An Anonymous Law Review's Case Against Tuanku Muhriz Examined
A critical examination of the evidence, assumptions, and constitutional reasoning underlying the paper's case against Tuanku Muhriz.
An annotated reading of the Negeri Sembilan Constitution 1959 has been circulating, built around a single proposition: that His Highness deliberately disregarded the Constitution, and that the Undangs were therefore entitled to remove him.
The central weakness in the paper is that it assumes the most important point in the entire dispute: that removed Undang Mubarak is a valid Undang and Tuanku Muhriz was validly removed on 19 April 2026. What follows depends upon those two propositions being true.
The question is whether the Constitution, the facts, and the procedures actually support it.
1. The constitutional requirements of Article X were not shown to be satisfied
The red text states:
“On this basis, the Undangs exercised their authority to remove His Highness (or forced Him to abdicate) on 19 April 2026.”
The Constitution says the Undangs may call upon the Yang di-Pertuan Besar to withdraw or abdicate if, after “full and complete enquiry”, they determine one of the specified grounds exists.
The red commentary quietly skips several crucial questions:
Was there a full and complete enquiry?
Who conducted it?
What procedure was followed?
Was the finding formally made?
Was a proclamation issued in accordance with Article X?
The paper mistakes allegation for constitutional fact. Article X does not permit the removal of a Yang di-Pertuan Besar merely because the Undangs believe a breach has occurred. It requires a specific constitutional process.
The paper does not establish that these constitutional requirements were satisfied. Accordingly, the paper does not establish that the constitutional requirements for removing a Yang di-Pertuan Besar were satisfied on 19 April 2026, and its subsequent arguments therefore rest upon a proposition that remains contested.
Subsequent events reinforce that conclusion. No vacancy was treated as having arisen, Article XI was never triggered, no successor was recognised by the state or federation, and Tuanku Muhriz continued to be treated by public institutions as the Yang di-Pertuan Besar.
2. The paper assumes that Mubarak was still the lawful Undang of Sungei Ujong
The red argument assumes:
Attempted removal from the Dewan = breach of Article XVII = deliberate disregard of the Constitution.
As this publication previously argued in Mubarak No Longer Has Adat Authority as Undang, the Sungei Ujong Lembaga has spoken, and under Adat Perpatih it is the Lembaga that elects and removes the Undang of Sungei Ujong. Under Adat Perpatih the Lembaga elects and removes the Undang of Sungei Ujong, and it was the Lembaga that removed Mubarak, not the Dewan Keadilan dan Undang (DKU)re nor Tuanku Muhriz.
The paper’s constitutional analysis proceeds on the assumption that Mubarak remained the lawful Undang. Yet that assumption is wrong. If Mubarak had already lost his Adat authority and office through the action of the Sungei Ujong Lembaga, then much of the argument built upon Article XVII rests upon a premise that is false.
3. Article XVI creates DKU as an advisory body, not a removal power
The paper relies heavily on Article XVI, butArticle XVI creates an advisory body, not an executive one.
The Constitution repeatedly describes the function of the Dewan as being “to advise” on questions of Malay custom, election, succession, removal, and vacation of office. Advice, however important, is not the same thing as executive authority.
This creates a fundamental difficulty for the paper’s argument. Even if one assumes that a valid Dewan meeting took place and that advice was properly given, Article XVI does not state that the giving of advice itself removes the Undang.
The paper effectively conflates two distinct constitutional functions. It treats the Dewan’s advisory role under Article XVI as though it were itself the source of a power of removal. The Constitution does not say that,
At its highest, Article 16 permits the Dewan to advise, and the power of removal sits with the Luak under its own custom.
4. The paper ignores the finality of the DKU's recognition of mubarak's removal
The paper proceeds as though Mubarak unquestionably remained the lawful Undang of Sungei Ujong.
Yet the DKU had already recognised his removal by the Sungei Ujong Lembaga. Under Adat Perpatih, it is the Lembaga that elects and removes the Undang of Sungei Ujong. The DKU acknowledges and advises upon that decision, which the Lembaga make.
Article XVI(3) provides that the advice of the Dewan shall be final and not challenged in court. The paper relies heavily on that provision elsewhere, yet largely ignores its implications for the status of Mubarak himself.
The paper’s argument depends upon treating Mubarak as though he remained a lawful Undang. Yet that is precisely the proposition the DKU had already declined to accept when it recognised the decision of the Sungei Ujong Lembaga.
5. The paper assumes Article XXVI applies to the Tunku Panglima Besar appointment
The red text claims:
His Highness had not consulted with the Ruling Chiefs.
regarding both removal and conferment of the Tunku Panglima Besar title.
The paper assumes that Article XXVI governs the appointment. Article XXVI concerns the conferment of titles, dignities, Orders and badges of honour by His Highness as the fountain of honours within the State. The provision is directed principally at the creation and conferment of state honours and dignities.
The office of Tunku Panglima Besar is different in character. It is not created by the Constitution, its qualifications and succession are not prescribed by the Constitution, and it forms part of the internal structure of the Negeri Sembilan royal household rather than the constitutional machinery of the State.
Unlike the Undangs, the Tunku Besar Tampin, or members of the Dewan Keadilan dan Undang, the Tunku Panglima Besar is not mentioned anywhere in the Constitution. The title exists through royal custom and palace practice, not constitutional text.
The appointment of a Tunku Panglima Besar is an internal royal appointment made pursuant to custom and the prerogatives of the Yang di-Pertuan Besar, rather than an exercise of the Article XXVI honours power.
The red notes jump directly from:
His Highness had not consulted with the Ruling Chiefs when bestowing the title of Tunku Panglima Besar on 11 June 2026, which was an act that deliberately disregarded the provisions of this Constitution
A court would ask:
Was consultation required?
Did consultation occur?
If not, was the defect procedural or jurisdictional?
Does non-compliance invalidate the act?
The paper assumes that Article XXVI governs the appointment. It does not explain why a palace title, unknown to the Constitution and rooted in royal custom, should be treated as falling within Article XXVI at all.
Article LXXIX reserves to His Highness and the Ruling Chiefs the prerogatives, powers and jurisdiction they held before 1959, except in so far as the Constitution expressly provides otherwise. Where the text speaks, it governs, and where it stays silent, the customary prerogative survives intact. Since the office of Tunku Panglima Besar appears nowhere in the Constitution, Article 79 leaves the Yang di-Pertuan Besar’s customary power to fill it undisturbed.
Lastly, the paper proceeds as though Tunku Nadzaruddin was deprived of the title. In reality, he relinquished it himself. By accepting an invalid proclamation as Yang di-Pertuan Besar, he vacated the position he previously occupied and brought about the consequence that followed.
6. The document repeatedly substitutes allegation for proof
Notice the wording:
“as alleged on 17 April 2025”
The constitutional extract itself acknowledges an allegation. The red commentary then proceeds as though that allegation has already been proven. Treating an open question as a closed one is the mark of advocacy rather than constitutional interpretation.
It also states:
The document is a legal argument by an unidentified author. There is nothing improper about that. Our publication is also written pseudonymously. However, the arguments should be judged by the quality of its argument and the strength of its reasoning.
The central weakness
The red commentary depends on two propositions: that Tuanku Muhriz was validly removed on 19 April 2026, and that Mubarak remained the lawful Undang of Sungei Ujong.
Neither proposition is established by the paper. Yet much of its constitutional analysis depends upon both already being true. Once those assumptions are removed, the paper’s case largely collapses.
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Sources:
What Happened at the Seremban High Court Sitting on 13 May (Anak Nogori), 14 May 2026
‘Proclamation’ of new ruler invalid, says Negeri Sembilan palace (FMT), 9 June 2026
Tunku Zain named new Tunku Panglima Besar of Negeri Sembilan (Malay Mail), 11 June 2026
Tunku Zain proclaimed as Tunku Panglima Besar of Negri Sembilan (The Star), 11 June 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.
