In Masenang Sdn Bhd v Sabanilam Enterprise Sdn Bhd [2021] 9 CLJ 1, the Federal Court clarified that (i) the concept of the seat of arbitration applies to domestic arbitrations; (ii) the seat must be designated as a place within a country (and not the entire country); and (iii) the seat determines which High Court has exclusive supervisory jurisdiction over the arbitration (as opposed to the factors usually applicable in other types of civil proceedings).