1. See Aun, WM, The law of industrial relations in Malaysia, pg. 193-256; Siti Zaharah Jamaluddin, Pengenalan kepada undang-undang perhubungan perusahaan di Malaysia, Penerbit Universiti Malaya, Kuala Lumpur, 2000, pg. 101.
2. See for example, V. Anantaraman,Malaysian industrial relations law and practice, pg. 219; Kamal Halili Hassan, 'Trade unions, state discretionary powers and judicial control', Terbitan Tak Berkala, FUU, UKM, 1998, pg. 1.
3. See Padfield v. Minister of Agriculture, Fisheries and Food [1968] AC 997. On the other hand, the cases of Minister of Labour, Malaysia v. Sanjiv Oberoi &Anor andMinister of Labour, Malaysia v. Chan Meng Yuen & Anor seemed to advance a principle that the Minister was not under a duty to give reasons for his decisions; Gopal Sri RamJCA inHong Leong s case however did not agree with these two decisions.
4. The Industrial Court of Malaysia & Anor [1997] 1 MLJ 145.