(Updated 2 August 2026)
Article 22 sits in Chapter 6 of the Negeri Sembilan Constitution 1959, the chapter that establishes the Dewan Keadilan dan Undang (DKU). Read against the current dispute over access to the DKU’s 17 April 2026 minutes, it has become one of the more closely watched provisions in the Constitution.
What each clause means
Article 22(1): The requirement that minutes be kept of Dewan proceedings
(1) Minutes shall be kept of all the proceedings of the Dewan.
Every meeting of the Dewan must produce minutes, a written record of what took place. The Article does not say who prepares them, in what form, or on what timeline. That falls to Article 25, which allows His Highness to appoint a Secretary to the Dewan, and to Article 21, which lets the Dewan determine its own procedure.
Article 22(2): The confirmation of minutes at the next meeting, before other business
(2) At every meeting of the Dewan the minutes of the last preceding meeting shall be confirmed with or without amendment as the case may require, before proceeding to the despatch of any other business.
At the start of each meeting, the Dewan must first agree on the minutes of the meeting before it, confirming them as written or with amendment, before turning to any new item. It is a standard deliberative-body mechanism, designed to ensure the written record is checked against the collective memory of the members while that memory is still fresh, and before it is overtaken by the next round of business.
What Article 22 does not say
It does not say who, beyond the members of the Dewan, is entitled to see the minutes once they are confirmed.
Why this matters in 2026
The first is procedural
Following the DKU’s 17 April 2026 sitting, at which the removal of the previous, or removed, Undang of Luak Sungei Ujong, Mubarak, from office was acknowledged, Mubarak and three sitting Undangs filed an originating summons seeking release of the meeting’s minutes (The Star, 5 May 2026).
At the 13 May 2026 sitting in the Seremban High Court, the Negeri Sembilan state government argued that only Dewan members are entitled to the minutes and that their release falls outside state government jurisdiction, while counsel for the DKU raised a separate objection under Article 16(3), which places the Dewan’s advice on questions of Malay Custom, including the removal of a Ruling Chief, beyond challenge in any court on any ground.
The court fixed 28 July 2026 to hear that jurisdictional question. When the matter came before the court on 28 July, none of it proceeded. The scheduled committal hearing was adjourned to 28 September for case management, a fresh committal application was adjourned alongside it, and the recusal application was adjourned with the rest by consent of both sides (The Star, 28 July 2026; The Edge, 28 July 2026).
The Court of Appeal granted a stay of the committal proceedings the following day and fixed 19 October for case management of the underlying appeal (Free Malaysia Today, 29 July 2026).
No new date for the jurisdictional hearing on the minutes application had been confirmed in public reporting at the time of writing. Three and a half months after the 5 May filing, the question Article 22 leaves open, who outside the Dewan may see its minutes, remains formally undecided.
The second is political
The Negeri Sembilan state government, the third defendant in the minutes suit, changed hands at the 1 August 2026 state election, when a Barisan Nasional and Perikatan Nasional alliance won a landslide two-thirds majority and incumbent Menteri Besar Aminuddin Harun lost his own Linggi seat (Star, 1 August 2026).
The outgoing government’s position, that only DKU members are entitled to the minutes, was taken by the Pakatan Harapan administration. Article 22 does not say who inherits that position when the government changes.
Footnote: The Constitution numbers its Articles in Roman numerals. This publication uses Arabic numerals for readability.
Our posts referencing Article 22 or the DKU minutes:
What Happened at the Seremban High Court Sitting on 13 May: covers the originating summons for the 17 April DKU minutes and the state government’s jurisdictional objection that Article 22 sits behind.
Sources
Negri royal spat: Mubarak and fellow Undang go to court (The Star, 5 May 2026)
Undangs appealing leave for contempt at Court of Appeal (The Edge Malaysia, 27 July 2026)
Anak Nogori is independent commentary on the unfolding constitutional crisis in Negeri Sembilan, where centuries-old Adat Perpatih, royal succession law, and modern political manoeuvring are colliding in ways Malaysia has never seen before. If you find this useful, share it with someone who should be following this, or subscribe to receive the latest articles in your inbox.
