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Cross-border dispute routing
Pick the local forum (where the case is filed), the originating forum (where a foreign judgment / award came from, if any), the claim type, and the governing law. The resolver returns the rule chain — recognition gates first, then substantive rules, with public-policy overrides flagged. Driven by rules/_jurisdictions.json (per-tribunal posture, per-rule jurisdiction, cross-border path catalogue) plus the existing claim-type registry. Encodes the multi-jurisdiction tech of Stage 4: the protocol routes by tribunal-of-filing, and the rule modules tag which jurisdictions they apply in.
How to use this page
Work out which rules apply when a case crosses borders
Cross-border cases involve more than one legal system. A Singapore arbitral award being enforced in DIFC, for example, has to clear DIFC's recognition gates before any substantive rule even gets to apply. This page works out, given a fact pattern, the full rule chain : which gates have to be cleared, in what order, with which substantive rules behind them, and which public-policy overrides could trump the result.
Four inputs
Local forum — where the case is being filed (DIFC, ADGM, or SICC).
Originating forum — where a foreign judgment or arbitral award came from, if any. Leave blank for purely local disputes.
Claim type — what kind of dispute (e.g. enforcement of a foreign award, summary judgment, fresh-evidence application).
Governing law — the law that governs the substantive contract or instrument, if relevant.
What you get back
Recognition gates — the threshold rules that decide whether the foreign instrument is even admitted (e.g. New York Convention enforceability, public-policy gates).
Substantive rules — the rules that actually decide the dispute, listed in the order the local forum applies them.
Public-policy overrides — any rules flagged as capable of overriding the chain on local-policy grounds. These are highlighted.
Source citations — every rule in the chain links back to its source and its Catala module in the library.
The routing graph is curated. Currently three tribunals and a handful of cross-border paths; will expand as the corpus grows.
Inputs
local forum (tribunal of filing)
originating forum (where the foreign judgment / award came from — leave blank for purely local disputes)
— none / local —
FOREIGN_ARBITRAL_TRIBUNAL
HONG_KONG_HIGH_COURT
DIFC
ADGM
SICC
claim type
governing law (substantive law of decision; defaults to forum's own)
— forum default —
ENG · English common law
DIFC · DIFC own statutes
ADGM · ADGM regulations
SICC · Singapore law
UAE · UAE federal law
Resolve routing
Routing
Pick inputs on the left and click Resolve.
Tribunal posture catalogue