In this article, the writer compares the approaches taken by the Singapore Court of Appeal and the Malaysian Federal Court as to the permissibility of courts to imply words into their Constitution. While the two cases of Chee Siok Chin v Minister for Home Affairs and Dr Mohd Nasir bin Hashim v Menteri Dalam Negeri Malaysia were essentially interpreting what was on paper similar provisions, the holdings were completely dissimilar. He questions why this was so. Chee Siok Chin v Minister for Home Affairs was argued by M. Ravi in 2005.