Government Contracts and GLCs: Corruption Risks in Public Procurement
Government Contracts and GLCs: Corruption Risks in Public Procurement
Whether GLCs are caught by Section 17A, why “I declared my interest” is not enough, and what the SRC, Felda hotel and CIDB cases teach companies that deal with the government
Why Public Sector Corruption Matters to Businesses
Almost every business deals with the government at some point, whether bidding for a tender, applying for a licence, clearing goods through customs or facing an inspection. These dealings carry corruption risks that are quite different from those between private companies.
Malaysia’s standing has slipped in recent years. According to the book, Malaysia’s ranking in Transparency International’s Corruption Perception Index for the public sector fell as follows:
Year | Malaysia’s ranking | Score |
|---|---|---|
2019 | 51 | Not stated |
2020 | 57 | Not stated |
2021 | 62 out of 180 | 48 out of 100 |
2022 | 61 | 47 out of 100 |
The book explains that public sector corruption drains public funds through misallocation, higher costs and poorer quality work. It also distorts competition, limits market access and discourages foreign investors. With more than one million public officers in Malaysia, the book notes that systemic corruption is hard to reduce while some officers continue to benefit from a culture of corruption.
Section 17A of the Malaysian Anti-Corruption Commission Act 2009 (“MACC Act”) now makes companies liable when their people pay bribes. This covers bribes to public officers, including payments to speed up an application or to avoid being charged for an offence.
Are GLCs and State-Owned Companies Caught by Section 17A?
Section 17A applies to “commercial organisations”, meaning companies and partnerships that carry on business in Malaysia. Government departments and public authorities are not its target. The question is what happens to companies owned or controlled by the government.
The MACC Act defines a “public body” very widely. Besides the Federal and State Governments, local authorities and statutory authorities, it includes registered societies, sports bodies, co-operatives, trade unions and youth societies, as well as any company or subsidiary over which any of these bodies has controlling power or interest.
The book’s view is that such companies are caught by both definitions. They are “public bodies”, but as long as they carry on business, they are also “commercial organisations” under Section 17A. When Section 17A was introduced in 2020, Parliament did not carve these companies out, and the definition of “public body” is also used in the Government’s Guidelines on Adequate Procedures.
The book also points to the UK Bribery Act 2010, on which Section 17A was modelled. The UK Ministry of Justice’s guidance makes clear that an incorporated body is caught if it engages in commercial activities, even if its main aims are charitable, educational or purely public. The courts have yet to test this point in Malaysia.
Type of body | Caught by Section 17A? |
|---|---|
Government ministries and departments | No, but their officers can be charged personally under other provisions of the MACC Act |
Statutory authorities (bodies set up by Federal or State law, such as CIDB) | No, but their officers can be charged personally |
Companies controlled by a public body (GLCs, state-owned companies and their subsidiaries) | Likely yes, if they carry on business, according to the book |
Private companies bidding for or performing government contracts | Yes |
Case Spotlight: Mohamad Taip bin Johari v Public Prosecutor [2018] MLJU 1894 (High Court, Bintulu) The facts: Mohamad Taip was the branch manager of the Construction Industry Development Board (CIDB) in Bintulu, Sarawak. In November 2016, he approved the award of two small jobs at the CIDB office to Masjora Supplier & Services: air conditioner maintenance worth RM1,085 and the repair and installation of glass doors worth RM6,580. The business was solely owned by his sister. How it happened: The evidence showed that he had told his sister about the jobs in advance and asked her to send him her documents. When his staff obtained three quotations for the glass doors, he rejected them as too costly and then had his sister’s quotation passed to the officer handling the matter. He signed the letters of award and later signed off her invoices. He never told anyone at CIDB that the business belonged to his sister, and his sister admitted handing him RM7,200 after being paid. His arguments: He argued that CIDB was only a body corporate, not a public body, and that he had merely followed his officers’ recommendations. The decision: The High Court held that CIDB is a statutory authority and therefore a public body under the MACC Act. CIDB’s own Act deems its officers to be public servants, and he was on a government payroll performing a public duty. Once it was shown that he made a decision in a matter in which his relative had an interest, the law presumed under section 23(2) that he had used his position for gratification. His bare denial did not rebut the presumption. The court also noted that the CIDB procurement manual did not allow works to be awarded to officers’ relatives, and that Treasury Instructions require any officer with an interest in a tender or quotation to declare the interest and withdraw in writing. The sentence: The High Court upheld sentences of six months’ imprisonment and a RM10,000 fine on the first charge and 12 months’ imprisonment and a RM33,000 fine on the second, with the prison terms running concurrently. The judge stressed that such offences are serious and damage public confidence in the statutory body. |
The lesson for suppliers is simple. If you are related to, or connected with, the officer who will decide on your quotation, that officer must declare it and step aside. Winning the job anyway can expose both of you to prosecution, even when the contract value is small.
The Three Biggest Risk Areas
According to the book, the top three contributors to corruption risk in Malaysia are procurement, enforcement and grand corruption. In information received by the MACC from 2019 to April 2022, procurement accounted for 24.2 per cent and enforcement 24.4 per cent.
1. Public procurement
Public procurement in Malaysia falls into three categories:
Category | Examples |
|---|---|
Works | Construction and engineering for public infrastructure such as airports, roads, highways, dams and drainage |
Supplies | Raw, intermediate or finished goods such as uniforms, vehicles, equipment, spare parts and furniture |
Services | Engagement of manpower, expertise and consultants |
The Government has several safeguards. Bidders must sign an Integrity Pact promising not to offer bribes to win a contract, as a reward for winning one or to speed up procurement matters. Treasury Instructions regulate the financial and accounting side of procurement, and Treasury Circulars update the rules from time to time. However, the book observes that these measures have not been effective in curbing corruption within the public sector.
The book points to the Auditor-General’s Report 2021 Series 1 as evidence of weak safeguards. It stresses that the report did not link these problems to corruption, but warns that such gaps increase corruption risk and can benefit unqualified contractors at the expense of public funds:
Project | Finding in the Auditor-General’s Report 2021 Series 1 |
|---|---|
Parliament building upgrade | Initial allocation of RM520 million exceeded, with RM626.1 million spent as at the date of the report |
Urban Poverty Eradication Programme and Air Traffic Control Centre project for the Kuala Lumpur Flight Information Region | Government suffered a loss of RM2.80 million |
Kuala Lumpur City Hall (DBKL) flood mitigation | Three of six projects, worth RM27.68 million, did not comply with procurement principles |
2. Grand corruption
The book describes grand corruption as the abuse of high-level power by the political or administrative elite, benefiting a few at the public’s expense. It leaves national priorities underfunded, with taxpayers bearing the cost. The book notes that it is particularly hard to curb, because the officer involved holds so much power that ordinary checks and balances cannot work, and Malaysian law has no specific obligations aimed at preventing it. Tools like integrity pacts, which help against petty corruption, fall short here.
Case Spotlight: Dato’ Sri Mohd Najib bin Hj Abd Razak v Public Prosecutor [2022] 1 MLJ 137 (Court of Appeal) The charge: The former Prime Minister was charged under section 23 of the MACC Act with using his office for gratification of RM42 million by taking part in the Cabinet decisions of 17 August 2011 and 8 February 2012 to guarantee RM4 billion in loans from Kumpulan Wang Persaraan (Diperbadankan) (KWAP), the public pension fund, to SRC International Sdn Bhd. He also faced three charges of criminal breach of trust and three of money laundering. A public officer on three counts: The courts held that he was an “officer of a public body” as a member of the administration, as a Member of Parliament and as a person receiving remuneration from public funds. The interest he failed to declare: He chaired both Cabinet meetings, did not declare his interest and did not leave the room. The Court of Appeal noted that the Code of Ethics for members of the administration requires them to declare any conflict and leave the meeting. It held that his interest in SRC went well beyond his official roles. Through the company’s constitution, he had the power as Prime Minister to appoint and remove its directors, was its Advisor Emeritus, and as Finance Minister was its sole shareholder through MOF Inc. The “national interest” defence failed: He argued that he acted for the nation. The trial judge gave seven reasons why that could not be so, and the Court of Appeal agreed (see the table below). The outcome: He was convicted on all seven charges and sentenced to 12 years’ imprisonment and a RM210 million fine on the section 23 charge. The Court of Appeal dismissed his appeal in December 2021. According to the book, the Federal Court then upheld the conviction and sentence, finding his defence so inconsistent and incredible that it raised no reasonable doubt. |
Reason | Why the decision could not have been in the Government’s interest |
|---|---|
1 | The guarantees backed RM4 billion in financing to a newly formed company with no track record in natural resources |
2 | The Economic Planning Unit had refused a RM3 billion grant and suggested commercial banks or capital markets, but KWAP, a public pension fund, was asked to lend instead |
3 | The approval was rushed, before information about SRC and its plans could be properly verified |
4 | After drawdown, shareholder resolutions directed SRC’s funds to be deposited overseas, which had nothing to do with the stated purpose |
5 | SRC defaulted, needing further government loans of about RM650 million to pay interest, and the Government had to honour its guarantees |
6 | He refused the Second Finance Minister’s attempt to travel to Switzerland to verify the status of SRC’s funds |
7 | RM42 million from SRC entered his personal bank accounts in 2014 and 2015 and was used for his personal benefit |
Two points from the Court of Appeal are especially relevant to anyone involved in public decision-making. First, the offence was complete when he took part in the decisions with an undeclared interest. The money did not have to be received at the same time, and a gap of about three years made no difference. Second, a Government Minister’s approval did not stop the courts from examining whether proper processes, such as due diligence on the borrower, had actually been followed.
3. Regulatory and enforcement agencies
Based on complaints received by the MACC from 2013 to 2018, the enforcement sector ranked second as the sector most susceptible to corruption. The Police, Customs, Immigration and the Road Transport Department (JPJ) had the highest number of corruption cases under MACC investigation.
The MACC offers civil servants who report a bribe offer a reward equal to the bribe offered. However, the book observes that this may not work where bribery is endemic, since officers often solicit bribes while colleagues facilitate it or turn a blind eye, and reporting on fellow officers has not gained much traction in Malaysia.
Case Spotlight: Azahar Haji Abdul Aziz v Public Prosecutor [2019] 1 LNS 2032 (Court of Appeal) The facts: Azahar was a police sergeant in the narcotics unit. A man arrested as a suspected drug user was released on police bail pending his court date. Azahar told him that he could “arrange” a supervision order instead of imprisonment or a rehabilitation order, and asked him to prepare RM200. In fact, the man was represented free of charge by a legal aid lawyer, and the Magistrate simply accepted the recommendation of the rehabilitation officer. The trap: The man reported the matter, and the MACC recorded two phone calls between him and Azahar with his consent. Azahar was arrested at an eatery after taking the RM200 in marked notes. The decision: Azahar was convicted on two charges under section 17(a) of the MACC Act and sentenced to ten months’ imprisonment and a RM10,000 fine on each charge, with the prison terms running concurrently. The Court of Appeal held that a call recorded with the consent of one of the parties is not an “interception” that needs prior authorisation from a Deputy Public Prosecutor, so the transcripts were admissible. His claim that the money was for the lawyer’s fees was rejected as an afterthought. |
In another case described in the book, Divananthan Murugan & Satu Lagi lwn Public Prosecutor, two police officers stopped a man on the road and one asked for RM1,500 to release him. When he did not have enough cash, the other officer followed him to collect it. The man reported the matter to the MACC instead of paying. Both officers were sentenced to eight months’ imprisonment and a RM10,000 fine for each charge.
In both cases, the bribes were demanded by the officers. The book explains that under Section 17A, companies are now expected to have procedures that prepare their staff for this situation: a framework to prevent corrupt conduct, due diligence on relevant parties including senior public officials, and whistleblowing channels. The aim is a culture where staff faced with a demand refuse to pay and report it to the company.
Conflicts of Interest: Declaring Is Not Enough
A conflict of interest arises when a public officer’s public duties clash with his personal interests, or with a position he holds in the private sector. Under the MACC Act, a public officer must not use his office for gratification for himself, his relative or his associate. Both terms are defined widely:
Relative includes | Associate includes |
|---|---|
Spouse, and the spouse’s brothers and sisters | A nominee or employee of the person, or someone who manages his affairs |
Brothers and sisters, and their descendants | An organisation in which he or his nominee is a partner or has control or a controlling interest |
Parents, grandparents, children and grandchildren, including those of the spouse | A company in which he or his nominee is a director or in control, or holds at least 30 per cent of the issued capital |
Uncles, aunts, cousins, sons-in-law and daughters-in-law | The trustee of a trust he created, or to which he contributed at least 20 per cent of its assets |
Regulation 4(2) of the Public Officers (Conduct and Discipline) Regulations 1993 also requires public officers to avoid conflicts. Among other things, an officer must not place his private interests above his public duty, act in a way likely to cause reasonable suspicion that he has done so or used his position for personal advantage, or bring outside influence or pressure to support any claim relating to the public service.
The book warns that officers may also exploit their power to give jobs or favours to family members (nepotism) or friends and associates (cronyism), even where the person chosen lacks the qualifications or skips the proper procedures.
Case Spotlight: Public Prosecutor v Amir Dagang [2009] 10 CLJ 448 (High Court, Sandakan) The facts: The headmaster of a primary school in Sandakan, Sabah, faced eight charges under section 15(1) of the Anti-Corruption Act 1997, the predecessor of section 23. In 2003, the school issued eight local purchase orders to Nurakmal Enterprise, which he owned jointly with his wife. He signed all the purchase orders, and his wife said he helped prepare the invoices. The defence that worked at first: He called finance committee meetings, told the members that the business belonged to his wife, and suggested it be appointed for speedy supply. The committee agreed unanimously. The Sessions Court acquitted him without calling for his defence, reasoning that he had declared his interest and the committee made the decision. The High Court’s decision: On the prosecution’s appeal, the High Court set aside the acquittal and ordered him to enter his defence. It held that avoiding a conflict requires two steps: declaring the interest and disqualifying yourself, which includes not being present at the meeting. He was the most senior person on the committee, the members were his subordinates, he chaired the meeting, and he stayed throughout, including for the decision. The court asked how his staff could freely overrule their superior in his presence. A half-truth made it worse: He told the committee the business belonged to his wife, but not that he was a co-owner himself. The court also noted that for purchases under RM10,000 he could have awarded the work without any meeting, so calling one showed that he knew there was a conflict. Note: The book cites this case as Public Prosecutor v Amin Dagang. The judgment gives the name as Amir Dagang. The final outcome after the defence was called is not stated in the materials. |
Case Spotlight: Public Prosecutor v Dato’ Waad bin Mansor [2005] 2 MLJ 101 (Federal Court) The facts: Dato’ Waad was a Negeri Sembilan state assemblyman and a member of the State Executive Council and the Tampin District Land Committee. A company set up by his wife and two others, each holding RM1 in shares, applied for state land for quarrying just three weeks after it was formed. He sat in all three meetings that recommended the application, approved it and later extended the time to pay the premium. The land was then sold to a third party for RM1.1 million, and at the sale meeting he was paid RM150,000 and his wife RM100,000. The lower court’s sentence: The Court of Appeal convicted him of corrupt practice under the Emergency (Essential Powers) Ordinance No 22 of 1970, but imposed only a fine of RM15,000 on each charge. It said the application could have been approved without him in the room, and that corruption should not be equated with crimes such as robbery or rape. The Federal Court’s decision: The Federal Court replaced the fines with two years’ imprisonment on each charge, to run concurrently. It held that unchecked corruption has more far-reaching consequences than robbery, criminal breach of trust or rape, and that in corruption cases it is hard to imagine public interest not requiring deterrence to come first. The loss of his political career and good name were not reasons for sympathy. They were matters he should have considered before embarking on the scheme. |
What the officer did | Was it enough? |
|---|---|
Said nothing about the relative’s business (Mohamad Taip) | No. Convicted and jailed |
Declared his wife’s interest but stayed in the meeting and chaired it (Amir Dagang) | No. Ordered to enter his defence |
Sat in the meetings without declaring, and later received payment (Waad Mansor) | No. Jailed for two years |
Declared the interest, left the meeting, and let others decide | This is what the courts and the rules expect |
Influence Peddling and “Consultants”
The book warns companies not to use third parties to do their corrupt work. A common scenario is hiring a former public officer as a “consultant” to lobby a former colleague who is still in office, so that a decision goes the company’s way.
Case Spotlight: Pendakwa Raya lwn Tan Sri Mohd Isa bin Abdul Samad [2021] MLJU 596 (High Court, Kuala Lumpur) The background: Tan Sri Isa Samad was Menteri Besar of Negeri Sembilan from 1982 to 2004. He later became chairman of Felda, and also chairman of Felda Investment Corporation Sdn Bhd (FICSB), a wholly owned subsidiary set up to make Felda’s strategic investments. The owner of Merdeka Palace Hotel & Suites in Kuching offered to sell the hotel through a letter handed to his special officer. How the deal was revived: FICSB’s board first rejected the purchase at RM200 million, as its management found it would take 27 years to recover the investment. After the matter was revisited, the board approved the purchase at RM160 million, even though management had recommended RM153 million. A later valuation in 2017 put the hotel at about RM80 million, and FICSB recorded impairment losses of RM82.5 million. The bribes: After the approval, his special officer told the seller’s director that Isa Samad needed “political funds”. The seller agreed to pay RM3 million, funded mainly from a RM10 million commission paid to its property agent. Over nine payments between July 2014 and December 2015, a total of RM3.09 million in cash was delivered to his office. Each payment followed a message from Isa Samad passed on through his special officer, asking the officer to convey his regards to the seller. The decision: The High Court convicted him on all nine charges of receiving bribes under section 16(a)(A) of the MACC Act and sentenced him to six years’ imprisonment on each charge, to run concurrently, and a fine of RM15.45 million, five times the bribes. The court noted that the bribes did not need to be paid for doing anything illegal. It was enough that they were a reward for his part in approving the purchase. Acquitted of criminal breach of trust: He was acquitted of a separate charge of criminal breach of trust for approving the purchase without Felda’s approval. The court found that the decision was made by FICSB’s board collectively, not by him alone, and that Felda had impliedly approved the purchase by later financing it. The court also criticised FICSB’s management for failing to seek Felda’s approval as required, and noted there was then no standard procedure for doing so. Status: He was granted a stay of execution pending appeal. The outcome of the appeal is not stated in the materials. |
The case holds lessons for GLC boards as well as for suppliers. Even where a purchase is approved by a board, the chairman can still be convicted if he takes money for his part in it. And gaps in internal procedures, such as unclear rules on when a parent entity’s approval is needed, create room for abuse.
The book also refers to Merong Mahawangsa Sdn Bhd & Anor v Dato’ Shazryl Eskay bin Abdullah [2015] 5 MLJ 619, where the Federal Court refused to enforce a promise to pay a RM20 million “consultancy fee” for using the respondent’s close relationships with government officials to secure a contract. The agreement was void for illegality. In other words, a company that pays an influence peddler cannot rely on the courts to enforce that arrangement.
How the Courts Sentence Public Sector Corruption
The book describes a “public interest rationale”: corruption involving public officers should normally be punished with prison, because of the strong public interest in stamping it out. Courts in both Malaysia and Singapore have applied this principle, often increasing sentences on appeal.
Case | What happened | Sentence |
|---|---|---|
PP v Dato’ Waad bin Mansor (Federal Court, 2005) | State assemblyman approved land for his wife’s company and was paid RM150,000 | Fine of RM15,000 per charge replaced with two years’ imprisonment per charge |
Dato’ Sri Mohd Najib v PP (Court of Appeal, 2021) | Prime Minister took part in Cabinet guarantees for SRC and received RM42 million | 12 years and a RM210 million fine upheld. The Court of Appeal said the law applies equally to all |
Mohd Ismail bin Syed Merah v PP (Court of Appeal), as described in the book | Police officer took bribes to protect illegal gambling operators, with proceeds of about RM3.35 million | Sentence increased on appeal to deter conduct that betrayed public trust |
Chua Tiong Tiong v PP (Singapore High Court), as described in the book | Illegal moneylender bribed a senior police officer for help and insider information on arrests | Increased from 18 months to 48 months’ imprisonment. The officer received 30 months |
PP v Wong Chee Meng (Singapore High Court), as described in the book | Employee of the private managing agent of Ang Mo Kio Town Council took bribes from contractors | Aggravated prison terms for both giver and receiver, because the private company performed public functions |
The book observes that Malaysia has no uniform sentencing framework for corruption offences, and it remains to be seen whether officers of companies charged under Section 17A will receive prison terms.
Bribing Foreign Officials: The Malaysian Connection in a Singapore Case
Section 22 of the MACC Act makes it an offence to bribe a foreign public official, and for a foreign public official to solicit or accept a bribe. A foreign public official includes anyone holding legislative, executive, administrative or judicial office in a foreign country, anyone exercising a public function for a foreign country (including employees of bodies performing functions for that country), and anyone authorised to act for a public international organisation. The book notes that there are no reported Malaysian cases yet, but the risk is real.
Case Spotlight: Public Prosecutor v Tan Kok Ming Michael and other appeals [2019] 5 SLR 926 (Singapore High Court) The Malaysian enforcement angle: Tan owned a Singapore oil trading company. In 2016, he paid S$10,000 to a “fixer” for the benefit of officers of the Malaysian Maritime Enforcement Agency (APMM), so that they would detain a competitor’s vessel. He hoped to spark a conflict between two rivals and “conquer the market”. The vessel was never detained, and the fixer returned S$8,500. Earlier, Tan had also paid S$10,000 to get two of his own vessels released by APMM. The US Navy case heard together: Gursharan Kaur, a lead contract specialist for the US Navy in Singapore, leaked non-public information about US Navy contracts to the chief executive of a ship-husbanding company, in return for bribes including S$50,000 in cash twice and a Bali resort stay. The leaked information related to 16 contracts, 11 of which the company won, worth about US$48 million. The key ruling: The Singapore High Court held that bribing foreign public officials does not fall under Singapore’s “public service rationale”, which protects Singapore’s own public administration. But it is not a merely commercial case either. It is a separate aggravating factor, because it threatens Singapore’s reputation for incorruptibility, undermines its international obligations against transnational corruption and risks fostering a culture of corruption. The starting point is prison. The court also held that a civilian employee of a foreign government counts as a foreign public official. The outcome: Tan’s sentence of four months’ imprisonment was upheld, and the court refused to add a fine for the returned money. Kaur’s sentence was increased from 33 to 40 months’ imprisonment. The book states that the prosecution succeeded in increasing the sentences, but according to the judgment, only Kaur’s sentence was increased. |
The book welcomes this approach, noting that deterrent sentences discourage repeat offending, and that in Singapore both the giver and the receiver of a bribe are typically charged. This sends a clear message that enforcement is not selective.
Practical Checklist for Companies Dealing with the Government and GLCs
- Find out whether you are a “commercial organisation”. If you are a GLC or a subsidiary of one and carry on business, assume Section 17A applies and put adequate procedures in place.
- Map your touchpoints with government. Identify every tender, licence, permit, inspection and enforcement interaction, and treat procurement and enforcement as high-risk areas.
- Honour the Integrity Pact. Train bid teams that no payment may be offered to win a contract, as a reward for winning one, or to speed up a process.
- Declare relationships with decision-makers. If anyone in your company is related to or connected with the officer handling your bid, disclose it in writing so the officer can step aside.
- For GLC boards and officers, declare and withdraw. Record the declaration, leave the room, and make sure the minutes show that you did not take part.
- Be wary of “consultants” with connections. Do due diligence on former public officers and agents, pay only for genuine, documented services, and never pay for access or influence.
- Prepare staff to refuse and report. Tell staff what to do if an enforcement officer asks for money, and give them a safe whistleblowing channel.
- Treat foreign officials the same way. Your policy should expressly prohibit bribing officials of any country, including through agents or “fixers”.
- Keep clear approval procedures. Set out when board or parent entity approval is required, so that no one can bypass it.
Conclusion
Public procurement and dealings with enforcement agencies remain the areas where companies are most exposed to corruption in Malaysia. The cases show a consistent message: small contracts and small bribes still lead to prison, declaring a conflict is meaningless if you stay in the room, and even the highest office in the land offers no protection.
As the book concludes, corporate liability alone will not eliminate corruption, and both enforcement agencies and the courts have important roles to play. The book recalls the words of Raja Azlan Shah FJ (as His Royal Highness then was) in Public Prosecutor v Datuk Haji Harun bin Haji Idris (No 2) [1977] 1 MLJ 15, cited again by the Court of Appeal in the SRC case, that the law is no respecter of persons. For companies dealing with the government, the safest course is to make sure their own people never give an officer a reason to test that principle.
Cases Referred To
- Mohamad Taip bin Johari v Public Prosecutor [2018] MLJU 1894 (High Court, Bintulu)
- Dato’ Sri Mohd Najib bin Hj Abd Razak v Public Prosecutor [2022] 1 MLJ 137 (Court of Appeal), with the Federal Court decision reported at [2022] 8 CLJ 393, as described in the book
- Azahar Haji Abdul Aziz v Public Prosecutor [2019] 1 LNS 2032 (Court of Appeal)
- Divananthan Murugan & Satu Lagi lwn Public Prosecutor [2016] 1 LNS 202, as described in the book
- Public Prosecutor v Amir Dagang [2009] 10 CLJ 448 (High Court, Sandakan), cited in the book as Amin Dagang
- Public Prosecutor v Dato’ Waad bin Mansor [2005] 2 MLJ 101 (Federal Court)
- Pendakwa Raya lwn Tan Sri Mohd Isa bin Abdul Samad [2021] MLJU 596 (High Court, Kuala Lumpur)
- Merong Mahawangsa Sdn Bhd & Anor v Dato’ Shazryl Eskay bin Abdullah [2015] 5 MLJ 619 (Federal Court)
- Mohd Ismail bin Syed Merah v Public Prosecutor and other appeals [2022] 3 MLJ 786, as described in the book
- Chua Tiong Tiong v Public Prosecutor [2001] 2 SLR(R) 515 (Singapore High Court), as described in the book
- Public Prosecutor v Wong Chee Meng and another appeal [2020] 5 SLR 807 (Singapore High Court), as described in the book
- Public Prosecutor v Tan Kok Ming Michael and other appeals [2019] 5 SLR 926 (Singapore High Court)
- Public Prosecutor v Datuk Haji Harun bin Haji Idris (No 2) [1977] 1 MLJ 15
Related Articles
The MACC Is at Your Door: What Your Company Should Do During a Dawn Raid
Bribe First, Launder Later: How Corruption Cases Become Money Laundering Cases
A Ready-to-Use Anti-Corruption Toolkit: Sample Clauses, Integrity Pacts and a Compliance Checklist
Inflated Claims and Fake Invoices: How Section 18 Can Land You in Court Even Without a Bribe
Blowing the Whistle in Malaysia: Are You Really Protected?
Beyond Bribery: MACC Offences Most Employees Have Never Heard Of
Is Private Sector Corruption Less Serious? Lessons from Airbus, Rolls-Royce and the Rosmah Solar Case
The Hidden Cost of a Bribe: Void Contracts, Unenforceable Awards and Lost Business
Spotting Corruption Before the MACC Does: Risk Mapping and Data Analytics for Companies
