The High Court denied the application for recognition and enforcement of two  DIFC-LCIA awards. The Court followed the approach adopted by the UK Supreme Court in Dallah – that the court has the “last word” on the question of jurisdiction, without regard to the tribunal’s determination – and therefore reviewed the findings of the arbitral tribunal. The Court concluded that recognition and enforcement should be denied under Art. V(1)(d) of the New York Convention, because the arbitral tribunal had not determined the seat of arbitration in accordance with the agreement of the parties. The parties’ contract referred to “Dubai, UAE” as the “location” of the arbitration. In view of the parties’ disagreement as to the proper seat of the arbitration – Dubai or the Dubai International Financial Centre (DIFC) – the tribunal had bifurcated the proceedings to deal with jurisdiction and procedural issues first. By a partial award, the tribunal had held that the DIFC was the arbitration’s seat, and had then proceeded to issue an award on the merits and an award on costs.