Conflict between Syariah Law and Civil Law in Malaysia: A Constitutional Analysis

Introduction

Under the Federal Constitution (FC) of Malaysia, Malaysia adopts a dual legal system, which include civil law and Syariah law. The coexistence of these two legal systems reflects Malaysia’s historical development and recognition of Islam as the religion of the Federation. While civil law generally governs matters under federal jurisdiction, Syariah law applies exclusively to Muslims in matters relating to personal law as provided under the State List in the Ninth Schedule. However, the coexistence of these two legal systems has given rise to various conflicts. In response to these conflicts, Article 121(1A) was introduced. According to Professor Ahmad Ibrahim, the important effect of the amendment is to avoid conflict between decisions of Syariah courts and civil courts.

Nevertheless, the introduction of Article 121(1A) further intensified debates regarding the separation of judicial authority and the limits of civil court intervention in Syariah matters. Former Chief Justice of Malaysia, Abdul Hamid Mohamad, observed that the conflict between Syariah and civil jurisdictions does not arise solely from attempts by the civil courts to interfere with the jurisdiction of the Syariah courts. Rather, it is also caused by the tendency of State legislative bodies to enact laws that exceed or contravene the constitutional limits prescribed by the FC.[1]

Thus, this paper argues that although Malaysia’s dual legal system of civil and Syariah law is constitutionally structured to operate in parallel under the FC, conflicts persist due to inconsistencies in state Syariah enactments. The article proceeds as follows: Section II discusses on the issue of conversion of minor to Islam, and Section III examines on apostasy matters.

Conflict of Laws: Conversion of Minor to Islam

The conversion of minors to Islam has caused confusion between civil and Syariah courts, as their rulings have contradicted each other. These two laws are enforced by Syariah courts and civil courts respectively. The common issue arisen when one of the spouses converts to Islam and unilaterally converts the children to Islam as well.[2] As a result, the child custody is granted by Syariah court to that converted spouse although marriage is essentially of a civil nature.

Legal Framework in relation to Conversion of Minor

Pursuant to Article 12(4) of FC, the religion of a minor (individual below 18-year-old) shall be determined by their parent or guardian. The issue had been raised when it comes to the interpretation of “parent”. Furthermore, according to the Eleventh Schedule of the FC, words in the singular include the plural, and words in the plural include the singular. Thus, the word “parent” should be regarded as plural form as well although the term used in Article 12(4).[3] In other words, the consent of both parents is required for conversion of minor.

Despite that, conversion of minor to Islam is governed under States Administration of Islamic Law Enactment. However, state laws are not uniform. There are some states requiring the consent of only one of the parents (see Table 1). For Kelantan, requirement for consent of parent for a minor’s conversion is not provided.[4]

Table 1: States’ Requirement of Parental Consent in Conversion of Minor to Islam

State	Conversion of Minor to Islam
Melaka	Consent of one parent or guardian suffice
Negeri Sembilan
Johor
Perak
Kedah
Perlis
Sarawak, Sabah
Federal Territories
Penang	Consent of both parents or guardians is required
Pahang
Selangor
Terengganu

Case Laws’ Perspective on Matter of Conversion of Minor

(a) Shamala Sathiyaseelan v Dr. Jayaganesh & Anor

The wife requested the court to declare the conversion of her two minor children to Islam invalid, arguing that the conversion was not with her consent. She further argued that, under Article 12(4) of FC, she had the right to decide the religious beliefs of her two minor children. Also, she pointed out that the term “parents” in Article 12(4) necessarily refers to both living parents. However, Faiz Tamby Chik J held a different view. The learned judge provided as followed:

Where the language of a statute is plain and explicit, effect must be given to its ordinary grammatical meaning, applying the plain meaning rule, …. Accordingly, the expression “parent or guardian” in its singular form denotes that the consent of either one parent or a guardian is sufficient, unless the statute expressly requires otherwise.[5]

(b) Landmark Case: Indira Gandhi Mutho v Pengarah Jabatan Agama Islam Perak & Ors and Other Appeals

The material facts states that there was a Hindu father converted to Islam and, without the mother’s knowledge or consent, converted his children as well. He subsequently gained custody of the children from Syariah court. The mother, Indira, then applied to civil court to set aside the father’s unilateral conversion. This has resulted in the High Court granting Indira the full custody. A conflict between the Syariah and civil courts’ decision occurred.

The Federal Court in this case established a significant precedent. It set aside the husband’s unilateral conversions of his children and held that under the constitutional guarantee to equality, consent of both parents is a prerequisite before the religion of minor can be changed. In interpretating Article 12(4) of FC, the Court held that consent from both parents is necessary. The Court refused to interpret Article 12(4) literally and stated as follows:

A purposive reading of Article 12(4) that promotes the welfare of the child and is consistent with good sense would require the consent of both parents (if both are living) for the conversion of a minor child.[6]

Additionally, the Court further held that Syariah court would, if a party in the suit is non-Muslim, have no jurisdiction even the case falling within the permitted areas of its jurisdiction in State List. The court highlighted that this was to preserve non-Muslim’s right to fair trial, as they lack the locus standi before Syariah court and would be unable to defend themselves.

Table 2: Analysis of Court’s Judgement

Case	Principle
Shamala (2004)	Article 12(4) provides for singular word “parent”.
Subashini a/p Rajasingam[7]	The consent of either parent is sufficient to satisfy the legal requirement for consent.
Indira Gandhi (2018)	The word “parent” in Article 12(4) means “parents”.
Rosliza bt Ibrahim (2021)[8]	Referring Indira Gandhi’s case, the father had no legal right to convert Rosliza to Islam unilaterally during her minority without obtaining the consent of her mother.
Loh Siew Hong (2025) [9]	Referred to and followed principles in Indira Gandhi’s case. The conversion of the minor children by the father alone, in the absence of the mother’s consent, was declared void.

As observed, the evolving trend in Malaysian judicial decisions pre-Indira Gandhi case regarding this issue has been “one parent’s consent” rather than “both parents” consent” (see Table 2). The civil courts determined that the consent of a single parent suffices for a child to officially convert to Islam. This trend continued until the Federal Court’s decision in Indira Gandhi. The implication of Indira Gandhi’s case is significant, where Loh case in 2025 clearly reinforced its decision.[10] This shows that Indira Gandhi in 2018 is still a good precedent and is applicable to all States.

Recent Controversy: Conflict Persists

Regretfully, despite famous Federal Court decision in Indira Gandhi, the conflict between civil law and State Syariah enactments remains in practice. Several State Administration Enactments still allows unilateral conversion of minors based on the consent of only one parent. Such continuing conflict can be seen in the recent legal challenge filed by Indira Gandhi and 13 other people to nullify provisions relating to unilateral conversion in Johor, Perlis, Melaka, Kedah, Negeri Sembilan, Perak and the Federal Territories.[11] However, the High Court dismissed the case in June 2026 due to lack of locus standi.

This present event evidenced that the conflict in terms of conversion of minor persists until today despite famous Indira Gandhi’s case in 2018. This is because most states’ laws still allow for unilateral conversion of a child below the age of 18 years. These are inconsistent with constitutional position of Article 12(4) of FC and also contradict established Federal Court precedent.

III. Constitutional Rights in tension within Dual Legal System: Apostasy Matter

Malaysia is a multiracial country with multiple religions are being practiced (see Figure 2). Therefore, religious freedom is enshrined in the Constitution since Merdeka to preserve the harmony of Malaysia.

Figure 2: Distribution of Population based on Religion (Source: 2026 Department of Statistics Malaysia)

Fundamental Principle in Islam

Freedom of belief has consistently been recognised as a principle under Syariah.[12] Accordingly, every individual is at liberty to choose the faith he wishes to profess, and no person may be compelled to embrace any religion. This is provided in Al Baqarah 2:256, where it states: “Let there be no compulsion in religion”. Forcing non-believers to convert is not allowed.

Most importantly, in the religion of Islam, individual who has accepted Islam as his religion is prohibited from returning to his former religion. In simple words, every Muslim should be a Muslim forever as Hadith has made it clear: “Any person who has changed his religion, kill him”. 

Freedom of Religion in Malaysia’s Constitution

Article 11(1) of FC has expressly provided citizens with freedom of religion. It stipulates that “Every person has the right to profess and practice his religion”. Religious freedom is rooted in an individual’s ability to select their religious beliefs freely. Paradoxically, in the FC, Article 160(2) defines “Malay” as an individual who professes the religion of Islam. This raises the concern of freedom of religion as the law effectively links an ethnic identity with religion and imposes a belief on the group that is not based on personal choice.[13]

States’s Syariah Enactment Criminalising Apostasy

Apostasy is a crime in some States in Malaysia. By virtue of Article 74(2), there are states which have enacted legislation to criminalise Muslims’ conversion. In regard to this, it is also worth to mention that the concern of equality may arise due to unstandardised punishment for apostasy in each state.

The scope of the fundamental protection in Article 11 has been limited by States in criminalising apostasy. While apostasy is not punishable by death penalty on apostates in Malaysia, they may, in some states, still subject to legal consequences such as fine or imprisonment. This seems to be contrary to the religious freedom guaranteed by Article 11(1) of FC.[14] These provisions have also drawn criticism from human rights advocates, who argued that it is a violation to constitutional protections of individual and religious freedom.[15] In this context, reference to cases in relation to apostasy matter should be made.

Courts’ Perspective on Conversion out of Islam

The issue has been raised in civil courts, yet there are decisions holding that the issue of conversion out of Islam is a matter within Syariah Courts under Article 121(1A) of FC and not a matter under Article 11(1). However, in the context of conflict of laws, the issue should be discussed beyond jurisdictional questions when freedom of religion, as a constitutionally protected freedom, may be denied. Lawyer-activist Malik Imtiaz Sarwar also noted that FC does not provide for apostasy to be regulated by Syariah courts.[16] Therefore, the main question is whether Muslims have the right to renounce Islam as part of their freedom of religion. In Nordin Salleh, the court provided that courts should lean in favour of the fundamental rights guaranteed by the Constitution, because these rights enjoy precedence.[17] From these wordings, it can be argued that restrictions should not be imposed on religious practices.[18] Hence, issue of apostasy in Malaysia is complex. Whenever religious conversion case is presented to Court, the concern of constitutional and human rights will be raised. On the other hand, the role of Islam as country’s religion as prescribed in Article 3, will be considered as well.[19]

Over time, Malaysian courts have handled numerous cases involving apostasy with varying verdicts. In Lina Joy, the plaintiff applied to have the word “Islam” removed from her IC, contending that Article 11 entitled her to freely choose her religion.[20] The court, however, ruled that the religious freedom under Article 11(1) must be interpreted in conjunction with Article 3, which accords Islam a unique constitutional status. Article 11(1) does not grant the plaintiff unrestricted freedom to choose any religion, and it is subject to Articles 11(4) and 11(5). The Federal Court held that the plaintiff could not rely on Article 11(1) before resolving the matter of renouncing Islam. Notably, Justice Richard Malanjum FCJ in this case had made a mindful dissenting judgement. He stated that Article 3(1) never intended to override any right in FC by virtue of the wordings in Article 3(4).

Similarly, in Rosliza, the court stated that one cannot unilaterally renounce faith of Islam. This would constitute an offence under law.[21] In addition to this, in Ketua Pegawai Penguatkuasa Agama & Ors v Maqsood Ahmad & Ors and another appeal, the court had reaffirmed that the freedom of religion to non-Muslims does not apply to Muslims with equal force.[22]

Therefore, referring to abovementioned judicial decision, it can be concluded that there is no absolute freedom of religion for Muslim despite the ruling in Nordin Salleh. Regardless the rights to freedom of religion guaranteed under Article 11(1), it is not true for the Muslim.[23] Most importantly, the issue of conflict remains unresolved as there appears to be inconsistencies between State legislations that punish conversion out of Islam and Constitution.[24] 

Figure 3: Registered and Withdrawn Cases for Declaration of Religious Status in Selangor (2020 to 2024)

(Source: Portal Rasmi Dewan Negeri Selangor)

The data shows that a total of 24 applications for religious status declarations were withdrawn between 2020 and 2024 (see Figure 3). Such withdrawal further suggests the barriers faced by applicants seeking to convert out of Islam despite the constitutionally guaranteed religious freedom.

Conclusion

Malaysia operates under a dual legal system of Syariah law and civil law, reflecting the country’s cultural values ​​and worldview. As a society with three main ethnic groups and diverse religious traditions, tolerance and mutual respect must take precedence over homogeneity. In this way, Malaysia may maintain its unique identity as a melting pot of cultures.

However, the relationships between the Syariah and civil law within the framework of our present legal system have been hazy. It is respectfully submitted that jurisdictional conflicts, in fact, will not arise if legislatures and state legislatures strictly adhere to the Federal and State lists when enacting laws. Such conflicts are inevitable if state legislatures overstep their authority and enact laws beyond the jurisdiction of Parliament. Regretfully, such state laws do exist, particularly in the area of criminal law.

Based on this, it must be recognised that such disputes cannot be resolved solely through individual case rulings. Accordingly, meaningful reform requires a practical mechanism to improve coherence between the civil and Syariah judicial frameworks. In this regard, proposals such as cross-disciplinary judicial training have become especially relevant. This is because judges in Syariah courts must be able to uphold fairness towards all parties.[25] In so doing, the principles expounded in the Quran may be uphold, where it states in An-Nisaa 4:58 as follow:

Allah has commanded you to render back your trusts to those to whom they are due and when you judge between mankind that you judge with justice. Verily how excellent is the teaching which he gives vou.  For Allah is He who hears and sees all things.

Referenc(S):

Cases

Dewan Undangan Negeri Kelantan v Nordin Salleh [1992] 1 MLJ 697.

Indira Gandhi Mutho v Pengarah Jabatan Agama Islam Perak & Ors and Other Appeals [2018] 2 MLRA 1.

Ketua Pegawai Penguatkuasa Agama & Ors v Maqsood Ahmad & Ors and another appeal [2021] 1 MLJ 120.

Lina Joy v Majlis Agama Islam Wilayah Persekutuan & Anor [2007] 3 MLJ 557.

Pendaftar Mualaf Negeri Perlis & Ors v Loh Siew Hong and Another Appeal [2025] 1 ShLR 1.

Rosliza bt Ibrahim v Kerajaan Negeri Selangor & Anor [2021] 2 MLJ 181.

Subashini a/p Rajasingam v Saravanan a/l Thangathoray [2007] 2 MLJ 798.

Shamala Sathiyaseelan v Dr. Jayaganesh & Anor [2004] 2 MLJ 648.

Legislation

Federal Constitution (Malaysia).

Secondary Sources

Ahmad NM, ‘Jurisdictional Conflict between Syariah and Civil Laws in Iki Putra Case: The Way Forward for Malaysian Legal System’ <https://oarep.usim.edu.my/server/api/core/bitstreams/82af1207-1902-4737-b59d-3490d51152b1/content> accessed 23 June 2026.

Azam M, ‘Is Unilateral Conversion the Best Solution?’ (NST Online26 August 2019) <https://www.nst.com.my/opinion/columnists/2019/08/516228/unilateral-conversion-best-solution> accessed 19 May 2026.

bin Abdullah MA, ‘Analyzing the Dynamics between Sharia Law and Civil Law in Governing Divorce Proceedings among Muslims in Malaysia and Comparing Legal Outcomes’ (2024) 3 Law and economy 29.

Choong DKA, ‘The Conflation of Ethnicity and Religion: The Malaysian Constitution Revisited’ (The Conflation of Ethnicity and Religion: The Malaysian Constitution Revisited30 November 2012).

Department of Statistics Malaysia, ‘Kawasanku | OpenDOSM’ (OpenDOSMOctober 2025) <https://open.dosm.gov.my/dashboard/kawasanku> accessed 23 June 2026.

Dewan Negeri Selangor, ‘KES MURTAD ATAU KELUAR DARI ISLAM DARI TAHUN 2020-2024 | Dewan Negeri Selangor’ (Dewan Negeri SelangorNovember 2024) <https://dewan.selangor.gov.my/question/kes-murtad-atau-keluar-dari-islam-dari-tahun-2020-2024/> accessed 23 June 2026.

Khairulrijal R, ‘Court to Decide Indira Gandhi Challenge on Unilateral Child Conversion on May 21’ (NST Online3 February 2026) <https://www.nst.com.my/news/nation/2026/02/1370455/court-decide-indira-gandhi-challenge-unilateral-child-conversion-may-21?source=widget> accessed 19 May 2026.

Krishnan L, ‘THE ANTITHESIS between CIVIL LAW and ISLAMIC LAW in a PLURALISTIC SOCIETY’ (2026) 18 Jurnal Syariah 401 <https://ejournal.um.edu.my/index.php/JS/article/view/22669> accessed 19 May 2026.

Lim I, ‘Lawyers: Change State Islamic Laws to Match Proposed Unilateral Child Conversion Ban’ (Malay Mail 10 December 2016) <https://www.malaymail.com/news/malaysia/2016/12/11/lawyers-change-state-islamic-laws-to-match-proposed-unilateral-child-conver/1269459> accessed 19 May 2026.

Malaysian Bar, ‘Press Release: Unilateral Conversions of Minor Children Are Unconstitutional – the Malaysian Bar’ (Malaysianbar.org.my2013) <https://www.malaysianbar.org.my/article/news/press-statements/press-statements/press-release-unilateral-conversions-of-minor-children-are-unconstitutional> accessed 23 June 2026.

Mohamed Adil MA, WAN MANSOR WN and MOHD AMIN A, ‘View of the Right to Freedom of Religion and Jurisdictional Conflicts in Malaysia’ (Spaj.ukm.my2023) <https://spaj.ukm.my/sinergi/index.php/sei/article/view/63/88> accessed 23 June 2026.

Mohamed Azam MA, ‘Punishment for Apostasy : Conflict between the Right to Freedom of Religion and Criminal Sentence, a Case Study in Malaysia / Mohamed Azam Mohamed Adil – UiTM Institutional Repository’ [2005] Uitm.edu.my <https://ir.uitm.edu.my/id/eprint/11531/> accessed 23 June 2026.

Musa R and others, ‘APOSTASY PUNISHMENT in ISLAMIC SCHOLARLY DISCOURSE: PERSPECTIVES and IMPLICATIONS in the MALAYSIAN CONTEXT’ (2025) 13 Malaysian Journal of Syariah and Law 637 <https://www.researchgate.net/publication/399037399_APOSTASY_PUNISHMENT_IN_ISLAMIC_SCHOLARLY_DISCOURSE_PERSPECTIVES_AND_IMPLICATIONS_IN_THE_MALAYSIAN_CONTEXT> accessed 23 June 2026.

Noor ’Ashikin H, Maheran M and Abdul Majid Hafiz M, ‘Right to Change the Religion in Malaysia’.

Rajanthiran RS, ‘THE IMPACT of ART. 121 (1A) 1988 on ART. 11 – the FREEDOM of RELIGION in the FEDERAL CONSTITUTION of MALAYSIA: THE APOSTASY CASE of LINA JOY’ (2017) 26 SEJARAH 117.

Penang State Sharia Justice Department, ‘Recent Developments in Shariah Law in Malaysia’ <https://jksnpp.penang.gov.my/index.php/en/component/content/article/91-recent-developments-in-shariah-law-in-malaysia?catid=18:penerbitan-mahkamah&Itemid=101> accessed 23 June 2026.

Rusli N and Kadir FK, ‘The Challenges Encountered by Mualaf after Conversion to Islam: A Study on the Apostasy (Murtad) Cases in Malaysia’ [2022] International Journal of Academic Research in Business and Social Sciences.

Safei S and others, ‘Judicial Trend in Relation to Unilateral Conversion of Minor Children to Islam: An Analysis of Recent Cases in Malaysia’ (2025) 9 International Journal of Research and Innovation in Social Science 6197 <https://rsisinternational.org/journals/ijriss/article.php?id=1944> accessed 19 November 2025.

Samuri MAA and Quraishi M, ‘Negotiating Apostasy: Applying to “Leave Islam” in Malaysia’ (2014) 25 Islam and Christian–Muslim Relations 507.

Sebastian ML, ‘APOSTASY as a CRIME in MALAYSIA’ (www.linkedin.com2023) <https://www.linkedin.com/pulse/apostasy-crime-malaysia-matthew-levi-sebastian-lejwc/> accessed 23 June 2026.

Shariffuddin N, Mohd Padil H and Abd Samad S, ‘APOSTASY: PERSONAL RIGHTS GUARANTEED?’ [2022] International Conference of Law, Accounting & Finance ICLAF 2022 <https://ir.uitm.edu.my/id/eprint/133194/1/133194.pdf> accessed 23 June 2026.

[1] Nisar Mohammad Ahmad, ‘Jurisdictional Conflict between Syariah and Civil Laws in Iki Putra Case: The Way Forward for Malaysian Legal System’ <https://oarep.usim.edu.my/server/api/core/bitstreams/82af1207-1902-4737-b59d-3490d51152b1/content> accessed 23 June 2026.

[2] Mohamed Azam Mohamed Adil, WAN NAIM WAN MANSOR and AZRIL MOHD AMIN, ‘View of the Right to Freedom of Religion and Jurisdictional Conflicts in Malaysia’ (Spaj.ukm.my2023) <https://spaj.ukm.my/sinergi/index.php/sei/article/view/63/88> accessed 23 June 2026.

[3] Malaysian Bar, ‘Press Release: Unilateral Conversions of Minor Children Are Unconstitutional – the Malaysian Bar’ (Malaysianbar.org.my2013) <https://www.malaysianbar.org.my/article/news/press-statements/press-statements/press-release-unilateral-conversions-of-minor-children-are-unconstitutional> accessed 23 June 2026.

[4] Mohamed Azam, ‘Is Unilateral Conversion the Best Solution?’ (NST Online26 August 2019) <https://www.nst.com.my/opinion/columnists/2019/08/516228/unilateral-conversion-best-solution> accessed 19 May 2026.

[5] Shamala Sathiyaseelan v Dr. Jayaganesh & Anor [2004] 2 MLJ 648 [6].

[6] Indira Gandhi Mutho v Pengarah Jabatan Agama Islam Perak & Ors and Other Appeals [2018] 2 MLRA 1 [164].

[7] Subashini a/p Rajasingam v Saravanan a/l Thangathoray [2007] 2 MLJ 798.

[8] Rosliza bt Ibrahim v Kerajaan Negeri Selangor & Anor [2021] 2 MLJ 181.

[9] Pendaftar Mualaf Negeri Perlis & Ors v Loh Siew Hong and Another Appeal [2025] 1 ShLR 1.

[10] Su’aida Safei and others, ‘Judicial Trend in Relation to Unilateral Conversion of Minor Children to Islam: An Analysis of Recent Cases in Malaysia’ (2025) 9 International Journal of Research and Innovation in Social Science 6197 <https://rsisinternational.org/journals/ijriss/article.php?id=1944> accessed 19 November 2025.

[11] Rahmat Khairulrijal, ‘Court to Decide Indira Gandhi Challenge on Unilateral Child Conversion on May 21’ (NST Online3 February 2026) <https://www.nst.com.my/news/nation/2026/02/1370455/court-decide-indira-gandhi-challenge-unilateral-child-conversion-may-21?source=widget> accessed 19 May 2026.

[12] H Noor ’Ashikin, M Maheran and M Abdul Majid Hafiz, ‘Right to Change the Religion in Malaysia’.

[13] Dr Kartina A Choong, ‘The Conflation of Ethnicity and Religion: The Malaysian Constitution Revisited’ (The Conflation of Ethnicity and Religion: The Malaysian Constitution Revisited30 November 2012).

[14] Mohamed Adil Mohamed Azam, ‘Punishment for Apostasy : Conflict between the Right to Freedom of Religion and Criminal Sentence, a Case Study in Malaysia / Mohamed Azam Mohamed Adil  – UiTM Institutional Repository’ [2005] Uitm.edu.my <https://ir.uitm.edu.my/id/eprint/11531/> accessed 23 June 2026.

[15] N Rusli and FK Kadir, ‘The Challenges Encountered by Mualaf after Conversion to Islam: A Study on the Apostasy (Murtad) Cases in Malaysia’ [2022] International Journal of Academic Research in Business and Social Sciences.

[16] R Sivaperegasam P. Rajanthiran, ‘THE IMPACT of ART. 121 (1A) 1988 on ART. 11 – the FREEDOM of RELIGION in the FEDERAL CONSTITUTION of MALAYSIA: THE APOSTASY CASE of LINA JOY’ (2017) 26 SEJARAH 117.

[17] Dewan Undangan Negeri Kelantan v Nordin Salleh [1992] 1 MLJ 697.

[18] Loganathan Krishnan, ‘THE ANTITHESIS between CIVIL LAW and ISLAMIC LAW in a PLURALISTIC SOCIETY’ (2026) 18 Jurnal Syariah 401 <https://ejournal.um.edu.my/index.php/JS/article/view/22669> accessed 19 May 2026.

[19] Mohamed Azam Mohamed Adil, WAN NAIM WAN MANSOR and AZRIL MOHD AMIN, ‘View of the Right to Freedom of Religion and Jurisdictional Conflicts in Malaysia’ (Spaj.ukm.my2023) <https://spaj.ukm.my/sinergi/index.php/sei/article/view/63/88> accessed 23 June 2026.

[20] Lina Joy v Majlis Agama Islam Wilayah Persekutuan & Anor [2007] 3 MLJ 557.

[21] Rosliza (n 8) [88].

[22] Ketua Pegawai Penguatkuasa Agama & Ors v Maqsood Ahmad & Ors and another appeal [2021] 1 MLJ 120 [118].

[23] Norashikin Shariffuddin, Hazlina Mohd Padil and Suhaimi Abd Samad, ‘APOSTASY: PERSONAL RIGHTS GUARANTEED?’ [2022] International Conference of Law, Accounting & Finance ICLAF 2022 <https://ir.uitm.edu.my/id/eprint/133194/1/133194.pdf> accessed 23 June 2026.

[24] Matthew Levi Sebastian , ‘APOSTASY as a CRIME in MALAYSIA’ (www.linkedin.com2023) <https://www.linkedin.com/pulse/apostasy-crime-malaysia-matthew-levi-sebastian-lejwc/> accessed 23 June 2026.

[25] Penang State Sharia Justice Department, ‘Recent Developments in Shariah Law in Malaysia’ <https://jksnpp.penang.gov.my/index.php/en/component/content/article/91-recent-developments-in-shariah-law-in-malaysia?catid=18:penerbitan-mahkamah&Itemid=101> accessed 23 June 2026.