InFrontier AF LP v Rahmani: Pitfalls Of Arbitral Institution Change

It is rare that an arbitral institution and its procedural rules are altered through legislative decree. Interestingly, this scenario arose in the Superior Court's recent decision in InFrontier AF LP v Rahmani, 2025 ONSC 3968 ("InFrontier"), presenting an unusual question of enforcement where the parties' arbitration agreement did not contemplate such a circumstance. Specifically at issue inInFrontierwas whether an award rendered under the rules of a legislatively-substituted institution – the Dubai International Arbitration Centre ("DIAC") – could be enforced in Ontario, despite the arbitration agreement referencing the now-defunct rules of its predecessor, the Dubai International Finance Centre – London Court of International Arbitration (the "DIFC-LCIA").