Saturday 31 / October / 2026
A foreign arbitral award is generally an award made outside Oman or one that is not considered a domestic award in Oman for the purposes of recognition and enforcement. The 1958 United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards (New York Convention), to which Oman acceded under Royal Decree 36/98, is the treaty governing the recognition and enforcement of such awards between contracting states. The procedure for seeking enforcement of such awards is governed by the applicable legal framework in force in Oman.
Speaking exclusively to the Times of Oman, Dr. Mohammed Ibrahim Al Zadjali, Chairman of Mohammed Ibrahim Law Firm, said that “a foreign arbitral award cannot be enforced automatically in Oman. The party seeking enforcement must apply to the competent Omani court for an enforcement order, and enforcement cannot be ordered unless the legal requirements are met.”
He explained that “the application for an enforcement order is filed before the Primary Court, composed of three judges, within whose jurisdiction enforcement is to be carried out, in accordance with the ordinary conditions for filing a lawsuit. Enforcement cannot be ordered unless the court first verifies that the award was issued by a competent authority under the rules of international jurisdiction of the country where it was made, became final under that country’s law, and was not obtained through fraud. The parties must also have been duly summoned and properly represented.”
“The court must also verify that the award does not include a claim based on a violation of a law in force in Oman, conflict with a previous Omani judgment or order, or contain anything contrary to public order or morals. The court must also verify that the country where the award was issued accepts the enforcement of Omani court judgments in its territory. A further condition specific to arbitral awards is that the award must concern a matter that may be arbitrated under Omani law and be enforceable in the country where it was issued,” he said.
Dr. Mohammed further noted that “the applicable legal framework also provides that the preceding enforcement rules do not prejudice the provisions of treaties between Oman and other states concerning the same subject.”
He concluded by stating that the framework provides a legal basis for enforcing foreign arbitral awards in Oman while preserving the integrity of arbitration.
(Mohammed Ibrahim Law Firm ([email protected]), (+968 244 87 600) was established on 14th December 2006 and is serving clients through its offices in Muscat and Sohar, as well as operating on a request basis in other areas. It offers legal representation across a wide range of practice areas that include Labour Law, Corporate, Commercial, Contracts, Banking and Finance, International Trade, Foreign Investment, Maritime Law, Construction and Engineering Contracts, International Arbitration, Intellectual Property and more).
