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CENTRE FOR FOUNDATION STUDIES OF

INTERNATIONAL ISLAMIC UNIVERSITY OF MALAYSIA


NILAI

GENERAL PRINCIPLES OF LAW II


SAM 2283

WRITTEN ASSIGNMENT
SEM 2, 2009/2010
MADAM BADARIAH HAJI SADIN

GROUP 3
No. Group Members’ Name Matric No.
1. AIZUREEN BT MOHD ANINI 085273
2. ‘ADILAH BINTI SABRI 085435
3. WARDATUL IKMAL BT MOHD KAMAL 085439
4. NADRA FATIMA BINTI MANNAN 085789
5. ALIA BINTI ABDULLAH 085814

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C ont e nts
TOPIC PAGE

v Introduction 3-4

v Elaboration 5-17

v Bibliography 18

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“Judges are qualified person appointed to be the member of the judicial and legal services
of the Federation. They enjoyed full immunity and not easily to be removed.”

Elaborate of the special rights given to the judges and to what extent their immunity is
being safeguarded.

INTRODUCTION

In order to perform the court’s role in determining the constitutionality of statutes and
administrative actions, court must be independent from the other two branches of
government. This is called the ‘Independence of Judiciary.’ There are many ways to ensure
this. In the theory of the independent judiciary by Alexander Hamilton, (America's first
lawyers who wrote most of the Federalist Papers, a primary source for Constitutional
interpretation), he stated,

“Next to permanency of office, nothing can contribute more to the independence of the
judges than a fixed provision for their support…In the general course of human nature, a
power over a man’s subsistence amounts to a power over his will. And we can never hope to
see realised in practice the complete separation of the judicial from the legislative power, in
any system which leaves the former dependent for pecuniary resources on the occasional
grants of the latter…This provision for the support of the judges bears every mark of
prudence and efficacy; and it may be safely affirmed that, together with the permanent tenure
of their offices, it affords a better prospect of their independence than is discoverable in the
constitutions of any of the states, in regards to their own judges.”

The concept of judicial independence requires that judges be free from any interference in
the exercise of their judicial powers. Each judge must be independent from external
influences that may seek to reduce his or her objectivity and impartiality. This requires
independence both from the other branches of government, and from any other influences
that may affect the capacity of a judge to decide a case strictly on the basis of its legal merits.
It also requires independence from other judges involved in decision making, although the
systems of appellate and judicial review necessarily impinge on a judge's independence of
action. An impartial assessment of the facts and objective application of the law are essential
for legal independence.

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Judicial independence encompasses both institutional and individual aspects. As an
institution, the judiciary must be respected as a distinct, separate and independent branch
of government. At the same time, within the judiciary, individual judges must have the
substantive freedom necessary to perform their duties in an independent and impartial
manner, beyond any improper or undisclosed influence and pressure. The key provisions in
the Constitution in respect to judge’s includes:

1. Judge’s immunity
2. Security of Tenure
3. Security of Remuneration
4. Contempt of court
5. Prohibition on public discussion on judges conduct

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1. Immunity

Judges enjoy immunity from any civil or criminal liability in the course of proceedings
presided by him. This legal immunity applies to both superior and inferior courts’ judges.

Judicial immunity of judges is granted both at common law and, in Malaysia, by Section 14
of the Courts of Judicature Act 1964 which reflects the age-old common law principle that
persons exercising judicial functions are exempt from all civil liability of any kind, in respect
of anything done or said by them in their judicial capacity.

This is what section 14 says— its heading requires some attention, by the way:

14. Protection of Judges and other judicial officers1

(1) No Judge or other person acting judicially shall be liable to be sued in any civil court for
any act done or ordered to be done by him in the discharge of his judicial duty, whether or
not within the limits of his jurisdiction, nor shall any order for costs be made against him,
provided that he at the time in good faith believed himself to have jurisdiction to do or order
the act complained of.

Thus, and as an illustration, if a judge makes a comment, inference, or finding of fact in the
course of judgment, he or she is accorded the protection of judicial immunity, and cannot be
sued in any court. This protection applies even where the judge has acted outside the ambit of
his jurisdiction, so long as at the time of so acting the judge himself (whether rightly or
erroneously) believed that he had the jurisdiction to do what he did.

The existence of judicial immunity is rooted in sound and solid grounds of public policy. If
judges do not enjoy such immunity, and if they can be taken to court for what is alleged to be
a wrong finding, comment or decision, then no judge will be able to carry out his or her
judicial function free from fear. The fabric of the independent exercise of judicial decision
making will wholly disintegrate.

Any error alleged to have been made by a judge must be addressed by way of the appeal
process, and not by seeking to establish liability on the part of the judge.

1
COURTS OF JUDICATURE ACT 1964 (ACT 91) ; (AS AT 5TH JULY 2004) (Petaling Jaya: International
Law Book Services, 2004), p. 13

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However, it is also important to realise that judicial immunity does not mean that the
decisions and conduct of judges may not be commented upon or criticised. The contrary is in
fact the case, in any democratic society that cherishes accountability. Judges’ decisions and
conduct may properly be the subject matter of discussion and criticism, unless it is done with
malice, or as a deliberate attempt to undermine the administration of justice.

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2. Security of Tenure

Besides that, the Malaysian Constitutional also includes provisions concerning the removal
judges which are contained in three clauses of Article 1252:-

125. Tenure of office and remuneration of judges of Federal Court


(3) If the Prime Minister, or the Chief Justice after consulting the Prime Minister, represents
to the Yang di-Pertuan Agong that a judge of the Federal Court ought to be removed on the
ground of any breach of any provision of the code of ethics prescribed under Clause (3B) or
on the ground of inability, from infirmity of body or mind or any other cause, properly to
discharge the functions of his office, the Yang di-Pertuan Agong shall appoint a tribunal in
accordance with Clause (4) and refer the representation to it; and may on the recommendation
of the tribunal remove the judge from office.

This means that a judge may only be removed on the ground of misbehaviour or of inability
from infirmity of body or mind or any other cause properly to discharge the functions of his
office. The procedure is as follows3:-

(1) First a representation that he ought to be removed will have to be made to the King
by either the Prime Minister or the Lord President. If it is made by the Lord
President, the latter is required to consult the Prime Minister.
(2) Upon receipt of the representation, the King has to appoint a tribunal of judges and to
refer the representation to the tribunal for its report and recommendation and pending
such reference, he may suspend the judge from discharging the function of his office.
(3) Finally upon receipt of the report and recommendation of the tribunal, the King may
on its recommendation remove the judge.

The nature of a tribunal established under art. 125 was considered briefly in Tun Dato Haji
Mohamed Salleh Bin Abas. In this case Attorney General applied to set aside an ex parte
order restraining the tribunal appointed under art 125(3) of the Federal Constitution from
submitting any recommendations, report or advice respecting the inquiry into representation

2
FEDERAL CONSTITUTION (AS AT 20TH JUNE 2009) (Petaling Jaya: International Law Book Services,
2009), p. 107-108
3
Tun Salleh Abbas. THE ROLE OF THE INDEPENDENT JUDICIARY; With Translation in Bahasa Malaysia,
(Malaysia: Percetakan A-Z Sdn. Bhd., 1989), p. 36.

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concerning Tun Dato Haji Mohamed Salleh bin Abas to the Yang di-Pertuan Agong until
further order. Hashim Yeop A Sani SCJ in delivering the judgment of the court observed,

“The functions of the tribunal appointed under art 125(3) of the Constitution are to inquire
and investigate on the representation and then report to the Yang di-Pertuan Agong with any
recommendation it may make. The tribunal is a body which investigates and does not
decide. It is performing a constitutional function. The tribunal should not therefore be
restrained from performing its constitutional function.

Finally, the members of the tribunal are appointees of the Yang di-Pertuan Agong. From the
language of art 125 it is clear that the Yang di-Pertuan Agong is entitled to the report of the
tribunal. To restrain the tribunal from submitting their report is in effect to restrain His
Majesty from receiving the report.”4

Hence, the appointment of members of the tribunal required guidelines which can be refer to
art. 125(4)5:-

125. Tenure of office and remuneration of judges of Federal Court


(4) The tribunal appointed under Clause (3) shall consist of not less than five persons who
hold or have held office as judge of the Federal Court, the Court of Appeal or a High Court,
or, if it appears to the Yang di-Pertuan Agong expedient to make such appointment, persons
who hold or have held equivalent office in any other part of the Commonwealth, and shall be
presided over by the member first in the following order, namely, the Chief Justice of the
Federal Court, the President and the Chief Judges according to their precedence among
themselves, and other members according to the order of their appointment to an office
qualifying them for membership (the older coming before the younger of two members with
appointments of the same date).

Appointment of the Tribunal is another matter of great concern. The Tribunal is appointed by
the King and the guidelines are as follows:-
(1) The number of members should not be less than 5.
(2) The members must be judges or persons who have held office as judges.

4
TUN DATO HAJI MOHAMED SALLEH BIN ABAS V TAN SRI DATO ABDUL HAMID BIN OMAR &
ORS [1988] 3 MLJ 149, p. 151.
5
FEDERAL CONSTITUTION (AS AT 20TH JUNE 2009) (Petaling Jaya: International Law Book Services,
2009), p. 108

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(3) They may be persons who hold or have held equivalent office in any part of the
Commonwealth if it appears to the King expedient to make such appointment.

Thus, in order to remove a judge evidence is demanded of the particular judge if he is either
guilty of misbehaviour or inability from infirmity of body and mind to properly discharge the
functions of their office. This is shown that the judges are difficult to be dismissed as it must
be with a recommendation from a tribunal consisting of at least five or ex-judges which take
a duration of time as to meet up their special rights to safeguard their judges’ immunity as
established in Federal Constitution.

However, public confidence in the Bench has been in free fall since 1988 when the top judge,
Tun Salleh Abas, and other two other judges were sacked for reasons always suspected to be
politically motivated. Further scandals like the fixing judicial appointments and case-fixing
have tarnished its reputation so badly that foreign investors routinely refuse to take their
disputes to Malaysian courts. Thus, Malaysian government makes raft of reforms to overhaul
the judiciary by offering ex gratia payments to the judges who lost their jobs in 1988, and
acknowledged ‘the pain and the loss they have endured during the era of ex-Prime Minister,
Tun Abdullah Ahmad Badawi in year 2008.6

The Code of Ethic for judges that is mentioned in art. 125 and also can be referred to a case
in Allied Capital. In this case, the Federal Court considered the Code of Ethics with regard to
conflict of interest. Mohtar Abdullah FCJ in delivering judgment of the court observed,
“In Malaysia, pursuant to cl. (3A) of art. 125 of the Federal Constitution, the Yang di-
Pertuan Agong have prescribed the Judges Code of Ethics 1994 to govern, the judicial
conduct of judges. The breach of any provision of the Code may constitute a ground of the
removal of the judge from office. Paragraph 3(1)(a),(b) and (c) is relevant to our discussion.
It provides
(1) A judge shall not-
(a) Subordinate his judicial duties to his private interests;
(b) Conduct himself in such manner as is likely to bring his private interests into
conflict with his judicial duties;
(c) Conduct himself in any manner likely to cause a reasonable suspicion that-
6
http://www.malaysianbar.org.my, The Malaysian Bar; Abdullah promises pay rises for judges, Friday, 18
April 2008.

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(i) He has allowed his private interests to come into conflict with his judicial duties
as to impair his usefulness as a judge; or
(ii) He has used his judicial position for his personal advantage ...
Under the Anti-Corruption Act 1997 (‘the ACA’), the definition of ‘officer of a public body’
includes ‘a judge of the High Court, Court of Appeal or Federal Court’. Under subsection
(1) of s. 15 of the ACA, any officer of a public body, which includes a judge, who uses his
office or position for any gratification, shall be guilty of an offence. Subsection (2) of s. 15 of
the ACA provides:
(2) For the purpose of subsection (1), an officer of a public body shall be presumed, until the
contrary is proved, to use his office or position for gratification when he makes any
decision, or takes any action, in relation to any matter in which such officer, or any
relative or associate of his, has an interest, whether directly or indirectly.”7

In view of the provisions of the Judges Code of Ethics 1994 and the ACA on conflict of
interests, it is indeed a very serious matter to raise against a judge that he is biased or has a
personal interest, financial or otherwise, in any case he is hearing or in any decision he makes
in his judicial capacity. If the allegation is true, then not only would his judgment or decision
be vitiated, but disciplinary or criminal proceedings may be instituted against the errant
judge. However, if the allegation is unfounded, there would be an unwarranted aspersion cast
on the integrity of the judge even if the complainant categorically states that he does not
question the integrity of the judge in raising such objection or allegation.

The current Code of Ethics was drawn up in 1994 and amended in 2000, and is to be found in
Clause 3(A) of Article 125 of the Federal Constitution. This is one of the many steps to repair
the judiciary.

Hence, this is the list of what a judge cannot do and observed8:-


1. Put his private interests before his judicial duties.
2. Behave in a way that might bring his private interests into conflict with his judicial
duties.

7
ALLIED CAPITAL SDN BHD V MOHAMED LATIFF BIN SHAH [2002] 2 MLJ 305 FC, p. 312-313
8
http://history.nst.com.my/Current_News/NST/Sunday/SundayInterview/2581837/Article/index_html,
NST Online, Current Judges' Code of Ethics, 14th June 2009.

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3. Behave in a manner that might cause a reasonable suspicion that he has allowed his
private interests to come into conflict with his judicial duties, to the extent of
impairing his usefulness as a judge.
4. Behave in a way that might cause a reasonable suspicion that he has used his judicial
position for his personal advantage.
5. Conduct him dishonestly or behave in a manner that would discredit the Judiciary or
bring it into disrepute.
6. Be lacking in efficiency or industry.
7. Be late in disposing of cases, delivering decisions, and writing grounds of judgment,
without reasonable explanation.
8. Refuse to obey a proper administrative order or refuse to comply with any statutory
direction.
9. Be absent from his court during office hours without a reasonable excuse or prior
permission from the Chief Justice, President of the Court of Appeal, or Chief Judge.
10. Be a member of any political party, or participate in any political activity.

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3. Security of Remuneration
Moreover, the judges not only enjoy immunity but also have security of remuneration
(salaries) which is provided and established in the Federal Constitutional in art. 125(6) and
art. 125(7)9:-

125. Tenure of office and remuneration of judges of Federal Court


(6) Parliament shall by law provide for the remuneration of the judges of the Federal Court,
and the remuneration so provided shall be charged on the Consolidated Fund.
(6A) Subject to the provisions of this Article, Parliament may by law provide for the terms of
office of the judges of the Federal Court other than their remuneration.
(7) The remuneration and other terms of office (including pension rights) of a judge of the
Federal Court shall not be altered to his disadvantage after his appointment.

This means that a judge’s remuneration is charged in the consolidated fund which means it
does not require annual parliamentary debate and is paid automatically. Nonetheless, there is
a problem in financing the judiciary. All the revenues collected by the courts go into a central
fund, called the Federal Consolidated Fund, out of which no expenditure is allowed without
an Act of Parliament. Thus, for the running of the judiciary, like payment of salaries of staff,
repairs to court buildings and equipments, etc., the judiciary receives an allocation passed by
the Parliament as determined by the executive, especially the Treasury. Whilst the judges’
salaries are guaranteed because they are a charge on the Consolidated Fund, money for other
matters must be allocated and determined by the Treasury with reference to the Government
priorities.

This lack of finance hampers the work of the judiciary. Many court houses are old and,
therefore, need to be replaced and expanded and new ones to be built. Without funds the
work of the courts will suffer. This is an area in which I feel the Government should
appreciate the importance of judicial work in the context of the progress and well-being of
the nation. It is a humiliation for the judiciary to be told repeatedly that the Government
cannot approve the funds for the purpose because of other priorities.10

9
FEDERAL CONSTITUTION (AS AT 20TH JUNE 2009) (Petaling Jaya: International Law Book Services,
2009), p. 108
10
Tan Sri Dato’ Haji Mohamed Salleh bin Abas. Selected Articles & Speeches on Constitution, Law &
Judiciary, (Kuala Lumpur: Malaysian Law Publishers Sdn. Bhd., 1984), p. 221-222

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4. Contempt of court

The judge has the power to punish for any contempt by individuals or organizations which
demonstrated in art. 12611:-

126. Power to punish for contempt.

The Federal Court, the Court of Appeal or a High Court shall have power to punish any
contempt of itself.

This is one of the means to protect the administration of justice from undue interference. A
person may be found to be in contempt of court in respect of certain kinds of conduct done
either inside or outside a courtroom. Example of contempt of the court as such perjury,
obstructing the course of justice or failure to obey any court's orders.

Contempt of court may be divided into two:

1) Civil contempt: Failure to comply with an order duly made by superior Court.

2) Criminal contempt

a. Scandalising the court


b. Contempt in the face of court
c. Publication detrimental to a fair proceeding
d. Publication detrimental to a fair criminal trial

There are two main types of contempt by publication:


a. Sub judice rule
b. Scandalising the court

Sub judice rule is a rule that prohibit the discussion on pending case, generally cases being
heard by courts. Generally the rational of this restriction is to prevent interference and
unwarranted influence of juries and judges in deciding cases. In Attorney-General v Times
Newspapers Ltd [1974] AC 273, HL, p. 309, Lord Diplock explained,

11
FEDERAL CONSTITUTION (AS AT 20TH JUNE 2009) (Petaling Jaya: International Law Book Services,
2009), p. 109

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“The due administration of justice requires first that citizens should have unhindered access
to the constitutionally established courts of criminal or civil jurisdiction for the determination
of dispute as to their legal right and liabilities: secondly, that there should be able to rely
upon obtaining in the courts the arbitrament of a tribunal which is free from buyers against
any party and whose decision will be based upon those facts only that have been proof in
evidence adduced before it in accordance with the procedure adopted in courts of laws.; and
thirdly that, oce the dispute have been submitted to a court of laws, there should be able to
rely upon there be no usurpation by any other person of the function of that court to decide
according to laws. Conduct which is calculated to prejudice any of this three requirements or
to undermine the public confidence that there will be observed is contempt of court.”

In the case of Lim Kit Siang v Dato Seri Dr Mahathir Mohamad [1987] 1 MLJ 383,
which concerns the contempt of Court on the issue whether words uttered by respondent
brought judiciary into disrespect, disrepute and offended its dignity. In this case the appellant
had applied for an order of committal for contempt of court arising out of the remarks of the
respondent in a interview given to and published in Time magazine. The application was
dismissed in the High Court and the appellant appealed. The judgment was held on the basis,

(1) viewed objectively and dispassionately and in proper perspective the excerpt complained
of appears to be an articulation of the executive's frustration in not being able to achieve its
objects in matters where the intervention of the courts have been sought to some avail, and
the way the position is expressed, perhaps somewhat injudiciously in that it may not
inconceivably well be open to misconstruction, does not amount to an attack on the courts as
to constitute a contempt, but only stems from a misconception of the role of the courts;

(2) in this context there is no call to be overly hypersensitive and to overact impetuously as
the impugned remarks do not ex necessitate connote, within the requisite of the strictest
burden of proof for proceedings for contempt, an attack on the judiciary in the way suggested
by the applicant but rather tend to ventilate, perhaps understandably, the vexation of the
executive in not being able to get through some desired objective or end without curial
intervention;

(3) this is not a case where leave should be given to apply for committal proceedings.12

12
LIM KIT SIANG V DATO SERI DR MAHATHIR MOHAMAD[1987] 1 MLJ 383

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5. Prohibition on public discussion on Judge’s conduct

Furthermore, one of the special rights of the judge is the restriction on Parliamentary
discussion of conduct of judge which is also significant for independence of judiciary from
the powers of executive and legislature. This is mentioned on article 12713:-

127. Restriction on Parliamentary discussion of conduct of judge.

The conduct of a judge of the Federal Court, the Court of Appeal or a High Court shall not
be discussed in either House of Parliament except on a substantive motion of which notice
has been given by not less than one quarter, of the total number of members of that House,
and shall not be discussed in the Legislative Assembly of any State.

In Raja Segaran a/l S Krishnan v Bar Council Malaysia & Ors [2004] 1 MLJ 34 the
defendant intended to convene an Emergency General Meeting of the Bar for the purpose of
discussing certain allegations relating to the judiciary which they considered matters of public
interest. The plaintiff brought an action in the High Court of Kuala Lumpur to stop the
Emergency General Meeting and for a number of declaration, inter alia, that the EGM and the
proposed resolution constitute contempt of court and amounted to offences and the Sedition
Act 1948. The Court who had earlier granted an interlocutory injunction granted the relief
prayed for including a permanent injunction such EGM and such proposed resolution.
Kamalanathan Ratnam J after referring to art. 125(3) and art. 127 said,

“(p. 54) It seems to me that Parliament, although supreme, is unable to discuss the conduct
of a judge unless a provision to Art. 127 applies....Whilst on the need to protect and uphold
the independence of the judiciary, it must be seen to be manifest that no external pressure is
exerted against the judiciary either from the executive or from any other sources including
the Bar.”

The Court then referred to the Indian case of C Ravichandran Iyer v Justice AM
Bhattacharjee & Ors [1995] 5 SCC 457, SC where the Indian Supreme Court stated,

“The judiciary stands between the citizens and the State as a bulwark against executive
excesses and misuse or abuse of power by the executive. It is, therefore, absolutely essential
that the judiciary must be free from executive pressure or influence which has been

13
FEDERAL CONSTITUTION (AS AT 20TH JUNE 2009) (Petaling Jaya: International Law Book Services,
2009), p. 109-110

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secured by making elaborate provisions in the Constitution with details. The independence
of judiciary is not limited only to the independence from the executive pressure or
influence; it is a wider concept which takes within its sweep independence from any other
pressure and prejudices. It has many dimensions, viz, fearlessness of other powers centres,
economic or political, and freedom from prejudices acquired and nourished by the class to
which the judges belong. [...]

Resultantly, the discussion of the conduct of a judge or any other evaluation or inferences as
to its merit is not permissible elsewhere except during investigation before the Inquiry
Committee constituted under the Act for this purpose.[...]

By necessary implication, no other forum or for a or platform is available for discussion of


the conduct of a judge in the discharge of his duties as a judge of the Supreme Court or the
High Court, much less a Bar council or group of practising advocates. They are prohibited to
discuss the conduct of a judge in the discharge of his duties or to pass any resolution in that
behalf.”

However, the Court of Appeal in Majlis Peguam Malaysia & Ors v Raja Segaran a/l S
Krishnan [2002] 3 MLJ 155, CA Gopal Sri Ram JCA in delivering the judgment of the Court
put emphasised on the consideration of freedom of speech in considering restriction on
discussing conduct of judges. This case arises from the same case as above but on appeal
from a judgment of the High Court that granted the application for discontinuance by the
plaintiff. Gopal Sri Ram JCA observed,

“First, the defendants in exercising their undoubted constitutional rights of freedom of


speech initiated the holding of a general meeting to discuss the affairs of the judiciary. Here
we need not go into the question whether art 10 of the Federal Constitution prevails over art
127 or whether art 127 ought to be read in the restrictive fashion....Suffice to say that the
defendants were exercising their bona fide constitutional right. As Lord Atkin observed in
Ambard v A-G for Trinidad & Tobago [1936] AC 322, ‘Justice is not a cloistered virtue’ and
we are certainly not prepared to say that the conduct of judges should never be discussed at a
general meeting of the Bar. Woe beget the day that such a rule is handed down by this
court.”

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In conclusion, even though the judges are served and rewarded with immunity and special
rights but yet they have to hold a heavy burden of responsibility and public trust in order to
upheld the justice transparently, fairly and wholly. In addition to that, the law need to be
always being developing to meet up the needs of society and surroundings with a better,
serious independence judicial system.

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BIBLIOGRAPHY
• FEDERAL CONSTITUTION (AS AT 20TH JUNE 2009) (Petaling Jaya: International
Law Book Services, 2009)

• COURTS OF JUDICATURE ACT 1964 (ACT 91) ; (AS AT 5TH JULY 2004)
(Petaling Jaya: International Law Book Services, 2004)

• TUN DATO HAJI MOHAMED SALLEH BIN ABAS V TAN SRI DATO ABDUL
HAMID BIN OMAR & ORS [1988] 3 MLJ 149

• ALLIED CAPITAL SDN BHD V MOHAMED LATIFF BIN SHAH [2002] 2 MLJ
305 FC, p. 312-313

• Tun Salleh Abbas. THE ROLE OF THE INDEPENDENT JUDICIARY; With


Translation in Bahasa Malaysia, (Malaysia: Percetakan A-Z Sdn. Bhd., 1989)

• Tan Sri Dato’ Haji Mohamed Salleh bin Abas. Selected Articles & Speeches on
Constitution, Law & Judiciary, (Kuala Lumpur: Malaysian Law Publishers Sdn. Bhd.,
1984)

• http://www.malaysianbar.org.my, The Malaysian Bar; Abdullah promises pay rises


for judges, Friday, 18 April 2008.

• http://history.nst.com.my/Current_News/NST/Sunday/SundayInterview/2581837/
Article/index_html, NST Online, Current Judges' Code of Ethics, 14th June 2009.

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