such other relief as may be appropriate.” (own emphasis added) [14] In support of this Applicant the Defendant relies on the following provisions of the Arbitration Act: i) Section 8 of the Arbitration Act “No court shall intervene in matters governed by this Act, except where so provided in this Act” Page 5 of 13 ii) The Preamble to the Arbitration Act “An Act to reform the law relating to domestic arbitration, provide for international arbitration, the recognition and enforcement of awards and for related matters.” (own emphasis added) [15] Both learned counsel for the Defendant and the Plaintiff have gone to great lengths to submit orally and in writing on this issue of jurisdiction. However, with respect to both counsel, I am of the considered view that all the arguments raised revolve around one central question: whether the Plaintiff can restrain the Defendant from recognising and enforcing the DT Award in any manner whatsoever. The net effect of the reliefs sought by the Plaintiff is to restrain the Defendant from proceeding with the Defendant’s application to recognise the DT Award in OS 49. [16] My short answer to this question is in the negative. [17] Simply put, the Plaintiff cannot restrain the Defendant from its legal right to apply to the Court for the DT Award to be recognised. Thus, the Plaintiff has no jurisdiction over the Defendant in respect of the subject matter of the claim or the relief or remedy sought in this action. [18] It was submitted by learned counsel for the Defendant that from the strict reading of the Arbitration Act provisions above, it is clear that the Malaysian courts are precluded by the Arbitration Act from granting orders relating to the enforcement of or the challenge to sums due under foreign arbitral awards outside of the specific powers granted under the Arbitration Act. This is because the Arbitration Act is a complete and comprehensive statute which exhaustively and exclusively sets out the Court’s jurisdiction in respect of all matters relating to the registration and enforcement of arbitral awards, including foreign arbitral awards. Page 6 of 13 [19] I agree with learned counsel for the Defendant’s above submissions. This Court has limited jurisdiction to grant any relief beyond that which is provided for under the Arbitration Act. [20] An application similar to this Application was made in the case of Danieli & C. Officine Mecchaniche SPA v. Southern HRC Sdn Bhd [2021] 10 MLJ 48 which involve Danieli Italy (as the plaintiff) and the Plaintiff herein (as the defendant) with regards to the DI Award. [21] In Danieli & C. Officine (supra), Danieli Italy based on the DI Award, requested access to the Plaintiff’s site to inspect the plant to determine its status as well as integrity and ability to operate. In response, the Plaintiff took the position that they would only give Danieli Italy access to the plant subject to them paying the award sum. Danieli Italy, on the contrary, took the position that their access to the site could not be conditional on the payment of the award sum. This then led to the filing of the action where Danieli Italy sought, inter alia, a declaration that they are entitled to inspect the plant and consequential orders based on the DI Award. [22] Before the case was heard, the Plaintiff filed an application under, inter alia, Order 28 Rule 3B(1) ROC for a declaration that the Court has no jurisdiction over the Plaintiff in respect of the remedy sought by the Danieli Italy and for an order that the Danieli Italy’s originating summons be struck off. [23] The Plaintiff clearly took the Defendant’s position in Danieli & C. Officine (supra) but is now arguing the opposite. In allowing the Plaintiff’s application the High Court held, inter alia, as follows: “[34] Hence, it is the defendant s contention that in respect of matters that fall within the ambit of AA 2005, the court has no jurisdiction, whether inherent or express, other than that expressly provided for in the Act. The explanatory notes referred to above clearly fortifies the defendant’s contention. In relation to the specific words ‘governed by this act’ in s 8, the defendant highlights that s 51(4) refers to the exact same words. It is thus submitted that upon reading the two sections together, as encl 1 relates to an arbitration commenced after the commencement of the Act, then this court cannot intervene save where provided for in the Act. Page 7 of 13 ……….. [42] In this regard, the defendant submits that the cause of action created by an arbitral award is the right to recognise and enforce it by entry as a judgment of the High Court. This was clearly an option open to the plaintiff under s 38 of the AA 2005 and utilising the procedure in O 69 of the ROC. Reliance for this proposition was placed on cases such as Malayan Flour Mill Bhd v Raja Lope & Tan Co [2000] 6 MLJ 591 as well as Mobikom Sdn Bhd v Inmiss Communications Sdn Bhd [2007] 3 MLJ 316. [43] The defendant also relies on the decision in Sintrans Asia Services Pte Ltd v Inai Kiara Sdn Bhd [2016] 2 MLJ 660 where the Court of Appeal when dealing with a Singapore arbitral award held that the court in Malaysia is purely an enforcement court and must recognise a valid arbitration award. [44] Similarly, in the case of Hiap-Taih Welding & Construction Sdn Bhd v BousteadPelita Tinjar Sdn Bhd(formerly known as Loagan Bunut Plantations Sdn Bhd) [2008] 8 MLJ 471, David Wong J (as His Lordship then was) had occasion to examine what was a parties cause of action once an arbitration award has been handed down wherein His Lordship concluded that the award itself does not give rise to a cause of action but that the cause of action is to enforce the award.” (own emphasis added) [24] I note that learned counsel for the Plaintiff had attempted to distinguish the Danieli & C. Officine (supra). Whilst there is some difference in the facts of Danieli & C. Officine (supra) and the present case, the central issue is that of jurisdiction which is the same as it is here. The main difference there was the fact that the originating summons was argued to tantamount to an application to enforce the DI Award. The Court did not agree with this argument and held that the reliefs prayed for in the originating summons was indeed a Court proceeding relating to arbitration and as such Section 8 of the Arbitration Act is applicable so as to prohibit intervention of the Court. [25] From the intitulement of the Originating Summons, it can be seen that the Plaintiff is relying on substantially Sections 41 and 42, Specific Relief Act 1950. The Plaintiff was clearly not relying on Page 8 of 13 any provision of the Arbitration Act or even Order 69 ROC which govern arbitration proceedings. Nevertheless, the DT Award and DI Award were stated in the intitulement and is a subject matter of the Originating Summons. [26] Therefore, it is clear to me that the subject matter and reliefs in Originating Summons were in relation to the DT Award and DI Award. However, the Originating Summons was not pursuant to or based on any of the provisions of the Arbitration Act. This is notwithstanding the fact that the Court cannot intervene in matters governed by the Arbitration Act except where so provided in the Act. [27] In this regard, the Federal Court in Far East Holdings Bhd & Anor v. Majlis Ugama Islam dan Adat Resam Melayu Pahang and other appeals [2018] 1 MLJ 1 listed out the applicable provisions of the Arbitration Act in which the Court has jurisdiction to intervene: [114] The AA 2005 is devoid of a provision in the words of s 81 (2) of the UK Arbitration Act 1996. But the AA 2005 is nonetheless clear that ‘No court shall intervene in matters governed by this Act, except where so provided in this Act’, Pertinent to ‘where so provided in this Act’, the AA 2005 provides for court intervention in the matters statedin ss 10, 11, 13(7), 15(3), 18(8), 29, 37, 41, 42, 44(1), 44(4), 45, and 46 of the AA 2005. ‘Where a party seeks intervention is one of those situations, the court is permitted to intervene only in the manner prescribed by the model law, and in the absence of any express provision the court must not intervene at all. By contrast, where the situation is not of a type to which the model law is addressed, the court may intervene or decline to intervene in accordance with the provisions of the relevant domestic arbitration law’ (A Guide to the UNCITRAL Model Law on International Commercial Arbitration: Legislative History and Commentary by Howard M Holtzmann and Joseph E Neuhaus, published in 1994 at p 224). Accordingly, s 8 ‘would... not exclude court intervention in any matter not regulated by (the AA 2005)’ (The Arbitration Act 2005 at p 8.17); matters which are not governed by the Model Law include the following areas: the inherent jurisdiction in the court to grant an injunction to stay arbitral proceedings; and the whole topic of confidentiality of arbitral proceedings (for a non-exhaustive list of matters not governed by the Model Law, see A Guide to the UNCITRAL Model Law on International Commercial Arbitration at p 218). Page 9 of 13 [115] But ‘...’ in situations expressly regulated by the Act, the courts should only intervene where so provided in the Act... ’ (LW Infrastructure Pte Ltd v Lim Chin San Contractors Pte Ltd and another appeal [2012] SGCA 57 per Sundaresh Menon JA, as he then was, delivering the judgment of the court). Since the setting aside of an award is a matter governed by the AA 2005, the court is permitted to set aside an award only in manner prescribed by the AA