In Cruz City 1 Mauritius Holdings v Unitech Ltd ,¹ a case which concerned the court's jurisdiction under section 44(2)(e) of the Act to grant "an interim injunction or the appointment of a receiver", Males J (as he was then) considered in obiter comments that " the better view is that section 44 does not include any power to grant an injunction against a non-party ". Subsequently, in DTEK Trading SA v Morisov ,² the English court considered whether it had jurisdiction under section 44(2)(b) of the Act to make an order for the preservation and inspection of a document in the possession of a third party in Ukraine. Sara Cockerill QC (as she then was) followed Males J's analysis in Cruz City and concluded that the wording of section 44 did not indicate that it was intended to cover applications against third parties. Accordingly, she held that the English court did not have jurisdiction under section 44 of the Act to make an order against a non-party to the arbitration.