Faculty of Law

(FOL)

PIL 0012
Introduction to Law

Foundation in Law

ONLINE NOTES

Chapter 3

Understanding the Statutes

MULTIMEDIA UNIVERSITY (436821-T)

MELAKA CAMPUS, JALAN AYER KEROH LAMA, 75450 MELAKA, MALAYSIA.
Tel 606 252 3594 Fax 606 231 8799
URL: http://fosee.mmu.edu.my/~asd/
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i-INTERNAL & EXTERNAL AIDS IN THE CONSTRUCTION OF STATUTES

• It is essential to understand the presentation of a statute in order to understand it.

• Usually the presentation of the statute is also important as aids in the construction
of a statute.

INTERNAL AIDS

1. Headings

• Heading is a broad title that exactly reflects the whole matter of the entire text of
an Act.
• E.g:

ENVIRONMENTAL QUALITY ACT,1974

2. Short Title

E.g:

This Act may be cited as the Contracts Act 1950

Nothing herein contained shall affect any written law or any usage or custom of
trade, or any incident of any contract, not inconsistent with this Act.

(Adapted from the Contracts Act 1950)

• This is the short title of the Act, together with the year of publication.

• When a statute is being quoted, it is normal to use the short title and the year of
publication to describe the statute.

• Sometimes when a statute is referred to constantly, the short title is abbreviated.

• It can hardly be said to reflect the objective or the purpose of the Act as a whole,
but it is part of an Act, which helps reader to get an idea on what the Act is all
about.

3. Statute number (Act Number)

E.g:

CONTRACTS ACT 1950 (ACT 136)

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• This is the official citation of the statute.

• Each Act passed in any one year is given its own number.

• This is known as its statute number.

• Its statute number and year can describe a statute.

• The citation, Act 136 could only mean the Contracts Act 1950.

4. Long title or preamble

E.g:

An act to provide for the internal security of Malaysia, preventive detention, the
preventive of subversion, the suppression of organized violence against persons
and property in specified areas of Malaysia, and for matters incidental thereto.

(Adapted from the Internal Security Act 1960)

• This is a long title of the Act.

• It gives some indication of the purpose behind the Act.

• It may be of some use in deciding what the Act is all about.

• It may provide a useful guide to the general objectives of the Act.

• Long title is also referred to as the Preamble.

• The preamble is that part of the Act that comes before the enacting words or
sections containing the provisions of the Act.

• It is like an introduction to the Act.

• Usually contains the reason why the Act was passed.

• This feature is only apparent in Old English Acts.

• Modern Acts do not have a preamble.

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5. Enacting Formula

E.g:

BE IT ENACTED by the Duli Yang Maha Mulia Seri Paduka Baginda Yang Di-
Pertuan Agong with the advice and consent of the Dewan Negara and Dewan
Rakyat in Parliament assembled, and by the authority of the same, as follows:

(Adapted from the Official Secrets Act 1972)

• It is the standard form of words used to indicate that a Bill has been properly
passed by all the different parts of the legislature.

6. Section- Subsections, paragraphs, provisos.

• The main body of the statute, which follows is broken up into numbered sections.

• Each section contains a different rule of law.

• When a rule of law contained in a statute is referred to, the section where the rule
is being referred to must be mentioned.

• This is to enable others to check the source mentioned and to see whether they
agree with your interpretation of the law.
• Instead of writing ‘section’, it is usual to abbreviate it as ‘S.’

• Thus, Section 1 becomes S.1

• Sections are often subdivided.

• These subdivision are known as subsections.

• Subsections are referred to by adding the subsection in brackets after the main
section.

• A subdivision following a subsection is called a paragraph.

• Both the subsection and paragraph have letters in brackets.

• Subsections are numbered in numbers while paragraphs are numbered in
alphabets.

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• After a paragraph in a section, sometimes there is a proviso.

• The proviso lays down the conditions that need to be fulfilled in the particular
paragraph.

E.g:

15. Courts to be open and public.

Section
(1)    The place in which any Court is held for the purpose of trying any case or
matter, civil or criminal, shall be deemed an open and public court to which the public
generally may have access:

Sub-Section
Provided that the Court shall have power to hear any cause or matter or any part
thereof in camera if the Court is satisfied that it is expedient in the interests of justice,
public safety, public security or propriety, or for other sufficient mason so to do.

(2)    A Court may at any time order that no person shall publish the name, address or Proviso
photograph of any witness in any case or matter or any part thereof tried or held or to be
tried or held before it, or any evidence or any other thing likely to lead to the
identification of any such witness; and any person who acts in contravention of any such
order shall be guilty of an offence and shall, on conviction, be liable to fine not exceeding
five thousand ringgit or to imprisonment for a term not exceeding three years or to both.

18. Proceedings in High Court to be disposed of by single Judge.

(1)    Every proceeding in the High Court and all business arising thereout shall, save as
provided by any written law, be heard and disposed of before a single Judge

(2)    "Whenever any Judge, after having heard and recorded the whole or any part of the
evidence in a proceeding, is unable through death, illness or other cause to conclude the
proceeding, another Judge may-

(a) continue with the proceeding from the stage at which the previous Judge left it
and-

(i)   act on the evidence already recorded by the previous Judge; or

Paragraph
(ii)  act on the evidence partly recorded by the previous Judge and partly by
himself; or

(b) re-summon the witnesses and recommence the proceeding.

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(Adapted from Court of Judicature Act 1964)

7. Articles – clauses, paragraphs, provisos

• Unlike the legislation and subsidiary legislation, the Federal Constitution is

broken up into numbered Articles.

• Similar to the legislation and subsidiary legislation, each Article contains a

different rule of law.

• When a rule of law contained in a statute is referred to, the Article where the rule
is being referred to must be mentioned.

• This is to enable others to check the source mentioned & to see whether they
agree with your interpretation of the law.

• Instead of writing ‘Article’ it is usual to abbreviate it as “Art.”

• So, Article 1 becomes Art. 1.

• Articles are often sub-divided and known as ‘clauses’.

• Clauses are referred to by adding the clauses in brackets after the main Article.

• A subdivision following a clause is called a paragraph.

• Both the clause and paragraph have letters in brackets.

• However, paragraphs are numbered in alphabets.

• After paragraphs in an Article, sometimes there is a proviso.

• Proviso lays down the conditions that need to be fulfilled in the particular
paragraph.

E.g:

Article 43

Article 43. Cabinet

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(1) The Yang di-Pertuan Agong shall appoint a Jemaah Menteri (Cabinet of Ministers) to
advise him in the exercise of his functions.
Clause
eeh
(2) The Cabinet shall be appointed as follows, that is to say –

(a) the Yang di-Pertuan Agong shall first appoint a Perdana Menteri (Prime
Minister) to preside over the Cabinet a member of the House of Representative
Paragraph who in his judgment is likely to command the confidence of the majority of the
members of that House; and

(b) he shall on the advice of the Prime Minister appoint other Menteri (Ministers)
from among the members of either House of Parliament;

but if an appointment is made while parliament is dissolved a person who was a member
of the last House of Representatives may be appointed but shall not continue to hold
office after the beginning of the next session of Parliament unless, if he has been
appointed Prime Minister, he is a member of the new House of Representatives, and in
any other case he is a member either of that House or of the Senate.

Article 53

53. Decisions as to disqualification

(1) If any question arises whether a member of a House of Parliament has become
disqualified for membership, the decision of that House shall be taken and shall be final:

Provided that this Article shall not be taken to prevent the practice of the House
postponing a decision in order to allow for the taking or determination of any proceedings
that may affect the decision (including proceedings for the removal of the
Proviso disqualification).

(2) Where a member of either House of Parliament becomes disqualified under paragraph
(e) of Clause (1) of Article 48 or under a federal law made in pursuance of Clause (2) of
Article 48, Clause (1) shall not apply and he shall cease to be a member of that House,
and his seat shall become vacant, immediately upon his disqualification taking effect in
accordance with Clause (4) of Article 48.
(Adapted from the Federal Constitution)

8. Interpretation section

• The Federal Constitution and most modern Acts have an interpretation section,
where it gives the meaning or definition of words and terms used in the context of
that particular Act.

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E.g:

Article 160 of the Federal Constitution

160. Interpretation

(1) The Interpretation and General Clauses Ordinance, 1948, as in force immediately
before Merdeka Day shall, to the extent specified in the Eleventh Schedule, apply for the
interpretation of this Constitution as it applies for the interpretation of any written law
within the meaning of that Ordinance, but with the substitution of references to the Yang
di-Pertuan Agong for references to the High Commissioner.

(2) In this Constitution, unless the context otherwise requires, the following expressions
have the meanings hereby respectively assigned to them, that is to say –

"Aborigine" means an aborigine of the Malay Peninsula;

"Act of Parliament" means a law made by Parliament;
"Attorney General" means the Attorney General of the Federation;
"Borrow" includes the raising of money by the grant of annuities or by entering into any
arrangement requiring the payment before the due date of any taxes, rates, royalties, fees
or any other payments or by entering into any agreement whereby the Government has to
repay or refund any benefits that is has enjoyed under that agreement, and "loan" shall be
construed accordingly;
"Casual vacancy" means a vacancy arising in the House of Representatives or a
Legislative Assembly otherwise than by a dissolution of Parliament or of the Assembly;
"Chief Minister" and "Menteri Besar" both mean the president, by whatever style known,
of the Executive Council in a State;

COURTS OF JUDICATURE ACT 1964

3. Interpretation.

In this Act unless the context otherwise requires—

"action" means a civil proceeding commenced by writ or in such other manner as is

prescribed by rules of court, but does not include a criminal proceeding;
"cause" includes any action, suit or other original proceeding between a plaintiff and
defendant, Act any criminal proceeding;
"Chief Judge" means the Chief Judge of the High Court in Malaya or of the High Court
in Sabah and Sarawak as the case may require;
"Constitution" means the Constitution of Malaysia;
"Court" means the Federal Court, the Court of Appeal or the High Court, as the case may
require;

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9. Parts

• In larger statutes, sections may be grouped together into different Parts.

• Each Part deals with a separate area of law.

• Looking for the correct Part will help you to find the particular legal rule that you
want.

• Similar to the legislation and subsidiary legislation, the Federal Constitution is

also divided into Parts.

E.g:

Part PART III

COURT OF APPEAL

General

38. Composition of the Court of Appeal.

(1) Subject as hereinafter provided, every proceeding in the Court of Appeal shall be
heard and disposed of by three Judges or such greater uneven number of Judges as the
President may in any particular case determine.

(2) In the absence of the President the senior member of the Court shall preside.

39. Sittings of the Court.

(1) The Court shall sit on such dates and at such places as the President may from time to
time appoint:

Provided that the President may, when he deems it expedient, direct that any appeal
be heard at any time and in any place in Malaysia.

(2) The President may cancel or postpone any sitting of the Court which has been
appointed under subsection (1).

(Adapted from the Courts of Judicature Act 1964)

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PART III
Part
Citizenship

Chapter 1 - Acquisition of Citizenship

14.Citizenship by operation of law

(1) Subject to the provisions of this Part, the following persons are citizens by
operation of law, that is to say:

(a) every person born before Malaysia Day who is a citizen of the Federation
by virtue of the provisions contained in Part 1 of the Second Schedule; and

(b) every person born on or after Malaysia Day, and having any of the
qualifications specified in Part 11 of the Second Schedule.

(c) (Repealed).

(2)(Repealed).

(3)(Repealed).

(Adapted from the Federal Constitution)

10. Schedules and paragraphs (Statute/Acts)

• Some statutes have one or more Schedules at the end.

• The content of these varies.

• Some contain detailed provisions, which are not found in the main body of the
Act.
• Others are merely convenient remainders and summaries of legal rules, and
changes to legal rules, found elsewhere in the Act.

• They provide additional information by showing example of forms, list of goods,

calculation etc.
• References to Schedules are often abbreviated as “Sch.”

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• Where a Schedule is divided up, the divisions are known as “paragraphs” and can
be abbreviated as “para”.

E.g:

Schedule (sch.) FIRST SCHEDULE

htt((ksoka(sch.
[Sections 4 (2) (c), 13 (2), (5) and (6), 17 (3) and (4)]

MALAYSIAN ASSETS AUTHORIZED FOR DEPOSITS AND TAKAFUL FUNDS

1.  Investment certificates issued under the Government Investment Act 1983, or any
other securities of which the principal is charged directly or by way of guarantee on the
Consolidated Fund of the Federation or of any State.
Paragraph 2. Shares in, or securities of, a body incorporated in Malaysia, which are listed by any
(para) stock exchange approved under the Securities Industry Act 1983.
3.  Shares in, or securities of, a society registered under the Co-operative Societies Act.
4.   Estates or interests in land in Malaysia and, up to the value of that security, advances,
loans, credit facilities or financing facilities secured on any such estate or interest.

(Adapted from Takaful Act 1984)

11. Schedules : sections, provisos (Federal Constitution)

• Unlike the legislations and the subsidiary legislations, the division in the
Schedules of the Federal Constitution are referred to as section and can be
abbreviated as ‘s’.

E.g:

Schedule (sch.) TENTH SCHEDULE

htt((ksoka(sch. [Article 109, 112C, 161C (3)]
GRANTS AND SOURCES OF REVENUE ASSIGNED TO STATES

PART I

CAPITATION GRANT

1.(1) The capitation grant payable to each State in respect of a financial year shall be at
the following rates:
(a) for the first 100,000 persons at the rate of RM72.00 per person;
Section
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(b) for the next 500,000 persons at the rate of RM10.20 per person;
(c) for the next 500,000 persons at the rate of RM10.80 per person;
(d) for the remainder at the rate of RM11.40 per person,

Provided that if the last census was taken one year before the beginning of the financial
year, the grant for that particular year shall be based on the population as determined by
that population census.
Proviso (2) (Repealed).

PART II
STATE ROAD GRANT

2. The State road grant payable to each of the States of Malaya in respect of a financial
year shall be calculated by multiplying –

Section (a) the average cost to a State of maintaining a mile of State road at the minimum
standard determined for State roads in those States by the Federal Government after
htt((kso consultation with the National Finance Council; by

(b) so much of the mileage of State roads in the State as qualifies for grant.

3. For the purpose of section 2 -

(a) the mileage of State roads in a State shall be taken to be that mileage as on the thirty-
first day of December of the preceding financial year, and the average cost mentioned in
Section
paragraph (a) of that section shall be taken to be the average cost in that State calculated
htt((kso in the preceding financial year

(Adapted from Tenth Schedule of the Federal Constitution)

12. Explaination, illustration

• Some statues have explaination at the end of a particular whole section.

• The explaination serves to explain the section in a clearer manner,

• Many Acts give illustrations after some sections.

• These illustrations are examples which can show the effects of the sections.

• Judges refer to illustrations in explaining the application of the sections.

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E.g:

21.Agreement void where both parties are under mistake as to matter of fact.

Where both the parties to an agreement are under a mistake as to a matter of fact essential
to the agreement, the agreement is void.

Explanation - An erroneous opinion as to the value of the thing which forms the subject-
matter of the agreement is not to be deemed a mistake as to a matter of fact.

Explanation ILLUSTRATIONS Illustration

(a)A agrees to sell B a specific cargo of goods supposed to be on its way from England to
Kelang. It turns out that, before the day of the bargain, the ship conveying the cargo had
been cast away and the goods lost. Neither party was aware of the facts. The agreements
is void.

(b)A agrees to buy from B a certain horse. It turns out that the horse was dead at the time
of the bargain, though neither party was aware of the fact. The agreement is void.

(c)A, being entitled to an estate for the life of B, agrees to sell it to C. B was dead at the
time of the agreement, but both parties were ignorant of the fact. The agreements is void.

(Adapted from the Contracts Act 1950)

13. Marginal notes

• These are notes printed in the margins of Acts of Parliament and explanatory of
the sections.

• They do not form part of an Act (except in the case of certain private Acts)

• However they may be considered by the courts in the event of ambiguity.

• In Re Tan Keng Tin [1932] MLJ 134, the court was of the opinion that the
marginal notes form part and parcel of an Act of Parliament and if necessary the
notes could be used for the purpose of interpretation, in the event of ambiguity of
a statute.

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• In Foo Loke Ying & Anor v Television Broadcast Ltd & Ors (1985) 2 MLJ 35, the
Supreme Court confirmed the above and added:

“ A side note or marginal note to a section is part of the statute. It may be

considered in construing the section or any other provision of the statute,
provided due account is taken of the fact that its function is merely to serve as a
brief guide to the content of the section.”

EXTERNAL AIDS

The external aids are:

• Law textbooks (written by established authors)

• Legal articles
• Legal dictionaries- Oxford Dictionary
• Legislative history –refers to the history of the Act i.e the objects and reasons
for the introduction of the statute.

ii-INTERPRETATION TO STATUTES

• Law exists or are created or enacted by the Legislature.

• These laws are called statutes.

• The courts apply and interpret the statutes when a case is put before them.
• More often than not, the wordings of a certain provision/s of the statute are
unclear.

• It’s not easy for the judges to decide its true meaning.

• Therefore judges used a certain method to aid them in interpreting a particular

statute.
• The different approaches used by courts in England, which have been adopted by
courts in Malaysia can be summarized under four (4) categories.

• The methods used are as follows:

• i-The Literal rule

• ii-The Mischief rule
• iii-The Golden rule
• iv-The Purposive approach

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i-The Literal Rule

• This approach was popular in the 19th Century.

• This approach is used when the words of the statute are clear in their ordinary and
natural meaning.

• Hence, this approach assumes that the meaning and intention of the legislature
have been expressed effectively by the actual words used in the act or enactment
to be interpreted and that the court need not do more than to give effect to those
words.

• The court will then follow the ordinary and natural meaning.

• Under this approach, the court does not look at any background policy or the
intent of the Parliament and need not consider the strength or weakness of the
legislation.

• For example, in interpreting the provision of the Civil Law Act 1956 as follows:

Section 3 provides:

(1) Save so far as other provision has been made or may hereafter be made by
any written law in force in Malaysia, the Court shall-

(a) in West Malaysia or any part thereof, apply the common law of
England and the rules of Equity as administered in England on the 7th day
of April 1956

• The literal approach would mean that the Malaysian courts would only be bound
to apply the common law of England and the rules of Equity as administered in
England on the 7th day of April 1956, not before or even after the date.

• In many cases, this approach enables the questions presented to the court to be
answered quite confidently with no difficulties.

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• It must be remembered however, that the literal meaning of the words almost
always depends to some extent on their context and the context of words in a
statute is the whole statute in which they are found.

• This is illustrated in the case of Kon Fatt Kiew v PP [1935] MLJ 239. In this case,
it was held that ‘scrap rubber’ falls within the definition of rubber.

• Hence, sections of a statute should be construed according to the universal rule,

i.e, the grammatical and ordinary sense of the word, then the grammatical and
ordinary sense of the word may be modified by virtue of the case H. Rubber
Estate Bhd. V D.G of Inland Revenue [1979] 1 MLJ 115

ii-The Mischief Rule

• Sometimes words in a statute bear a plain meaning.

• Otherwise, words or phrases are ambiguous.

• Some in their application to particular circumstances, words or phrases though not

perhaps strictly ambiguous in themselves are vague or uncertain.

• In such cases, the court will look into overall intention of the legislature as
discovered from reading the statute as a whole.

• According to this rule, the court is allowed to look at the state of the former law to
discover the mischief in it, which the present statute was designed to remedy.

• The following are the 4 guidelines to be considered by the court in order to know
the intentions and purpose of the statute in questions.

• The guidelines are provided in Heydon’s case (1584) ER 637:

a) What was the common law before the making of the Act;
b) What was the mischief and defect for which the common law did not provide;
c) What remedy the Parliament has resolved and appointed to cure the disease of
the commonwealth;
d) What was the true reason for the remedy

• The mischief rule had been explicitly applied in the case of Lim Moh Joo v PP
[1970] 2 MLJ 113 at page 114.

• In this case, the statute in question was the Criminal Procedure Code. Wan
Sulaiman J. held that the provisions of S.391(1) of the Code which required the
Public Prosecutor to deliver a copy of the report to the accused person not less

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than 10 clear days before the commencement of the trial should be applied where
the prosecution was by a private person. He stressed that the court must modify
the language of the law to meet what must be the intention of the legislature.

iii-The Golden Rule

• The golden rule will be applied if the literal approach leads to absurdity,
inconsistency and uncertainty in the actual meaning.

• This rule may be used in 2 ways:

a-narrow way
b-broader way

a) Narrow way

• The golden rule lays down that if the words used are ambiguous, the court should
adopt an interpretation, which avoids an absurd result.

• This can be illustrated in the case of Re An Advocate [1964] MLJ I

Facts of the case:

The respondent was an advocate on the roll of advocates for Sarawak. In

November 1962, he visited Kuching in the course of carrying on his practice and
as a favour for a friend, he imported with him ladies’ dresses and arranged
advertisements and representatives. He also settled accounts and attended customs
formalities in his own name and made use of his hotel room to facilitate the
business

Issue of the case:

Whether his conduct fell within Section 12(g) of the Advocates Ordinance,
because if he did he could be struck off the role of advocates or suspended from
practice.

Section 12(g) of the Advocates Ordnance:

“Any advocate may be suspended from practicing in Sarawak, or his name may
be struck off the role of advocates…by order of a Judge for any of the following
cases:

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(g) if he does any act, which, if done in England, would render him liable
to be disbarred or struck off the roll of the court, suspended from
practicing, if a barrister or solicitor in England.”

Held:

The word ‘or’ in the section could not be given a literal interpretation, because to
do so, would make all legal practitioners in countries where the two branches of
the legal profession were fused NOT liable to be struck off the roll, or suspended
from practice. The court held that the word ‘or’ should be read as ‘and’ order to
avoid absurd consequences.

b) Broader way

• The golden rule is sometimes used in preference to the literal rule where the
words can only have one literal meaning.

• This is especially so where considerations of public policy intervene to discourage

the obnoxious interpretation.

iv-The Purposive Rule

• The purposive approach requires the whole statute to be read in its appropriate
context (of which the purpose of the statute is part) before determining the
ordinary meaning of the words.

• The ordinary meaning of the words and the purpose of the statute must
correspond.

• Whenever the strict application of the statute gives rise to an absurd an unjust
situation, the judge in the case of Nothman v Barnet London Borough Council
[1978] 1 WLR 221 stressed that judges can and should use their good sense to
remedy it-by reading words in, if necessary-so as to do what Parliament would
have done, had they had the situation in mind.

• In the case of United Hokkien Cementries, Penang v Majlis Perbandaran Pulau

Pinang [1979] 2 MLJ 121 at page 123, the issue was whether columbarium (a
place where urns of cremated ashes of the deceased contained) can be included
within the meaning of ‘All buildings used exclusively as places for religious
worship…’ as stated in S.59(5) of the Municipal Ordinance (S.5 Laws Cap 133)

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as if it is within the meaning above, it would be exempted from payment of rate or

rates.

• Held:

The literal approach of construction is now completely out-of date and has been
replaced by a purposive approach and held that “all buildings used exclusively as
places for religious worship” should be interpreted by the use of purposive
approach and not literal rule.

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