2024. Outside these cities the ordinary commercial courts continue.
News page published 16 July 2024, updated 9 January 2025. Exact page title not captured; publisher and item number given instead. Reused from fr-disputes-001.
Questions on this topic
10 statements on commercial courts
