PENDAKWA RAYA Pendakwa Raya TERTUDUH 1. ) SADAM HUSAIN BIN USTAZ AHMAD NABI 2. ) MOHD AMIRUL ASRAF BIN ABU BAKAR 3. ) WALIZA BIN SADAT GUL

ja-45a-153-12-2022 High Court (Mahkamah Tinggi) 31 March 2026 • JA-45A-153-12/2022 • 70 min read
14 cases cited (0 SG, 14 foreign)

Catchwords

CRIMINAL LAW: Drug trafficking – Charge under s. 39B(1)(a) Dangerous Drugs Act 1952 – Elements of offence – Whether prosecution required to establish that substance was a dangerous drug, that accused was in possession, and that accused was trafficking – Proof of trafficking by direct evidence of conduct falling within definition in s. 2 Dangerous Drugs Act 1952 – Trafficking established alternatively through statutory presumption under s. 37(da) Dangerous Drugs Act 1952 upon proof of possession exceeding prescribed threshold weight CRIMINAL LAW: Drug trafficking – Possession – Actual possession established by direct evidence – Physical element of custody or control – Mental element of knowledge of existence of the drug – Whether proximity alone sufficient to establish possession – Whether named tenant of premises constructively in possession of all items found therein – Whether tenancy status determinative of constructive possession CRIMINAL LAW: Drug trafficking – Statutory presumption of trafficking – Double presumption rule – Whether prosecution permitted to rely on presumption of possession under s. 37(d) Dangerous Drugs Act 1952 in order to trigger presumption of trafficking under s. 37(da) of the same Act – Whether possession must first be established by independent evidence before trafficking presumption may be engaged CRIMINAL LAW: Drug trafficking – Common intention – Charge under s. 39B(1)(a) Dangerous Drugs Act 1952 read with s. 34 Penal Code – Elements of common intention – Whether prosecution required to prove pre-arranged plan directed at specific offence charged – Whether common intention may be inferred from surrounding circumstances and conduct – Whether mere presence at premises sufficient to establish liability under s. 34 Penal Code CRIMINAL LAW: Possession of scheduled poison – Charge under s. 30(3) Poisons Act 1952 – Distinction between possession offence under Poisons Act 1952 and trafficking offence under Dangerous Drugs Act 1952 – Whether prosecution required to establish trafficking element for Poisons Act offence – Whether same legal framework for possession applies to both Acts CRIMINAL PROCEDURE: Prima facie case – Duty of court at close of prosecution's case – Maximum evaluation under s. 180(1) Criminal Procedure Code – Whether court required to make positive assessment of credibility of prosecution witnesses – Whether evidence emerging from cross-examination of prosecution witnesses to be considered – Whether court may draw inferences favourable to prosecution to fill gaps in its own case – Whether where prosecution evidence admits of two or more inferences court duty-bound to draw inference most favourable to accused EVIDENCE: Adverse inference – Failure to call material witness – Whether failure by prosecution to call witnesses present during raid and body search justified drawing of adverse inference under s. 114(g) Evidence Act 1950 – Whether uncorroborated evidence of single police witness on central issue sufficient where corroborating witnesses available but not called – Whether prosecution's failure to call landlord's employee with direct knowledge of who occupied premises a material omission EVIDENCE: Chemist evidence – Challenge to scientific evidence – Whether failure to tender calibration records for laboratory equipment affected admissibility or weight of chemist's findings – Integrity of exhibits

Judges (1)

Counsel (12)

Parties (4)

Statutes Cited

Dangerous Drugs Act 1952
s 39B(1)(a)
Poisons Act 1952
s 30(3)

Cases Cited (14)

MY (14)
[1949] 1 MLJ 54 [1956] 22 MLJ 237 [1956] MLJ 28 [1987] 1 CLJ 540 [1995] 2 MLJ 433 [1998] 2 MLJ 273 [2002] 3 MLJ 401 [2003] 1 CLJ 734 [2004] 4 CLJ 551 [2005] 1 CLJ 85 [2006] 1 CLJ 457 [2009] 1 CLJ 717 [2011] 4 CLJ 113 [2016] 9 MLJ 133

Judgment

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Source: eJudgment (ja-45a-153-12-2022)