FACULTY OF LAW AND INTERNATIONAL RELATIONS
SEMESTER III SESSION 2023/24
BACHELOR IN LAW WITH HONOURS
_______________________________________________________________________
CONSTITUTIONAL LAW I (LLB20303)
DEMONSTRATE HOW FAR THE INDEPENDENCE OF JUDICIARY HAS BEEN
ACHIEVED IN MALAYSIA
MADAM NOORASHIKIN BINTI HAMID
NO NAME MATRIC
1 MUHAMMAD AL FATIH BIN MD RUSLAN 073403
2 NUR AIN ADLIN BINTI AHMAD 074411
3 UMMI ABIHAH BINTI MOHAMAD 074410
4 ROZAIREEN SOFIA BINTI ROZMAN 074413
5 ASMA HALWA BINTI DULLAH 074481
1.0 INTRODUCTION
The judiciary holds a central role in the organizational structure of democratic systems,
particularly within the constitutional framework, where judges assume a crucial function in
the checks and balances system to prevent the misuse of authority. The constitutional and
legal framework in Malaysia that upholds the independence and integrity of the judiciary is
enshrined in both the Federal Constitution and the Judicial Appointments Commission Act
2009 (Act 695). This framework establishes a three-tier superior court system, comprising
the Federal Court as the highest authority, the Court of Appeal as an intermediary appellate
court, and the High Courts of Malaya and Sabah/Sarawak as the lower-tier superior courts.
The Federal Constitution serves as the supreme law, outlining the structure and functions
of the federal government, the states, and the rights of citizens. Pertaining to the judiciary,
it delineates the powers and independence of the courts. Meanwhile, the Judicial
Appointments Commission Act of 2009 created the Judicial Appointments Commission
(JAC), tasked with advising the Yang di-Pertuan Agong (the King) on judicial appointments.
This measure aims to ensure transparency and merit-based selections, reinforcing the
independence of the judiciary. In accordance with Article 4(1) of the Federal Constitution,
the Constitution holds the highest authority in the federation, and any law conflicting with it
is deemed void. In order to ensure constitutional supremacy, there must be an impartial
arbiter in place. Judicial independence is crucial for the effective enforcement of
constitutional supremacy. An independent judiciary holds significant authority and
responsibility in scrutinizing the actions of the executive and legislative branches for
potential "unconstitutionality" in a nation with a supreme and written constitution. Article
162(6) of the FC further empowers the courts to amend or nullify laws that existed before
Merdeka if they are inconsistent with the Constitution. This underscores that neither the
government nor the Parliament is considered supreme in the country. Certain core
constitutional values are safeguarded from the influence of elected assemblies, and the
courts, due to their independence, have the authority to determine the validity of enacted
laws in accordance with the Constitution.
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2.0 ISSUES
2.1 Insulation from Politics
The Federal Constitution of Malaysia, detailed in Part IX (Articles 121-131A), contains
specific provisions aimed at safeguarding the judiciary's independence from undue
influence by the executive and legislative branches. Article 121(1) outlines the
establishment of two high courts with equal jurisdiction and status, endowed with powers
conferred by federal law. Additionally, Article 127 prohibits the discussion of a judge's
conduct in Parliament unless initiated by a substantive motion supported by at least one
quarter of the total members of the Parliaments, extending the insulation of judges from
political interference.
2.2 Judicial Immunity
Judicial immunity, integral to judicial independence, shields judges from legal repercussions
in the execution of their judicial duties. Section 6(3) of the Government Proceedings Act
1956 safeguards the government from proceedings related to actions carried out by
individuals discharging judicial responsibilities. Section 14 of the Courts of Judicature Act
1964 provides immunity to judges from civil suits for acts performed in the discharge of their
judicial duties. The Defamation Act 1957 (Revised 1983), in section 11(1), confers absolute
privilege on reports of judicial proceedings, encompassing pleadings, judgments,
sentences, or findings. Notably, while Article 122 AB(1) of the Federal Constitution grants
immunities for Judicial Commissioners, it does not explicitly extend such protection to other
judges.
c. Contempt of Court
Contempt of court is one of the crimes of disobeying or disrespecting a court of law and its
officers by behaviours that contradicts or challenges the court's power, justice, and dignity.
Majlis Perbandaran Melaka Bandaraya Bersejarah v Yau Jiok Hua [2006] 5 MLJ 389, it was
held that the respondent was committed for contempt of court, which highlighted in the case
that, the respondent's submissions on their merits and all the issues and points raised by
the respondent were highly technical, that contempt of the court. Rules of court contain
vehicles for the purposes of obtaining necessary prayers according to the rights and
obligations of the parties under the law. A highly technical argument made by the
respondent should not render the rules ineffectual. Thus, there is no statutory limit to the
imposition of the fine. The culpability of the respondent is appropriate to a substantial fine,
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which includes the damage to the public interest, and the seriousness of the contempt must
be taken into account by the court as empowered under Article 126.
3.0 DISCUSSION AND ANALYSE
3.1 Insulation from Politics
The most pressing issue confronting the Malaysian judiciary revolves around the process
of appointing judges to the highest courts and key judicial offices. During Prime Minister
Abdullah Badawi's tenure, spanning from 2003 to 2009, there were initiatives aimed at re-
establishing a judiciary that is credible, effective, and independent. One such initiative
involved the establishment of a Judicial Appointments Commission (JAC) in 2009, tasked
with recommending candidates for judicial roles at the High Court level and above, subject
to the Prime Minister's consideration.
In Malaysia, the executive branch, particularly the Yang di-Pertuan Agong who acts on the
advice of the Prime Minister, plays a significant role in the appointment of judges to the
higher courts. The Judicial Appointments Commission (JAC) held the responsibility to
advise the King on the appointment of judges. Thus, the Prime Minister's role in advising
the King remains a crucial part of the process. This mechanism aims to ensure a more
transparent and merit-based selection process, reducing the potential for political
interference in appointments.
Despite these efforts, the effectiveness of these reforms has been questioned, primarily
due to the prevailing constitutional and legal framework. The existing legal stance maintains
that the ultimate authority for appointments rests with the Prime Minister. The Yang di-
Pertuan Agong of Malaysia appoints judges based on the advice of the Prime Minister, who
is constitutionally obligated only to 'consult' the Conference of Rulers and specific senior
members of the judiciary, depending on the position in question as per Article 122B of the
FC. Notably, the Prime Minister directly appoints five out of the nine positions within the
JAC itself. This configuration sustains an imbalance, allowing the Prime Minister to wield
significant influence over judicial appointments.
Additional controversy arose in 2017 during the administration of Dato' Sri Haji Mohammad
Najib when the tenure of the Chief Justice of Malaysia and the President of the Court of
Appeal, the two highest office-holders in the Malaysian judicial hierarchy, was extended
beyond their constitutionally-mandated retirement age. This extension was achieved by
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appointing them as 'additional judges' of the Federal Court. This unprecedented move led
to multiple constitutional challenges, with both the Malaysian Bar and the current Prime
Minister during that time, Tun Dr Mahathir Mohamad, raising concerns and objections.
From the above statements, the question whether politics interferes with the appointment
and removal of judges in Malaysia is a matter of ongoing debate and has been a subject of
concern for various stakeholders. The issue of executive involvement in judicial
appointments in Malaysia is a complex and nuanced one, influenced by legal, constitutional,
and political considerations. Any potential reform would likely require careful examination
of the constitutional framework, public opinion, and the overall goals for the judiciary's
independence and effectiveness in the Malaysian legal system. It is a matter that involves
a delicate balance between preserving constitutional principles and ensuring a fair and
impartial judiciary. Here are some perspectives on this issue:
i. Executive Influence: Critics argue that the appointment process, where the
executive provides advice to the constitutional monarch on judicial appointments,
may create opportunities for political considerations to influence decisions.
ii. Allegations of Partisanship: Over the years, there have been allegations that
certain judicial appointments or removals were influenced by political
considerations, potentially undermining the independence of the judiciary.
iii. Impact on Judicial Independence: The perception of political interference can
have implications for the perceived independence of the judiciary, as an
independent judiciary is crucial for upholding the rule of law and ensuring fair and
impartial justice.
Political interference in the judiciary system is a complex and contentious issue. In an ideal
democratic system, the judiciary is expected to be independent and free from political
influence, ensuring that legal decisions are based on the merits of the case and the rule of
law. Political interference in the judiciary can erode the separation of powers and undermine
the principles of justice and fairness. Concerns about political interference in the judiciary
often center around the need for maintaining the rule of law, upholding constitutional
principles, and protecting individual rights. Efforts to ensure judicial independence typically
involve establishing transparent and merit-based processes for judicial appointments,
providing judges with security of tenure, and fostering a culture of impartiality within the
legal system.
There are a few cases in which political interference in the Malaysia judiciary system:
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● Sacking of Tun Salleh Abas (1988): This is a landmark case where the then-Prime
Minister, Dr. Mahathir Mohamad, was accused of influencing the removal of the Lord
President (the head of the judiciary), Tun Salleh Abas, in 1988. The incident raised
concerns about the independence of the judiciary.
● Teoh Beng Hock Case (2009): Teoh Beng Hock was a political aide who died in
suspicious circumstances while being questioned by the Malaysian Anti-Corruption
Commission (MACC). The case raised concerns about the treatment of detainees
and the independence of the MACC. While not a direct judicial interference case, it
highlighted broader issues within the legal system.
● Anwar Ibrahim Trials (1998-2004): The current prime minister of Malaysia, Dato'
Seri Anwar bin Ibrahim, a prominent Malaysian politician, faced legal troubles in the
late 1990s. His trials were widely criticized for alleged political interference. Anwar
claimed that the charges against him were politically motivated, and his trials raised
questions about the independence of the judiciary.
Therefore, interference in legal matters, particularly those of significant public concern,
directly undermines the roles and responsibilities of both the Attorney General and the
court. Any claimed unconstitutional conduct of this nature would seriously compromise the
pursuit of justice and raise doubts about the integrity of both the Attorney General and the
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judicial system. Public trust in the judiciary is crucial for a functioning democracy, and any
perception of political interference can undermine that trust.
3.2 Judicial Immunity
According to the Sixth Schedule of Malaysian Constitution,
Any person appointed to high judicial office is required to take an oath or make an
affirmation that he or she will faithfully discharge the 'judicial duties in that office' and will
'preserve, protect and defend' the country's Constitution. Judges who make themselves
beholden to the executive or powerful individuals or corporations have clearly violated their
judicial oath or affirmation.
In addition, according to Article 127 of the Federal Constitution,
The conduct of a judge of the Supreme Court 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 no less than one quarter of differences in the system of land tenure in the same manner
as they apply to other States.
This section established a nature-law which safeguard the members of judiciary as to
practice and perform their duty freely, in accordance with the rule. It is critical that judges
have the autonomy to decide any case they hear in court. This is to guarantee that the
judges are free to decide without any outside pressure or doubt of future consequences
that might sway the outcome of a trial.
Assault in the judiciary might seem impossible to arise. However, it was released in 1987
under the tenure of Mahathir Mohamad, our fourth prime minister. Several publicly critical
remarks about the judiciary were released, along with laws that significantly curtailed the
court's authority. This action resulted in the Supreme Court's Lord President being
suspended due to allegations that impacted his freedom of speech as a judge in 1988. To
address the accusations made against the Supreme Court judges, Mahathir Mohamad also
organized a tribunal. However, the tribunal's proceedings fell short of international norms
and lacked impartiality.
The independence of the judiciary is essential to our democratic governance and cannot
be taken lightly. This is to protect any potential for judicial fraud and to assure its survival
and in preserving the judiciary's independence requires safeguarding it against political
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meddling. The idea of judicial independence has been stated that the court should not be
subject to influence or intervention from other departments of government, political figures,
or outside groups as mentioned in paragraph 5 of the Federal Constitution. This safeguard
is intended to prevent political authorities from having an excessive influence over judges
and the judicial system, maintaining the fairness and integrity of the legal system.
3.3 Contempt of Court
In Red THE Kingdom v SC Goho [1948] MLJ 17, contempt of court has broad definitions
that are considered ordinary contempt, thus the act of scandalizing the court itself is
considered as exceptional contempt.
Contempt of court is recognized as any conduct that leads to disrespect or degrades the
administration of the law or interferes with or prejudices parties, litigants, or their witnesses
during the lawsuit. Contempt of court applies not only to those who are obliged by the court
order but also to those who instigated or assisted the disobedience to the court. Held in
Syed Kechik Holdings Sdn Bhd & Ors v Syed Gamal bin Syed Kechik [2013] 8 MLJ 720,
an establishment of an injunction is not required in order to counter measure the act of
contempt of court. The test was not whether there was violation of the order, but rather an
interference with the administration of justice or the course of justice.
In the mentioned case, contempt can be recognized by the ignorance and dispute in the
courts' order of the defendant and his solicitor. This was treated lightly by the defendant
and the solicitor, and it contributed significantly to the court's disrespect, which degraded
the judiciary's independence. According to Article 126 of the Federal Constitution, the court
has the authority to penalize contempt, in order to maintain the prosperity and dignity of the
court.
Donovan LJ of the Court of Appeal, in the case of Attorney-General v Butterworth and
Others [1963] 1 QB 696, asserted that "an intention to interfere with the proper
administration of justice is not an essential ingredient of the offence of contempt of court. It
is enough if the action complained of is inherently likely to interfere." These remarks were
cited in Malaysian cases, namely T.O. Thomas v Asia Fishing Industry Pte Ltd [1977] 1 MLJ
151 by the Federal Court and Jasa Keramat Sdn. Bhd v Monatech (M) Sdn Bhd [2001] 4
MLJ 577 by the Court of Appeal.
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It is contended that such a definition may be potentially misleading for contempt law, as
courts retain discretion to deem conduct as constituting this offense, even if the offending
party did not specifically intend to commit the offense. While motive can be a relevant factor
for the courts to consider, the absence of a clear motive may not, in itself, preclude judges
from exercising their discretion to apply this law. Some definitions have instead focused on
specific issues within contempt law, such as freedom of speech and disobeying court
orders. It is argued that while these issues can be involved in contempt law, they may not
comprehensively capture the entirety of the law's scope.
Contempt in the face of the court can manifest in various forms, including comments made
directly to a judge, as seen in Karam Singh v Public Prosecutor [1975] 1 MLJ 229, disposing
of the subject matter in a pending proceeding, as illustrated in Jasa Keramat Sdn Bhd v
Monatech (M) Sdn Bhd [2001] 4 MLJ 577, or failing to attend court when the case was
called for hearing, as in Dr. Leela Ratos & Ors v Anthony Ratos s/o Domingo Ratos & Ors
[1997] 1 MLJ 704.
Contempt of court by disobeying a court order typically involves either positive actions
prohibited by a court order or omissions in failing to comply with actions required under a
court order. For instance, in T.O. Thomas v Asia Fishing Industry Pte Ltd [1977] 1 MLJ 151
and Chai Tze Foh & Anor v Asia Fishing Industry Pte Ltd [1977] 2 MLJ 195, contempt
occurred by interfering with the use of a factory and removing assets therein in breach of a
prohibitory order. In Hong Leong Finance Co Bhd v Lee Geng and ors [1990] 3 MLJ 474
and Syarikat M. Mohamed v. Mahindapal Singh & Ors [1991] 2 MLJ 112, contempt of court
was raised for failing to disclose particulars required under a court order. The first two cases
involved contempt through actions, while the latter two cases involved omissions.
Therefore, contempt of court does not universally involve freedom of speech alone as some
definitions highlight more on the other functions of contempt of court.
Contempt of court can be distinguished in two ways, civil contempt and criminal contempt.
Civil contempt is applied to compel a party to obey a court order or to reimburse the
opposing party for losses suffered as a result of non-compliance. In maintaining the fairness
of justice, this contempt has been set out with the enforcement of compliance with the court
rulings and decrees, sanctioned through fines or coercive measures. Contrary to criminal
contempt which is an act of disobeying, offending, or disrespecting a court's authority in a
way directly or indirectly in or outside the judge's presence. It is a major goal to administer
justice by establishing fines or imprisonment as a punitive measure.
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In Floyd v. Floyd, 215 Ga. 284, 110 S.E.2d 405 (Ga. 1959), the differences between civil
and criminal contempt are discussed. It is stated that when evaluating civil or criminal
contempt, the nature and motive of contempt must be considered. Civil contempt is used
to coerce the defendant to perform what the court requires for the benefit of the complaint.
Criminal contempt is used to protect the court's authority and penalize those who disobey
its orders. Furthermore, while exercising the right to free expression, there is criticism of the
court or its decisions on matters of public concern. Although inaccurate, it does not
constitute contempt of court if such criticism is within the bounds of reasonable civility and
good faith, as decided in R v Commissioner of Police of the Metropolis [2009] UKSC 3.
Moreover, according to O. 52 r. 2A contempt of court that is committed in the face of the
court, shall not be necessary to serve a formal notice, hence the court itself has to ensure
the alleged party understands the offense against him or the court may order the contemnor
to appear before him on the purpose of purging his name. Additionally, if the alleged party
took action and tendered his apology, judges may excuse the person. Contrary if the person
declines or refuses in his contempt, the sentence shall be fallen onto him by the judge.
3.0 SUGGESTION
As for the first issue in regards to insulations from politics, it is suggested that it could be
performed by reform of the appointment process by removal of the executive’s role. There
are few key matters on how the action of removal could maintain the independence of the
judiciaries. First and foremost, it helps in enhancing the independence itself as there will be
less interference from the executives and any such political influence. Thus, critics argued
that reducing the executive's role could further enhance the independence of the judiciary,
as it may minimize perceptions of political influence in the appointment process. Next, is by
maintaining and improvement of the merit-based appointment. This system shifts towards
a system with less executive involvement which could promote a more transparent and
merit-based appointment process, focusing more on the qualifications and capabilities of
candidates. The existence of the Judicial Association Committee (JAC) plays a significant
role therefore there is still room for improvement. These may be performed by stricter
selection of the members of the JAC and by having more specific authorities rather than
just the role of an ‘advisor’. It is an act of counter-measure as to the power granted to the
Prime Minister in the appointment process.
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Moving on to the second issue of judicial immunity, we would like to highlight that it is crucial
for the judiciaries to have its own power separated by the other bodies. Without an honest
judiciary body, citizens that depend on the law will be discriminated against for their rights
and liberties. It is essential for a functioning judiciary, to conduct as a fair and independent
body (Andrew Jackson). The judiciary body should be free of influence and pressure from
public and political views, judges are required to determine further the rights and claims
pursued by parties and observe the legal authority before deciding a case. The judiciary is
a vital branch of government, thus is responsible for governing itself and is accountable to
the public. In deciding cases, judges are expected to follow strict ethical conduct to ensure
fairness (Pejabat Ketua Pendaftar Mahkamah Persekutuan Malaysia, N.D.)
As for the last issue on contempt of court. Contempt of court has to be taken seriously as
contempt to the authorities that we rely on for justice and fairness, should not be contempt.
By provoking, criticizing, and disrespecting the court, is disrespecting the law in Malaysia.
Hence, we suggested that by creating guidelines regarding contempt of court in the judiciary
system. Specific rules or provisions for contempt proceedings are crucial for several
reasons. Firstly, non-compliance with these rules has led to the dismissal of contempt cases
by the courts. Secondly, clear rules guide applicants and alleged contemnors, preventing
confusion in significant proceedings. Thirdly, rules safeguard the rights of the parties
involved. Consistency in rules is vital to ensure fairness across different courts in similar
proceedings. The rules should cover both summary and non-summary contempt
proceedings, with specific guidelines for each. A thorough review of existing procedures is
recommended, extending to all courts and including separate procedures for summary
contempt cases. Issues like when to institute summary proceedings, differences from non-
summary proceedings, maximum detention period, the need for a written charge, and the
rights of the alleged contemnor should be addressed.
4.0 CONCLUSION
To encapsulate each context thoroughly, these findings are based on the issue that arose
in determining the independence of the judiciary in Malaysia. Furthermore, based on the
analysis to demonstrate how far the independence of the judiciary in Malaysia is, it is well-
determined and focused on how the system works in Malaysia. Considering how judges in
Malaysia are appointed through ultimate authority for appointments by the Prime Minister
whereas the Prime Minister only needs to consult Yang di-Pertuan Agong of Malaysia
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regarding the matter of judges' appointment. This is based on insulation of political findings
whereas there is still interference of politics in electing judges.
In the event of the second issue relating to judicial immunity, which highlights the Article
127 of the Federal Constitution for the judge to perform their duty without any interference
in order to prevent judicial fraud and the preservation of the justice system's fairness and
integrity depends heavily on safeguards against political meddling. The Federal
Constitution is cited, highlighting the constitutional protection against unwanted influence
on judges and the legal system.
At last, the third issue shows the independence of the judiciary in Malaysia where no one
shall contempt anything related to the decision by the court. The power of contempt court
can be found under Article 126 of the Federal Constitution where the procedures of non-
compliance behaviour will be punished accordingly. This matters to have the citizen abide
by the court’s decision to protect peace and to have a systematic and well-organized
judiciary system in Malaysia. Thus, it still lacked in terms of specific provisions or laws as
to measure how an act is considered to be an act of contempt towards the court.
The judiciary must uphold the community's trust in fairness to effectively fulfill its
constitutional duty because as of today, our judiciary system is still being influenced by the
political system. According to Lord Taylor of Gosforth, the public's confidence in the justice
of the judicial system depends significantly on the fairness and impartiality of judges,
unaffected by external influences. The preservation of judicial independence is of utmost
importance to guarantee impartiality in the judiciary and protect human rights. A truly
independent judiciary remains unaffected by inappropriate influences, whether from
politicians, government entities, judges, individuals in positions of power, or personal
connections.
Hence, it is crystal clear that it is undeniable that Malaysia does have independence with
our own system. However, there is always a loop before the road gets straight to your home.
Similar to our situation in Malaysia, the system is still not able to prevent the interference of
politics in the judiciary system before it gets independence. The effectiveness of our system
is on its way to shine independently if it is not because of the issues of interference of the
executive, politicians, or any other related influences that try to fit in with the Malaysian
judiciary.
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REFERENCES
PRIMARY SOURCES
• Statutes
- Federal Constitution of Malaysia
- Judicature Act 1964
- Government Proceedings Act 1956
- Judicial Appointments Commission Act 2009 (Act 695)
- The Defamation Act 1957
• Cases
- Majlis Perbandaran Melaka Bandaraya Bersejarah v Yau Jiok Hua [2006] 5
MLJ 389
- Re Teoh Beng Hock [2010] 1 MLJ 715; [2010] 2 CLJ 192; [2009] MLJU 863
- Public Prosecutor v Dato’ Seri Anwar Bin Ibrahim & Anor [2001] 3 MLJ 193
- In Red THE Kingdom v SC Goho [1948] MLJ 17
- Syed Kechik Holdings Sdn Bhd & Ors v Syed Gamal bin Syed Kechik [2013] 8
MLJ 720
- Attorney-General v Butterworth and Others [1963] 1 QB 696
- T.O. Thomas v Asia Fishing Industry Pte Ltd [1977] 1 MLJ 151
- Jasa Keramat Sdn. Bhd v Monatech (M) Sdn Bhd [2001] 4 MLJ 577
- Karam Singh v Public Prosecutor [1975] 1 MLJ 229
- Dr. Leela Ratos & Ors v Anthony Ratos s/o Domingo Ratos & Ors [1997] 1
MLJ 704.
- Chai Tze Foh & Anor v Asia Fishing Industry Pte Ltd [1977] 2 MLJ 195
- Hong Leong Finance Co Bhd v Lee Geng and ors [1990] 3 MLJ 474
- Syarikat M. Mohamed v. Mahindapal Singh & Ors [1991] 2 MLJ 112
- Floyd v. Floyd, 215 Ga. 284, 110 S.E.2d 405 (Ga. 1959)
- R (on the application of L) v Commissioner of Police of the Metropolis [2009]
UKSC 3
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