The I·CONnect-Clough Center 2017 Global Review of Constitutional Law Malaysia: The State of Liberal Democracy

Andrew James Harding
Faculty of Law, National University of Singapore

Jaclyn Ling-Chien Neo
Assistant Professor
Faculty of Law, National University of Singapore

Dian Abdul Hamed Shah
Research Fellow, Centre for Asian Legal Studies
Faculty of Law, National University of Singapore

Wilson Tay Tze Vern
PhD Candidate
Faculty of Law, National University of Singapore

I. Introduction

Malaysia approaches its 14th General Election, which must be held by 24 August 2018 at the latest. This election will determine whether the ruling BN coalition returns to power despite the 1MDB corruption scandal that has attracted worldwide attention,[1] and recaptures the two-thirds majority in the federal Parliament which will enable it to amend the Federal Constitution. No party has enjoyed such a majority since 2008; hence no constitutional amendment has taken place since then. Against this backdrop, the constituency-redelineation exercise of the Election Commission of Malaysia (EC), which started in September 2016, has been particularly contentious. Opposition parties and their supporters have alleged, claiming extensive gerrymandering, that this redelineation gives further advantages to the ruling coalition (which the EC strenuously denies), and the exercise itself has been held up by extensive litigation across the country stretching throughout 2017.

Legal and political developments with a religious aspect continued to be particularly emotive in this country where Islam is constitutionally enshrined as ‘the religion of the Federation’[2] but which is also home to a sizeable non-Muslim minority of around 39% of the population.[3] These developments continue to test the dividing line between the two legal systems that co-exist in Malaysia’s pluralist legal sphere – one centred around the regular or ‘civil’ courts and the other around the religious or Syariah courts which exercise jurisdiction over Muslims in Malaysia. As exemplified by the ‘bin Abdullah’ case discussed further below, also at issue is the extent to which Islamic religious precepts and institutions can influence secular administrative bodies wielding governmental power in Malaysia.

II. Liberal Democracy on the Rise or Decline?

Liberal democracy could be said to remain in a relatively precarious position in Malaysia. While opposition politicians, civil society leaders, and the alternative media have generally been able to continue highlighting scandals such as that of state investment vehicle 1Malaysia Development Berhad (1MDB), and to organize public rallies such as the ‘Love Malaysia, End Kleptocracy’ event on 14 October, criminal charges have been pressed against several prominent opposition leaders that could disqualify them from politics. This year, a Committee of the Inter-Parliamentary Union adopted a Decision expressing concern over the use of criminal investigations and legal action against 19 opposition parliamentarians in Malaysia.[4]

The abolition of the mandatory death penalty for drug trafficking, passed by Parliament in December, represents a tentative step forward for the cause of liberal democracy. Amendments to the Dangerous Drugs Act 1952 now enable courts to impose a sentence of life imprisonment plus whipping for that offence in lieu of the mandatory death penalty if it finds that the accused ‘has assisted an enforcement agency in disrupting drug trafficking activities within or outside Malaysia.’[5]

It is encouraging that the government, in response to public pressure, removed a provision in the original bill that would have given Malaysia’s Attorney-General, as the Public Prosecutor, the sole discretion to certify whether or not the accused person had rendered such assistance to an enforcement agency. In the amendment’s final version, that discretion now rests with the courts. Thus the reform – originally modelled on Singapore’s 2013 amendment to its penalty for drug trafficking – has gone one step further and achieved an even more complete separation of powers by giving to the judicial branch, rather than the Public Prosecutor, full control over the decision whether a death sentence should be imposed.[6] This reform enhances the content and significance of the constitutional guarantee in Article 5(1) that no person shall be deprived of life or personal liberty, save in accordance with law.

On the other hand, speech and activity with religious aspects have come under increasing control and suppression in Malaysia. Many publications touching upon Islam have been banned on the basis that they could cause ‘confusion’, ‘anxiety’, ‘anger’, or even ‘division’ among the Muslim community, which the government considers to be public order concerns.[7] When faced with challenges to such bans, the courts have tended to adopt a deferential approach, affirming the government’s decisions.

Furthermore, religious freedom – especially for Muslims – continues to be highly restricted in Malaysia. In several cases that came up for consideration in 2017, the courts affirmed existing doctrine that the question of whether a person was a Muslim or not is a matter under the exclusive jurisdiction of the Syariah Court. This means that even where a person had publicly renounced Islam (eg by way of a statutory declaration), they are still bound by Islamic law, particularly its rules on conversion out of Islam. They can only convert out of Islam if the Syariah courts ‘certify’ their conversion, which in the current constitutional context remains highly unlikely.[8]

These developments could be seen as lack of due regard for the freedom of speech as well as freedom of religion, which are enshrined in Articles 10(1) and 11 of the Federal Constitution, respectively.

III. Major Constitutional Developments

Constituency Boundaries Litigation

The Malaysian courts continued to be the main avenue for opposition parties and concerned citizens to mount challenges against the Election Commission (EC)’s redelineation exercise. The EC had, in September 2016, published notice of its proposed recommendations for the redelineation of Federal and State constituencies in Peninsular Malaysia, as is mandated every eight years or more under Article 113(2) of the Federal Constitution. These recommendations are thereafter to be reported to the Prime Minister, who then tables it before the House of Representatives (the lower house of Parliament) alongside a draft order giving effect to the recommendations, with or without modifications. Upon the draft order being approved by not less than one-half of the total members of the House, it is submitted to the Yang di-Pertuan Agong (the King) who makes an Order in terms of the draft, completing the redelineation. However, at the notice stage, any State Government or local authority whose area is affected by the recommendation, or any body of 100 or more persons in an affected constituency, may object, whereupon the EC shall hold local enquiries in respect of these constituencies and may modify its recommendations if necessary.

The Selangor State Government – controlled by political parties in opposition at the federal level – sought judicial review against the EC recommendations in Selangor, highlighting that they resulted in malapportioned, gerrymandered constituencies, were based on incomplete and defective electoral rolls, and lacked particulars necessary for voters to make meaningful representations in response.[9] After a prolonged hearing, the High Court declined to intervene on the basis that the EC’s recommendations and its discretion to take into account the principles governing redelineation as provided for in the Thirteenth Schedule of the Federal Constitution were non-justiciable since the final decision on the redelineation is reserved for Parliament. The State Government nonetheless secured a stay, pending an appeal, preventing the EC proceeding further with the redelineation; but the Court of Appeal swiftly overturned that stay. Other court challenges to various EC recommendations were also mounted, unsuccessfully, by groups of voters in other states. The deluge of litigation, however, appears to have significantly delayed the completion of the redelineation exercise which, under Article 113(2)(iii) of the Federal Constitution, must conclude by September 2018.

The redelineation exercise is a serious matter due to the persistent problem of electoral malapportionment and gerrymandering in Malaysia. Coupled with Malaysia’s first-past-the-post electoral system, the absence of concrete rules and ratios governing the apportionment of electors to constituencies in Part I of the Thirteenth Schedule (which sets out the so-called ‘Principles Relating to the Delimitation of Constituencies’) has already produced a situation where, in the previous general election, the ruling coalition polled 47% of the votes in an essentially two-party contest, yet secured 60% of the parliamentary seats.[10] The latest redelineation exercise will allegedly exacerbate the problem even further; to cite but one example, one of the new constituencies it would produce will contain approximately ten times more electors than another.[11] There are also serious allegations of ethnic discrimination in the redrawing of constituency boundaries.[12] Since the exercise directly affects not only the question of who forms the government post-election but also whether a government emerges with the two-thirds majority needed to amend the Federal Constitution, this is a debate of momentous significance.

Two Landmark Cases on Separation of Powers

In Semenyih Jaya Sdn Bhd v Pentadbir Tanah Daerah Hulu Langat & Anor,[13] the Federal Court re-examined a 1988 constitutional amendment that deleted ‘the judicial power of the Federation’ from the provision in the Federal Constitution establishing the courts of first instance [Article 121(1)]. Departing from precedents interpreting this amendment as having drastically curbed the jurisdiction and powers of the Malaysian courts vis-à-vis Parliament,[14] the Federal Court stridently affirmed that judicial power, judicial independence and the separation of powers ‘are as critical as they are sacrosanct in our constitutional framework.’[15] Therefore, Article 121(1) was interpreted as continuing to enshrine the separation of powers and the independence of the judiciary as basic features of the Federal Constitution.[16] Judicial power to adjudicate matters brought to court is vested only in the courts, and ‘any alterations made in the judicial functions would be tantamount to a grave and deliberate incursion into the judicial sphere.’[17] Thus, the Federal Court struck down a statutory provision restricting the courts’ ability to determine whether owners of land compulsorily acquired by the government had been adequately compensated in accordance with the rights to property protected under Article 13 of the Federal Constitution. This reassertion of judicial power augurs well for the role of the courts in safeguarding the supremacy of the Federal Constitution and the rule of law.

Semenyih Jaya also revived discussion of the ‘basic structure doctrine’, under which a legislature cannot amend the written constitution in ways that would destroy its basic structure, even if the stipulated amendment procedure is followed. The Federal Court’s explicit assertion that Parliament does not have the power to amend the Federal Constitution to the effect of undermining the separation of powers and the independence of the judiciary enshrined therein[18] is a landmark development that departs significantly from previous rulings on the issue and brings Malaysia in line with some other Commonwealth jurisdictions.

In Teng Chang Khim (appealing as Speaker of Selangor State Legislative Assembly) v Badrul Hisham bin Abdullah & Anor,[19] the Federal Court clarified the limits of judicial intervention into legislative proceedings, given the concept of parliamentary privilege. The Speaker’s act of declaring a member of the State Legislative Assembly’s seat vacant upon the latter’s prolonged absence without leave – as the Speaker is empowered to do under the Selangor State Constitution – was held to be ‘inevitably connected with the essential business of the Legislative Assembly’, such that it was protected by parliamentary privilege under Article 72(1) of the Federal Constitution, even though the declaration itself was made at a press conference and not in formal Assembly proceedings. The Federal Court clarified that the court could only intervene if the Legislative Assembly, or a committee or officer thereof, was acting ultra vires its legal powers. Otherwise, it would be non-justiciable due to parliamentary privilege.

Religion and Administrative Power

In A Child & Others v Jabatan Pendaftaran Negara & Others,[20] the Court of Appeal examined the proper exercise of administrative power in matters implicating religious identification. In this case, a child was born out of wedlock under Syariah law to Muslim parents. When the National Registration Department (NRD) issued the birth certificate, the child’s name bore the patronymic surname ‘bin Abdullah’ instead of his father’s name. This was done against the wishes of the parents, who proceeded to make an application to correct the surname to reflect the name of the father. The NRD rejected the application and justified the decision on religious grounds, asserting that under Syariah law – which governs Muslims in Malaysia – an illegitimate Muslim child could not bear the name of his father, but must be ascribed with the surname ‘bin Abdullah’. The Director-General of the NRD relied on two fatwas from the National Fatwa Committee in 1981 and 2003 in preference to the statutory provisions governing his exercise of power, ie the Births and Deaths Registration Act 1957 (BDRA).

The Court of Appeal judgment, in favour of the appellants, is significant for three reasons. The first concerns the reach of religious authorities and injunctions in civil or ‘secular’ matters. Unlike the High Court decision that approved the NRD’s reliance on Islamic law in deciding an illegitimate child’s surname, the Court of Appeal insisted that this issue is governed only by the BDRA. From this perspective, the NRD had acted irrationally and exceeded the scope of its power, as it only needed to consider whether the appellant had met the statutory registration requirements. The Court stressed that the BDRA does not sanction the application of Islamic law or principles in the registration process[21] and that fatwas are irrelevant to the exercise of statutory duties under the BDRA.[22] 

Second, the Court’s reasoning has implications for the country’s federal arrangement in matters involving Islam. National registration is a ‘civil’ matter under the federal list of powers and any attempt to allow fatwas – which do not have binding or legislative force in this particular instance – to dictate the administration of civil law would be unconstitutional. The case also raises a question about a federal body encroaching on state authority in Islamic law matters. The fatwas in question, having been issued by the federal-level National Fatwa Committee, could not have applied to the appellants, who were residents of the state of Johor. By deciding the way it did, the Court of Appeal keeps intact the constitutionally-demarcated federal and state division of powers – powers that have recently been increasingly blurred by fervent exercises of power by federal-level religious bodies.

Finally, the judgment displayed great sensitivity to extra-legal considerations, ie, as the Court aptly expressed, ‘whether an innocent child should be subjected to humiliation, embarrassment and public scorn for the rest of his life.’[23] This of course does not dilute the significance of the legal reasoning offered by the Court, but when considered together with the astute legal analysis, overall the decision is a welcome approach to deciding important questions involving religion and constitutional law.

Religion and Freedom of Expression

One of the most prominent cases this year was the ban on a book by a Canadian lesbian author titled ‘Allah, Liberty & Love: The Courage to Reconcile Faith and Freedom’ and its translated Malay version. The stated ground for the ban was that the book was prejudicial to morality and public order. Following the ban, the enforcement division of the Selangor state religious department raided the offices of the publisher of the translated book and sought to charge the director of the publishing house before the Syariah Court under the Syariah Criminal Offences (Selangor) Enactment 1995. Under section 16 of the Enactment, a person who publishes or has in his possession religious publications contrary to Islamic law is liable on conviction to a fine not exceeding RM3,000 and/or imprisonment not exceeding two years. The publisher and the director challenged the provision in the Enactment and the actions of the religious department officers on constitutional and administrative law grounds. The High Court dismissed the application on a preliminary objection,[24] but on appeal, the Court of Appeal held that the dismissal was erroneous and remitted the matter to the High Court for a substantive hearing of the judicial review application.[25]

Another case to monitor concerns the constitutionality of a fatwa by the Selangor Fatwa Committee against a prominent women’s rights group, Sisters In Islam, designating the group as ‘deviant’. The group’s challenge was also initially dismissed by the High Court on the basis that only Syariah courts have the power to deal with a religious decree. However, the Court of Appeal reversed the ruling and remitted the case back to the Kuala Lumpur High Court.[26] This will be another important case as it implicates the scope of a religious fatwa committee’s powers and the extent to which it is subject to the Federal Constitution’s guarantees of fundamental liberties, which include the freedom of association and assembly as enshrined in Article 10.

Child Conversions and Law Reform (Marriage and Divorce) Act 1976

In November 2016, a bill was tabled in Parliament to amend the Law Reform (Marriage and Divorce) Act 1976, which included provisions requiring both parents in a civil marriage to consent to a minor’s conversion into Islam and providing that a child will remain in the religion of his/her parents at the time the marriage was registered.[27] This offered the best hope for an end to lingering problems brought about, in part, by civil-Syariah jurisdictional battles in matters concerning conversions.[28] However, when Parliament passed the bill in August 2017, section 88A which would have invalidated unilateral conversions of children, was conspicuously missing. The government claimed that it withdrew the provision as it would conflict with existing Federal Court decisions on the unilateral conversion of children.[29]

Even though the final amendment contained positive developments—for instance, it cemented the position that disputes relating to custody, maintenance, and matrimonial assets that arise from the dissolution of a civil marriage must be resolved in the civil courts rather than the Syariah courts (despite the conversion of one spouse to Islam), as well as inserting a provision that both the converted and non-converting spouse could petition for divorce before the civil courts—critics argue that the main objective behind efforts to amend the law had always been the issue of unilateral conversion. The fact that section 88A fell through demonstrates how the government and the political process could cave in to majoritarian pressures surrounding the question of conversion. The passing of the bill may well have ended any legislative initiative to resolve the long-standing controversy surrounding unilateral conversions of underage children.[30] It also raises a crucial question – if the judicial and political processes do not protect fundamental rights and minorities, what recourse would citizens then have?

Controversial Extension of Chief Justice’s Tenure

In July, the Government announced that Tun Raus Sharif’s term as Chief Justice of the Federal Court (the highest judicial appointment in Malaysia) would be extended for three years from 4 August, while Tan Sri Zulkifli Ahmad Makinudin would continue as President of the Court of Appeal (PCA) for two years from 28 September. Both senior judges were to have retired on these dates upon reaching the constitutional age-limit for judges of the Federal Court. This unprecedented extension of the CJ’s and PCA’s tenure beyond retirement age was purportedly done under Article 122(1A) of the Federal Constitution, which allows the appointment of ‘additional judges’ of the Federal Court beyond the age limit. However, it remains highly questionable whether that provision allows for a judge’s tenure qua CJ and PCA (as opposed to an ordinary membership of the Federal Court) to be extended in that manner.

Several parties subsequently attempted to challenge these appointments by way of judicial review. In November, former Prime Minister Tun Dr Mahathir Mohamad’s application for judicial review was dismissed by the High Court on the basis that there could be no statutory duty for the Prime Minister to advise the King to revoke the allegedly unconstitutional appointments.[31] In December, another application for judicial review, by opposition party Amanah, was also dismissed due to lack of locus standi.[32]

The Malaysian Bar took a strong stand on the matter, convening an Extraordinary General Meeting on 3 August, at which it resolved that these extensions were ‘unconstitutional, null and void.’[33] The Bar also resolved that it would ‘no longer have confidence’ in these two judges continuing to hold office as CJ and PCA, and mandated the Bar Council to institute legal proceedings challenging the constitutionality of the extensions. This duly took place and on 19 December, the Bar was granted leave by the High Court to refer six questions regarding the constitutionality of these appointments for determination by the Federal Court in 2018. A singular difficulty arising in this litigation is how the case will be heard and disposed of, given that the persons who are the subject of the challenge are currently occupying the top two positions in the very same court hearing the case.

IV. Looking Ahead to 2018

The main event in 2018 is undoubtedly the upcoming 14th general election, in which all seats in the Lower House of the federal Parliament, as well as every state legislature except Sarawak’s, will be up for election. This election will test whether the incumbent BN can head off the main opposition ‘Coalition of Hope’ (PH) and even possibly recapture a two-thirds majority in Parliament, which would enable it to amend the Federal Constitution at will once again.

If 93-year old former Prime Minister Mahathir Mohamad – the one-time strongman of Malaysia turned government arch-critic – remains at the helm of PH, this election will demonstrate how far he can sway popular support against scandal-hit incumbent Prime Minister Najib Razak, particularly among the latter’s core constituency of Malay and indigenous voters. This election will also determine – at least for the duration of the next parliament – the ability of the Islamic Party of Malaysia (PAS) to continue pushing its Islamist agenda for Malaysia since PAS has chosen to align itself with neither the BN nor PH.[34]

The Malaysian Bar’s challenge to the constitutionality of the reappointment of the Chief Justice and the President of the Court of Appeal – presently before the Federal Court – is a case to watch in 2018. This scenario, unprecedented in Malaysian constitutional history, will test the ability of the apex court to deliver a convincing and well-reasoned resolution capable of sustaining current efforts to rebuild public confidence in the Malaysian judiciary.

Cases on religious issues, as highlighted above, will also, as ever, be notable in 2018. Three such cases – the government’s appeal against the A Child & Others decision at the Federal Court, and the substantive judicial review applications involving Canadian author Irshad Manji and Sisters in Islam – will be particularly important to watch.

IV. Further Reading

HP Lee, Constitutional Conflicts In Contemporary Malaysia, (2nd edn, OUP 2017).

Andrew Harding and Dian AH Shah, Law and Society in Malaysia: Pluralism, Religion and Ethnicity (Routledge 2017).

Andrew Harding, ‘Devolution of Powers in Sarawak: A Dynamic Process of Redesigning Territorial Governance in a Federal System’ [2017] 12 Asian Journal of Comparative Law 257.

Gopal Sri Ram, ‘The Dynamics of Constitutional Interpretation’ [2017] 4 MLJ i.

[1] See Jaclyn LC Neo et al, ‘Malaysia: Developments in Malaysian Constitutional Law’, in Richard Albert et al (eds), I·CONNECT-Clough Center 2016 Global Review of Constitutional Law (I·CONNECT, 2017) 125-126.
[2] Federal Constitution of Malaysia (‘Federal Constitution’), Art 3(1).
[3] ‘The World Factbook’ (Central Intelligence Agency, July 2017) <> accessed 8 January 2018.
[4] Committee on the Human Rights of Parliamentarians, ‘Decision adopted by the Committee on the Human Rights of Parliamentarians at its 152nd session (Geneva, 23 January to 3 February 2017)’ <> accessed 28 December 2017.
[5] Dangerous Drugs (Amendment) Act 2017, s 2, passed by both Houses of Parliament on 14 December. 
[6] Amnesty International, ‘Singapore: Executions continue in flawed attempt to tackle drug crime, despite limited reforms’ (Amnesty International, 11 October 2017) <> accessed 4 January 2018.
[7] See eg Mohd Faizal bin Mus v Minister of Home Affairs [2017] 11 MLJ 397 (High Court, Kuala Lumpur).
[8] Jenny bt Peter @ Nur Muzdhalifah Abdullah v Director of Jabatan Agama Islam Sarawak & Ors and other appeals [2017] 1 MLJ 340 (Court of Appeal); Mardina Tiara bt Abdullah Emat @ Margaret ak Emat v Director of Jabatan Agama Islam Sarawak & Ors [2017] 9 MLJ 293 (High Court, Kuching); Syarifah Nooraffyzza Wan Hosen v Director of Jabatan Agama Islam Sarawak & Ors [2017] 1 LNS 995 (High Court, Kuching)
[9] Kerajaan Negeri Selangor v Suruhanjaya Pilihan Raya & Others [2017] MLJU 1902 (High Court, Kuala Lumpur).
[10] ‘What’s Malay for gerrymandering?’ (The Economist, 9 August 2014) <> accessed 4 January 2018.
[11] ‘Selangor voters cite massive size discrepancies in objections to EC’s redelineation’ (Malay Mail Online, 3 January 2018) <> accessed 4 January 2018.
[12] ‘EC’s Redelineation Clearly Biased, Critics Tell PM’s Aide’ (The Malaysian Insight, 19 December 2017)  <> accessed 4 January 2018.
[13] [2017] 3 MLJ 561 (Federal Court).
[14] See Public Prosecutor v Kok Wah Kuan [2008] 1 MLJ 1 (Federal Court); Danaharta Urus Sdn Bhd v Kekatong Sdn Bhd [2004] 2 MLJ 257 (Federal Court).
[15] Semenyih Jaya, 593.
[16] ibid 590.
[17] ibid [67], [84].
[18] ibid [76].
[19] [2017] 5 MLJ 567.
[20] [2017] 4 MLJ 440.
[21] ibid 455.
[22] ibid 453.
[23] ibid 445.
[24] ZI Publications Sdn Bhd & Anor v Jabatan Agama Islam Selangor & Ors [2017] 1 LNS 1816.
[25] ZI Publications Sdn Bhd & Anor v Jabatan Agama Islam Selangor & Ors [2017] 1 LNS 997.
[26] Zurairi AR, ‘SIS allowed to continue judicial review against ‘deviant’ fatwa’ (Malay Mail Online, 2 March 2017) <> accessed 6 January 2018.
[27] Law Reform (Marriage and Divorce) (Amendment) Bill 2016, s 88A.
[28] See eg Jaclyn Neo, ‘Competing Imperatives: Conflicts and Convergences in State and Islam in Pluralist Malaysia’ [2015] 4 Oxford Journal of Law and Religion 1.
[29] In Subashini a/p Rajasingam v Saravanan a/l Thangathoray and Other Appeals [2008] 2 MLJ 147, the Federal Court held that the conversion of a child by either parent is valid ie it does not require the consent of both parents. This decision was affirmed in Pathmanathan Krishnan v Indira Gandhi Mutho and Other Appeals [2016] 1 CLJ 911. See also Dian AH Shah, ‘Religion, Conversions and Custody: Battles in the Malaysian Appellate Courts’, in Andrew Harding & Dian AH Shah (eds), Law and Society in Malaysia: Pluralism, Religion, and Ethnicity (Routledge 2018) 145, 150-152.
[30] See Dian AH Shah, ‘Religion, conversions and custody: battles in the Malaysian appellate courts’ in Andrew Harding and Dian AH Shah, Law and Society in Malaysia: Pluralism, Religion, and Ethnicity (Routledge 2018) 145 – 162.
[31] ‘Dr Mahathir Loses Bid to Challenge Appointment of Two Judges’ (New Straits Times, 6 November 2017) <> accessed 6 January 2018.
[32] ‘Amanah fails in judicial review bid against CJ’s appointment’ (Malay Mail Online, 19 December 2017) <> accessed 5 January 2018.
[33] Resolution Adopted At The Extraordinary General Meeting of the Malaysian Bar (3 August 2017) <> accessed 28 December 2017.
[34] Yang Razali Kassim, ‘Is A New PAS Emerging?’ (Straits Times, 5 May 2017) <> accessed 28 December 2017.


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