Law of Duress in Malaysia and United Kingdom

CRIMINAL LAW GLUP2054
1
1.0 INTRODUCTION
Duress is a part of defense for accused to exclude themselves from liability or any crime
committed by them. In this research, we are going to discuss in details on duress defense
provided in Malaysia, United Kingdom (Common Law) and Singapore. The main objective of it
is to find and thus, clarify the similarities and differences on the application of the defense
among these States.
The defense of duress first appeared in the Indian Penal Code 1860 and remained
unchanged until now under Section 94 of Penal Code1. The objective for this defense is to
operate as an excuse since accused’s conduct is regarded as wrongful in the eyes of society, but
the circumstances in which the accused committed such offense rendered him or her blameless.
The defense of duress recognizes that it would be unfair to convict and punish such a person
‘whose only choice was the morally unacceptable one between either self-sacrifice or breaking
the law’.
In the case of Attorney General v Whelan2, Murnaghan J stated that duress is a defense
because threats of immediate death or serious personal injury so great as to overbear the ordinary
powers of human resistance should be accepted as a justification for acts which would otherwise
be criminal. On the other hand, duress is an excusary defense. An accused who commits criminal
offences under duress is excused from liability because he is not held to be blameworthy enough
to warrant a criminal sanction and make it as a complete defense. Thus, if pleaded successful, the
accused will be acquitted. But accused carry a heavy burden of proof in proving he was under
duress when committing the offence. Meanwhile, it is the duty of prosecution to disprove the
duress beyond reasonable doubt, which means the evidence must be so strong that there is no
reasonable doubt that the defendant was not under duress.
There are few elements of duress. Those elements include getting a direct, serious and
fatal threat from coercer, the threat must be directed at accused alone and it must be threat of
instant death, accused must have reasonable apprehension that the thread will be carried out,
have a duty to escape, do not place himself in a situation by which he became a subject of
1 Act 574
2 [1934] in Irish CourtOf Appeal

2
threats, have physical presence of coercer, and accused must not have any voluntary association
with criminal group. These elements are crucial in determining whether accused was under
duress or not and judges will look on the proofs and circumstances when the offences occurred.
1.1 Definition of Duress
In Malaysia, definition of duress has been stated clearly under section 94 of Malaysian
Penal Code. The provision stated that,
“Except murder, offences included in Chapter VI punishable with death and offences
included in Chapter VIA, nothing is an offence which is done by a person who is compelled to
do it by threats, which, at the time of doing it, reasonably cause the apprehension that instant
death to that person will otherwise be the consequence:
Provided that the person doing the act did not of his own accord, or from a reasonable
apprehension of harm to himself short of instant death, place himself in the situation by which he
became subject to such constraint.”
Meanwhile in Singapore, definition of duress also has been stated clearly under section
94 in Penal Code of Singapore. But since Singapore also following Indian Penal Code 1860 like
Malaysia, then the provision and definition are almost as the same as Malaysian Penal Code.
There are just slight differences in the matter of interpretation of the said act by the court.
On the other hand, duress in English law is a complete common law defense, operating in
the favour of those who commit crimes because they are forced or compelled to do so by the
circumstances, or the threats of another. The doctrine arises in both English criminal law and in
civil law. There are no specific enactment specify the meaning of duress under Common Law.
But, it is generally accepted that definition of duress in civil law is every contract that has been
made under some form of pressure or threat which is offerer threatens that unless the offeree
accepts the terms offered, he will not get the benefit of the offer. So long as a threat is just one of
the reasons a person enters an agreement, even if not the main reason, the agreement may be
avoided. Meanwhile, under criminal law, the defense of duress was laid down in M’Growther’s

3
case3 whereas a person has been committed crime because of serious threat from another person
to do so, but the threat must be persistent, imminent and extreme to exclude him from the
criminal liability.
2.0 POSITION OF DURESS IN MALAYSIA
In Malaysia, defense of duress is best described under section 94 of the penal code. The
elements found under this section are the moralized accounts of the defense focusing on the
desserts of the offender4. Duress, which is an amalgam of statutory, cannot be extended to apply
where the accused meets force with force in situations where self-defense is not available. In
fact, the defense of duress, in its statutory and common law forms, is largely the same and both
forms share the following common elements.5.
On the ground of the first element, the threat must be directed at the defendant and not
some other person. Reviewing the Malaysian Penal Code, the need to extend this aspect of
section 94 and did so by recommending that the defense be available to cases where the threats
were directed at ‘any near relative of the defendant who was present when the threats were
made’, with the term ‘near relative’ defined to mean parents, spouse, son or daughter.
The second element discussed here is the need for the threat to be an instant death.
Pursuant to section 94 of the Code and the case of Public Prosecutor v Mohd Amin bin Mohd
Razali & 28 Ors6, Zulkefli b Ahmad Makinudin J stated that threat or compulsion from the
accused, is not a defense to the charge faced by the accused persons. If an accused is to succeed
in putting up such a defense, evidence must be produced to show that there was a reasonable
fear at that very time, of instant death. Mere menace of future death is not sufficient in a situation
by which an accused person became subject to the threat of another person, whatever the threats
that may have been used against him.
3 (1746) 18 St Tr 301
4 J.L. Hill,‘A Utilitarian theory of duress’(1999) 84 Iowa L. Rev. 275.
5 Reuters .T. (2013) Criminal Law - R v Ryan. Current Law Journal,retrieved 26 October 2014,from
http://westlaw.com.my/eng/Journals.htm
6 [2002] 1 AMR 969

4
On the other hand, the physical presence of coercer is also needed even though it is not
precisely stated under section 94 of the penal code. This element can be referred to the case of
Public Prosecutor v Tanha Ghassem Mohamadkaram7. Under the law of duress, the threatener
had to be present to execute the threat of instant death if the accused failed to commit the
offence. In this case, the 6th mobster was nowhere to be seen. There were also a number of
police officers at the scene attending to the accused at KLIA. Consequently, the court finds there
was no basis for thinking that the accused was obsessed with such thoughts at the material time
to the extent that he was deterred from seeking police protection in Malaysia.
The phrase ‘reasonably cause the apprehension’ appearing in section 94 injects an
objective element into an assessment of the defendants belief as to the existence and nature of the
threat confronting him or her.it is not simply that the defendant himself or herself believed (in
which case the test would be purely subjective) but what the defendant reasonably believed. This
required the trier of fact to consider what the defendants beliefs as to the threat was, and then
decide whether such belief was reasonably held8.
On the other hand, citing a passage from Gour's Penal Law of india 9, which read as
follows:
… the central point which must be borne in mind is, that the right of private defense
continues only so long as a reasonable apprehension of the danger persists. When a number of
injuries come to be inflicted by an accused person in the exercise of the right of private defense,
As further explained in the case of Patrick Chau Fook Henn v Public Prosecutor10, the
important point which has to be determined is as to whether in the circumstances in which the
accused person was placed, the apprehension had persisted in his mind when he inflicted a
7 2013] MLJU 52
8 codificaton,macaulay and the Indian penal code: the legacies and modern challenges of criminal lawreform by
wing cheong chan,barry rightand Stanley yeo.
9 pp 814–815
10 . [2014] 3 MLJ 825

5
particular injury or injuries that his life was in danger and whether, under the circumstances in
which he was placed, that apprehension was a reasonable ones.
Basically, for the element of duty to escape from the coercer by the defendant does not
appear in the section 94 of the penal code unless a reasonable opportunity is present. Indeed, it
may be thought that the requirement of instant death dispenses with the issue of escape because
the extremely brief time connoted by the word ‘instant’ inevitably renders absent any
opportunity to escape. In addition, when duress is pleaded merely involves a considerably longer
time period between the threats was made and the crime was to be committed. This situation is
well explained in the case of Natcha Dabkaew (Thai) v Public Prosecutor.11
The next element discussed is that the harm threatened must be death. Before being
amended, the Penal Code referred the English Common Law position that recognizes threats of
serious bodily harm as a threat of death. Referring to Latif Khan AIR12, nothing short of fear of
death will suffice for the defense to be applied. Besides under section 94 of the Penal Code, this
element is also mentioned under Section 320 of the penal code which provides the definition of
grievous hurt. In the book of criminal law in Malaysia and Singapore, written by Stanley Yeo,
the differences between the both sections are explained briefly as section 94 only applies
specifically to short of death but section 320 provides a better option in the provision of duress
which specifies that the harm threatened must be death or serious harm. The term used under
section 320 has a wide meaning which includes both physical and psychological harm.
The final element is that the accused must not have any voluntary association with
criminal group. The defense of duress is not available to person who commits crimes as a
consequence of threats from members of violent gangs which they have voluntarily joined. A
defendant who joins a criminal association which could force him to commit crimes can be
blamed for his actions. In joining such an organization, fault can be laid at his door and his
subsequent actions described as blameworthy, where a person has voluntarily and with
knowledge of its nature, joined a criminal organization or gang which he knew might bring
pressure on him to commit an offence and was an active member when he was put under such
11 [2014] AMEJ 0576
12 . (1995) 20 Bom 394

6
pressure, he cannot avail himself of the defense of duress. The defense is not inevitably barred
because the duress comes from a criminal organization which the defendant has joined. It
depends on the nature of the organization and the defendant's knowledge of it. If he was unaware
of any propensity to violence, the defense may be available.13
3.0 POSITION OF DURESS IN SINGAPORE
It is well known that Singapore’s Penal Code is virtually identical to the Indian Penal
Code 1860. Not long after its enactment, the Indian Penal Code received high praise for its clear
articulation and thinking concerning criminal responsibility. However, even the best codes would
lose much of their attributes if they remained unaltered over an extended period. As a result, the
Penal Code struggles to remain the principle repository of the foundational principles of criminal
responsibility, having hardly any influence on the development of subsequent penal legislation.
The duress under Singapore’s Penal Code also falls under section 94 as Malaysian Penal Code.
Therefore, all the elements involved in duress in Malaysia are also applied in duress in
Singapore.
In the case of Public Prosecutor v Nagaenthran a/l K.Dharmalingam14, the Prosecution
submitted that the accused was guilty of the offence charged because he knew that he was
importing the controlled drug heroin into Singapore at the material time. In particular, the
Prosecution argued that the accused already had either actual knowledge or imputed knowledge
(in the form of willful blindness) of the actual contents found in the Bundle when he was stopped
at Woodlands Checkpoint on 22 April 2009. The court held that set out the principles governing
the defense of duress since the accused could not prove he was under duress in the balance of
probabilities.
Apart from that, Stanley Yeo15 stated that in spite of the clear invocation under
section 94, coercer must have threatened to kill the accused instantly if he or she refused to break
the law. The term ‘imminent’ has crept into the judicial authorities on the subject. The difference
between the words ‘instant’ and ‘imminent’ is not a mere matter of semantics. The former
13 http://www.lawteacher.net/criminal-law/cases/duress-1.php
14 [2011] SGHC 15
15 Criminal Lawin Malaysia and Singapore:a Casebook Companion (LexisNexis,2009). p 547

7
requires the threatened harm to be carried out within a very short time and is synonymous with
the word ‘immediate’. In contrast, the term ‘imminent’ is synonymous with ‘impending’ and it
permits a longer time interval to occur between the accused’s refusal to break the law and the
coercer’s carrying out of the threat.
4.0 POSITION OF DURESS IN UNITED KINGDOM
In studying the defense of duress through the common law perspective, there are some
elements that need to be focused on. Among the elements which are important in recognizing the
duress is the degree of harm threatened. Apart from taking the generally accepted standard that
the threat of duress can only be raised upon the threat of death, it also allows a lower degree of
threat which is the threats of serious bodily injury. The rational is such threat of injury believed
to be capable of being as compelling as a threat of death. Should there be an injury less harmful
than fatal or gravies, mitigation would be enough.
In 1985, Valderrama-Vega16, the defendant stated three reasons for committing cocaine
smuggling. He alleged that he and his family were threatened with death or injury if he did not
participate. He also claimed that he was in serious financial problem and at the same time was
facing a threat of getting his homosexual tendencies revealed.
The trial judge ruled that the jury should concentrate on whether the defendant had
committed the offence as a result of the threats of violence in allowing the defense. The
defendant was convicted and appealed. On appeal, the Court of Appeal ruled that the jury should
be entitled to see the cumulative effect of other factors.
The presence of other elements such as financial issue will open new assumption that
even without the duress of threat forced against him, he is might still commit the crime in order
to satisfy the other elements.
Secondly, on the question on who may be subjected to the threat, the English Common
Law stated that apart from threat against the person himself, the member of the accused’s
16 [1985] Crim LR 220

8
immediate family or the people who the accused reasonably considered him as responsible
towards their safety are also put into account.
In the case of R v Shayler17, Shayler was a member of MI5 and had breached a
declaration under the Official Secrets Act in which he had signed. The judge ruled that the
defense of duress of circumstances was not available for him. He appealed against this ruling
contending that the disclosure was necessary to safeguard members of the public. The appeal
was dismissed. It was held that there is nothing confirms that the action that will create imminent
threats to life. He also failed to recognized the potential victims or prove that he had
responsibility for them.
The Attorney General v Whelan case suggests that duress is a situation where the
accused is put under a very great threat of immediate death or serious personal injury that it is
unbearable for a human to endure18. It is pertinent to note that here that the threat must be of
immediate threat. But, the court usually more prefer to use the term imminent as it is more
proper to be used.
The strict definition of immediacy in terms of time taken for an incident to happen could
hardly be fulfilled. Thus, the court usually included the surrounding circumstances into account
in determining if there are needs for the defense of duress is to arise.
In Abdul-Hussein19, the case involved the hijacking of a plane to escape persecution in
Iraq, the Court recognized that knowing exactly when the threat might be carried out would still
have an effect on a person's actions and held that the threat must be 'imminent' and operating on
the defendant's mind at the time of the offence. In this case those defendants were threatened
with the execution of themselves and their family on their return to Iraq.
One must also have reasonable apprehension that the threat will be carried out to
establish duress. The accused must have a reasonable ground to belief that the threat will be
carried out. The common law agreed with the submission that there are certain conditions in
17 [2001] EWCA Crim 1977
18 Murnaghan J,1934
19
[1999] CrimLR 570

9
which its occurrence will affect the judgment of the person on whether the threat will be carried
out.
In the case of R v Bowen20, the appellant received electrical goods total up to £20,000 by
deception. He alleged that he was threatened that he and his family will be harmed. The appellant
had a low IQ of 68. He was convicted and appealed. The court held that the appeal was
dismissed and conviction upheld. A low IQ is not counted as being a mental impairment.
On the other hand, Stuart Smith LJ mentioned that the elements of age, sex, pregnancy,
serious physical disability, a recognized mental illness or psychiatric condition as the
characteristics could be taken into account. Such personal characteristic are not within the
accused’s control and it could affect their belief on the nature of threat.
However, there are certain limits ruled out where the defense of duress is not made
available. The defense of duress is shall not be raised where the defendant could reasonably have
taken evasive action. If the defendant could, by any reasonable way secured the police protection
or avoid the crime they are expected to make the evasive action. Someone who stands a chance
to get the police protection but he fail to utilize this opportunity should not be able to rely on the
defense of duress. This was clearly stated by Lord Lane CJ when he said that there is no doubt
that someone who was put under the duress should use any reasonable way to escape the
duress21.
For example, in the case of R v Hudson and Taylor22 where two teenage girls were
scared into perjuring and pleaded the defense of duress by threats. They alleged that they had
been threatened with serious violence. The trial judge ruled out the defense on the basis that the
threats were not sufficiently present and immediate. However, they were not convicted,
considering their age was relevant and police protection not always seen to be safe.
20 [1997] 1 WLR 372
21 Lord Lane CJ in R v. Sharp [1987] QB 853
22 [1971] CA

10
The judge also made it clear that a defense of duress must be preceded by a threat that is
effective when the crime take place. Should there be any safe evasive way available; the defense
of duress shall be invalid23.
In R v Abdul-Hussain, the seven appellants were Shiite Muslims from Southern Iraq.
Abdul-Hussain had been sentenced to death in Iraq following a confession which had been
extracted by torture. The other appellants were also fugitives facing death sentences in Iraq. They
had hijacked an airplane but upon negotiations, agreed to surrender. At trial, the judge ruled that
the defense of duress of circumstances could not be put before the jury as there was a lack of the
requirement of immediacy. The appeal of the case allowed. The convictions were quashed.
Imminent peril of death or serious injury is a good element to plead for both types of duress.
The act of joining violent gang is considered as a self-induced duress. The defense of
duress cannot be raised by the persons who did crimes because of threats from members of
violent gangs which they have, without being pressured, joined.
In R v Hasan, the appellant worked as a driver for woman who works in the prostitution
area. She then became involved with another man, Frank Sullivan, who was a violent drug
dealer. The appellant was aware that Sullivan was a dangerous man. One night Sullivan and
another man told him to commit a ransacked a house belongs to the woman’s clients. He threats
him to do that that with him and his family’s safety on the line. The appellant did so and was
convicted of aggravated burglary. His defense of duress was rejected by the jury. He appealed to
the Court of Appeal.
The Court of Appeal allowed the appeal and quashed his conviction. The Crown appealed
to the Lords. House of Lords held that the appeal was allowed. It was stated that if a person gets
involved by voluntary with people, known to him or he is capable of knowing that the person is
engaged in criminal activity and thus, he may be the subject of compulsion by them or their
associates, then he cannot rely on the defense of duress, in case anything happened24. However,
the successful of the defense depends on the nature of the organization and the defendant's
23 Widgery LJ, 1971
24 Lord Bingham, 2005

11
knowledge of it. If he was unaware of any probability to get involve in violence, the defense may
be available.
Meanwhile any murder related crimes such as murder, attempted murder or accessory to
murder are NOT entitled to get the defense of duress. This is because the law put great
appreciation for life. Thus, it is irrelevant for someone to put other’s life at risk in order to save
his life and the life of the people he cherished.
This is paralleled with Lord Hale’s suggestion that if a man is desperately assaulted, and
his life is threaten, and there is no way out but to follow the order by the assailant the fear of
murdering another person will not free him from the punishment of murder because in one’s
natural conscience, he would rather to die himself than killing an innocent person25.
An example in case of murder that rejected the plea of duress is the case of Abbott v The
Queen26. Abbott had taken part in a brutal killing in fear of a death threats made against himself
and his mother. He held the victim while she was being attacked with a cutlass and then buried
her alive. He was convicted of murder and sentenced to death. He appealed his conviction
relying on the defense of duress. It was held that appeal dismissed and conviction upheld. The
defense of duress is not available for murder to a principal in the first degree.
Lord Griffith in his judgment for the case of R v Howe and Banister27 had clearly stated
that an attempted murder may be more intent upon taking a life than a murder. Thus, those who
commit attempted murder should hold the same result as a murder and deserve no defense of
duress.
25 Matthew Hale, Pleas of the Crown (1736)
26 [1977] AC 755 Privy Council
27 [1987] AC 417

12
5.0 ANALYSIS OF THE ISSUE
The previous discussion particularly explains in details about the duress defense based on
the law provided in Malaysia, Singapore and also Common Law. Duress is an established
principle of criminal law that a person cannot be criminally liable just for doing any wrongs or
crimes. Pursuant to all related laws, we can dictate that criminal law provides duress as an
exception to the general principle of criminal law. The rationale is that it is unfair for those who
choose to break the law are held responsible for the crimes that they commit is that the choice is
not wholly voluntary. Referring to the book of Criminal Law in Malaysia and Singapore, written
by Stanley Yeo, duress is a special form of the defense of necessity. Besides that, there are varies
definition of duress as has been mentioned at the beginning part of the law assignment.
Even the duress under Penal Code remained unchanged since Indian Penal Code 1860,
but applications of duress are different in each Commonwealth country. The first restriction on
the defense is the harmed threatened must be death. There is a relationship exists as stated in
Penal Code and Common Law. Before being amended, the Penal Code referred the English
Common Law position that recognizes threats of serious bodily harm as a threat of death.
According to the Common Law, apart from taking the generally accepted standard that the threat
of duress can only be raised upon the threat of death, it also allows a lower degree of threat
which is the threats of serious bodily injury. However, Malaysian Law provides that in order to
invoke this defense, the accused must be in the position of “reasonable fear of instant death”
(Section 94 of the Act) and it must be imminent, extreme and persistent. Nothing short of fear of
death will suffice for the defense to be applicable as proved in the case of Latif Khan AIR.28
Therefore, we could say that Common Law provides broader opportunity on the application of
this defense compared to other laws.
Other ground that has clear distinction among the laws is that section 94 of the Penal
Code, like the Indian Penal Code requires that the threat must be directed at the accused himself.
On the other hand, Singaporean Law as amended in 2007, permits the defense where the threat
was directed at the accused ‘or any other person’. The Singaporean position is too broad.
Meanwhile, the threats may be directed at some other persons according to English Common
28 (1995) 20 Bom 394.

13
Law. They include a member of the accused’s immediate family or someone for whose safety the
accused’s regarded himself to be responsible. Thus, it can be seen that the Singaporean position
is too broad. Reviewing the Malaysian Penal Code, there is absolutely a need to extend this
aspect of section 94. It is recommended for Malaysian law to follow the idea of Common Law
where the threats were directed at ‘any near relative of the defendant who was present when the
threats were made’, with the term ‘near relative’ defined to mean parents, spouse, son or
daughter.
Furthermore, the need for the threat to be of instant death is required in laws from all
States. So, we can say that this point plays a vital part in determining the use of duress as a
defense. Court will definitely go through the facts based on the circumstances available with
care. Malaysian Law emphasizes on the term of instant and imminent. In the local case of Tan
Seng Ann v PP29, Malaysian Court of Criminal Appeal, the learned judge said ‘only fear of
intermediate death’ would be a sufficient excuse. Meanwhile, in the M’Growther ‘s case, Willan
CJ stated that duress to be pleaded successfully must be imminent, extreme and persistent.
Thereafter series of local case have described threat under section 94 of the penal code as having
to be imminent, extreme and persistent. For instance, in the local case of PP v Ng Pen Tin30 with
the word “imminent” suggesting that the threatened harm need not be carried out immediately or
within a very short time span. In United Kingdom Law (Common Law), most of the case the
court held that the term imminent is more proper to be used. In A-G v Whelan [1993] IEHC, the
accused was told to commit an offence and was subject to: “Threats of immediate death or
serious personal violence so great as to overbear the ordinary powers of human resistance.
Section 94 of the Penal Code did not mention clearly on the need to escape for an
accused from his or her coercer. Moreover, the word ‘instant’ in the provision had illustrated a
very limited period for the accused to escape as in the case of Chu Tak Fai31. The Singapore
High Court had justified this matter by looking at the accused’s reasonable belief as it shown in
the case of PP V Ng Pen Tine. In this case, the court acknowledged that there can be a situation
where no amount of police protection would be enough to counter the threats. However, such
situation was regarded as exceptional. In short, the law will presume that the police protection
29 [1949] MLJ 87
30 [2009] SGHC 230. A Singaporean case.
31 [1998] 4 MLJ 246

14
will be effective unless show otherwise. The situation is also similar under the United Kingdom
Law as referred in R v Hudson & Taylor32.
The final element is that the accused must not have any voluntary association with
criminal group. This condition is a restriction under the criminal law in Malaysia, United
Kingdom and Singapore. A defendant who joins a criminal association which could force him to
commit crimes can be blamed for his actions. However, the successful of the defense depends on
the nature of the organization and the defendant's knowledge of it. If he was unaware of any
propensity to violence, the defense may be available. In our point of view, the law is correct in
assisting this matter as the act of joining such an organization itself can be described as
blameworthy, where a person has voluntarily and with knowledge of its nature, joined a criminal
organization or gang which he knew might bring pressure on him to commit an offence.
In a nutshell, duress is a type of criminal defense that seem to be fair for accused. This is
in order to exclude themselves from liability or any crime committed by them where he or she at
that time is lacked free choice. There are indeed similarities and differences on the application of
the defense among the Criminal Law in Malaysia, United Kingdom and Singapore. We
acknowledged the few matters that maybe can be put into consideration in Malaysian Law for
improvement or law reform especially in regards to the person who may be subjected to threat in
duress defense as discussed before.
32 [1971] CA

15
6.0 References
Stanley, Y. (2007). Criminal Law in Malaysia and Singapore. LexisNexis Malaysian Law Sdn
Bhd. Page 625-653.
All Answers Ltd. (2014). Duress by Threats. http://www.lawteacher.net/criminal-
law/cases/duress-1.php retrieved on 23rd of October 2014.
Just, A. (2013). The Defence of Duress. http://www.inbrief.co.uk/court-proceedings/defence-of-
duress.htm retrieved on 20th of October 2014.
Law, M. (2014). Explain How the Defence of Duress Operates.
http://www.lawmentor.co.uk/resources/essays/explain-how-defence-of-duress-operates/ retrieved
on 28th of October 2014.
Law, T. (2012). Duress by Threats. http://www.lawteacher.net/criminal-law/cases/duress-1.php
Retrieved on 28th of October 2014.
M, Souper (2008). General Defences - Duress and Duress of Circumstances.
http://sixthformlaw.info/01_modules/mod3a/3_40_gen_defences/03_duress_and_circsm
retrieved on 20th of October 2014.
M, Hart.( 2012). Duress 2012. http://www.slideshare.net/mariettehart/duress-2012-
13058098?next_slideshow=1 retrieved on 19th of October 2014.

16
Shummi. (2012). Lecture on duress copy. http://www.slideshare.net/shummi/lecture-on-duress-
copy retrieved on 21st of October 2014.
P, Masons LLP. (2014). Defence of Duress in Criminal Law. http://www.e-
lawresources.co.uk/Defence-of-Duress.php retrieved on 20th of October 2014.

Law of Duress in Malaysia and United Kingdom

Recommended

Recommended

More Related Content

What's hot

What's hot (20)

Similar to Law of Duress in Malaysia and United Kingdom

Similar to Law of Duress in Malaysia and United Kingdom (20)

More from ASMAH CHE WAN

More from ASMAH CHE WAN (20)

Recently uploaded

Recently uploaded (20)

Law of Duress in Malaysia and United Kingdom