The world has relied on fossil fuel energy for a long time, producing many adverse effects. Long-term fossil fuel dependency has increased carbon emissions and accelerated climate change. In addition, fossil fuels are also depleting and will soon be very costly. Moreover, the expensive national electricity grid has yet to reach rural areas and will be cut off in inundation areas. As such, alternative and carbon-free hydrogen fuel cell energy is highly recommended as it solves these problems. The reviews find that (i) compared to renewable energy such as solar, biomass, and hydropower, a fuel cell does not require expensive transmission through an energy grid and is carbon-free, and hence, it is a faster agent to decelerate climate change; (ii) fuel cell technologies have reached an optimum level due to the high-efficiency production of energy, and they are environmentally friendly; (iii) the absence of a policy on hydrogen fuel cells will hinder investment from private companies as they are not adequately regulated. It is thus recommended that countries embarking on hydrogen fuel cell development have a specific policy in place to allow the government to fund and regulate hydrogen fuel cells in the energy generation mix. This is essential as it provides the basis for alternative energy governance, development, and management of a country.

As a party to the United Nation Framework Convention on Climate Change (UNFCCC), Malaysia is committed to reduce its greenhouse gases (GHG) emission intensity of gross domestic product (GDP) by 45% by 2030 relative to the emission intensity of GDP in 2005. One of the ways for Malaysia to reduce its GHG emission is to diversify its energy mix and to include hydrogen fuel cell (HFC) in its energy mix. Since Malaysia does not have any legal framework for HFCs, it is best to see how other countries are doing and how can it be replicated in Malaysia. This paper reviews the HFC legal framework in the United States, Germany and South Korea as these countries are among those that have advanced themselves in this technology. The researchers conducted a library-based research and obtained the related materials from online databases and public domain. Based on the reviews, the researchers find that these countries have a proper legal framework in place for HFC. With these legal frameworks, funds will be available to support research and development, as well as demonstration of HFC. Thus, it is recommended that Malaysia to have a proper HFC legal framework in place in order to support the development of the HFC industry.

The government of Malaysia has declared the Movement Control Order (MCO) for the whole nation in order to flatten the curve of COVID-19 infection. The MCO has, among others, caused parties in a contract to question the effect of the MCO on the contract. As the areas of law are wide, this paper aims to discuss the effect of MCO on a tenancy contract. The paper analysed the legal position of doctrine of frustration and force majeure clause in the context of tenancy contract in Malaysia. The analysis was done based on the law cases and legal provisions in Malaysia. Reference was also made to case law from the United Kingdom and Singapore as their law is in pari materia with Malaysian law and they are persuasive in nature. This paper found that the doctrine of frustration can be invoked if the performance of the obligation under the tenancy contract is prevented due to the MCO. However, the court will apply the doctrine of frustration in a very careful manner to respect the sanctity of the agreement. As for the force majeure clause, it can be successfully invoked if the scope of the clause covers the event in question, such as the MCO. In conclusion, whether a tenancy contract can be terminated due to the MCO, it will depend on the terms of each tenancy contract.