View
293
Download
4
Category
Preview:
DESCRIPTION
JHJ's bi-annual newsletter. Issue 1 of 2013 features common legal concerns such as Tenancy, Sexual Harrassment at Workplace and Insurance Claims.
Citation preview
LEGAL CAULDRON Jayadeep Hari & Jamil
Advocates and Solicitors
PETALING JAYA
Unit 612, 6th Floor, Menara Mutiara Majestic, No. 15, Jalan Othman,
46000 PJ, Selangor. T: 03-7784 7255
F: 03-7781 7255
KOTA BHARU 1
2713, 1st Floor, Section 22, Batu 2, Jalan Kuala Krai, 15050 Kota Bharu,
Kelantan. T: 09-741 2050
F: 09-741 2051
KOTA BHARU 2
Tingkat 2, Lot 11, Bangunan Tabung Haji, Kompleks Niaga, Jalan Dato Pati,
15000 Kota Bharu, Kelantan. T: 09-747 7782
F: 09-747 4733
Issue no. 1
of 2013
LE
GA
L C
AU
LD
RO
N Iss
ue N
o 1
of 2013
MELAKA
No.54-1, Jalan TU 2, Taman Tasik Utama, 75450 Ayer Keroh,
Melaka. T: 06-234 7330
F: 06-234 4800
In this issue:
Our offices:
No KDN: PP 15706/02/2013
(032198)
KUALA LUMPUR
Suite 2.03 (2nd Floor) Block A, No 45, Medan Setia Satu, Plaza Damansara, Bukit Damansara,
50490 Kuala Lumpur. T: 03-2096 1478 | F: 03-2096 1480
www.jhj.com.my
Landlord vs. Tenant -
A Guide To Tenancy Manage-
ment
Sexual Harassment -
How Safe Are You At Work?
Seeing Double -
Insurance Claim or Full Sum
Damages, or Both?
JHJ New Strategic Alliance In
Singapore - Voskamp Lawyers
JHJ Office Trip - Tioman Is-
land Vacation
Season’s Greetings - JHJ
Christmas Kringle
EDITOR:
Adeline Chin
DESIGN & LAYOUT:
Andrew Chee
CONTRIBUTORS:
Manisah Saharin
Siti Khadijah Md Yunus
Shobana Padmanathan
Editor’s Note:
“If you change the way you
look at things, the things you
look at change.” Change is the
only constant, and if not for
change, we would have none
to learn nor to improve upon.
This first issue of the 2013
Legal Cauldron would be our
way of embracing, sharing and creating with you,
Change.
2012 had come and gone so swiftly. While we re-
joice having made it through the year alongside
the highly publicised eschatological belief of an
apocalypse, 2012 had also seen many earnest
changes in JHJ. Amongst which were the addition
of new members to our team and the celebration
of several nuptials during the second half of the
year. Besides expanding our practice areas to in-
clude the provision of advisory services for the
mining and quarrying industry, we are also proud
to announce a new strategic alliance with Vos-
kamp Lawyers of Singapore.
Voskamp Lawyers is the largest Dutch legal firm
in South East Asia to date, with offices in Singa-
pore, Amsterdam and Malaysia. The increasingly
globalised nature of today’s business and commu-
nication structure had made it important for us to
provide you the ease and comfort of having quali-
ty cross-border legal services without the hassle
and risk of venturing into overseas transactions
based on unsafe sources. We hope that with this
new strategic alliance, JHJ will be able to continue
providing you a peace of mind as you advance to
broaden your scope of business ventures, be it
geographically or professionally.
As JHJ had always been a staunch believer of con-
tinuous learning, we expand our knowledge spec-
trum by learning about your needs and catering to
them. Hence please do keep those inquiries com-
ing in! Our team would be delighted to hear from
you.
On a lighter note, this issue of the Legal Cauldron
also shares insights on our annual office trip to the
beautiful Tioman Island and tidbits on our Christ-
mas Kringle alongside other events. We have even
decided to spice things up by sharing our stories
via QR codes! So just whip out your mobile
phones and scan away to view the full write-up or
simply log on to our website at
www.jhj.com.my for more information.
My hope as new editor of the Legal Cauldron is to
continue sharing and bringing forth to you these
changes, regardless it being a casual JHJ event or
simply good-to-know legal information. We hope
you would enjoy this issue of the Legal Cauldron
as much as we enjoyed sharing it.
Happy reading and have a blessed 2013 from all of
us here at JHJ!
Legal Cauldron 1 of 2012 | 2
EDITOR
Adeline Chin Knowledge Department
adeline@jhj.com.my
Recently, more and more issues regarding tenancy
have arisen due to the rapid development in the
property sector. And for this reason, I am called
to discuss on the conflicts between the landlord
and the tenant, along with suggestions to cater to
some of the issues that commonly arise.
I often suggest to my friends that if they have ex-
tra money, invest in property; to be landlords and
rent out their properties to cover the bank loan.
However, being a landlord is not the easiest job in
the world, especially if you happen to have a ten-
ant from “hell”.
The term “Landlord” indicates a person who is
either a registered owner or one who has benefi-
cial interest in a land or premise; be it a shop lot,
dwelling house, factory or etc. A “Tenant” on the
other hand is a person who is granted a tenancy
either on a contractual or a monthly basis of the
said land or premise. A tenant need not necessari-
ly be an individual. A company can also be a ten-
ant.
A “Tenancy Agreement” is defined as a contract
signed by both the landlord and the tenant which
states all the terms and conditions for the rental
of a property. Statutorily, a tenancy exceeding 3
years will be considered a “lease of property” that
would be subject to registration against the title
to the property under the National Land Code
1965 (“the Act”). Legally, whilst a landlord to a
registered lease under the Act is afforded statuto-
ry protection, a landlord of an unregistered lease
may not be, and therefore, would be well advised
to have his relationship with his tenant reduced
into a formal agreement or a Tenancy Agreement.
“Standard Tenancy Agreement”
From the point of time when the Tenancy Agree-
ment is signed by both parties, the landlord and
the tenant are deemed to be bound by its terms
and implications. The principle of freedom to con-
tract strives to ensure a win-win situation for both
parties, allowing there to be a consensus ad idem
(“meeting of minds”) before an agreement could
be deemed valid. Hence, you should never believe
that there is only one standard tenancy agree-
ment. Ideally, an astute person should ensure that
the terms contained in the tenancy agreement are
not lop sided.
It is pertinent for both parties to know their rights
and obligations under the Agreement to ensure an
effective tenancy management.
In Malaysia, quite frequently rental practices do
not involve any kind of written contract binding
the landlord and the tenant. This is sad but true.
Although a written contract of tenancy is highly
encouraged, any tenancy with no written agree-
ment can still be valid and enforceable by law un-
Legal Cauldron 1 of 2012 | 3
LANDLORD VS TENANT
A Guide To Tenancy Management By Manisah Saharin
“…being a landlord is not the easiest
job in the world…”
“…never believe that there is only
one standard tenancy agreement.”
der s213 (2) (a) of the Act. Where the existing
tenancy has expired or where there is no written
tenancy agreement but rental is still being paid,
the tenancy would be deemed as a month to
month tenancy, that is to say, deemed renewed
automatically every month upon the expiry of the
previous month unless expressed otherwise by
notice.
It is submitted that this position rather favours
the tenant. So long as a Tenancy Agreement is
“deemed” to subsist, the law affords protection to
the tenant. An added burden is placed on the
landlord to issue a termination notice allowing for
a reasonable amount of time to elapse before ter-
mination taking effect legally.
Termination
The Agreement usually indicates the manner of
which termination of a tenancy should take place.
Prior to such termination, a notice of termination
or a notice to vacate is usually given to the tenant
within the time stipulated in the Agreement. If
sufficient notice had been given; the landlord has
the right to vacant possession of the premises
without payment of any compensation. If the ten-
ant so wishes to continue the tenancy beyond its
term, the terms of a new tenancy or a renewal
(and a possible rent adjustment) of the previous
must be mutually agreed upon, failing which the
Tenancy Agreement is considered expired and
the tenancy granted therein, terminated.
“Tenants from Hell”
Difficulties arise when in spite of termination, a
tenant refusing to leave. Termination may have
been the result of several acts of default of the
Tenancy Agreement. We have seen several in-
stances where tenants overstay or “disappear”, or
create a nuisance or damage the property or use
the property for wrong, illegal or immoral purpos-
es. Whatever the case may be, often, despite best
intentions, the landlord would incur costs, time
and expense in seeking his remedies.
In a fit of spite, the landlord might decide to take
the law into his own hands and break into the
premise, cut off the power supply, prevent the
tenant from entering into the premise and the list
goes on. STOP!
The tenant, besides having a right to claim damag-
es from the landlord, may also initiate an injunc-
tion proceeding to claim his rights to rent or to
stay in the premise, and to prohibit the landlord
from interrupting his stay on the premise. So in-
stead of recovering vacant possession of the prop-
erty or at least the rent or the said premise, the
landlord may end up facing a civil claim by his / her
tenant.
The landlord may be deemed a trespasser for
denying the tenant access into the premise. Lock-
ing up the premise for non-payment of rent is no
justification in the eyes of the law.
The amended section 7(2) of the Special Relief Act
1950 relegates remedy for ‘self-help’ to making it
incumbent to the landlord to seek to enforce his
right to recover his property by way of a Court
action alone.
Landlord’s Remedies
The landlord may file a distress proceeding against
the tenant if he wishes to collect his overdue rent-
al from the tenant. He could also file an eviction
summons in Court if he wishes to recover vacant
possession of his premises.
Legal Cauldron 1 of 2012 | 4
“In a fit of spite, the landlord might
decide to take the law into his own
hands… STOP!”
For that, an eviction notice must be served to the
tenant, giving the tenant certain grace period to
handover a vacant possession and pay all overdue
rental. After the expiry of such notice, the land-
lord must take out a court order for eviction.
Only then can the landlord seal the premises with
the help of the court bailiff (to prevent access and
entry to the delinquent tenant). In such instances,
the landlord may also claim double rental if the
tenant remains in occupation of the premises
from the time of the eviction notice until such
time as vacant possession is redelivered.
A Call for a Tenancy Act
At present, the law places the burden on land-
lords to ensure that their tenancy agreement suffi-
ciently provides for all eventualities and to take
specific steps before forcibly claiming possession
of his property.
There is no specific law governing the relationship
between the landlord and the tenant in Malaysia.
Tenancy agreements are covered under the Con-
tracts Act 1950, whilst the eviction of a tenant is
covered under the Specific Relief Act 1950. Cer-
tain provisions regarding leases and tenancies are
in turn contained in our National Land Code of
1965. These provisions although existing, are nev-
ertheless less than expedient in protecting the
rights of the landlord.
Having a specific Tenancy Act will no doubt help
solve many problems arising from a tenant-
landlord relationship. In the United Kingdom for
example, the Landlord and Tenant Act 1985 con-
solidated certain provisions pertinent to both the
landlord and the tenant such as matters concern-
ing the disclosure of identity, interests, remedies
for breach of contract, etc. Protection is afforded
to both parties statutorily and one cannot con-
tract out of these statutory provisions. The UK
Tenancy Act spells out all the rights, duties, obliga-
tions and remedies of the parties that can sum-
marily be effected without involving distressful,
lengthy and convoluted court processes.
In conclusion, until such time as there is a
“Tenancy Act” or the like in a Malaysian context,
as a landlord, you are well advised to be cautious
and be prepared to be faced with difficulties even
if you have a tenancy agreement that spells out all
the rights and duties of you and your tenant.
By Manisah Saharin
manisah@jhj.com.my
Legal Cauldron 1 of 2012 | 5
NEWSFLASH
JHJ is proud to announce another strategic alliance
between:
and
Voskamp Lawyers is the largest Dutch legal firm
in the South East Asia region since August 2010,
specializing in integrated tax and legal advice on
cross border transactions. Together, we strive to
provide you the assurance and assistance you
need in your overseas business ventures, giving
you peace of mind because We Care.
“…be cautious and be prepared to
be faced with difficulties…”
Have you ever been a victim of offensive sexual
remarks or jokes at work? Or has a colleague at-
tempted to touch you in any way? Were you un-
happy about it? If your answer is yes, you are a
victim of sexual harassment. A survey carried out
in some industrialized countries which have laws
specifically governing sexual harassment showed
that 7 out of 10 female employees were sexually
harassed at their workplace. Sadly in Malaysia
there is no Act that specifically governs the law
on sexual harassment.
INTRODUCTION
This article aims to outline the law on sexual har-
assment at the workplace and the legal remedies
available to individuals of a workplace.
Before we go any further, it is of utmost im-
portance to first clarify that sexual harassment
not only happens to women but also to men, and
not only to employees but also to employers.
Sexual harassment may happen regardless of it
being a heterosexual or homosexual relationship,
and hence such wide scope will be dissected for
better understanding and clarity in the following
paragraphs.
WHAT IS SEXUAL HARASSMENT?
Sexual harassment can be defined as any unwel-
come sexual behaviour that is repeated and inter-
feres with your work. If the conduct was subtle
and you are uncertain if it was indeed harassment,
the question to ask is whether the act offended,
humiliated or intimidated you.
The intention of the harasser is irrelevant so long
as the victim can corroborate the allegation with
documentary, oral, circumstantial, similar fact, ex-
trinsic or physical evidence.
Another recognised means of sexual harassment
can come in the form of suggestive remarks.
Comments that attack a person’s intelligence and
capabilities based on his/her gender could amount
to sexual harassment. For instance, a comment
such as “women should be at home raising the
children and not working” can constitute a form
of sexual harassment.
THE LAW IN MALAYSIA
Knowing that there is no Act which specifically
governs such offences, how then can we seek re-
dress if we have been sexually violated at the
workplace? The victim or complainant may choose
to seek legal recourse under the employment law
or alternatively, lodge a police report to press
criminal charges against the offender under the
Penal Code.
Employment Act 1955
Recent amendments to the Employment Act 1955
which came into force on 1 April 2012 introduced
the criminalization of sexual harassment in the
workplace.
The Act introduced Part XVA: Sexual Harassment
alongside a definition of such “act” which coin-
Legal Cauldron 1 of 2012 | 6
SEXUAL HARASSMENT
How Safe Are You At Work? By Shobana Padmanathan
“A survey…showed that 7 out of 10
female employees were sexually har-
assed at their workplace.”
cides with the intensified anti-harassment efforts
and pursuits by non-governmental organizations in
Malaysia. Sexual harassment is now defined in the
Act as any “unwanted conduct of a sexual nature,
whether verbal, non-verbal, visual, gestural or
physical, directed at a person; the act which is of-
fensive or humiliating or is a threat to his well-
being, arising out of and in the course of his em-
ployment.”
Section 81A of the amended Act recognised that
a complaint of sexual harassment means a com-
plaint by an employee against another employee /
the employer, or an employer against an employ-
ee.
One of the options made available to the com-
plainant is that he / she may terminate the con-
tract of service WITHOUT NOTICE once the
alleged sexual harassment can be proven before
the Director-General. The complainant will then
be entitled to wages, termination benefits and in-
demnity (if any) as if he / she have given notice of
termination.
THE EMPLOYER’S DUTY
The Act has now made it compulsory for an em-
ployer to inquire, in the prescribed manner, into a
complaint made by a victim immediately upon re-
ceiving it. However, the employer may refuse to
inquire (with reasons) in writing within 30 days
upon receipt of the complaint. The Act also spec-
ified situations in which it is acceptable for the
employer to refuse to inquire, which are: -
1) The complaint has been previously inquired
into;
2) There was no sexual harassment proven;
3) The employer feels that the complaint is frivo-
lous or not made in good faith.
Fret not if a complaint has been refused to be in-
quired into. It is not the end of the road. The
complainant can refer the matter to the Director-
General who will then have the power to direct
the employer to address the complaint immedi-
ately. Should this fail to provide any remedy to the
complainant, one may then file an appeal to the
High Court to challenge the Director-General’s
decision. In addition to this, if the complaint is
made against an employer who is a sole proprie-
tor, the Director-General must inquire into the
matter himself.
The employer who is convinced of the occurrence
of the offence (proven from inquiry conducted)
may take disciplinary action against the wrongdoer
which includes dismissing the wrongdoer employ-
ee without notice, downgrading the employee or
imposing any other punishment which the employ-
er deems fit. If the punishment imposed is suspen-
sion without wages, it must not exceed a period
of two weeks.
The Act has also imposed a mandatory obligation
on the employer’s part with regards to this. An
employer who fails or refuse to inquire into a
complaint and to submit a report of inquiry to the
Director-General is deemed to have committed
an offence and if convicted, will be liable to a fine
not exceeding RM10,000.00.
Intentional Tort
A victim may also bring an action against the
wrongdoer under intentional torts. Under this
common law doctrine, the victim must prove that
the wrongdoer had acted with the specific intent
to perform the offence. The employer or the or-
ganization may also be vicariously liable for the act
of the harasser.
Legal Cauldron 1 of 2012 | 7
“Sexual harassment not only happens
to women but also to men.”
Penal Code
The four main sections that deal with the offence
are (i) Section 354 which provides for assault or
use of criminal force to a person with intent to
outrage modesty, (ii) Section 355 which provides
for assault or criminal force with intent to dishon-
our a person, otherwise than on grave provoca-
tion, (iii) Section 375 which provides for rape and
(iv) Section 509 which provides for word or ges-
ture intended to insult the modesty of a woman.
Code of Practice on the Prevention and
Eradication of Sexual Harassment in the
Workplace
The Code of Practice on the “Prevention and
Eradication of Sexual Harassment in the Work-
place” came into force in August 1999 under the
purview of the Ministry of Human Resources Ma-
laysia. The Code encourages employers of both
public and private sector to implement in-house
mechanisms to prevent, handle and eradicate sex-
ual harassment in the workplace. The in-house
mechanism provided by the Code included a poli-
cy statement prohibiting sexual harassment in the
organisation, a clear definition of sexual harass-
ment, a complaint/ grievance procedure, discipli-
nary rules and procedure against the harasser and
those who make false accusations, protective and
remedial measures for the victims and promotion-
al and educational programmes to educate the
company’s employees.
The Code ingeniously stipulated the meaning and
spheres that encompasses the word “workplace”
in the context of sexual harassment, something
which the amended Employment Act 1955 failed
to consider. Situations under which such employ-
ment-related sexual harassment may take place
include, but is not limited to are: at work-related
social functions, in the course of work assign-
ments outside the workplace, at work-related
conferences or training sessions, during work-
related travel, over the phone and through elec-
tronic media.
This Code will serve as an effective guideline in
organizations that do not have their own policy in
place to challenge sexual harassment in the work-
place.
RECOURSE FOR THE AGGRIEVED EM-
PLOYEE (HARASSER)
The employee who feels that he / she had been
wrongly accused and punished (dismissed) by the
employer may under section 20 of the Industrial
Act 1967, make representations to the Director-
General for reinstatement and this representation
must be filed within 60 days of the dismissal.
CONCLUSION
The requirement of adopting the policy statement
prohibiting sexual harassment in the workplace is
not mandatory under the Employment Act 1955.
It is the author’s opinion that employers should
adopt the in-house mechanism provided by the
Code, albeit it being a mere guideline, to ensure a
safe and conducive working environment for its
employees. Any unwelcome behaviour that threat-
ens the safety or well-being of an individual at the
workplace would not only affect one’s occupation-
al health, productivity and morale but also leaves a
long-term effect on the emotional health of the
victim. It is the legal and moral obligation of the
employer to safeguard and protect its employees
from avoidable occupational hazards such as this.
By Shobana Padmanathan
shobana@jhj.com.my
Legal Cauldron 1 of 2012 | 8
Legal Cauldron 1 of 2012 | 9
JHJ Office Trip Tioman Island Vacation
Scan QR Code for full story
Season’s Greetings JHJ Christmas Kringle 2012
Scan QR Code for full story
If you have met with an accident and are suing
for damages with regards to personal injury
from the wrongdoer, you would want the full
sum of damages according to what you have
suffered or incurred.
But can you still get the full sum of damages
from the wrongdoer (through his insurer) if
you are already covered by your own insur-
ance and your insurer had already paid for the
medical expenses or have paid you for the
same? Can you have both, damages claim from
the wrongdoer, and monies from your own in-
surer?
The relevant law in this regard is section 28A
(1) (a) of Civil Law Act 1956 (“the Act”)
which provides that in assessing damages re-
coverable for non-fatal personal injury, no de-
duction should be made to any sum paid or
payable in respect of such personal injury un-
der any contract of assurance or insurance, re-
gardless whether it was made before or after
the coming into force of this Act.
This simply means that the court, in calculating
damages to be awarded to you by the wrong-
doer, must not deduct any sum paid that is
payable by your insurer. Thus in answering the
above question of whether you are entitled to
get both, damages from the wrongdoer and,
your insurer, the answer would appear to be a
resounding “yes”.
But in my opinion, it is not so simple. I would
argue that S28A applies when a Plaintiff has tak-
en out a Personal Accident policy or a similar
policy and has received payment from his/her
insurance company. Then I would argue S28A
applies and the sum received by the Plaintiff
cannot be taken into account when determining
quantum if he met with an accident.
However if the Plaintiff had taken out a Hospi-
talisation policy, then I would argue that S28A
would not apply. And if his insurers have paid
under the Hospitalisation policy, then the Plain-
tiff would not be entitled to claim for the same
medical expenses from the wrongdoer.
The case of Ward v Malaysian Airlines Sys-
tem Bhd [1991] 3 MLJ 317, seem to adopt
this position. In this case, the court held that
considering the nature of an insurance policy
scheme, the insurance benefits were not de-
ductible under section 28A (1) (a) of the Act.
The words used in that section should be inter-
preted in its plain and ordinary meaning. By
adopting a strict rule of interpretation, our Par-
liament in its wisdom had made it crystal clear
that any sum paid or is payable in respect of a
non-fatal personal injury under any contract of
assurance or insurance shall not be taken into
account in assessing damages.
The case of Sin Hock Soon Transport Sdn
Bhd & Anor v Low King Ban [2006] 3 MLJ
Legal Cauldron 1 of 2012 | 10
SEEING DOUBLES
Insurance Claim or Full Sum Damages, or Both? By Siti Khadijah Md Yunus
‘…the answer would appear to be a
resounding “yes”. But…it is not so
simple.’
174 echoed Ward’s case and held that where
the employer was the party who paid for the
premium under the contract of employment,
damages awarded and received by the Plaintiff
should not be deducted. However in the in-
stant appeal, the respondent himself purchased
the policy and paid for the premiums. By apply-
ing the principles as enunciated in Ward's case,
the respondent was clearly entitled to the in-
surance monies paid under his own insurance
coverage and also the special damages awarded
by way of his claims against the appellants.
However prior to Sin Hock’s case [supra], the
courts held in the case of Khairul Sham bin
Ahmad & Anor v Yesudass a/l Michaelsamy
[2005] 2 MLJ 679 that the Plaintiff cannot
claim for medical expenses paid by the insur-
ance company as the rights to recover the
medical expenses lies in the hands of his insur-
er. The medical expenses of RM30,000 award-
ed by the learned Sessions Court judge had
simply enriched the Plaintiff. This enrichment
violated the philosophy behind the principle of
compensatory damages upheld in this country.
Therefore such an award should not be al-
lowed.
Until recently, the question as to whether one
would be entitled to claim for damages from
the wrongdoer in addition to receiving insur-
ance monies from his own insurer pursuant to
a hospitalisation policy still remained unclear
until the recent Court of Appeal decision in
the case below was made.
The judge in Sathisvaran a/l Chandrasegaran
v Agilan a/l Vanmugelan & Anor [2012] 4
MLJ 548 differentiated general damages and
special damages, contending that in Ward’s case
the Plaintiff was seeking an award of general
damages for pain and suffering and thus section
Legal Cauldron 1 of 2012 | 11
28A (1) (a) applies; whilst in the present case,
the Plaintiff was seeking special damages which
should be the amount spent by the Plaintiff
himself and hence the section does not apply.
Furthermore, if the claim was allowed, it would
enrich the Plaintiff out of his misfortune, and
this would be contrary to the universal rule
that one is not allowed to recover something
which he has not lost. Therefore the medical
bill paid by the Plaintiff’s insurer in this case
was deducted from the damages awarded.
Even though section 28A (1) (a) does not state
whether the word “damages” is one under the
head of general or special damages, this case
made it clear that medical expenses or any
expenses that have been paid by the
Plaintiff’s own insurance are deductible in
calculating the damages.
Hence you are unlikely to be able to claim or
the expenses that have been paid or are paya-
ble by your insurance.
As for general damages or damages for pain
and suffering, Ward’s case stands. You may get
a full sum of damages even if your own insurer
has paid you.
By Siti Khadijah Md Yunus
sitikhadijah@jhj.com.my
“…if the claim was allowed, it would
enrich the Plaintiff out of his misfor-
tune…”
Kuala Lumpur . Petaling Jaya . Kota Bharu . Melaka
This is a publication produced by the JHJ Knowledge Department. For any inquiries, please do not hesitate to contact
us: T: 03-2096 1478 | F: 03-2096 1480 | E: kd@jhj.com.my | W: www.jhj.com.my
Publisher: Messrs Jayadeep Hari & Jamil, Suite 2.03 (2nd Floor), Block A, Plaza Damansara, Bukit Damansara, 50490 KL.
Printers: Pressworks Enterprise, No 20, Jalan Usaha Satu 25/2A, 40400 Shah Alam.
Recommended