Bulletin_30

CLJ Bulletin, Issue 2011, Vol 30

5 August 2011

CLJ Law Malaysia

http://www.cljlaw.com

Introduction:
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New This Week	1. Legislation Highlights
	2. Articles
	a) Legal Network Series Articles
	3. Latest Cases
	a) Legal Network Series
	b) CLJ Volume 6 (Part 1) 2011

1. Legislation Highlights

Principal Acts

NUMBER
TITLE

DATE COMING INTO FORCE

REPEALING

ACT 723 Price Control And Anti-Profiteering Act 2011 1 April 2011 [PU(B) 146/2011] - Nil -

ACT 724 National Visual Arts Development Board Act 2011 Not Yet In Force - Nil -

ACT 725 Renewable Energy Act 2011 Not Yet In Force - Nil -

ACT 726 Sustainable Energy Development Authority Act 2011 Not Yet In Force - Nil -

ACT 727 Food Analysts Act 2011 Not Yet In Force - Nil -

Amending Acts

NUMBER
TITLE

DATE COMING INTO FORCE

AMENDING

ACT A1391 Road Transport (Amendment) Act 2011 31 January 2011 [PU(B) 37/2011] ACT 333

ACT A1392 Supplementary Supply (2010) Act 2011 3 June 2011 ACT A1361

ACT A1393 Merchant Shipping (Amendment And Extension) Act 2011 Not Yet In force ORD 70/1952

ACT A1394 Merchant Shipping (Oil Pollution) (Amendment) Act 2011 Not Yet In force ACT 515

ACT A1395 Arbitration (Amendment) Act 2011 1 July 2011 [PU(B) 342/2011] ACT 646

PU(A)

NUMBER TITLE DATE COMING INTO FORCE
PRINCIPAL ACT NO

PU(A) 246/2011 Insurance (Exemption) (No 2) Order 2011 20 July 2011 ACT 553

PU(A) 247/2011 Factories And Machinery (Exemption To Polypropylene (M) Sdn Bhd, Kuantan, Pahang) Order 2011 21 July 2011 ACT 139

PU(A) 248/2011 Registration Of Pharmacist (Amendment Of Second Schedule) Order 2011 - Corrigendum 21 July 2011 ACT 371

PU(A) 249/2011 Customs (Values) (Palm Oil) (No 30) Order 2011 25 July 2011 ACT 235

PU(A) 250/2011 Child Care Centre (Compounding Of Offences) Regulations 2011 26 July 2011 ACT 308

PU(B)

NUMBER TITLE DATE COMING INTO FORCE
PRINCIPAL ACT NO

PU(B) 363/2011 Appointment Of Member Of Pardons Board For Security Offences 8 July 2011 ACT 000

PU(B) 364/2011 Notification Of Exemption Under Section 11e 8 July 2011 ACT 371

PU(B) 365/2011 Declaration Of Dangerous Pest 2011 8 July 2011 ACT 167

PU(B) 366/2011 Notification Of The Certificate Of Approval Under Section 15 8 July 2011 ACT 367

PU(B) 367/2011 Temporary Exercise Of Ministerial Functions 25 July 2011 ACT 388

Bills

NUMBER TITLE DATE COMING INTO FORCE
PRINCIPAL ACT NO

DR 20/2011 Money Services Business Bill 2011 - -

DR 21/2011 Federal Agricultural Marketing Authority (Amendment) Bill 2011 - ACT 141

DR 22/2011 Lembaga Kemajuan Ikan Malaysia (Amendment) Bill 2011 - ACT 49

DR 23/2011 Fisheries (Amendment) Bill 2011 - ACT 317

DR 24/2011 Domestic Violence (Amendment) Bill 2011 - ACT 521

2. Articles

a) Legal Network Series Articles

1. Non Verbal Communication And Mediation* ^{[Read
excerpt]}
By Joel Lee, Assoc Prof, Faculty Of Law, National University Of Singapore**

2. Best Practice Responding To Allegations Of Misconduct With Frankness And
Candour - Rule 39 Legal Profession (Solicitors) Rules 2007 ^{[Read excerpt]}
By Rob Reis, Professional Standards Director, ACT Law Society*

3. Latest Cases

a) Legal Network Series

CITATION TITLE SUBJECT

[2009] 1 LNS 1724 [HC] Spectra Chemicals (M) Sdn Bhd v. Trimech Engineering (M) Sdn Bhd

CIVIL PROCEDURE: Injunction - Erinford injunction - Application by plaintiff to preserve status quo - Pending appeal to Court of Appeal against decision of High Court dismissing plaintiff's action - Damages not an adequate remedy - Appeal, if successful, would be rendered nugatory - Balance of convenience - Jurisdiction of High Court to grant after having dismissed plaintiff's action - Whether High Court already functus officio - Whether Erinford injunctions are interlocutory and cannot be granted after final disposal of action - Whether application for Erinford injunction is in the nature of an original motion

[2009] 1 LNS 1729 [HC] Low Poh Chin v. Low Poh Yoke & Anor

PARTNERSHIP: Accounts - Dissolution of partnership - Claim by one partner against another - Proof - Cost of machinery - Invoices - Claim for loss of investment - Claim for loss of machinery - Claim for loss of profit

PARTNERSHIP: Liabilities of partners - Accountability of partners for private profits - Duty of partner not to compete with firm - Partnership Act 1961, ss. 31(1), 32

PARTNERSHIP: Liabilities of partners - Payments made by partner - Termination of services of business's employee's and payment of compensation - Unilateral action of one partner without knowledge of the other partner - Whether a payment made in ordinary and proper conduct of the business or for preservation of the business - Whether covered by s. 26(a) and (b) Partnership Act 1961

PARTNERSHIP: Termination - Suit for dissolution - Partnership Act 1961, s. 34(2)

[2009] 1 LNS 1732 [HC] Mahsan Abdullah & Ors v. Perusahaan Langat Sdn Bhd & Ors

CONTRACT: Sale and purchase of property - Consideration - Sufficiency and adequacy

CIVIL PROCEDURE: Pleadings - Parties bound by pleadings - Issues not pleaded in statement of defence - Whether can be considered by court

LAND LAW: Conveyancing - Sale of property - Caveat - Plaintiffs failing to lodge caveat despite being represented by solicitors in purchase of subject property from 1^st defendant - 2^nd and 3^rd defendants purchasing subject property from 1^st defendant without notice of plaintiffs' interest - Whether there was fraud or collusion by defendants - Whether 1^st defendant (in winding-up) could execute memorandum of transfer in favour of 2^nd and 3^rd defendants - Failure of 1^st defendant's provisional liquidators to register order of appointment - Companies Act 1965, s. 233 - National Land Code 1965, ss. 340, 414, 415 - Whether 2^nd and 3^rd defendants were bona fide purchasers for value without notice of plaintiffs' interest - Indefeasibility of 2^nd and 3^rd defendants' title as registered proprietors and interest of 4^th defendant as chargee bank

[2009] 1 LNS 1733 [HC] KVC Industrial Supplies Sdn Bhd v. Bekal Hikmat Sdn Bhd
SALE OF GOODS: Unpaid seller - Claim for goods sold and delivered - Plaintiff delivering parts allegedly purchased by defendant to third party's premises - Defendant alleging that parts were fraudulently ordered by third party - Whether purchase order (on letterhead) emanated from defendant - Whether defendant's staff who issued purchase order an agent of third party or on third party's payroll - Delivery address on purchase order - Effect of MOU between defendant and third party - Whether plaintiff entitled to enter summary judgment

[2009] 1 LNS 1734 [HC] Kasinathar Balendra Thuraisingham v. Affin Bank Berhad
LEGAL PROFESSION: Practice of law - Partnership between solicitors - Power of partner to bind firm - Whether plaintiff's partner had authority to deal with stakeholder moneys - Whether defendant bank knew partner had no authority or did not believe he was a partner - Allegation of fraud and negligence against defendant bank not particularised - Claim by plaintiff for indemnity from defendant bank - Application by defendant bank to strike out plaintiff's statement of claim under O. 18 r. 19(1)(b) or (d) Rules of the High Court 1980 - Partnership Act 1961, ss. 7, 8, 10

CITATION	TITLE	SUBJECT
[2009] 1 LNS 1724 [HC]	Spectra Chemicals (M) Sdn Bhd v. Trimech Engineering (M) Sdn Bhd	CIVIL PROCEDURE: Injunction - Erinford injunction - Application by plaintiff to preserve status quo - Pending appeal to Court of Appeal against decision of High Court dismissing plaintiff's action - Damages not an adequate remedy - Appeal, if successful, would be rendered nugatory - Balance of convenience - Jurisdiction of High Court to grant after having dismissed plaintiff's action - Whether High Court already functus officio - Whether Erinford injunctions are interlocutory and cannot be granted after final disposal of action - Whether application for Erinford injunction is in the nature of an original motion
[2009] 1 LNS 1729 [HC]	Low Poh Chin v. Low Poh Yoke & Anor	PARTNERSHIP: Accounts - Dissolution of partnership - Claim by one partner against another - Proof - Cost of machinery - Invoices - Claim for loss of investment - Claim for loss of machinery - Claim for loss of profit PARTNERSHIP: Liabilities of partners - Accountability of partners for private profits - Duty of partner not to compete with firm - Partnership Act 1961, ss. 31(1), 32 PARTNERSHIP: Liabilities of partners - Payments made by partner - Termination of services of business's employee's and payment of compensation - Unilateral action of one partner without knowledge of the other partner - Whether a payment made in ordinary and proper conduct of the business or for preservation of the business - Whether covered by s. 26(a) and (b) Partnership Act 1961 PARTNERSHIP: Termination - Suit for dissolution - Partnership Act 1961, s. 34(2)
[2009] 1 LNS 1732 [HC]	Mahsan Abdullah & Ors v. Perusahaan Langat Sdn Bhd & Ors	CONTRACT: Sale and purchase of property - Consideration - Sufficiency and adequacy CIVIL PROCEDURE: Pleadings - Parties bound by pleadings - Issues not pleaded in statement of defence - Whether can be considered by court LAND LAW: Conveyancing - Sale of property - Caveat - Plaintiffs failing to lodge caveat despite being represented by solicitors in purchase of subject property from 1^st defendant - 2^nd and 3^rd defendants purchasing subject property from 1^st defendant without notice of plaintiffs' interest - Whether there was fraud or collusion by defendants - Whether 1^st defendant (in winding-up) could execute memorandum of transfer in favour of 2^nd and 3^rd defendants - Failure of 1^st defendant's provisional liquidators to register order of appointment - Companies Act 1965, s. 233 - National Land Code 1965, ss. 340, 414, 415 - Whether 2^nd and 3^rd defendants were bona fide purchasers for value without notice of plaintiffs' interest - Indefeasibility of 2^nd and 3^rd defendants' title as registered proprietors and interest of 4^th defendant as chargee bank
[2009] 1 LNS 1733 [HC]	KVC Industrial Supplies Sdn Bhd v. Bekal Hikmat Sdn Bhd	SALE OF GOODS: Unpaid seller - Claim for goods sold and delivered - Plaintiff delivering parts allegedly purchased by defendant to third party's premises - Defendant alleging that parts were fraudulently ordered by third party - Whether purchase order (on letterhead) emanated from defendant - Whether defendant's staff who issued purchase order an agent of third party or on third party's payroll - Delivery address on purchase order - Effect of MOU between defendant and third party - Whether plaintiff entitled to enter summary judgment
[2009] 1 LNS 1734 [HC]	Kasinathar Balendra Thuraisingham v. Affin Bank Berhad	LEGAL PROFESSION: Practice of law - Partnership between solicitors - Power of partner to bind firm - Whether plaintiff's partner had authority to deal with stakeholder moneys - Whether defendant bank knew partner had no authority or did not believe he was a partner - Allegation of fraud and negligence against defendant bank not particularised - Claim by plaintiff for indemnity from defendant bank - Application by defendant bank to strike out plaintiff's statement of claim under O. 18 r. 19(1)(b) or (d) Rules of the High Court 1980 - Partnership Act 1961, ss. 7, 8, 10

a. CLJ Volume 6 (Part 1) 2011

COURT

COURT OF APPEAL

Fernrite Sdn Bhd v. Perbadanan Nasional Bhd
Low Hop Bing, Syed Ahmad Helmy, Mohamed Apandi Ali JJCA
(Securities; Contract - Shares - Agreement - Whether defendant held shares on constructive trust for plaintiff) [2011] 6 CLJ 1 [CA]

Johan Properties Sdn Bhd v. Lee Yin Chuan & Ors
Zainun Ali, Abdul Wahab Patail, Clement Skinner JJCA
(Contract - Breach - Building contract) [2011] 6 CLJ 14 [CA]

PP v. Zainal Arpan Molana
Suriyadi Halim Omar, Abdul Wahab Patail JJCA, Linton Albert J
(Criminal Law; Evidence; Criminal Procedure - Dangerous Drugs Act 1952 - Section 39B(1)(a) - Trafficking - Information leading to fact discovered) [2011] 6 CLJ 28 [CA]

Zulpadli & Edham v. Inai Offshore & Marine Engineering Sdn Bhd (In Liquidation)
Sulaiman Daud, Jeffrey Tan, Zaharah Ibrahim JJCA
(Company Law; Legal Profession - Winding up - Remittance effected after presentation of winding up petition - Remuneration - Lien - Whether appellant entitled to a charge on property recovered or preserved) [2011] 6 CLJ 47 [CA]

HIGH COURT

Chong Siew Chiang v. Ng Kim Ho & Anor
Ravinthran Paramaguru JC
(Tort - Defamation - Libel and slander - Damages - Principles applicable) [2011] 6 CLJ 62 [HC]

Lim Giat Eng v. Farlim Group (M) Bhd
Noraini Abdul Rahman JC
(Contract; Labour Law; Tort - Employment contract - Breach - Dismissal) [2011] 6 CLJ 101 [HC]

Power Root (M) Sdn Bhd & Ors v. Ketua Pengarah Kastam
Aziah Ali J
(Revenue Law; Evidence - Sales tax - Assessment - Expert evidence - Analysis of products) [2011] 6 CLJ 114 [HC]

Raveendaran Chellaiah lwn. Subramaniam Ellaih
Umi Kalthum Majid PK
(Persatuan Tak Diperbadankan - Injunksi - Permohonan - Bantahan awal - Sama ada plaintif mempunyai locus standi) [2011] 6 CLJ 129 [HC]

SUBJECT INDEX

COMPANY LAW

Winding up - Payment by company to solicitors - Remittance effected after presentation of winding up petition - Whether in contravention of s. 223 Companies Act 1965 - Whether there was an order of validation or charging order - Whether entire remittance void
Zulpadli & Edham v. Inai Offshore & Marine Engineering Sdn Bhd (In Liquidation)
(Sulaiman Daud, Jeffrey Tan, Zaharah Ibrahim JJCA) [2011] 6 CLJ 47 [CA]

CONTRACT

Breach - Building contract - Sale and transfer of land - Defendant's failure to comply with the request of plaintiff for delivery of vacant possession of land - Whether there was wrongful repudiation or breach of agreement - Whether plaintiff failed to furnish performance bond within reasonable time - Whether learned judge erred in his findings
Johan Properties Sdn Bhd v. Lee Yin Chuan & Ors
(Zainun Ali, Abdul Wahab Patail, Clement Skinner JJCA) [2011] 6 CLJ 14 [CA]

Employment contract - Breach - Plaintiff absent from work for more than two consecutive days - Whether plaintiff breached contract of service - Whether plaintiff was present at site office - Whether defendant entitled to rely on Employment Act 1955, s. 15(2)
Lim Giat Eng v. Farlim Group (M) Bhd
(Noraini Abdul Rahman JC) [2011] 6 CLJ 101 [HC]

Shares - Agreement - Whether defendant held shares on constructive trust for plaintiff - Whether plaintiff could claim equity against defendant in respect of dividends received by defendant - Defendant did not pay purchase price - Whether retention of dividends by defendant amount to unjust enrichment
Fernrite Sdn Bhd v. Perbadanan Nasional Bhd
(Low Hop Bing, Syed Ahmad Helmy, Mohamed Apandi Ali JJCA) [2011] 6 CLJ 1 [CA]

CRIMINAL LAW

Dangerous Drugs Act 1952 - Section 39B(1)(a) - Trafficking in a dangerous drug - Whether drugs found were of insignificant size and meant for self consumption - Drugs found in a house occupied by others - Whether there was a failure to establish possession by direct evidence - Custody and control of drugs - Whether established - Whether trafficking charge tainted - Whether prosecution failed to establish a prima facie case
PP v. Zainal Arpan Molana
(Suriyadi Halim Omar, Abdul Wahab Patail JJCA, Linton Albert J) [2011] 6 CLJ 28 [CA]

CRIMINAL PROCEDURE

Disclosure of information - Statement of accused- Admissibility - Entries in pocket diary were not made contemporaneously - Whether police acted on prior information - Evidence Act 1950, s. 27
PP v. Zainal Arpan Molana
(Suriyadi Halim Omar, Abdul Wahab Patail JJCA, Linton Albert J) [2011] 6 CLJ 28 [CA]

EVIDENCE

Expert evidence - Chemist's report - Analysis of products - Addition of water and carbon dioxide - Chemist analysed products and determined physical properties - Whether tribunal should consider chemist's report - Whether tribunal's finding supported by chemist's report
Power Root (M) Sdn Bhd & Ors v. Ketua Pengarah Kastam
(Aziah Ali J) [2011] 6 CLJ 114 [HC]

Information leading to fact discovered - Admissibility of statements - Entries in pocket diary were not made contemporaneously - Whether police acted on prior information - Evidence Act 1950, s. 27
PP v. Zainal Arpan Molana
(Suriyadi Halim Omar, Abdul Wahab Patail JJCA, Linton Albert J) [2011] 6 CLJ 28 [CA]

LABOUR LAW

Employment - Absenteeism - Plaintiff absent for more than two consecutive days - Defendant could not locate plaintiff at site office - Plaintiff dismissed from employment - Whether plaintiff's dismissal lawful - Whether defendant entitled to rely on Employment Act 1955, s. 15(2) - Whether witness' testimony hearsay - Whether claim time barred
Lim Giat Eng v. Farlim Group (M) Bhd
(Noraini Abdul Rahman JC) [2011] 6 CLJ 101 [HC]

Employment - Dismissal - Plaintiff absent for more than two consecutive days - Defendant could not locate plaintiff at site office - Plaintiff dismissed from employment - Whether plaintiff's dismissal lawful - Whether defendant entitled to rely on Employment Act 1955, s. 15(2) - Whether witness' testimony hearsay - Whether plaintiff's salary reduction without reason or notice - Whether plaintiff agreed to salary reduction - Whether plaintiff arbitrarily demoted - Whether defendant's explanation reasonable - Whether claim time barred
Lim Giat Eng v. Farlim Group (M) Bhd
(Noraini Abdul Rahman JC) [2011] 6 CLJ 101 [HC]

Employment - Reduction in salaries - Whether plaintiff's salary reduction was without reason or notice - Whether plaintiff agreed to salary reduction - Whether claim time barred
Lim Giat Eng v. Farlim Group (M) Bhd
(Noraini Abdul Rahman JC) [2011] 6 CLJ 101 [HC]

LEGAL PROFESSION

Remuneration - Lien - Whether appellant entitled to a charge on property recovered or preserved - Whether lien of appellant could only be enforced by charging order - Whether property recovered under a judgment - Whether appellant had right to retain property when it was recovered by negotiation - Whether there was no lien - Legal Profession Act 1976, s. 123
Zulpadli & Edham v. Inai Offshore & Marine Engineering Sdn Bhd (In Liquidation)
(Sulaiman Daud, Jeffrey Tan, Zaharah Ibrahim JJCA) [2011] 6 CLJ 47 [CA]

REVENUE LAW

Sales tax - Assessment - 'Other non-alcoholic beverages' subject to 10% sales tax - 'Extracts or concentrates of coffee' subject to 5% sales tax - Specific description for products - Respondent's classified products under 'beverages' - Whether respondent erred in decision - Whether tribunal had given reasonable consideration before dismissing appellants' application against respondent's decision - Consumer's view of products - Chemist's report - Tribunal acknowledged products were not thirst quenchers - Whether tribunal erred in law and in fact - Whether there was sufficient evidence for products to be classified as 'extracts or concentrates of coffee' under First Schedule to the Custom Duties Order 2007 [P.U.(A) 441/2007], Heading no. 2101.12.900
Power Root (M) Sdn Bhd & Ors v. Ketua Pengarah Kastam
(Aziah Ali J) [2011] 6 CLJ 114 [HC]

SECURITIES

Shares - Agreement - Whether defendant held shares on constructive trust for plaintiff - Whether plaintiff could claim equity against defendant in respect of dividends received by defendant - Defendant did not pay purchase price - Whether retention of dividends by defendant amount to unjust enrichment
Fernrite Sdn Bhd v. Perbadanan Nasional Bhd
(Low Hop Bing, Syed Ahmad Helmy, Mohamed Apandi Ali JJCA) [2011] 6 CLJ 1 [CA]

TORT

Defamation - Claim based on innuendo - Whether plaintiff's claim based on mere allegations - Whether letter of dismissal to plaintiff defamatory
Lim Giat Eng v. Farlim Group (M) Bhd
(Noraini Abdul Rahman JC) [2011] 6 CLJ 101 [HC]

Defamation - Damages - Principles applicable in awarding damages in libel and slander cases
Chong Siew Chiang v. Ng Kim Ho & Anor
(Ravinthran Paramaguru JC) [2011] 6 CLJ 62 [HC]

Defamation - Defence - Fair comment - Test - Whether defendant's statements qualified as comments - Whether statements made in public interest - Whether defence established
Chong Siew Chiang v. Ng Kim Ho & Anor
(Ravinthran Paramaguru JC) [2011] 6 CLJ 62 [HC]

Defamation - Defence - Justification - Test - Whether truth of impunged statements established - Whether defence established
Chong Siew Chiang v. Ng Kim Ho & Anor
(Ravinthran Paramaguru JC) [2011] 6 CLJ 62 [HC]

Defamation - Defence - Qualified privilege - Test - Whether defendant had duty to publish the defamatory words to the public - Whether public had reciprocal interest in receiving the communication - Whether defence of qualified privilege in the form of Reynolds privilege applied - Whether defence established
Chong Siew Chiang v. Ng Kim Ho & Anor
(Ravinthran Paramaguru JC) [2011] 6 CLJ 62 [HC]

Defamation - Libel and Slander - Test for establishing defamatory nature of statement - Whether defendant's statement defamatory of plaintiff - Whether impugned words calculated to disparage plaintiff's reputation - Whether defamatory words referred to class of people or to plaintiff in particular - Whether plaintiff lowered in estimation of right thinking members of society - Defences - Truth and justification, whether established by defendant
Chong Siew Chiang v. Ng Kim Ho & Anor
(Ravinthran Paramaguru JC) [2011] 6 CLJ 62 [HC]

Defamation - Publication of news report - Second defendant reporting defamatory speech made by first defendant against plaintiff - Words complained of in news report, whether defamatory of plaintiff - Statements referred to plaintiff - Whether steps taken to verify the information before publication
Chong Siew Chiang v. Ng Kim Ho & Anor
(Ravinthran Paramaguru JC) [2011] 6 CLJ 62 [HC]

INDEKS PERKARA

PERSATUAN TAK DIPERBADANKAN

Injunksi - Permohonan - Permohonan injunksi menghalang defendan daripada meneruskan mesyuarat melibatkan hal-hal persatuan - Bantahan awal - Sama ada tindakan plaintif suatu tindakan perwakilan atau peribadi - Sama ada pertikaian harusnya dirujuk kepada Pendaftar Pertubuhan dan bukan mahkamah - Sama ada plaintif mempunyai locus standi untuk memulakan tindakan
Raveendaran Chellaiah lwn. Subramaniam Ellaih
(Umi Kalthum Majid PK) [2011] 6 CLJ 129 [HC]

CASE OF THE WEEK

UPMARKET DEVELOPMENT SDN BHD v. SRIERA DEVELOPMENT SDN BHD

LAND LAW: Caveats - Private caveat - Caveat forms - Caveator claiming title and/or interest in respect of a certain portion of land - Whether caveator must expressly state in Form 19B that caveat to bind only that part of land - Whether caveat defective in form and substance - Liberal and progressive approach - Balance of justice - Status quo - National Land Code, s. 322(1)

CLJ Bulletin
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NUMBER	TITLE	DATE COMING INTO FORCE	REPEALING
ACT 723	Price Control And Anti-Profiteering Act 2011	1 April 2011 [PU(B) 146/2011]	- Nil -
ACT 724	National Visual Arts Development Board Act 2011	Not Yet In Force	- Nil -
ACT 725	Renewable Energy Act 2011	Not Yet In Force	- Nil -
ACT 726	Sustainable Energy Development Authority Act 2011	Not Yet In Force	- Nil -
ACT 727	Food Analysts Act 2011	Not Yet In Force	- Nil -