The court had jurisdiction to grant a final injunction under s37 of the Senior Courts Act 1981 restraining foreign proceedings brought in breach of an arbitration agreement even though there was no actual, proposed or intended arbitration. The courts’ power to grant interim injunctive relief for the purpose of preserving evidence or assets under s44 of the Arbitration Act 1996 only applies where arbitral proceedings are underway or intended (AES Ust-Kamenogorsk Hydropower Plant LLP v Ust-Kamenogorsk Hydropower Plant JSC (2011).