Multi-tiered dispute resolution clauses in construction contracts

Multi-tier dispute resolution (“MDR”) clauses, also known as filter clauses, provide a prescriptive route to disputed parties before escalation to arbitration. MDR clauses require parties to engage in specific steps before arbitration proceedings commence. Such steps may involve negotiation, followed by mediation or conciliation proceedings.

MDR Clauses encourage parties to an impending or active dispute, to make efforts to settle the dispute before escalating the matter to a more formal arbitration, thereby mitigating costly, lengthy, and complicated legal proceedings. Such clauses are increasingly used in today’s construction contracts although problems may arise where the prescribed steps are not followed.

As part of Dubai Arbitration Week 2022, Galadari Advocates & Legal Consultants together with White & Case, will be hosting a panel on Multi-Tiered Dispute Resolution Clauses in Construction Contracts on 16 November 2022. Speakers, Abdulla Galadari and Youssef Khalaf from Galadari Advocates, and Karim Mariey from White & Case will delve into the various mediums for dispute resolution and take a closer look at the enforcement of dispute resolution clauses in construction contracts, as well as the enforcement of arbitral awards in both Dubai and DIFC.

The author of this article is Joe Khalaf is a Senior Associate at Galadari Advocates and Legal Consultants where he specialises in contentious construction matters. To connect with Joe, please contact him on

For more information on this panel, please get in touch with