Maid abus e in mal ays ia

AB S T R ACT
This research paper discusses on the escalating cases of maid abuse happening in Malaysia which has
generated much attention in the media. The lack of legal protection for foreign domestic workers has
resulted in fractures among diplomatic ties between Malaysia and Indonesia, the largest exporter of
maids to our country. This research aims to identify the lacunas in our legal system which has led to the
rampant cases of maid abuse and suggestions to remedy the situation. In addition, emphasis is also
given towards the many organizations within Malaysia and at the international level which have been
fighting for the rights of foreign domestic workers over the years. Generally, this research paper consists
of headlines on recent maid abuse cases, reports on the struggle of various organizations, insights in the
loopholes of our laws and analysis of the rationale behind Malaysia taking fast steps to solve this
pressing issue of maid abuse.

K E YW OR D S
Malaysia, Indonesia, maid abuse, foreign domestic workers, migrants, laws.

1
IN T R OD U CT ION
In Malaysia, the number of maid abuse cases has been increasing every year and this is a serious
trend which must not be taken lightly. On 26 June 2009, it got to the point where Indonesia temporarily
banned maids from getting employed in Malaysia.1 This has caused severe effects to Malaysia which
relies heavily on foreign labour, driving maid agencies out of business and disrupting daily management
of households.

Firstly, this research paper discusses the origins of maids since the medieval world and an
overview of modern maids today. Then, the plights of abused maids come into the scene and Malaysia’s
stance is questioned regarding the recent developments of maid abuse cases.

The second part of this research paper is designed to recognize the causes of maid abuse in
Malaysia. After going through reports, newspapers, journals and analyzing opinions from experts, we
have identified that the main cause of maid abuse lies in our flawed legal system which offers little, or
no protection whatsoever to foreign domestic workers.

Later, the research assignment is going to discuss the efforts done to alleviate the plight of
foreign domestic workers. It was found that several non-governmental organizations (NGOs), the
Human Resources Ministry, legal experts and top leaders of the nation are making the effort to remedy
the situation, especially by having talks and meetings with the Indonesian government. In addition, we
are able to analyse the development of policies that benefit foreign domestic workers over the months
since Indonesia started its maid freeze in July 2009.

After going through the efforts made to improve working conditions of maids, it is only natural
now to identify the flaws and fractures in our legal system which catalysed the rampant maid abuse
cases in Malaysia. This research’s main objective is to analyse parts of the Employment Act have gaping
loopholes for us to look into that do not protect the thousands of foreign domestic workers in this
country.

The significance of this research paper is explained when it dwells into the rationale and reasons
on why maid abuse has to be stopped. The diplomatic ties of Indonesia and Malaysia, safety of
Malaysians and blatant violation of human rights are at stake here. Malaysia needs to act fast in
amending the laws and showing that it is genuine in solving the problem of maid abuse.

Moreover, this research also accommodates a case study on a court case regarding maid abuse
and the relevance of the court’s ruling towards both employers and maids in Malaysia.

Lastly, all the issues that we have discussed are linked and suggestions to remedy the situation
at hand will be elaborated.

1
Cheah, Royce. (2009, June). Indonesian maid ban: Busted businesses and households, The Star Online, retrieved
on 10 October 2010, from
http:/ / thestar.com.my/ news/ story.asp?file=/ 2009/ 6/ 26/ nation/ 20090626143651&sec=nation

2
H IS T OR Y AN D OR IGIN S OF MAID S
The maid system originated from a long slave history. It was a system in which people are made
into the property of others. Slaves can be held against their wills from the time of their capture,
purchase or birth and deprived of the right to leave, to refuse to work or even to demand
compensation.

It all started 11,000 years ago during the Neolithic Revolution after the invention of agriculture
activities. Slavery entered the human history with civilization.2 During the early part of life, hunter-
gatherers and primitive farmers have no use of slaves because they collect or grow just enough food for
themselves and there was no economic advantage in owning another human being at that time.
However, once people gather in towns and cities, a surplus of food was created in the countryside,
which made in possible for a wide range of crafts in town.

At that point of time, there was a need for slavery on condition that the costing is no more than
the minimum of food and lodging. Back then, slaves are easy to acquire as history shows every ancient
civilization in the world having slaves. People became slaves due to their debts, punishment for their
crimes and enslavement for being prisoners of wars. Furthermore, most of them are abandoned
children, the offspring of slaves themselves and in many cases, captives sold by notorious pirates.3

Ancient civilizations like Egypt, China, the Acadian Empire, Assyria, India, Greece and many more
world powers exploited slaves. In the civilization of Greece for example, the land of Sparta and Athens
were depended upon forced labour.4 The majority was domestic servants, where the male slaves will
run the household as stewards and the female slaves look after the children or acted as concubines. The
Romans slaves were employed with greater brutality. They were whipped by overseers in mines and
forced to engage in terrifying combat as gladiators in public arenas.

Slavery continues in the countries around the Mediterranean as slaves were employed almost
exclusively in households, offices, and armies. This is due to the fact that the Mediterranean provides
the geographical and economic environment to encourage a slave trade, even though its civilized
regions were surround by the central sea, but the north and south stretch vast areas were populated by
unsophisticated tribes. Therefore, there was border warfare that resulted in tribal captives being
enslaved and there was the presence of market forces that encourage these tribes to seize prisoners of
their own to service a developing slave trade.

Slavery was also accepted during the time of Prophet Muhammad in the 7th century as the
Quran offers no arguments against slavery except for the fact that slaves should be well treated. Slaves

2
History of Slavery, History World, retrieved on 5 October 2010, from
http:/ / www.historyworld.net/ wrldhis/ PlainTextHistories.asp?historyid=ac41
3
History of Slavery, Wikipedia (2010), retrieved on 3 October 2010, from
http:/ / en.wikipedia.org/ wiki/ History_of_slavery
4
Op.cit.

3
in African cultures were basically not to be made the chattel of other men, nor enslaved for life as they
were paid with wages and were able to accumulate property.5

In the 1900s, domestic workers or maids were once part of an elaborate hierarchy in great
houses, featuring dominantly in British mansions. In this modern world, a single maid may be the only
domestic worker that upper and even middle-income households can afford, as was always the case for
many households. In the Western world, people rely on periodic cleaners because few households can
afford live-in domestic help.

This is a brief historical flashback of the history of slavery which basically led to the development
of modern domestic workers we see today. It is a fact that slaves were once inhumanely treated and as
time passes, these helpers were given better treatment and granted certain rights.

5
History of Slavery, Wikipedia ( 2010), retrieved on 3 October 2010, from
http:/ / en.wikipedia.org/ wiki/ African_slave_trade

4
OVE R VIE W OF F OR E IGN D OME S T IC W OR K E R S
This segment of the research paper is a basic overview of the condition and employment of
maids around the world.

A domestic worker or in current usage maid is a female employed in domestic service. Maids
perform typical domestic chores such as cooking, ironing, washing, cleaning the house, grocery shopping,
walking the family dog, and taking care of children. In many places in some poor countries, maids often
take on the role of a nurse in taking care of the elderly and people with disabilities.

In Asia, women from Indonesia, the Philippines, Sri Lanka, Bangladesh, Pakistan and India often
go to Middle East oil exporting countries as well as Malaysia, Singapore and Hong Kong to be domestic
workers.6 There was a drastic increase in migration trends during the Asian financial crisis where large
numbers of women who work in low-skilled wage employment were laid off. The total number of
international labour migrants deployed from Indonesia increased from 120, 896 in the period of 1995-
1996 to 235,275 in 1997-1998.7 In 2007, the World Bank showed that 88% of female migrant workers
work in the domestic sector which has dirty and dangerous conditions.8

Abuse means wrong or improper use; misuse: the abuse of privileges, harshly or coarsely
insulting language; bad or improper treatment.9 For example, the acts of scalding the skin using an iron,
splashing boiling water, whipping using belts or hangers, slapping and punching are unethical abuses
suffered by maids daily. Besides, sexual abuse and harassment by employers towards maids often result
in deep mental torture.

6
(2010, October). Southeast Asia: Maids, Countries, Migrant News, retrieved on 11 October 2010, from
http:/ / migration.ucdavis.edu/ mn/ more.php?id=3033_0_3_0
7
G.Hugo. “Establishing the information needs of Indonesian international labour migrants: background and
methodology.” Paper presented at Workshop Indonesia. PPT-LIPI in collaboration with ILO (Jakarta, May 20-23,
2000)
8
Raul Hernandez-Coss et al, The Malaysia-Indonesia Remittance Corridor: Making Formal Transfers the Best Option
for Women and Undocumented Migrants, World Bank Working Paper No. 149. (World Bank: Washington DC,
2008), p. xiii
9
Oxford Dictionary

5
 The pressing issue of maid abuse is widespread and not confined to a few nations only. As what
Human Rights Watch reported in the state of Kuwait, migrant domestic workers are forced to work long
hours with no days off, are deprived from adequate food and suffer physical or sexual abuse. What is
worse is that they face state prosecution when they try to escape.10

Back in South East Asia in our neighbour Singapore, a 40 year old employee named Annie Tan
banged her maid Vilma Lambino Manuel’s head against the wall 3 times and slapped her face, causing
her nose to bleed.11 She had done this just because her maid ate biscuits on 18 September 2008. Ms
Annie may face a jail term of up to three years or a fine of up to $5,700 on each charge. On November
2008, a police staff, Lawrence Lim Hwang Ngin, 36, was found guilty on five charges for kicking his
Indonesian maid, hitting her on the head and rapping her forehead with his knuckles. He was sentenced
to a year‘s jail.12 In a separate case, Tay Wan Leng, 41, was jailed for five weeks and fined $700 for
pinching and slapping her Indonesian maid.13 Besides the escalating number of maid abuse cases in the
island republic, one should also be concerned at the unconvincingly low monetary compensations and
lenient jail terms meted out as punishment, which could hardly serve as a reminder to the public.

10
Kuwait Samachar. (2010, October). Maid abuse rising in Kuwait: HRW, SILObreaker, retrieved on 8 October 2010,
from http:/ / v2.silobreaker.com/ maid-abuse-rising-in-kuwait-hrw-5_2263778249840525394
11
Chong, Elena. (2010, September). Exec cleared of maid abuse, The Straits Times, retrieved on 9 October 2010,
from http:/ / www.straitstimes.com/ BreakingNews/ Singapore/ Story/ STIStory_580786.html
12
Iyer, Rahman. (2008, November). Singapore jails police officer, woman for maid abuse, Top News Law, retrieved
on 2 October 2010, from http:/ / www.topnews.in/ law/ singapore-jails-police-officer-woman-maid-abuse
13
Ibid 5

6
T H E P L IGH T S OF AB U S E D MAID S
In Malaysia, where the focus of this assignment lies, it is indeed shocking that our country has
an alarmingly high rate of maid abuses reported every single year. In the chronology of events that have
unfolded in recent years, we begin back in November 2008 where the infamous Nirmala Bonat abuse
case shocked the nation.14 Housewife Yim Pek Ha was sentenced to 18 years jail after she was found
guilty of three charges for causing grievous hurt to her former Indonesian maid Nirmala Bonat. Yim Pek
Ha scalded Bonat with both hot water and iron. In addition, Bonat was beaten and burned for mistakes
she made during the 5 months she worked in Yim’s home since 2004. The accused even took a hot iron
and pressed it against Bonat’s breasts after complaining that the clothes had not been ironed properly
by her. There were a lot of burns and bruises over much of her body. On appeal to the High Court,
Judicial Commissioner Azman Abdullah reduced Yim Pek Ha’s sentence to 12 years. Human rights groups
and Indonesian officials have urged Malaysia to strengthen laws to protect some 300,000 Indonesia
domestic workers.

On July 2009, another two cases of maid abuse surfaced. A 45-year-old, who has been beating
her maid for 1-1/ 2 years, was caught unaware when her son, 17, surrendered his handphone with the
recording to police. It was later revealed that the video showed his mother beating the maid. But the
other maid, Ms Modesta Rangga Kaka, 25, was not so lucky.

Housewife Choo Pei Ling, 37, who was seven-months pregnant, owed nearly RM10,000 ($4,100)
in wages to Ms Kaka. Moreover, the maid claims of abuse ranged from being fed once a day, caned,
punched and being told to bathe with bleach to cleanse her of "kuman" (Malay for germs) that her
employer accused her of harbouring. She was only rescued when neighbours heard her yell for help
after being locked in the house for not doing laundry.

Once again, shockwaves spread all over Malaysia with a recently reported case on an Indonesian
maid who was abused by her employers in Penang on 17 September 2010.15

A 26-year-old Indonesian maid, with burnt and scalded marks found on her back and chest, also
claimed she was hit on the head, hands and legs by her employers using a belt. Later, there was a
shocking revelation that the employer, in the most unimaginable way, had engaged the victim in a
threesome sexual act with his wife. The maid’s horrifying four-month ordeal came to an end when she
was given RM30 before being dumped at a residential area by her employers. She was then left
wandering by the roadside for more than 12 hours before a good Samaritan brought her to a police
station in the district the following day.

Such are the cases of maid abuse in Malaysia and there will be many more to come if steps are
not taken to address this issue. In fact, there are many more unreported cases and perhaps hundreds
more suffering silently under the hands of Malaysian employers.

14
(2010, November). Nirmala Bonat case: Housewife found guilty, 18 years jail, The StarOnline, retrieved on 30
September 2010, from
http:/ / thestar.com.my/ news/ story.asp?file=/ 2008/ 11/ 27/ nation/ 20081127110151&sec=nation
15
Sin Chow, Tan. (2010 September). Maid alleges employers hit her, forced threesome sex on her, The Star Online,
retrieved on 30 September 2010, from
http:/ / thestar.com.my/ news/ story.asp?file=/ 2010/ 9/ 18/ nation/ 20100918144529&sec=nation

7
MAL AYS IA’S S T AN CE
Over and over again, the Malaysian public never ceases to witness such gruesome acts of
atrocities happening at home.

The question is: Why are Malaysians continuing to be oblivious to this state of affairs and not
taking any concrete actions? Doesn’t the society in general know that abusing any person is a gross
infringement of human rights itself? What are the rippling effects of the high cases of maid abuse?

One of the most worrying concerns faced is the decision by the Indonesian government to ban
the export of maids into Malaysia. This is in accordance to the shocking number of maid abuse stories
highlighted in the Indonesian media which has, rightfully so, triggered the anger of its people.

Because of this, maid agencies are set to suffer huge losses due to Indonesia’s indefinite ban on
sending maids. Tens of thousands of households would face problems due to the delay in the arrival of
maids, leading to bigger problems in the long run as families struggle to cope with work and family
without helpers. The major problem faced now is the strained relationship between Kuala Lumpur and
Jakarta, which directly dwells into the economic, social and political ties by these two neighbouring
Muslim nations. This is a sign to the Malaysian government that something drastic needs be
implemented soon to address the issue of maid abuse.

Prime Minister Datuk Seri Najib Tun Razak nailed the important message for swift action to
protect the welfare and well being of foreign domestic maids. “We must step up effort to show more
caring attitude towards the welfare of the maids,’’ he said. “We must be quick to take action in cases
where maids are abused. Legal action taken should be fast and effective.

“We must step up effort to show more caring attitude towards the welfare of the maids,’’ he
said.16

The problem now is that the Malaysian legal system doesn’t have the capability to combat maid
abuse. The Malaysian government just announced plans last May for new laws to protect domestic
workers from sexual harassment, non–payment of wages and poor working conditions. The Prime
minister believes that the pressure to stop sending maids to our country is only temporary and he will
do his best to lift the ban.

In the meantime, the burden lies on the Parliament to elect new laws, government to enforce
regulatory controls and the public to be vigilant for this issue to be solved.

16
Habibu, Sira; Kong, Lester. (2009, June). Najib: Act fast to check maid abuse, Frost’s Mediations, retrieved on 1
October 2010, from http:/ / www.martinfrost.ws/ htmlfiles/ june2009/ check-maid-abuse.html

8
S t eps T ak en T o Addr es s Maid Abus e
Despite the many criticisms leveled against Malaysia, efforts have nevertheless been made by
the government to solve this issue. Furthermore, it is salutary that many organizations have stood up
and voiced out loud for the better protection of foreign domestic workers.

In May 2010, a Letter of Intent (LoI) on amendments to the MoU on the Recruitment and
Placement of Maids from Indonesia between the two governments was signed, witnessed by Prime
Minister Najib Razak and Indonesian President Susilo Bambang Yudhoyono.17 The agreement granted
maids one day off a week and ensured that they can keep their passports while in service. 18

However, a minimum wage still could not be agreed on. Later, on August 2010, the Indonesian
government demanded a minimum wage of RM800 a month. Human resources minister Datuk Dr. S.
Subramaniam said the memorandum of understanding between Indonesia and Malaysia on the proposal
could not materialise because Malaysia does not have a minimum wage structure.19

The Woman, Family and Community Development Ministry has been providing the Talian Nur
hotline service, created specifically to accept reports on maid abuse. The Ministry has received 83 calls
on maid abuse since it was activated on December 14 2009 until May 9 2010.20

G.Rajasekaran, secretary-general of the Malaysia Trade Unions Congress, has lobbied the
government to enforce minimum standards on working hours, living conditions and a RM600 minimum
wage.21 On the other hand, President of the Malaysian Bar Council, Mr. Ragunath Kesavan, also
recommended a few measures to tackle this issue. For example, urging the Employment Act to be
amended because domestic workers are currently not entitled to paid annual leave, sick leave or
limitations to the number of hours they should work.22

Tenaganita, a non-governmental organisation dedicated to fighting for the rights of migrants,

have also been an advocate for change in the laws of the country in the light of many maid abuse cases.
Its director, Ms. Irene Fernandez, said that contracts drawn up between the foreign maid and her
employer should include a lot more specifications referred to in the Employment Act, such as details of
working hours, off days, medical leave and wages.23 From 2004-2007, Tenaganita has rescued 148

17
Zulfakar, Mergawati; Singh, Dharmender. (2010, May). Indonesia expected to lift maid ban in two months, The
Star Online, retrieved on 5 October 2010, from
http:/ / thestar.com.my/ news/ story.asp?file=/ 2010/ 5/ 19/ nation/ 6287994&sec=nation
18
Ibid.
19
(2010, August). Indonesian maid minimum wage ‘unacceptable’ – Malaysia, Bintulu.org, retrieved on 5 October
2010, from http:/ / www.bintulu.org/ news/ 2010/ 08/ 08/ indonesian-maid-minimum-wage-unacceptable-malaysia-
minister.php
20
Hani, Azreen.(2010, June). Maid abuse tops Talian Nur list, Malay Mail Online, retrieved on 6 October 2010,
from http:/ / www.mmail.com.my/ content/ 40348-maid-abuse-tops-talian-nur-list
21
Adiwira in News. (2009, June). Abuse of Indonesian Maids, Warkah, retrieved on 7 October 2010, from
http:/ / warkah.com/ abuse-of-indonesian-maids/
22
(2009, June). Indonesian maid abuse will happen again!, Kinabalukini, retrieved on 10 October 2010, from
http:/ / kinabalukini.wordpress.com/ 2009/ 06/ 19/ indonesian-maid-abuse-will-happen-again/
23
Kaur, Ajinder. (2001, April). Maid abuse requires more solutions, Malaysiakini, retrieved on 12 October 2010,
from http:/ / www.malaysiakini.com/ news/ 2119

9
abused Indonesian maids with the help of the Malaysian police after the organisation received over 200
calls via its Domestic Workers Action Line. It has also recorded 1,050 violations of human rights, such as
non-payment of wages and sexual and physical abuse. On average, each domestic worker suffered 6-7
rights violations.24

Besides that, the government also decided to make it compulsory for foreign maids and
employers to attend a half- day course to learn about their respective responsibilities. Human Resources
Minister, Datuk Dr. S Subramaniam, had asked the Manpower Department to organise the course
throughout Malaysia every month. This course is held to curb maid abuse and at the same time reduces
wrong deeds of maid such as stealing. It also helps foreign maids to suit their life in Malaysia.25

24
Sally Cameron, Trafficking and Related Labour Exploitation in the ASEAN Region, International Council on Social
Welfare (ICSW) Briefing Paper, November 2007, p. 82.
25
Shari, Izatun. (2010, February). Foreign maids, employers must attend course from end of March, The Star

Online, retrieved on 12 October 2010, from

http:/ / thestar.com.my/ news/ story.asp?file=/ 2010/ 2/ 21/ nation/ 20100221193954&sec=nation

10
L OOP H OL E S IN T H E L AW
The main reason why maid abuse is so rampant in Malaysia is the lack of legal protection. There
are a few glaring weaknesses in the Employment Act 1995 that we should analyse into.

Firstly, there is no specific definition of ‘domestic work’ in the act itself, which exposes foreign
workers such as maids to exploitation. Under existing legislation, domestic workers are defined as
“servants” under the Employment Act 1955, and as such they are excluded from regulations relating to
such issues as rest days, hours of work, and termination benefits. While employers enjoy the benefit of
at least a day off a week, the nature of domestic work usually means that most foreign domestic
workers are on call for work twenty-four hours a day and seven days a week.

Because there are no guidelines to the specifity or nature of domestic work, it is up to the
employers to arbitrarily define the job description, sometimes to highly unreasonable levels. In many
cases, foreign domestic workers find themselves working not only in the employer’s house but also in
the homes of employers’ relatives, restaurants and other business outlets owned by their employer. As
a result, some maids have to work as long as sixteen hours a day, seven days a week without a break in a
year.

It is time that all levels of society recognise the contribution foreign domestic workers make
throughout society, by granting them the same labour rights and protection that is accommodated to
any other worker who deserves a day’s rest from work for the sake of their physical and psychological
well being.

Another issue that is of concern is the absence of a minimum wage for foreign domestic workers
in the context of our laws. Foreign domestic workers are the lowest paid workers in Malaysia. An
Indonesian domestic worker can earn as low as U.S.$92 a month in Malaysia, which is half the amount a
Filipina domestic worker earns (U.S.$200/ month).26 Furthermore, a “domestic servant” as defined by
the Employment Act, can only claim for unpaid wages in the labour courts. Before this, even their
passports and legal documents are held by employers or agents and they risk arrest by the immigration
services and RELA if they attempt to leave their employers to seek legal help.

Thirdly, maids are subjected to abuse if homes continue to be a private sphere. Maids are
usually confined to their employer’s household and lack access to health services and legal redress
should they face abuse. Due to the nature of home being viewed as simply a private sphere rather than
as a place of work, domestic workers are isolated from public scrutiny.

Perpetrators usually have little to fear from the criminal justice system. Unless the home is
recognised as a workplace under these conditions and those employed within are protected in terms of
their labour and human rights, the problem will continue and the abuses left unchecked.

26
Humans Right Watch, Help Wanted: Abuses against Female Domestic Workers in Indonesia and Malaysia. Vol.
16, No 9 (July 2004).

11
 R AT ION AL E
The rationale to look into the issue of maid abuse is that it concerns the diplomatic relationship
between two countries, Malaysia and Indonesia.

The highly publicised maid abuse cases have triggered much anger among certain
segments in t he Indonesian society and t his is reflected by t he many demonstrations which
have occurred over t he years. Recently, on 22 September 2010, Indonesian act ivists
demonstrated against Malaysia, this time over the physical and sexual abuse of an Indonesian
maid, Win Faidah, by her employers, a couple, in Malaysia. 27

Win Faidah, 26, from East Java, was scalded in t he breasts by a hot iron and was splashed
by boiling water. Her head was clobbered with a hard object and her limbs whipped with a waist belt.
Worse, she was sexually abuse by her employers.

The Ant i-Malaysia Yout h Alliance which was actually dominated by the Benteng
Demokrasi Rakyat (BENDERA), staged protests in a convoy of 150 motorcycles in t he anti-
Malaysia demonstration. The two other groups involved were t he Gerakan Pemuda Daerah
(District Youth Movement) and Relawan Pro Demokrasi (Pro-Democracy Volunteers). 28

The words "Ganyang Malaysia" (Crush Malaysia) were uttered in front of the Malaysian
ambassador's residence in Patra Kuningan and the Malaysian embassy in Kuningan, South
Jakart a. This is a very serious issue because it inst ils a very negative perception and deep hatred
amongst the minds of ordinary Indonesians. Plus, it reignites the dark history during t he
Indonesian-Malaysia confrontation during the formation of the federation of Malaya in 1963.

Indonesia and Malaysia have already embroiled in a fair share of controversies such as the
alleged incursions into Indonesian waters by the Royal Malaysian Navy in the Ambalat region29 and the
alleged ill-treatment of teenage model Manohara Odelia Pinot at the hands of her Kelantan prince
husband. 30 In addition, certain segments of Indonesian society are still enraged over Discovery
Channel’s depiction of the pendet dance, a tradition Indonesians feel strongly of, belonging to
Malaysia.31

27
(2010, September). Another Bendera protest demo in Jakarta, now on abused maid case, The Malay Mail,
retrieved on 3 October 2010, from http:/ / www.mmail.com.my/ content/ 50132-another-bendera-protest-demo-
jakarta-now-abused-maid-case
28
Ibid
29
Jusuf, Muhamad. (2009, May). Royal Malaysian Navy alleged went to Indonesian waters jurisdiction, ALLVOICES,
retrieved on 2 October 2010, from http:/ / www.allvoices.com/ contributed-news/ 3307172-royal-malaysian-navy-
alleged-went-to-indonesian-waters-jurisdiction
30
Manohara Odelia Pinot : Model Flees Clutches of Malaysian Prince, The News Bizarre, retrieved on 2 October
2010, from http:/ / newsbizarre.com/ 2009/ 06/ manohara-odelia-pinot-model-flees.html

31
Traditional dance is spurring unlikely calls for war, Intro2u Blog, retrieved on 11 October 2010, from
http:/ / www.intro2u.net/ new/ 2009/ 09/ traditional-dance-is-spurring-unlikely-calls-for-war/

12
 This is especially true when at times, the Indonesian media tend to manipulate t he issue
of maid abuse and create raging sentiment s among the readers. Malaysian defence minister
Ahmad Zahid Hamidi put it aptly, when, on the 12th of June 2009, he called on the Indonesian media to
refrain from sensationalising issues, which could be settled in a proper and amicable manner. "I hope
the Indonesian media will stop manipulating these issues, which have caused demonstrations to take
place outside the Malaysian Embassy in Jakarta," he says.32

It is worrisome that this chain of events, added with the maid abuse issue, would paint a bad
image of Malaysians among the people of Indonesia.

Secondly, the rationale into resolving maid abuse is to protect our national pride and identity.
This is because in the course of demonstrations, Indonesians have acted in ways that have humiliated
Malaysia’s national symbols and smeared our dignity.

For example, Bendera activists have been st aging anti-Malaysia demonstrations daily in
front of the Malaysian embassy where they stomped on, spat at and burned the Malaysian flag,
besides throwing faeces into the embassy following t he arrest of t hree officers from Indonesia's
Marine and Fisheries Ministry by Malaysian marine police for alleged encroachment of
Malaysia's territorial wat ers. 33

A nation’s flag represents and symbolises the love and devotion to a country and it is absolutely
dishonourable to see the Jalur Gemilang which has been raised proudly 53 years ago being desecrated in
this manner.

Thirdly, we have to take into considerat ion the safety of Malaysians in Indonesia itself.
Bendera have vowed to sweep Malaysians off the streets here. Armed with sharpened bamboo
and setting up roadblocks to screen for Malaysians, this is indeed a worrying trend because of
the high number of Malaysians residing in Indonesia, be it for business t ransactions, vacat ions,
family visit s or pursuing higher educat ion in various universit ies in Indonesia. Besides, Bendera
also threatened to ‘invade’ Malaysia wit h 1,500 people and are also aiming to gat her support
from the thousands of Indonesian workers in Malaysia. 34

Fourthly, Malaysian maid agencies will suffer huge losses due to Indonesia's indefinite ban on
sending maids. Raja Zulkeply Dahalan, president of the Malaysian Association of Foreign Maid
Agencies said that losses incurred could rise up to RM3.5 million.35

32
Osman, Salim. (2009, June). Indonesian president phones maid in abuse case to offer support, Asia News
Network, retrieved on 4 October 2010, from http:/ / www.asianewsnet.net/ news.php?id=6275&sec=1
33
(2010, September). Anti-Malaysia demonstrations start on maid abuse case, The Malaysian Insider, retrieved on
10 October 2010, from http:/ / www.themalaysianinsider.com/ malaysia/ article/ anti-malaysia-demonstrations-start-
on-maid-abuse-case/
34
Sihaloho, Markus Junianto; Osman, Nurfika. (2009, October). Indonesian Vigilantes Ready To ‘Invade’ Malaysia,
Leader Claims, Jakarta Globe, retrieved on 4 October 2010, from
http:/ / www.thejakartaglobe.com/ home/ indonesian-vigilantes-ready-to-invade-malaysia-leader-claims/ 334277
35
(2009, June). M’sia maid agencies fear huge losses after Indonesian ban, The Brunei Times, retrieved on 4
October 2010, from
http:/ / www.bt.com.bn/ 2009/ 06/ 27/ msia_maid_agencies_fear_huge_losses_after_indonesian_ban

13
 He said tens of thousands of households would face problems due to the delay in the arrival
of their maids. This would lead to bigger problems in the long run as families struggle to cope with
work and family without helpers in an imminent labour crisis in the future. 36

Lastly, the act of abusing maids is an outright violation of human rights and can never be
justified. No human should be treated in such a manner, by another. When one is employed, one is
paid for their skills and time and ability to do a task. Their dignity, respect, honour, body and mental
well being are not part of the payment. They are areas to be respected. According to Article 4 of the
Universal Declaration of Human Rights, “No one shall be subjected to torture or to cruel, inhuman or
degrading treatment or punishment”.37 It is an obligation of all citizens of the world regardless of
status, including Malaysia, to abide to this charter.

36
Ibid
37
The Universal Declaration of Human Rights, adopted on December 10, 1948 in the General Assembly of the
United Nations.

14
CAS E S T U D Y
MARNI ANYIM

v.

SHALINI SHANMUGAM & ANOR

SESSIONSCOURT, KUCHING

RHODZARIAH BUJANG J

[SUMMONSNO: 53-1-2001-I/ III]

[2006] 5 CLJ330

Material Facts
The plaintiff, an Indonesian domestic helper by the name of Marni Anyim, was employed by the second
defendant (Mr.Vijaya). The first defendant (Mdm Shalini) was the wife of the second defendant. Along
the course of her employment, the plaintiff had suffered moral degradation, verbal and physical abuse
by Mdm Shalini. In fact, Mdm Shalini had been convicted under ss. 326 and 323 of the Penal Code after a
full trial and has since been released after serving her sentences. On 27 November 2000, the plaintiff ran
away from their residence, lodged a police report and went through a medical examination. The plaintiff
claimed special and general damages for, inter alia, pain and suffering and loss of amenities resulting
from the injuries inflicted and the scars from injuries. Furthermore, the plaintiff claimed for the failure
on Mr. Vijaya’s behalf to discharge his duty of care owed to her as a legal employer. The defendants
jointly denied the alleged abuses and averred that she was treated like her own daughter.

Cause of Action
1) Plaintiff claims for special and general damagesfor inter alia (among the other things), pain, suffering
and loss of amenities resulting from the injuries inflicted and the scars from the injuries.

2) Plaintiff claims for breach of duty to take care by the second defendant as an employer to maintain
the well being of plaintiff

Prior Levels of Decisions

This is a case before the Sessions Court and there are no prior levels of courts involved. Before this, the
first defendant had gone through a criminal trial at the Sessions Court for charges under s. 326 and s.
323 of the Penal Code for injuries sustained by Marni. The first defendant was found guilty at the
Sessions Court but the High Court later discharged and acquitted her of both charges. Subsequently, the
Court of Appeal reversed that decision and the judgement of the Sessions Court was restored. The
plaintiff is now initiating a civil suit for monetary compensation.

15
Legal Issues
The legal issues discussed in this case are:

1) The liability on behalf of Mdm Shalini towards the plaintiff for causing grievous injuries.
2) The legal duty of an employer
3) General damages

Evidence
A total of 10 witnesses gave evidence to this case, 2 of whom were court personnel.

Dr. Kon Ka Hin examined Marni on 27 November 2000 and gave the following evidence:

i) laceration wound with haematoma, 2 additional scalp haematomas, periorbital swelling and
haematoma, crack (teeth mark) on both upper and lowerlips, abrasion wound on right chin.
ii) On the neck, abrasion wound was noted on both sides.
iii) On the back, a small swelling at T1 area, 2 white patchesone on each side probably due to
burn (old). Bruises on left lumbar area.
iv) On the upper limbs, there were bruises, abrasion wound, x-ray showed transverse fracture
of right 2nd distal phalanx and hairline fracture of proximal middle phalanx.
v) On the lower limbs, there were kelloids (old scar) abrasion wounds and bruises.

On 28 November 2000, Dr. Tok Man Tze, almost the same bruises and scars were found on the neck,
head, chest, abdomen and upper limb of Marni. The most notable injuries were the one to her right
index finger and an old scar in the shape of an iron on her back.

On 27 November 2000, Mr. Siaw Sui Min @ Tony Liau, a retired member of the police force took
photographs of Marni as appeared in exh. P3(a)-(f), which corroborated in some details in the report of
injuries as detailed by the 2 doctors.

Also on 27 November 2000, En Anwar Sulaiman from the Indonesian Consulate confirmed the injuries
suffered by Marni.

Marni testified that she was forced to wear Mdm Shalini’s old undergarments. She also said Mdm Shalini
placed a hot iron on her back but Mr Vijaya just kept quiet and did not reprimand her wife nor brought
her to seek medical treatment. Besides, she was hammered on the finger by Mdm Shalini and Mr Vijaya
did witness it. He merely shouted to her that she was a stupid woman and asked her to run and report
to the police. In addition, Marni alleged that she was fed leftovers and dog food and was forced to work
long hours from 4am till 11pm. Mdm Shalini also punched her on the left side of the eye, and her mouth
was also hit with a pellet until her tooth broke. She was also scalded with hot water and hammered on
the head. All these abuses were witnessed by Mr Vijaya who did nothing to help her.

Mdm Shalini denied inflicting the injuries on Marni. She alleged that the iron mark could be inflicted
before she worked with them.

16
Mr. Vijaya testified that he treated Marni well by bringing her along for holidays, buying her snacks and
Panadol when she was ill. He agreed that on the morning of 27 January 2000, Marni was frightened of
Mdm Shalini.

Mr. Yeap Kim Thim who was a friend of the Kumars testified that the family had always treated Marni
well.

Reasoning
Firstly, the issue of the liability of Mdm Shalini towards Marni. The judge admitted that there were no
eyewitnesses when most of the injuries were inflicted. However, the probability that she inflicted the
injuries to herself is too hard to believe. The incidents where she was scalded by an iron, poured with
hot water, hammered on the head & finger and punched in the eyes were mind boggling and could not
be reasonably inflicted by herself.

Besides, Marni did not suffer from any mental aberrations and delusions. The act of climbing through
the fence is corroborative of the fact that she suffered those abuses from her employers. Furthermore,
Mdm Shalini’s criminal convictions were prima facie evidence of her abuses.

The judge mentioned a persuasive case cited by the counsel for the plaintiff, Choo Michael v. Loh Shak
Mow [1994] 1 SLR 584.

Secondly, the issue of the legal duty of an employer. The judge referred back to the common law where
it is the duty of an employer to ensure that his employee worked in a safe and conducive working
environment. This was described in Halsbury Laws of England, 3rd edn, at p. 505 as a duty “to take
reasonable care the safety of his work-people in all the circumstances of the case so as not go expose
them to an unnecessary risk.”

The judge referred to the Privy Council’s case of Overseas Tanship (U.K.) Ltd v. The Miller Steamship Co.
(The “Wagon Mound”) (No. 2) [1967] 1 AC 617, 642-643 Lord Reid held that in general a person must be
regarded as negligent if he does not take steps to eliminate a risk which he knows or ought to know is a
real risk and not a mere possibility which would influence the mind of a reasonable man and “that it is
justifiable not to take steps to eliminate a real risk if it is small and if the circumstances are such that a
reasonable man careful of the safety of his neighbour would think it is right to neglect it.”

The court found that Mr Vijaya was aware of the abuses Marni suffered at the hands of his wife and did
not take any steps to protect her from those abuses as an employer. They live in a small household and
the injuries sustained by Marni were not minor. Even when Mr Vijaya was powerless to protect her, it
does not exonerate him from his culpability because his omission to act was not proven to have been
caused by any extenuating factors.

Thirdly, the judge assessed on special and general damages. The special damage was the sum of RM
3000 which has not been paid to her.

17
On general damages, RM 30,000 was awarded for the hot iron injury. The judge gave that figure
considering that it caused permanent scarring and excruciating pain.

RM 8,000 was compensated for the injuries on her fingers caused by the hammer. RM 10,000 was
awarded for the bruises and swelling to Marni’s head, left eye, lip and other injuries. A total of RM
48,000 was awarded for general damages.

Marni also applied for exemplary and aggravated damages. Exemplary damages are awarded if the
defendant behaved in an outrageous or insulting manner when committing the wrong. The judge did
not find solid evidence of Marni being insulted or humiliated for being forced to wear Mdm Shalini’s old
undergarments. Even if this was so, the degradation was not connected to physical abuse.

For aggravated damages, in the House of Lord’s case of Rookes v. Barnard [1964] AC 1129, it was held
that when assessing compensation, the court can take into account motives and conduct. The judge
found no evidence of such ‘motives’ or ‘conduct’ whereby the abuses were triggered just by incidences
which angered Mdm Shalini.

RULING
The court granted the plaintiff special damages in the sum of RM 3,000, being the plaintiffs back wages.
The court also granted the plaintiff with general damages in the sum of RM 48,000. Costs were not
awarded.

18
ANALYSIS OF DECISION
One very important ruling laid down by the court is the legal duty of an employer. We can see
how common law rules are applied in the Malaysian context of foreign domestic worker employment.
The court ruled that is the duty of an employer to ensure that his employee worked in a safe and
conducive working environment. The common law’s stance in this issue is “to take reasonable care the
safety of his work-people in all the circumstances of the case so as not go expose them to an
unnecessary risk.”

This rule is important in Malaysia as it sets a precedence that it is the obligation of the employer
to provide a safe and conducive working environment for the employee, which includes foreign
domestic workers. Therefore, maids cannot be subjected to any forms of abuse, harm and torture in the
vicinity of the house of the employer. Neither can maids be forced to work in harsh conditions and
unreasonably long working hours. Even if the employer was not directly involved in abusing the maid, he
or she still has a legal duty of care now to ensure that the interests of the maid are well taken care of.

As this case is guided by common law rules which may not be as persuasive as our statutes (the
Employment Act) which is visibly flawed based on the earlier analysis, the court should suggest the
legislature of our country to amend the Employment Act to provide foreign domestic workers with
better protection and welfare under the caretaking of the employer in black and white.

Although this case of maid abuse is only heard at the Sessions Court and not the higher courts
which have higher authority, nevertheless, it is a good step towards the justice of maids in our country
by laying down the rule that the legal duty of care of employers must be observed and adhered at all
costs.

19
CON CL U S ION & F IN AL R E MAR K S
In conclusion, as we see this issue far from settling down, we as the society must work together
to seek a legal change to curb this depressing issue. The blatant abuse of power by the employers
towards their maids in most abuse cases is unmistakable and abhorrent. Whilst there is no specific
conclusion, however solutions can be made to ensure that these foreign domestic workers will be
protected from harm and to secure the fact that they as humans are entitled to their basic human rights.

The earlier part of this research paper has highlighted the recent cases of maid abuse happening
in Malaysia and the bad publicity it has been generating for our country. It has also shown that our
leaders want this issue to be resolved as fast as possible

This research paper has shown how the issue of maid abuse began after analysing the various
loopholes in our Employment Act. There is no specific definition for the working nature of domestic
work and this exposes foreign domestic workers to inadequate rest days, long working hours, lack of
termination benefits and many more acts of exploitation by employers. Besides, the Indonesian
government has been pushing for a minimum wage scheme for their domestic workers in Malaysia and
this has still not been properly addressed. The fact that homes are described as ‘private spheres’ put
maids in a dangerous spot as their living conditions are hidden from public scrutiny.

Despite that, memorandums have been signed by Indonesia and Malaysia to come up with
solutions for maid abuse. The Malaysian Trade Union Congress, TENAGANITA, Bar Council and the
Women, Family and Community Development Ministry have been an active voice for the
underprivileged, pressing hard for reforms. Malaysia has an obligation to rectify maid abuse issues since
its ratification towards CEDAW and ILO.

Throughout our research, we have identified the rationale behind solving this grave issue for the
sake of our country. We do not want our neighbours to generate hatred towards Malaysians, our
national pride to be tarnished and the safety of Malaysians in Indonesia to be jeopardised. In terms of
economy, it would cripple the management of maid agencies and affect our trade ties with Indonesia.
Lastly, the rights of maids as humans cannot be violated based on the United Nations Charter of Human
Rights.

In the case of Marni Anyim v. Shalini Shanmugam & Anor, the courts have laid down an
important ruling which discusses the legal duty of care of an employer towards foreign domestic
workers. It is the obligation of the employer to ensure that maids are not exposed to abuse and are
treated well in a good working environment. Otherwise, the employer has to face the legal
repercussions for breaching its fundamental duty of care.

After looking into all these issues, it is important that the government and people of Malaysia to
initiate change. We reiterate our call that the government should provide a comprehensive mandatory
contract for foreign domestic workers into the Employment Act. We do not want any discrimination this
time around. It must be clearly stated the job scope of domestic workers and a minimum wage.
Furthermore, employers must always be prohibited to keep a domestic workers’ passport and any legal
documents. This contract spells out all the labour rights for foreign domestic workers in the Employment
Act which would then be enforceable as part of the Employment Act.

20
 Besides, the Human Resources Minister has to keep his promise that all domestic workers have
a right to a paid day off every week by the end of the year.

It is also right to suggest that all foreign domestic workers should attend courses before
absorbed into employment to teach them of their legal rights. The same can be done for employers
whereby they are exposed to the rights of the maid and repercussions if they were found guilty for maid
abuse. Maid agencies should also be regulated under a statutory body, maybe under the Women, Family
and Community Development Ministry, to standardise all forms of procedures.

It has also come to our light that there exist illegal immigrants who work as maids in households
without informing the authorities and these maids are most prone towards abuse. The Immigration
Department should frequently conduct inspections to weed out these illegal immigrants.

We can see the clear development of legal change after there is a social change in the case of
maid abuse. The gruesome cases of maid abuse exposed in the media, backlash from the Indonesian
government and continuous pressure from many organisations constitute social change. Our society as a
whole has reacted towards the many cases of maid abuse. As a result of this, the government has no
option but to tackle the social change head on by initiating legal change. Memorandums, letter of
intents and ratification of international conventions are small steps towards greater legal change. It is
our hope that legal change can finally be carried out by amending the Employment Act towards creating
a better society.

21
ACK N OW L E D GE ME N T S
Throughout the course of this research assignment, we would like to extend our gratitude
towards Puan Zalina Abdul Halim, Law and Society Coordinator, Faculty of Law, University of Malaya. We
appreciate the advice she wholeheartedly gave us all this while in terms of the requirements needed to
produce a good assignment and the research assignment rubric as a comprehensive guidance. Besides,
she has been kind enough to take time off her busy schedule for personal feedback towards the
progress of our assignment.

In addition, our sincerest appreciation goes to Mr. Zokhri Idris, our Law and Society tutor who
has been patient to deal with the complications and problems that constantly arose throughout the
completion of this assignment. He has given us good guidelines on how we should begin with and how
to develop our arguments in a coherent manner. Whether it is on a one to one basis, email or the
domains of Facebook, Mr. Zokhri proves that he is always reachable for quick comments.

Credit goes to Dr. Farah Nini Dusuki, our Legal Method coordinator, who took the pains to invite
Dr. David Yoong, a linguistic expert from the Faculty of Languages and Linguistics, University of Malaya,
to explain to us the steps towards producing a good research paper, which we hopefully have done. Of
course, we would like to also thank Dr.David Yoong for his insightful presentation which would benefit
us for the many more research assignments to come in law school.

Lastly, the contributions of all members of this Law and Society tutorial group will always be
cherished. It is the toil and hard work of all members that have led to the success of this research
assignment.

22
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23
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24
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25