Separated by Prison Bars: The Right to Humane Treatment
Does the country’s prison system actually facilitate rehabilitation? HAKAM Youth discusses the dire straits of Malaysian prisons with YB Nurul Izzah Anwar and Abdul Rashid Ismail.
SUARA MANDIRI Issue #6
In contemporary times, reports of abuse, torture, and deaths of detainees in police custody have prompted a mass public outcry. In comparison, less cognisance has been given to the plight of another vulnerable group who, akin to detainees, are voiceless and suffering away from the public eye: prisoners. Although convicted prisoners are no longer under the hegemony of the police, they face grave challenges while incarcerated. Even before COVID-19 wreaked havoc upon prisons in Malaysia, conditions have been less than ideal for a long time, primarily due to overcrowding.
In this issue of Suara Mandiri, HAKAM Youth dives deeper into the dire conditions of Malaysian prisons and tackles the quandary of whether the country’s prison system actually facilitates rehabilitation. This article also features insights from two prominent advocates for prisoners’ rights: YB Nurul Izzah Anwar, who works with the All-Party Parliamentary Group Malaysia for the Reform of All Places of Detention (APPGM-RAPD) and lawyer Abdul Rashid Ismail, both weighing in on the critical need for prison reform.
Abiding by the Existing Standard of Prison Conditions
The Prison Act 1995 puts forth a wide range of guidelines for optimal prison conditions to be met by the Malaysian Prison Department, outlining the sine qua non of humane treatments prisoners deserve.[1] For instance, Section 6 of the Act provides characterisation for “Appropriation of Prisons to Categories of Prisoners”. Further, Section 14 of the Act provides that prison inmates are entitled to be treated by medical and dental officers compelled to observe their duties as stated in Section 15. Accordingly, all matters of custody and removal of prisoners are to be executed in accordance with Part IV of the Prison Act 1995.
Internationally, the United Nations Standard Minimum Rules for the Treatment of Prisoners, famously known as the “Nelson Mandela Rules”, serves as the universal standard for prison regulations. Its goal is to establish baseline criteria for the respectful treatment of detainees.[2] The second rule provides that there should be no discrimination against inmates based on race, sex, religion, politics, or national origin. In addition, prison officials must consider the needs of all convicts, particularly the most vulnerable. Though comprehensive, the Mandela Rules are not binding, but merely guidelines pertaining to a broad scope of features within prisons.[3] Nevertheless, these guidelines must be crucially observed as jails confine captives in restricted spaces, keeping them hidden from plain sight – enabling mistreatment and brutality to emerge and burgeon.[4]
Have Malaysian Prisons Fallen Below the Expected Standards?
The short answer: yes. The poor conditions in prisons mostly stem from the overarching problem of overcrowding. Malaysia has 52 prisons in total, with an official capacity of 52,000.[5] However, there are 68,603 prisoners in total, as of August 2020, making the level of occupancy 131.9%.[6] The problem of overpopulation, present since 2016 is of such severity today that even the Prison Department and Ministry of Home Affairs have deigned to acknowledge it.[7]
In response, YB Nurul Izzah Anwar concurred that the government has taken some steps towards reducing prison congestion. For example, the Ordinan Darurat Kehadiran Wakil Pesalah-pesalah Pindaan 2021 was introduced to enable the release of low-risk prisoners and allow certain punishments to not be carried out behind bars. The government has also announced that they would be setting up 13 satellite prisons to reduce congestion issues. However, the latter solution does not address the main problem: “It’s not just about building new prisons, it’s really about addressing the fact that there’s no way you can ensure successful pandemic management in a closed, confined space, and [prisons are] one of those. “
YB Nurul Izzah Anwar opined the government has not done nearly enough in comparison with other countries at this crucial moment in time. This has inadvertently led to prisons becoming hotbeds for COVID-19 infections, which she likened to doling out death sentences to inmates. As of November 2020, more than 23 prison-related infection clusters have been reported nationwide, amounting to tens of thousands of COVID-19 cases within prison walls.
When the state of emergency was announced, it took away the opportunity for different branches of the government to convene and push for necessary pandemic countermeasures concerning prisons. This resulted in violations of the Mandela Rules regarding prisoners’ rights to basic health and wellbeing, not to mention the consequent threat to public health arising from the spillover of a prison-related COVID-19 cluster. As the PN administration has so far introduced zero laws to implement much-needed prison reform, YB Nurul Izzah saw the 5-day parliamentary sitting (set to begin on 25 July 2021) as a precious opportunity to ramp up progress and make up for the lost time.
Every single day you delay, looking at numbers, you can see that there are tens of thousands of new COVID-19 cases. These numbers are the ones we are aware of through dedicated contact tracing and testing, but we are not aware of those behind bars. - YB Nurul Izzah Anwar
Besides the congested environment, archaic structures (e.g. the bucket system), frequent water supply disruptions and insufficient funding altogether render hygiene care, adequate sanitation practices and physical distancing nearly impossible. It is no surprise then, that prisoners in Malaysia are particularly vulnerable to not just COVID-19, but also the common flu, scabies and tuberculosis, potentially spreading like wildfire in close quarters and endangering the lives of prisoners and wardens. Mr Abdul Rashid Ismail theorised that the conditions in holding and prison cells are deliberately kept at such deplorable levels to dehumanise detainees and prisoners.
Though many of the aforementioned diseases are treatable and usually non-fatal, prisoners also face the extra hurdle of impeded access to healthcare, largely due to the shortage of prison medical personnel – an issue amplified in unprecedented times such as the pandemic.[8] According to the 2018 Prison Department statistics, the ratio of doctors to prisoners is 1:1000, compared to the general population to doctor ratio of 1:454.[9] Evidently, there are insufficient doctors on hand to provide adequate healthcare for such a large number of prisoners, resulting in substandard care. YB Nurul Izzah Anwar also revealed that the custodial healthcare landscape is complicated by the conflict-of-interest medical personnel have, obligated to both their employer, the Prison Department and their patients: the prisoners. She stressed the need to establish some degree of career mobility for medical and dental officers working in Malaysian prisons as they have had to work beyond their abilities in tending to the inmates, risking themselves as well as their loved ones of infection while frequenting these places of detention. In addition, a key recommendation that the APPGM-RAPD has put forward with regards to more effective management of future pandemics is to place the purview of healthcare in prisons under the Ministry of Health. The overcrowding of prisons is one of the major issues that if handled, could solve many other consequential sub-issues.
Similar to the salient public health aspect of prisoners’ rights, the human rights perspective of their plight must be given equal importance. Independent agencies and NGOs are heavily constrained in their ability to detect incidents of concern taking place behind prison walls as inmates are separated from the public at large. Indeed, save for the little contact they are permitted with visiting family members, prisoners are virtually voiceless.
Prison wardens and police officers who are abusive towards prisoners and detainees have always enjoyed impunity, hiding behind higher authorities to escape accountability and inspection. One such horrifying case of abuse has surfaced since the pandemic: 22 prison inmates quarantined at Negeri Sembilan’s Jelebu Prison were allegedly beaten with canes, PVC pipes, chairs, wood pieces and other objects while handcuffed for an hour, had their private parts pepper-sprayed, then told to lie on the floor naked while beatings continued into the night.[10] None of them received hospital treatment for their injuries (except one who was treated for tuberculosis), and some have expressed to visiting family members that they have contemplated suicide over the abuse.
There has been a surge in stories about cruelty, brutality and inhumanity in prisons and police lockups during the tenure of Datuk Seri Hamzah Zainuddin as Home Minister. The then-retiring Inspector-General of Police, Tan Sri Abdul Hamid Bador had also complained that the Home Minister had politically interfered with the police and prevented it from becoming an independent and professional force.[11]
To date, 12 deaths in custody have been reported in 2021. Among the twelve, A. Ganapathy died after sustaining a serious leg injury from getting beaten with a rubber hose and being denied his right to receive immediate medical treatment.[12] Sevan Doraisamy, the executive director of Suara Rakyat Malaysia (SUARAM), estimated that 20-21 cases of death in custody are caused by abuse annually, and condemned the authorities for not addressing the issue seriously or attempting to put an end to the deaths. SUARAM’s 2016-2020 reports tallied 48 deaths in police lockups, 889 deaths in prisons and 181 deaths in immigration detention centres.[13]
No formal accountability mechanism currently exists against prison wardens or police officers who mistreat, abuse and torture prisoners. Previously, the Enforcement Agency of Integrity Commission (EAIC) was set up to regulate and investigate complaints made against government officials and bodies, but it was never wholly independent. The EAIC has since had their contract terminated in October 2019[14] and were told that they would be replaced by the proposed Independent Police Complaints of Misconduct Commission (IPCMC) Act.[15] At present, EAIC can only investigate complaints, but not take any action.[16]
Datuk Dr. P. Sundaramoorthy, a former professor of criminology in Universiti Sains Malaysia, highlighted that the formation of an independent panel - styled after the proposed IPCMC - to look into prison abuses would go a long way in ensuring responsibility among prison wardens and provide safeguards against misconduct and abuse of power.[17] In a similar vein, Charles Hector, a human rights lawyer, suggested that an individual independent of the Prisons Department should act as ombudsman or an official appointed to investigate complaints against a public authority.[18]
The proposed IPCMC Bill would address complaints, carry out investigations on misconduct committed by the police and set disciplinary procedures to deal with the misconduct which, according to Section 22 of the Act, includes (a) any action/inaction which is contrary to any written law; (b) non-compliance of rules and SOPs of the police; and (c) any act/inaction which is unreasonable, unjust, oppressive or improperly discriminatory. Several NGOs have been pushing for the Act to be tabled in the Parliament sitting this month, especially with the recent spate of custodial deaths. The Human Resources Minister Datuk Seri M. Saravanan has not raised the issue in Cabinet at all within the past year.
“Is our Parliament being suspended to allow untrammelled and unchecked abuse of power by certain political leaders?” - Lim Kit Siang
Another notable drawback is that mental health issues may develop and pre-existing conditions may worsen among inmates from being segregated from society.[19] Mental health issues must be recognised and treated seriously by the relevant authorities to ensure that affected inmates undergo treatments and begin their healing process immediately as per the diagnosis.[20] Consequently, there have been calls for rehabilitative architecture to be included as part of the prison reform in Malaysia.[21] However, due to the existing stigma against mental health and lack of political power advocating for such, such reforms seem like a faraway dream.
Do Prisons Facilitate Rehabilitation?
The problem of overflowing prisons naturally begs the question: why are the numbers of prisoners rising? Honest scrutiny of the prison population would lead one to wonder if there is any utility in incarcerating certain categories of offenders, especially when the Prison Department of Malaysia’s motto is menerajui perkhidmatan korektif (pioneering corrective services).
Pre-trial detainees contribute to a large part of the prison population, around 26.7% in 2018.[22] The massive number of pre-trial detainees in prisons is distressing, as it factors in miscarriage of justice. Prisons punish criminals by taking away their freedom. When bail is denied on a large scale, innocent suspects are wrongfully punished. Making matters worse, it is also a well-known fact that court procedures can drag on for years. Thus, conditions for bail must be revised to include non-cash bail, in order to decrease the number of detainees denied bail simply because they cannot afford it. Similarly, procedures for remand also need to be reviewed to make way for greater access to justice.
Drug addiction is a health issue instead of a criminal issue. - Abdul Rashid Ismail
Another major group in Malaysian prisons are drug addicts – in 2019 alone, 26,080 drug addicts were arrested throughout Malaysia.[23] Drug addicts are mostly arrested for drug-related offences, not violent crimes. The necessity of segregating them from society and locking them up in cells has been called for a probe in recent years.
Data from the US has shown that incarcerating people for drug-related offences have little impact on drug abuse rates.[24] It has an adverse effect instead – released inmates are at a 129% greater risk of dying from overdose than the general public.[25] Increased risks of overdose may be exacerbated by stress and depression suffered by inmates. High levels of stress and depression are very common among the prison population, and the roots of these mental illnesses are more often than not associated with imprisonment experience.[26]
Many newly admitted inmates suffer from depression due to shock or stress from adapting to the prison environment.[27] These mental illnesses, more prevalent among female inmates than male inmates, are often accompanied by self-harm and suicide.[28] A study in 2014 conducted by Universiti Sains Malaysia showed that 56.8% of male inmates and 75.9% of female inmates experienced stress and 40.5% of male inmates and 72.4% of female inmates experienced depression[29]. In another study, 10% of female inmates have been recorded to attempt suicide.[30]
Approaching the perennial issue of prisons serving a material purpose, just as the archaic forms of capital and corporal punishments, incarceration has been proven to be ineffective in deterring crime. Further, heavy punishment is ineffective as a crime deterrent for both potential criminals and formerly incarcerated inmates.
In 2011, the recidivism rate in Malaysia was 7.97%[31], but in 2018 it reached 10.32% (13,896 prisoners).[32] While Malaysia’s recidivism rates remain one of the lowest in Asia, the trend is concerning.[33] The main external factors leading to recidivism, include issues relating to employment and income, familial problems, and influence from the surrounding community.[34]
Repeat offenders often face familial problems, low socio-economic and/or educational backgrounds, live in communities hindering social reintegration, and do not receive adequate social support.[35] Subjecting them to imprisonment does not solve their problems, and emphasis should be placed on rehabilitation instead. Attesting to this, Mr Abdul Rashid believes prisoners should acquire practical skills and be provided with education as part of their rehabilitation to increase their chances of getting a job and earning a living, thereby avoiding relapses into the crime and poverty-stricken worlds upon their release.
Imprisoning drug offenders and other non-violent criminals is not only ineffective and damaging, but it also costs our country to keep them in prison - RM 2 to 3 million is spent annually just to punish drug offenders. YB Nurul Izzah has therefore been consistently advocating for a community-based rehabilitation approach to treat drug addicts, in hopes of keeping them out of prison. In recent years, she had worked to set up clinics attached to mosques, allowing drug addicts to receive both medicines to curb addiction and community support at the same time.
Recently, Parliament has also raised the possibility of replacing the Drug Dependents (Treatment and Rehabilitation) Act 1983 with the Drugs and Substance Abuse Act which focuses on rehabilitation and treatment rather than punishment. The government has started experimenting with rehabilitation programmes outside prisons in recent years. The parole system or community-based rehabilitation programme has proven to be effective, with a recidivism rate of only 0.4%.[36] It is hoped that by 2030, two-thirds of prison inmates will be rehabilitated within the community[37] Low-risk offenders, having only committed low-level offences should be allowed to rehabilitate within the community. instead of going for imprisonment as the default option as parole and community service may also serve as crime-deterring punishments.
Proposed Solutions
Adopted and proclaimed by the General Assembly Resolution 45/111 of 14 December 1990, Point 1 of Basic Principles for the Treatment of Prisoners reads: “ All prisoners shall be treated with the respect due to their inherent dignity and value as human beings.” Respectful treatment can improve the perceived legitimacy of the prison environment, minimise the occurrence of conflict within jail, and improve self-esteem as well as self-worth.[38]
In regard to minor drug offences implicating 36,000 individuals, Mr Abdul Rashid Ismail commented that these individuals should not be detained as drug-related offences should be treated as a health issue and imprisonment may worsen the conditions of these offenders.
Addiction can be completely controlled and kept at bay. Treatments have been proven to allow people to reclaim control of their life by counteracting addiction's severe disruptive effects on the brain and behaviour.[39] Targeted public re-education is more efficacious in eradicating drug abuse than punitive methods.[40] Further, by removing 36,000 individuals from the system, it can significantly ease overcrowding in prisons while allowing for the drug users to obtain effective rehabilitation.
Ubiquitous stigma and prejudice have denied convicts a second chance at life and opportunities to redeem themselves. For instance, most businesses are hesitant to hire ex-convicts and find them untrustworthy due to their marred history.[41] Their past of being a former prisoner and having served time in prison does not go away, making it arduous for them to reintegrate into society.[42] One way to uproot these stigmas would be by raising awareness of the importance of treating convicts and ex-convicts with dignity, including humane prison conditions and community-based rehabilitation. Be it by initiating or participating in discourses[43], social media activism[44] and other means of advocacy[45], these efforts would yield ripples of communitarian benefits.
Prison Reform - An Urgent and Meaningful Cause
To Mr Abdul Rashid Ismail, his staunch belief in treating prisoners with dignity is the driving force behind his tireless advocacy for their basic rights. He alluded to the tendency of some to treat prisoners as subhumans just because they had committed a crime. The fact that they have been arrested, convicted and have had their freedom of movement restricted does not mean that they subsequently lose their right to all other faculties of life in confinement. Though the penal system is meant for rehabilitation, released convicts will find making a return to society terribly onerous if their time in prison has left them traumatised from the mistreatment they suffered.
When it comes to the rights of prisoners, it is important for one to understand that one needs to treat them with dignity. - Abdul Rashid Ismail
YB Nurul Izzah Anwar, on the other hand, emphasised the lack of response to the urgent crisis prisoners are facing, especially the deafening silence of the executive arm in the midst of the pandemic. She recalled the affective words of Director-General Dato’ Haji Nordin Bin Haji Muhamad, who drew parallels between the lockdown and the plight of prisoners in confinement: “You members of Parliament have felt how [difficult] it is to be held and stopped from leaving your homes… so imagine the misery of prisoners.” This is symbolic of the Prison Department’s acceptance and espousal of recommendations for reform - in fact, many of the reform pledges (e.g. sentencing councils modelled after those in the UK) have emanated from the Prison Department itself. In truth, the real bottleneck lies with the executive, the Home Minister and the Attorney-General’s Chamber, who are the punca kuasa, holding power to approve or reject recommendations and drafts for legal reform.
We are working closely with different departments and Ministries, but the pandemic has really pushed back many of the efforts... we really need the executive to strengthen their political backbone because power is vested in their hands, and we hope that power will be used responsibly to address the needs of the most vulnerable. We do have legislative reforms (and it’s bad enough that we have not moved fast enough in that direction), but that is not the only dimension... we need more evidence-based approaches to overcrowding. This is not going to be the last pandemic, and overcrowding is going to stay with us. Looking at how we imprison lives is crucial. - YB Nurul Izzah Anwar
It is clear from our conversations with YB Nurul Izzah Anwar and Mr Abdul Rashid Ismail, there is simply no excuse for depriving prisoners of their fundamental human rights just because they have been convicted of a crime. As such, HAKAM Youth echoes the sentiment of both these advocates that the Malaysian society must thoroughly re-evaluate our attitude towards prisoners: who they are, how they are treated, other alternatives to rehabilitate certain types of offenders and indeed, the type of conduct we view as criminal and deserving of incarceration or other punitive repercussions in the first place.
References:
[1] Laws of Malaysia (Act 537) - Prison Act 1995.
[2] United Nations Standard Minimum Rules for the Treatment of Prisoners (The Nelson Mandela Rules).
[3] Paul Gregoire and Ugur Nedim, 'The Mandela Rules: Minimum Prison Standards Must Be Implemented' (Sydney Criminal Lawyers, 2018) <https://www.sydneycriminallawyers.com.au/blog/the-mandela-rules-minimum-prison-standards-must-be-implemented/> accessed 13 July 2021.
[4] ibid 3.
[5] World Prison Brief, ‘Malaysia’ <https://www.prisonstudies.org/country/malaysia> accessed 11 July 2021.
[6] ibid.
[7] ibid.
[8] Mazwin Nik Anis, ‘In Wake of Covid-19 Clusters, Prison Authorities Told to Come up with New SOPs’ The Star (Putrajaya, 2020) <https://www.thestar.com.my/news/nation/2020/10/07/in-wake-of-covid-19-clusters-prison-authorities-told-to-come-up-with-new-sops> accessed July 26, 2021.
[9] Zethy Suhaidah, Swee Kheng Khor and Sharan Raj, 'Letter - How To Reduce Covid-19 In Malaysian Prisons' Malaysiakini (2021) <https://m.malaysiakini.com/letters/576855> accessed 28 July 2021.
[10] Lim Kit Siang, 'Torture and Murder In Police Custody: When Will This Barbarism End?' Focus Malaysia (2021) <https://focusmalaysia.my/torture-and-murder-in-police-custody-when-will-this-barbarism-end/> accessed 19 July 2021.
[11] ibid.
[12] ibid 9.
[13] Elly Fazaniza, 'Call for Prison Abuse Watchdog Panel' The Sun Daily (Petaling Jaya, 2021) <https://www.thesundaily.my/home/call-for-prison-abuse-watchdog-panel-XA7882347> accessed 25 July 2021.
[14] Minderjeet Kaur, 'Activate EAIC Again until IPCMC is Set Up, Say Activists' Free Malaysia Today (Petaling Jaya, 2020) <https://www.freemalaysiatoday.com/category/nation/2020/01/09/activate-eaic-again-until-ipcmc-is-set-up-say-activists/> accessed 26 July 2021.
[15] Syed Jaymal Zahiid, 'The IPCMC: What You Need to Know, and Why It Matters Now More Than Ever’ Malay Mail (Kuala Lumpur, 2019) <https://www.malaymail.com/news/malaysia/2019/04/05/the-ipcmc-what-you-need-to-know-and-why-it-matters-now-more-than-ever/1739981> accessed 26 July 2021.
[16] 'Backlog of Complaints Piling Up at EAIC After Commissioners Told to Leave' Free Malaysia Today (Putrajaya, 2020) <https://www.freemalaysiatoday.com/category/nation/2020/01/08/backlog-of-complaints-piling-up-at-eaic-after-commissioners-told-to-leave/> accessed 26 July 2021.
[17] ibid 10.
[18] ibid.
[19] Amy Morin, ‘How Being In Prison Might Affect Your Mental Health’ (Verywell Mind, 2021) <https://www.verywellmind.com/menta-health-effects-of-prison-5071300> accessed July 26, 2021.
[20] ibid.
[21] Aainaa Azhari, ‘Reforming the Prison System: A New Perspective’ Malaysiakini (29 January 2019) <https://www.malaysiakini.com/news/462153> accessed July 26, 2021. [22] ibid.
[23] Dato' Sri Dr. Mohd Uzir Mahidin, ‘Crime Statistics Malaysia 2020’ (Department of Statistics Malaysia, 20 November 2020) <https://www.dosm.gov.my/v1/index.php?r=column/cthemeByCat&cat=455&bul_id=UFZxVnpONEJqUU5pckJIbzlXeEJ1UT09&menu_id=U3VPMldoYUxzVzFaYmNkWXZteGduZz09> accessed 11 July 2021.
[24] Betsy Pearl. ‘Ending the War on Drugs: By the Numbers’ (27 June 2018) <https://www.americanprogress.org/issues/criminal-justice/reports/2018/06/27/452819/ending-war-drugs-numbers/> accessed 11 July 2021.
[25] ibid.
[26] Affizal Ahmad and Nurul Hazrina Mazlan, ‘Stress and Depression: A Comparison Study between Men and Women Inmates in Peninsular Malaysia’ (2014) 4(2) International Journal of Humanities and Social Science 153-160.
[27] ibid.
[28] ibid.
[29] ibid.
[30] Teh Yik Koon, ‘Female Prisoners in Malaysia’ (2006) Journal of Offender Rehabilitation 45-64.
[31] Suhaizak Ab. Wahab, ‘An Introduction to Treatment and Rehabilitation for Illicit Drug Use Offenders in Malaysian Prisons’ (2018) 170th International Training Course Participants' and Observers' Papers 40-47.
[32] Mohd Alif Jasni, Siti Hajar Abu Bakar Ah and Norruzeyati Che Mohd Nasir, ‘Tough Life after Prison: An Analysis of 19 Former Prisoners in Malaysia’ (2021) Journal of Community Development Research Humanities and Social Sciences 24-36.
[33] ibid 29.
[34] ibid 30.
[35] ibid 28, 30.
[36] ‘Prisons Dept D-G: Malaysia’s Parole System Effective in Reducing Recidivism’ Malay Mail (Kuala Terengganu, 22 July 2020) <https://www.malaymail.com/news/malaysia/2020/07/22/prisons-dept-d-g-malaysias-parole-system-effective-in-reducing-recidivism/1887000> accessed 11 July 2021.
[37] ibid.
[38] Michelle Butler and Deborah H. Drake, 'Reconsidering Respect: Its Role In Her Majesty's Prison Service' (2007) 46 The Howard Journal of Criminal Justice.
[39]‘How Effective Is Drug Addiction Treatment?’ (National Institute on Drug Addiction,3 June 2020) <https://www.drugabuse.gov/publications/principles-drug-addiction-treatment-research-based-guide-third-edition/frequently-asked-questions/how-effective-drug-addiction-treatment> accessed July 26, 2021.
[40] ‘Contributory Factors: Drug Abuse in Malaysia’ (Monash University Malaysia, 8 January 2021) <https://www.monash.edu.my/research/researchers-say/contributory-factors-drug-abuse-in-malaysia> accessed 26 July 2021.
[41] Kalbana Perimbanayagam and Mohd Noor Aswad, 'No Matter How Much Good You Do, the Stigma Stays Forever' New Straits Times (Kuala Lumpur, 3 July 2019) <https://www.nst.com.my/news/nation/2019/07/501082/no-matter-how-much-good-you-do-stigma-stays-forever> accessed 26 July 2021.
[42] ibid
[43] Hilary Janks and Terry Locke, ‘Discourse Awareness in Education: A Critical Perspective’ (2008) Hornberger N.H. (eds) Encyclopedia of Language and Education.
[44] John D. H. Downing, ‘Social Movement Media and Media Activism’ (2018) Oxford Research Encyclopedia of Communication.
[45] Carl Rhodes, Christopher Wright and Alison Pullen, ‘Changing the World? The Politics of Activism and Impact in the Neoliberal University’ (2017) 25 Organization 139.