FEATURE

The Syariah Law System: Family Law Concerns and Reforms 1

The article sets out the main problematic areas of legal discrimination against Muslim women, with particular regard to family and personal laws.

S

IS is especially concerned that Muslim women are being discriminated against under the present statutory provisions in the Islamic Family Law Act and enactments. While it may be generally true that the legal provisions under the civil family law system for non-Muslims now confer equal rights on men and women (de jure at least), Muslim women face the problem of both de jure and de facto discrimination. Since the 1990s, SIS with other women NGOs have submitted several memoranda on proposals for reforms of the Islamic family law statutes, including the Memorandum on Reform of the Islamic Family Laws on Polygamy in 1996, Memorandum on Reform of the Islamic Family Laws and Justice in the Syariah System in 1997, Memorandum Pembaharuan Proses Perceraian dan Tuntutan Sampingan Dalam Prosiding Mahkamah Syariah in 2000, Memorandum Perbandingan Rang Undang-Undang Keluarga Islam dengan Akta Undang-Undang Keluarga Islam 1984 in 2002, and Memorandum Perbandingan Rang Undang-Undang Keluarga Islam 2003 (Negeri Selangor) dengan Enakmen Undang-Undang Keluarga Islam (Negeri Selangor) 1984 in 2003. The main problematic areas providing for legal discrimination against Muslim women include the gender specific provisions on marriage guardianship, polygamy, divorce and guardianship of children. Discrimination against Muslim women also results from the existence of such selective gender neutral provisions as the statutory provisions on harta sepencarian (matrimonial assets).

Constitutional Guarantee Against Discrimination Article 8(2) of the Federal Constitution now provides that: ‘Except as expressly

authorized by this Constitution, there shall be no discrimination against citizens on the ground only of religion, race, descent, place of birth or gender in any law or in the appointment to any office or employment under a public authority or in the administration of any law relating to the acquisition, holding or disposition of property or the establishing or carrying on of any trade, business, profession, vocation or employment.’ The amendment to Art 8 of the Federal Constitution is a major step forward in implementing the government’s commitment to uphold the principle of equality between men and women in Malaysia. It is hoped that all Malaysian women, Muslims as well as non-Muslims, will no longer suffer discrimination based on the grounds of religion and gender. The right to equality before the law and equal protection of the law and now the right to non-discrimination on the basis of gender are constitutional guarantees for all Malaysians to enjoy, Muslims and non-Muslims. We believe that nothing in these constitutional provisions conflict with Islam, a religion that upholds the principles of equality and justice for all. We hope that the term ‘discrimination against women’ will adopt the definition in Art 1 of the Convention on the Elimination of all Forms of Discrimination Against Women (‘CEDAW’) which states, that ‘discrimination against women’ shall mean ‘any distinction, exclusion or restriction made on the basis of sex which has the effect or purpose of impairing or nullifying the recognition, enjoyment or exercise by women, irrespective of their marital status, on a basis of equality of men and women, of human rights and fundamental freedoms in the political, economic, social, cultural, civil or any other field’. This would mean that even though a law was not purposely intended to discriminate, if the effect of its implementation denies equality

between men and women, then that law has discriminated against women. We are concerned that the use of religion has often perpetuated discrimination against Muslim women and denied them the increasing sphere of rights that is being granted to their nonMuslim counterparts. It would be most unreasonable for Muslim women to find themselves occupying a personal status that would be legally inferior not only to the status of Muslim men but also to that of non-Muslim women, and to find that they are unable to exercise some of the rights that may be exercised by all the other citizens in Malaysia, ie the men and non-Muslim women. We are particularly concerned as to the applicability of Art 8(2) in the realm of family and personal laws. We are concerned that while the amendment to Art 8(2) may prohibit discrimination that is solely on the basis of gender, discrimination may still be allowed if the basis for such discrimination is said to be on the ground of gender coupled with that of religion. If necessary, Art 8 should be further amended to clarify that the implementation of personal laws based on religion shall not be exempted from the provision prohibiting discrimination based on gender. We reiterate our belief that such a provision is not in conflict with, and is in fact in accordance with the teachings of Islam which raised the status of women and ensures equality and justice for all.

Problematic Areas and Concerns on Gender Specific Provisions Marriage guardianship (wali nikah) The concept of wali as a means to ‘protect’ women is a very paternalistic attitude, carrying with it the implication that women have no capacity to protect July 2004

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FEATURE themselves. This attitude may indeed have been proper in medieval societies, but it is hardly relevant under the present socio-economic circumstances, where many women are educated and also earn their own living. Even in the medieval era, the Hanafi school of law had already held that the wali is required only for marriages involving minor boys and girls, and that no wali is needed for the marriage of a competent adult woman. It is even more disturbing that although the Islamic Family Law Act and the majority of the state enactments provide that a woman cannot be compelled into marriage, the enactments in the states of Kelantan, Kedah and Melaka contain the archaic provisions on wali mujbir which allow the wali who is the woman’s father or paternal grandfather to marry off his virgin daughter or granddaughter without her consent under certain conditions. The conditions are that the wali mujbir and the prospective husband are not hostile to her; the prospective husband is of the same status as she (kufu) and the prospective husband is able to pay a reasonable maskahwin (mahr mithl). The doctrine of ijbar (compulsion) has always been controversial even in the medieval Islamic societies, as there is no justification for it in the Qur’an or Sunnah. On the contrary, the Prophet’s Traditions emphasise the right of a woman to be married only with her free choice and consent. The doctrine of ijbar may in fact be traced to the patriarchal tribal norms which existed in the pre-Islamic Arabian society, and also to the early period of Roman law. The traditional excuse for the doctrine of ijbar had been that women were unaccustomed to managing their own affairs and were therefore unaware of their own best interests. The doctrine of ijbar is now waning in most of the Muslim world, making it all the more absurd that it should be perpetuated as a statutory provision in a place such as Kelantan, where women have traditionally been accustomed to managing their family finances as well as their own businesses, and where the market places are dominated by tradeswomen. It is proposed that steps should be taken to review the provisions on marriage

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guardianship. Most importantly, the provisions on wali mujbir, where it exists in the states concerned, should be repealed.

Polygamy The main problem regarding polygamy is that there is a general misconception in Malaysia that polygamy is the ‘right’ of every Muslim male and that any attempt to criticise the present practice of polygamy is to challenge the word of Allah swt and the Sunnah of the Prophet (s.a.w.). However, a reading of Surah anNisa’ 4:3 in the Qur’an clearly shows that polygamy is not an unconditional right of the Muslim man. On the contrary, it is a responsibility to ensure that justice should be done to widows and orphans, for it states to the effect that: ‘If you fear that you shall not be able to deal justly with the orphans, marry women of your choice, two or three or four, but if you fear that you shall not be able to deal justly (with your wives), then (marry) only one ... that will be more suitable to prevent you from doing injustice.’ This verse was revealed after the Uhud battle which had resulted in many men being killed, leaving behind many war widows and war orphans. As the breadwinners were chiefly men, the widows found it difficult to provide for their children. It was in this context that polygamy was tolerated in Islam — to provide for the welfare of widows and their orphaned children. In fact, it is remarkable that given that dire postwar situation, the Qur’an discontinued the then-existing practice of unlimited polygamy. From a historical point of view, polygamy was an institution that existed not only in pre-Islamic Arabia, but also in various civilisations, religions and cultures in many parts of the world. Polygamy was practised among the Jews, Chinese, Indian Hindus and Mormon Christians, until it was abolished by the laws. In Malaysia, for example, polygamy was practised among the Chinese and Hindu communities until it was forbidden under the Law Reform (Marriage and Divorce) Act which came into force in 1982. The Prophet (s.a.w.) himself was monogamous throughout his 25-year

marriage to his first wife Khadijah (r.a.), and his polygamous marriages after her death were undertaken as a responsibility to widowed and divorced women with children for political and tribal reasons. The only virgin he married was his second wife, Aishah (r.a.). The Prophet did not marry younger and prettier women to fulfil his desires. Unlike the other men, the Prophet was allowed to keep all his wives after the maximum four wives limit was imposed upon the previous practice of unlimited polygamy, but he was eventually prohibited from adding to his wives or divorcing any of them with a view to taking another wife in her stead (Surah al-Ahzab 33:52). Many, if not most, polygamous marriages today share almost nothing in common with the Sunnah of the Prophet (s.a.w.). It would be unjust and offensive to even compare their justification for polygamy to the reasons that the Prophet (s.a.w.) practised it. Moreover, the Prophet (s.a.w.) did not allow his son-in-law, Saidina Ali ibn Abi Talib, to marry another woman ‘unless and until Ali ibn Abi Talib divorces my daughter (Fatimah)’ (reported in Sunan Ibn Majah). It would therefore appear from this authentic tradition that the first wife is fully entitled to reject the proposed polygamous marriage by refusing her consent, as well as to demand a divorce should the husband persist in his desire to marry another woman. A great-granddaughter of the Prophet (s.a.w.), Sakinah binti Hussein, a granddaughter of Ali and Fatimah, put various conditions in her marriage contract (ta’liq), including the condition that her husband would have no right to take another wife during their marriage. Polygamy in Islam should be looked at not as a ‘male right’ but as a ‘female privilege’. As such, it is thus necessary that all the parties to be involved — the husband, the existing wife and the prospective wife — should be aware of the potential responsibilities and consequences and agree to it before such a marriage could be contracted. The Islamic Family Law Act has attempted to control polygamy and prevent its abuse among the Muslims by requiring

FEATURE the permission of the court before a polygamous marriage may be contracted. However, it is often reported that syariah judges tend to give emphasis only to a man’s financial capacity to support more than one family in deciding whether or not permission should be granted. Scant regard is given to the other conditions which are aimed at securing justice to wives, and justice is mandatory in the Qur’an, as stated in the 1990 judgment of the Selangor Syariah Appeals Committee in the case of Aishah Abdul Rauf v Wan Mohd Yusof Wan Othman [1990] 3 MLJ lx. Unfortunately, the existence of separate state jurisdictions enables men to take advantage of the most convenient law for personal gain. Thus, in this case of Aishah v Wan Mohd Yusof, the husband was able to circumvent the decision of the Selangor Syariah Appeal Committee which rejected his application to marry another woman by simply crossing to the State of Terengganu to get married. The statutory penalties provided in the law are insufficient to serve as an effective deterrence for men who contravene the law as husbands who contract polygamous marriages without

the proper permission of the court are usually merely ordered to pay a small fine, as the maximum fine that may be imposed is only RM1,000. Due to the general misconception in our society regarding polygamy, women’s groups which propose stronger measures to prevent its abuse and who recommend that the first wife’s consent should be a necessary requirement are often accused of going against the teachings of Islam, although the women’s groups have not actually proposed abolishing polygamy outright. The proposal that a wife should be given the option of obtaining a divorce through ta’liq in such circumstances is not a recent, modernist view, but a practice existing in the early days of Islam, and a rule recognised in medieval times by the Hanbali school of law, the strictest and most conservative school among the four schools in Sunni Islam. This rule has now been adopted in various Muslim countries in the Islamic heartland, including among the Muslim communities who are not followers of the Hanbali school.

Divorce and ancillary reliefs Although the Islamic family law provides that women may apply for divorce through ta’liq (breach of stipulation in marriage agreement), fasakh (judicial dissolution of marriage) or khul’ (payment of compensation to husband where the wife has no legal ground for complaint against him, known in Malay as tebus talaq), there have been numerous complaints by Muslim women as to the lengthy divorce proceedings when an application for divorce is made by a woman. A woman has to endure endless delays to obtain a divorce. No time limit has been set at each step of the process a woman has to go through in her application for divorce. The husband’s failure to attend counselling sessions, to be present at court hearings, and to attend arbitration proceedings can delay the divorce by several years. Even though the law provides that the hakam (arbiters) appointed by the court can pronounce divorce on behalf of the husband if the parties fail to effect reconciliation, the court is usually reluctant to use this provision.

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FEATURE In contrast, husbands can easily and quickly divorce their wives as divorce pronouncements (talaq) made outside the court may be registered under s 55A of the Islamic Family Law Act. The statutory penalties provided in the law are insufficient to serve as an effective deterrence for men who contravene the law as husbands who pronounce talaq outside the court are usually merely ordered to pay a small fine, as the maximum fine that may be imposed is only RM1,000. There is at present no provision under the Islamic Family Law Act requiring the court, when approving the unpermitted divorce, to make orders to ensure that the divorced wife’s financial rights are secured. The court order in this case should cover the divorced wife’s right to iddah maintenance during the waiting period, mutaah (compensation) and harta sepencarian. There should be a presumption in the law that a husband who pronounces talaq without the permission of the court has divorced his wife without just cause, thus automatically entitling the wife to receive mutaah. There have also been numerous complaints by women regarding the delays they often face when seeking ancillary reliefs such as arrears of maintenance, iddah maintenance, mutaah and harta sepencarian, and the problems and complications in having to file separate applications for the various claims. Part of the problem faced by women in seeking redress is the provision on nusyuz which states that a wife is not entitled to maintenance when she ‘unreasonably refuses to obey the lawful wishes and commands of the husband’. Many unjust allegations of nusyuz are made against a woman by the husband who neglects to pay maintenance to the wife, and at the same time disputes her right to apply for divorce. We have received reports of many cases of wives who have been accused of nusyuz even when they have left the marital home with their husbands’ permission or because of fear of physical violence or mental abuse.

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The statutory provision apparently regards nusyuz as the wife’s disobedience to the husband, even though the Qur’an applies the term nusyuz in respect of both spouses, and should actually refer to the disruption of marital harmony by either spouse. It is proposed that procedures should be amended to provide for time limits on the periods relating to counselling sessions and arbitration proceedings; to abolish the need for women to file separate applications for different items of ancillary reliefs; and for automatic reciprocal enforcement of orders in different state jurisdictions.

Legal guardianship and physical custody of children The amendments to the Guardianship of Infants Act 1961 granting mothers the equal right to guardianship of their children only apply to non-Muslims as Muslim women come under the jurisdiction of Islamic family law statutes which currently recognise only the right of men to be guardians. Even though an administrative directive was issued to enable all mothers, including Muslim mothers, to sign official documents on matters related to their children, it is hoped that the right of Muslim mothers to be guardians of their children will also be explicitly recognised by law. At present, the statutory provisions in the Islamic family law statutes only recognise the father, paternal grandfather and their executors as entitled to legal guardianship. Traditionally, the legal guardians were persons associated with responsibility for the children’s maintenance. However, the actual situation in the present day realities is that the mother often has to contribute towards the family needs, even if it is not her legal duty to do so. Moreover, divorced or widowed mothers often face difficulties in obtaining financial assistance from the ex-husband or his relatives, but there is no statutory provision for the father’s loss of guardianship in the case of irresponsibility regarding the children’s maintenance.

Regarding physical custody, although the mother is said to be ‘of all persons the best entitled to custody of her infant children’, various conditions are attached to her right of custody. Some of the conditions are fair and proper, eg the right of custody is lost ‘by her neglect or cruelty to the child’. However, the right of custody is also lost ‘by her marriage with a person not related to the child within the prohibited degrees if her custody in such case will affect the welfare of the child’. Loss of custody on the ground of the mother’s remarriage is based on a hadith of the Prophet, where he said to a divorced wife, ‘You have the first right to look after [your child] unless you marry’. It is unfortunate that this hadith has often been interpreted as meaning that the mother loses the right to custody upon her remarriage, and that custody reverts to the father, regardless of whether he has remarried or not. However, it should be possible to interpret this hadith as conferring a prior right upon the mother before her remarriage, and if she remarries, then the mother and the father would have equal rights to custody, and each case should be considered on its individual merits. It is also unfortunate that there is no specific statutory provision on how a man may lose his right to custody, even if he is cruel or neglectful of the child. Perhaps this was an oversight, an assumption that the person having custody would be a woman, but such assumption is incorrect, as a man may also be given custody of his children.

Illegitimate children It is provided that custody of illegitimate children appertains exclusively to the mother and her relatives, and the court may order a woman to pay maintenance to her illegitimate child. There is no provision for the syariah court to order a man to pay maintenance or to contribute towards the maintenance of his illegitimate child. The traditional Shafi’i legal ruling is that no relationship whatsoever is recognised

FEATURE between a father and his illegitimate child. The authority often referred to in that ruling is a hadith relating to a dispute over custody of a child (re Sahih Muslim Vol II Hadith 3435). Sa’d ibn Abi Waqas claimed that the child was his nephew as his brother Utba had disclosed to him that the child was his natural son, and the child bore a clear resemblance to Utba. ‘Abd ibn Zaman, however, claimed that the child was his brother as he was born on his father’s bed. In the Prophet’s time, this was a case involving a tug of love, not a case involving a neglected child, and the Prophet granted custody to the family of the legal father and not to the family of the biological father, on the principle that a child belongs to the marital bed. The present day realities are often quite different. The lack of legal responsibility may encourage irresponsible men to indulge in illicit affairs, secure in the thought that even if a child is born as a result of the union, only the unfortunate mothers will have to be responsible for it. The statutory provisions should be amended to provide for the father’s responsibility to maintain or contribute to the maintenance of his illegitimate child.

Discriminatory Effect of Selective Gender Neutral Provisions We are also concerned with the possible discriminatory effect of certain legal provisions that are gender neutral in the language used, but which, when combined with certain other factors and gender specific provisions, have the effect of discriminating against Muslim women. The effect of selective gender neutral provisions could worsen, instead of improve, the position of Muslim women.

Harta sepencarian/matrimonial property An example of this may be seen in the provisions regarding harta sepencarian. The traditional view on harta sepencarian is that a wife may claim one-third of the properties acquired by the husband during the marriage in recognition of

her contributions in looking after the family. Harta sepencarian is based on Malay customary law which is found to be in accordance with the principles of syariah, eg in Mansyur v Kamariah [1988] 3 MLJ xliv, the wife, who had assisted the husband in cultivating the land, was awarded onehalf of the land based on the principle of musha (mixed properties), and in Rokiah v M Idris [1989] 3 MLJ ix, the wife, who was a housewife, was awarded one-third of the matrimonial home and other assets that had been acquired by the husband’s money, based on the principle of syarikatul abdan (partnership of efforts). The gender neutral language in the Islamic family law statutes enables either spouse to claim a share in the properties acquired by the other spouse during the marriage. The gender neutral language is similar to the provisions on matrimonial property in the Law Reform Act. However, the effect is discriminatory to Muslim women because the other provisions in the Islamic family law are not gender neutral. Muslim men may contract polygamous marriages, may unilaterally divorce their wives and are entitled to double shares of inheritance. Therefore, the marriage contract itself, allowing polygamy, is not gender neutral but the gender neutral provision on harta sepencarian would mean that a Muslim man with more than one wife could claim harta sepencarian from each of his wives. Regarding divorce, unlike July 2004

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FEATURE the divorce process under the Law Reform (Marriage and Divorce) Act, the divorce process under the Islamic family law is not gender neutral, and while husbands can easily divorce the wife even without the permission of the court, wives often face numerous difficulties when the husbands do not consent to their application for divorce. Thus, the Muslim wife’s negotiating position on divorce and ancillary reliefs would be further weakened if the husband disputes her application for divorce and could also bring a claim for harta sepencarian against her. As for the man’s double share of inheritance, in traditional Islamic law, a woman’s property is regarded as exclusively her own, while a man is obliged to apply his property for the upkeep of his wife and children. The problem for Muslim women is also compounded due to some confusion regarding the traditional ‘one-third rule’. This confusion has led to cases where, during the financial negotiations, the wives are offered only one-third of the matrimonial home or property concerned, even if the properties had previously been registered in their joint names, because of a belief that women are entitled to ‘one-third of the properties acquired during the marriage’. The original purpose was that women were entitled to one-third of the properties acquired by the husband, as traditionally, the husband was the sole acquirer of the properties and the wife’s contribution was the passive contribution in managing the household. Even in those days, however, the wife may be given as much as one-half in the then-exceptional circumstances where she had made some active contribution towards the acquisition of the properties. In the present day circumstances, it is unjust and discriminatory against women to regard one-third as the ‘normal’ share to be given to the wife. Even one-half may be inadequate in circumstances where the woman has carried a double burden, ie giving her financial contributions for the upkeep of the family as well as her non-financial contribution in doing most of the housework and looking after the children. The interests of the children should also be properly considered in

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the division of harta sepencarian. These factors are taken into account by the syariah court in Singapore, where both the wife’s financial and non-financial contributions have been combined to award the wife a larger share in the matrimonial home.

Gender Specific Provisions on Inheritance The traditional interpretations of Islamic law granted men and women different rights and assigned them different responsibilities in the family. The traditional approach was that those different, gender specific rights and responsibilities would eventually result in an equitable balancing of rights and responsibilities between men and women under the socio-economic conditions prevailing in most societies in those times. Unequal distribution of inheritance between male and female heirs was not a feature peculiar to Islamic law; in the past, male heirs were usually given preference over female heirs under many different legal systems throughout the world. For instance, in pre-Islamic Arabia, women had no automatic right of inheritance, and under the system of primogeniture in various parts of Europe prior to the 20th century, landed property descended from father to eldest son or nearest male heir. In Malaysia too, prior to the amendment to the Distribution Act in the 1990s, there was unequal distribution of inheritance in that husbands were entitled to inherit the whole of their wives’ properties, while wives were entitled only to inherit onethird of their husbands’ properties if they had children or one-half if there were no children. Under Islamic law, the advantage given to men under the faraid distribution of inheritance was directly linked to the increased responsibility of spending ‘for the support of women’ (Surah anNisa’ 4:34). Unfortunately, the present administration of the syariah laws on inheritance emphasise the provision that male heirs be given a double share under the faraid distribution, without emphasising on the rationale for this rule — that the man has the legal responsibility to provide maintenance

for the family, and thus every female should always have a man to provide for her needs, be he a father, a brother, a husband or a son. In today’s society, moreover, many women have to earn their own living and provide for their own needs, and widowed and divorced mothers often have to provide for their children’s needs. There is no mechanism in the present legal system for women to obtain the redress that would reflect on the balance and justice that was originally intended by the syariah.

Conclusion SIS is concerned that the use of religion has often perpetuated discrimination against Muslim women and denied them the increasing sphere of rights that is being granted to their non-Muslim counterparts. The provision in Art 8(2) of the Federal Constitution, prohibiting discrimination on the basis of gender, poses a special challenge to the Syariah Court and the Islamic religious authorities in Malaysia to take steps to end all forms of discrimination against Muslim women in law and in practice, committed in the name of Islam. It is also most unjust and improper if gender equality is used as an excuse to enact gender neutral provisions that are advantageous to Muslim men, while denying the enactment of gender neutral provisions that are advantageous to Muslim women. To ensure justice to both Muslim women and men, the changing socio-economic conditions in present day society should result in a reinterpretation and renegotiation of their traditional rights and responsibilities. In traditional societies, men had greater rights but were expected to shoulder greater responsibilities, while women had fewer rights but were expected to shoulder fewer responsibilities. In progressive societies, men’s traditional rights have been reduced and so have their traditional responsibilities, while women’s rights have been increased and so have their responsibilities. However, lack of understanding as to the rationale behind the formulation of certain roles, and the balance between rights and responsibilities, may lead to a distorted view resulting in injustice and greater discrimination.

FEATURE We are concerned that our society’s confusion regarding traditional and modern practices may lead to greater discrimination against Muslim women in the sphere of family law. There is a tendency to regard men’s traditional rights as immutable and unquestionable, instead of as the result of the development of fiqh rules by human juristic interpretations and understandings in accordance with the socio-cultural conditions of those times. On the other hand, women’s traditional rights are apparently regarded as subject to change of circumstances. Women are often told that they should be patient with their husbands’ shortcomings, and not to be ‘unreasonable’ and ‘materialistic’ in demanding for full maintenance from their husbands, as it is usually ‘unrealistic’ to have such expectations in today’s society. But husbands are not being told that under the circumstances it is unreasonable for them to continue to expect full obedience from their

wives. It therefore appears that Muslim women are expected to shoulder new responsibilities while enduring traditional restrictions on rights, while on the other hand, Muslim men are allowed to enjoy their full traditional rights although their traditional responsibilities have been reduced. The codification of Islamic law in modern statutory enactments is a relatively new development, and confusion may have arisen due to the fact that in referring to ‘syariah’ or ‘Islamic law’, little attempt is made to distinguish sources of authority, ie whether a particular rule is from the Qur’an, or authentic hadith of the Prophet (s.a.w.), or from various juristic opinions which form the bulk of classical Islamic jurisprudence. Too often, the terms syariah and fiqh are used interchangeably. However, law or fiqh is based upon human endeavours to understand the Divine Sources of syariah. The values and principles

contained in the Divine Sources are eternal and universal, but human juristic interpretations, opinions and understandings are not infallible and are therefore open to reinterpretation and reform in order to reflect the principles of justice and equity enshrined in the syariah. Nik Noriani Nik Badli Shah Sisters in Islam (SIS Forum Malaysia)

Endnotes 1

This article was first published in

InfoLine January/February 2004. It is reproduced here with the kind permission of the Malaysia Bar Council.

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