In brief The Dubai International Financial Centre (DIFC) Court of First Instance (DIFC Court) has considered in its recent Order of 19 September 2023 in Muhallam v Muhaf [ARB 021/2022] (the “Order”) whether a provisional award introducing interim measures is enforceable in the DIFC as an “award”. The dispute centred around the controversial issue of whether interim awards are final awards capable of recognition, including under the New York Convention. The DIFC Court held that…