Trafigura Pte Ltd v Gupta

The Claimants (“Trafigura") obtained a judgment in January 2026 against the First Defendant ("Mr Gupta") for over $700 million. In April 2023, Trafigura had obtained a without notice Chabra injunction in England over certain assets of the Second Defendant ("Mrs Gupta"), which was later supplemented with a notification undertaking regime. In April 2025, Trafigura sought and obtained corresponding orders against Mrs Gupta in the DIFC (the “DIFC freezing order").

In November 2025, Trafigura obtained further injunctive relief against Mrs Gupta partly on short notice and partly without notice (the “Interim Order”). Trafigura took steps to enforce the Interim Order in the onshore courts, including by obtaining a precautionary attachment and mandatory orders and by seeking an arrest warrant.

The conduit jurisdiction, under RDC Part 45 and Article 32 of the DIFC Courts Law (2 of 2025) (formerly Article 7(2)-(3) of the Judicial Authority Law), allows judgments and orders of the DIFC Courts to be enforced in the onshore courts without further review of their merits.

The Court held that a freezing order is not final and executory in nature, and the DIFC Court will not act as a conduit for interim relief (§§295-296). Further, insofar as the DIFC freezing order was to be invoked in seeking measures incidental to its enforcement, that should be subject to the supervision of the DIFC Court, in line with the guidelines in Dadourian Group v Simms [2006] 1 WLR 2499 (CA) (§§287-291, 294).

The judgment also contains an illuminating discussion of the principles on Chabra injunctions (§§68, 144-151) and the potentially important differences between English and Australian law on the duty of full and frank disclosure (§§130-134).

Andrew Trotter appeared for Mrs Gupta. The full judgment is available here.