Sports Arbitration Rulings Are Final: How to Challenge Them?
In a recent judicial principle, the General Assembly of the Dubai Court of Cassation, in Request No. 1 of 2025 issued on 5 November 2025, settled the question of challenging awards of the UAE Sports Arbitration Centre. It held that these awards are final, subject to expedited enforcement, and carry the force of an executive instrument; that no initial lawsuit to annul them may be filed before the courts for lack of jurisdiction; and that the only avenue to object is a substantive enforcement dispute before the competent execution judge, whose decision is appealable by cassation. This article explains the details of this principle, the basis on which it was built, and its practical impact on athletes, clubs, and trainers.
A Sports Arbitration Award Is Final and Cannot Be Annulled Before the Courts — So How Do You Challenge It?
1. The UAE Sports Arbitration Centre and Its Exclusive Jurisdiction
The UAE Sports Arbitration Centre was established under Federal Law No. 16 of 2016, and it has exclusive jurisdiction over the arbitration of sports disputes. The legislator dedicated a special law to it that removed these disputes from the courts' jurisdiction and vested jurisdiction over them in the Centre alone. The following are the most prominent matters within its jurisdiction:
1Decisions of Governing Bodies and the Olympic Committee
Final decisions issued by the operating bodies and the Olympic Committee in accordance with their statutes.
2Disciplinary Decisions
Disciplinary decisions issued under the regulations of the operating bodies.
3Anti-Doping Decisions
Appealable decisions issued by the National Anti-Doping Committee.
4Sports Arbitration Contracts
Sports disputes whose contracts contain a sports arbitration clause or submission agreement providing for recourse to the Centre.
The Centre's jurisdiction is general and covers all sports; it is not limited to a particular game. Football is included, along with disputes between foreign players and clubs and contract-related disputes. However, football has a special character at the international level, as it is subject to the framework of the International Federation of Association Football (FIFA). Disputes of an international character — such as international transfers and decisions of FIFA bodies — may fall under FIFA's framework and be appealed before the Court of Arbitration for Sport (CAS), while domestic disputes are heard before the Centre.
2. The Facts of the Case That Established the Principle
The dispute arose between a horse trainer and a stable owner over the division of a sale price. The trainer brought an arbitration case before the Centre, which issued an award ordering the stable owner to pay certain sums. The latter then filed a lawsuit to annul the arbitration award before the Dubai Court of Appeal. The case went through a multi-stage litigation journey before reaching the General Assembly:
1
The Centre's Award (15 February 2024) — issuance of the arbitration award in Case No. 8-7 of 2023 after dismissing the plea of lack of jurisdiction.
2
The Annulment Lawsuit (27 June 2024) — filing of Lawsuit No. 10 of 2024 before the Dubai Court of Appeal, which dismissed it.
3
Cassation, Reversal, and Remand — judgments in Appeals No. 351 and 533 of 2024, including a reversal and remand.
4
The Principle (5 November 2025) — referral of the request to the General Assembly, which held that the courts lack jurisdiction to hear an initial annulment lawsuit.
3. The Principle Established by the General Assembly
The General Assembly held that the awards and decisions issued by the UAE Sports Arbitration Centre — including arbitration and conciliation awards and the awards of the appellate chambers — are final, subject to expedited enforcement, and carry the force of an executive instrument and the authority of res judicata, and are not subject to appeal before the courts by any means of recourse. Accordingly, the Dubai courts lack jurisdiction to hear an initial lawsuit to annul an arbitration award issued by this Centre, given that the legislator dedicated a special law to it that vested jurisdiction over sports disputes in the Centre alone.
4. The Only Route to Object: The Substantive Enforcement Dispute
Since the Centre's awards are executive instruments, their enforcement takes place before the competent execution judge under the Civil Procedure Law. A party may object to the award when it is submitted for enforcement, as a substantive enforcement dispute that involves resolving a prior question that must be present before the enforcement order is issued — namely, whether the award qualifies as an executive instrument and meets its conditions. The execution judge may address this question before enforcement, and the judge's decision is appealable by cassation:
An award issued by the UAE Sports Arbitration Centre (final + executive instrument)
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No initial lawsuit to annul it is admissible before the courts, for lack of jurisdiction.
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Objection at enforcement, as a "substantive enforcement dispute" before the competent execution judge.
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The execution judge's decision is appealable by cassation.
5. What Changed? Before and After the Principle
This principle clarifies the correct place to object to the Centre's award, shifting it from an initial annulment lawsuit before the Court of Appeal to a substantive dispute before the execution judge:
Before the Principle
Filing an initial lawsuit to annul the arbitration award before the Court of Appeal and discussing its merits and grounds of annulment.
After the Principle
The annulment lawsuit is inadmissible; objection is made through a substantive enforcement dispute before the execution judge, whose decision is appealable by cassation.
6. Effective Judicial Oversight and Practical Impact
This principle does not mean that the Centre's award is entirely beyond judicial oversight, as effective, in-depth oversight remains available at the enforcement stage before the competent execution judge — consistent with the comparative approach adopted by the Court of Justice of the European Union and by the Court of Arbitration for Sport in Switzerland and its international council, whose awards are subject to review by the Swiss Federal Tribunal. In practice, a party who obtains an award from the Centre enforces it directly as an executive instrument, while a party who wishes to object waits for the enforcement stage and files a substantive dispute before the execution judge instead of an initial annulment lawsuit that will not be admitted.
7. The Lawyer's Role
The lawyer helps the client follow the correct path in light of this principle. For a party in whose favour the award was issued, the lawyer submits the award directly for enforcement before the execution judge as an executive instrument and pursues its procedures. For a party who wishes to object, the lawyer drafts the substantive enforcement dispute and builds the pleas on the prior question concerning the award's qualification as an executive instrument and the fulfilment of its conditions, then appeals the execution judge's decision by cassation where appropriate, avoiding an inadmissible initial annulment lawsuit that wastes time and costs.
8. Legal References
1- Federal Law No. 16 of 2016 on Establishing the UAE Sports Arbitration Centre. 2- The Procedural Rules of the UAE Sports Arbitration Centre (Second Edition 2023, in force from 25 October 2023). 3- The Statute of the UAE Sports Arbitration Centre (2020). 4- Federal Decree-Law No. 42 of 2022 issuing the Civil Procedure Law. 5- Federal Law No. 6 of 2018 on Arbitration. 6- Law No. 13 of 2016 on the Judicial Authority in the Emirate of Dubai. Reference: Request No. 1 of 2025 — General Assembly of the Dubai Court of Cassation, session of 5 November 2025.
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AWADH ALMHEIRI LAW FIRM AND LEGAL CONSULTATIONS
✓ Enforcing the Centre's awards as executive instruments ✓ Drafting the substantive enforcement dispute ✓ Cassation appeals against enforcement decisions
Can a lawsuit be filed to annul an arbitration award issued by the UAE Sports Arbitration Centre?+
No. An initial lawsuit to annul it is inadmissible before the courts for lack of jurisdiction; objection is made through a substantive enforcement dispute before the execution judge.
What is the legal value of the Centre's awards?+
They are final, subject to expedited enforcement, and carry the force of an executive instrument and the authority of res judicata.
How, then, do I object to an award issued by the Centre?+
When the award is submitted for enforcement, you file a substantive enforcement dispute before the competent execution judge regarding whether the award qualifies as an executive instrument.
Is the execution judge's decision final?+
No. The decision issued by the execution judge in this dispute is appealable by cassation.
Which body has jurisdiction over sports disputes?+
The UAE Sports Arbitration Centre has exclusive jurisdiction over the arbitration of sports disputes under its establishing law.
Does it cover football, or only certain sports?+
Its jurisdiction is general and covers all sports, including football; it is not limited to a particular game. However, football disputes of an international character may fall under FIFA's framework and be appealed before the Court of Arbitration for Sport (CAS), while domestic disputes are heard before the Centre.
Are the Centre's awards subject to any judicial oversight?+
Yes. Effective judicial oversight remains available at the enforcement stage before the execution judge, consistent with the comparative approach in international sports arbitration.
When is a sports arbitration agreement established?+
An arbitration agreement is established only in writing, through a clause in the contract or a submission agreement, or by a clear reference that makes the arbitration clause part of the contract.
Who rules on the plea that the Centre lacks jurisdiction?+
The arbitrator or arbitral tribunal rules on pleas of lack of jurisdiction, including pleas arising from the absence or invalidity of an arbitration agreement.
Does the principle apply to the awards of the Centre's appellate chambers?+
Yes. Awards issued by the arbitral tribunal of the appellate chambers are likewise not subject to appeal before the courts and receive the same treatment.
For precise legal advice on the awards of the UAE Sports Arbitration Centre and their enforcement, contact the team at AWADH ALMHEIRI LAW FIRM AND LEGAL CONSULTATIONS.Contact Us
Legal Disclaimer
This article is published to spread legal culture and promote community awareness. It does not constitute legal advice or a legal opinion to be relied upon in any particular case. Facts and circumstances differ from one case to another, and you are advised to consult a specialised lawyer to ascertain the ruling applicable to your case before taking any action. In the event of any discrepancy, the Arabic text shall be the authoritative reference.
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Demand is rising in the Emirate of Dubai for sports arbitration lawyers and for services enforcing the awards of the UAE Sports Arbitration Centre as executive instruments before the execution judge at the Dubai Courts. AWADH ALMHEIRI LAW FIRM AND LEGAL CONSULTATIONS provides advice on enforcing these awards, drafting the substantive enforcement dispute, and cassation appeals against enforcement decisions, safeguarding the rights of athletes, clubs, and trainers.
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