AHMAD IBRAHIM KULLIYYAH OF LAWS

LAND LAW I (LAWS 3310)

SEMESTER 1, 2023/2024

WRITTEN ASSIGNMENT
Torrens System: The Governance, Features, Pitfalls and
Moving Forward

TUTORIAL SLOT: TUESDAY 6 PM - 7 PM | SECTION 1

SUBMISSION DATE: 24th JANUARY 2024
INSTRUCTOR: PROF. TO’ PUAN DR. NOR ASIAH BINTI MOHAMAD
MEMBERS OF THE GROUP:

NO. NAME MATRIC NUMBER

1 ِAINUL MARDHIYAH BINTI RUSLI 2116168

2 ASIYAH MUTI’AH BINTI MOHD NASIR 2117524

3 FATIMAH AZ-ZAHRAH BINTI ZULKHAIRI 2118194

 Table of Contents

Introduction 3
Background of Torrens System and its Application in Malaysia 3
The Governance : Characteristics of Torrens System 4
Essential Principles of the Torrens System 5
Advantages of Torrens System 8
Pitfalls: Exploring the downside in adopting Torrens System 9
Moving forward : Advancement of Torrens System 10
Conclusion 12
References 13
Appendix 15

2
Introduction

The Torrens System, a pioneering land registration framework introduced by Sir Robert
Torrens in 1858, stands as a transformative force in the landscape of real property transactions.
Its inception marked a departure from traditional deed registration systems, offering a
centralized approach that prioritizes clarity, efficiency, and security in the transfer and
registration of land titles. In this comprehensive paperwork, we will embark on an exploration
of the Torrens System, dissecting its governance structures, distinctive features, the potential
pitfalls encountered in its implementation, and the forward-looking strategies to enhance and
adapt this system to contemporary needs. As we navigate through the intricate tapestry of the
Torrens System, we will unravel its historical roots, unravel the core principles that govern its
functioning, scrutinize the challenges that have surfaced over time, and envision innovative
paths forward to ensure its continued effectiveness in the ever-evolving landscape of property
law. Join us on this intellectual journey as we delve into the nuances of the Torrens System,
dissecting its governance mechanisms, appreciating its features, critically examining its pitfalls,
and charting a course for its progressive evolution.

Background of Torrens System and its Application in Malaysia

To address the issues that the Deeds system was causing at the time, the Torrens System
was designed using the Merchant Shipping Act of 1854 and the Admiralty Rules as a basis.
Title of Torrens is a land title system in which individuals listed in a state-maintained register of
land holdings are guaranteed indeteasible ownership. The old system of title, which relies on the
proof of an uninterrupted chain of title back to a sound root of title, presented issues of
uncertainty, complexity, and expense that the new system was designed to address. Sir Robert
Torrens, the colonial premier of South Australia at the time, devised the Torrens title system,
which was implemented in that state in 1858. Since then, it has spread widely throughout the
Commonwealth of Nations and the world at large. Only one state in the union has the Torrens
system in place over its whole territory: Minnesota, Massachusetts, Colorado, Georgia, Hawaii,
New York, North Carolina, Ohio, and Washington have only partially implemented it.

Malaysia has implemented such a system back in the 19th century and the current title
registration legislation, the National Land Code, was adopted as early as in 1965. It was first
introduced into Malaya through the Federated Malay States instead of applying the Islamic land
law. This marked the beginning of a new regime of title registration law akin to the Torrens
system in Australia on basis of the Real Property Act 1857 of South Australia.1 Therefore,
through the introduction of the Torrens System, it was integrated with a system of acquiring title

1
Wu, R., & Kepli, M. Y. Z. (2011). Implementation of land title registration system in Malaysia:
lessons for Hong Kong. Malayan Law Journal Articles. http://irep.iium.edu.my/29661/

3
by registration which prescribes registration of dealings in land. Moreover, it was stated in
National Land Code 1965 that Malaysia’s land law and transactions are guided by the Torrens
System, which ensures that the land registry accurately reflects all vital details about the land’s
registered owner.2 In the case of Sime Bank v Mohd Hassan bin Sulaiman3 said that;

“The National Land Code 1965 was made effective from 1st of January 1966
whereby thenceforth uniform system of land tenure and dealing existed
throughout Peninsular Malaysia. Penang and Malacca were also absorbed into
the system by the promulgation of the National Land Code (Penang and
Malacca) Titles Act 1963. In a gist, the system practiced is commonly referred to
as the Torrens System or the registration of titles system. It owed it's origin or
name after Sir Robert Torrens, who earlier had introduced it into South Australia
which thereafter spread throughout Australia, and eventually reaching our
shores.”

The Governance : Characteristics of Torrens System

This Torrens System of land registration is characterised by several fundamental

principles and features that set it part from traditional deed registration systems. Therefore, this
paperwork will be exploring and explaining the key characteristics of the Torren System,
shedding light on its impact on land transactions and ownership.

The Torrens system is essentially a means of registering land titles in order to provide a
dependable, easy-to-use, affordable, and community-focused system. The Torrens system is a
conveyancing method in which the parties' agreement determines who owns the title and
interests in the land. The register is of the highest significance. It was said in Teh Bee v
Marumuthu4 that;

“under the Torrens system the register is everything and it would be wrong to
allow an investigation as to the right of the person to appear upon the register
when he holds the certificates of title”

At the core of the Torrens system is the establishment of a centralized land register. This
official register serves as a comprehensive repository, containing information about land titles
and their respective owners. The record contains individual grant certificates or folios. There are
also papers, which may be uploaded during registration. Furthermore, the register contains all of
the details relevant to the registered owner's title in the land. Material facts include the name of
the current proprietor, the land that has been alienated, the land's extent and location, the survey
plan, and the land's border limitations. Aside from that, an official record is kept at a specific
location and can be examined by a prospective land purchaser. It allows for the recording of
specific interests exclusively while prohibiting the recording of others. The holders of interests

2
Section 89 of National Land Code 1965
3
[2000] 2 MLJ 158
4
[1977] 2 MLJ 7

4
are listed as proprietors of interests. Therefore, it can be seen that this land registration system is
based on the land as the basis of record. It advocates registration as the important step in
acquiring title. In the case of Dr Ti Teow Seo and Ors v Pendaftar Geran-Geran Tanah Negeri
Selangor5, Hashim Yeop Sani J had stated that;

“... it is registration that gives and extinguishes title under the National Land
Code. Registration is the corner-stone of the Torrens System.”

Moreover, the keystone of the Torrens System is the security of the Registered
Proprietor. The security of interests obtained in good faith on the strength of the Register is the
foundation of the system. As a result, if someone registers in good faith as the owner of an
interest in land, his interest will only be subordinated to those whose interest is recognised as
having priority over his on the Register. Therefore, this system measures to prevent double sales
of the same property. Once a person's ownership is registered, it is generally considered
indefeasible, reducing the risk of competing claims. This safeguard adds an extra layer of
protection for landowners and promotes the reliability of the system. The effect of applying this
system is the interest will be transferred to the registered proprietor free of any trusts and
equities that may exist outside the register and that the former registered proprietor may enforce.

One of the cornerstones of the Torrens system is the concept of indefeasibility of title.
Once ownership is properly registered, it is generally deemed indefeasible. This means that the
registered owner's title is secure and immune to easy challenge or invalidation. The government
often reinforces this security by providing a guarantee of title, standing behind the accuracy of
the register and offering protection against errors, fraud, or other issues in the registration
process. The assurance that the title to an estate would remain subject only to the interests listed
on the Register is granted to the registered proprietor. In the event that someone loses anything
as a result of a mistake made by the Registrar or any of his officers, or in the event that the
system deprives them of any estate or interest in land. The State will have the right to reimburse
the person who experiences the loss or deprivation for his damages.

Essential Principles of the Torrens System

Mirror Principle

The “mirror principle” in the Torrens system refers to the concept that the state of the
title register accurately reflects the current ownership and encumbrances of a property. The
Torrens system is a land registration system designed to simplify and facilitate land transactions
by providing a centralized and reliable record of land ownership. Therefore, the land
registration is a reflection of the material facts of the proprietor’s title in the land.
This is because it denotes the necessary and accurate information related to the land by having
good title.

5
[1982] 1 MLJ 38

5
 Under the Torrens system, when a person acquires land or property, their ownership is
registered in the public land register, also known as the Torrens register. The mirror principle
asserts that the information contained in this register should mirror or accurately reflect the
actual state of affairs regarding ownership and any encumbrances on the property.

In other words, the register is meant to be a true reflection of the legal status of the
property, and anyone dealing with the property can rely on the information in the register. This
principle enhances the reliability and efficiency of land transactions, as it minimizes the need for
extensive and time-consuming investigations into the history of the property title. Since the
good title is a reflection of the land, it also reflects on both the Register Document of Title and
Issue Document of Title. By virtue of this good title, they will obtain all the relevant particulars
of the land as well as any encumbrances created over the land

Moreover, indefeasibility is provided by the National Land Code 2020 upon registration
of any title or interest, demonstrating the strength of registration in and of itself.6 The Federal
Court in Teh Bee v K Maruthamuthu7 maintained the appellant Madam Teh Bee's title
registration despite her failure to pay land revenue items on time, in violation of section 81(2) of
the National Land Code 1965. The High Court had determined that her title was obtained
illegally. Ali Ag CJ in the Federal Court has stated that under the Torrens system, the register is
everything's, and it would be wrong to allow an investigation as to the right of the person to
appear upon the register when he holds the certificate of title. In that case, Chief Justice Ali also
cited Lord Wilberforce's well quoted remarks from the Frazer v Walker8 decision, according to
which he mentioned that “it is in fact registration and not its antecedents which vests and divests
title.” It is evident from this that they have a very egocentric approach to land title registration,
as was the case with the Torrens System.

Curtain Principle

The “curtain principle” refers to the idea that the state of the register (public land
register) is conclusive evidence of ownership and interests in land. Under the curtain principle, a
person dealing with a particular property can rely on the information contained in the official
register without having to investigate the historical chain of title. The register acts as a "curtain"
behind which the true state of ownership is hidden. In other words, the information on the
register is considered final and authoritative, and it provides a conclusive and irrefutable
evidence of ownership.

The Certificate of Title contains all of the information concerning the title, therefore
there is no need to go behind it. This means that ownership does not have to be proven by
extensive, complicated documentation retained by the owner, as in the Private Conveyancing
system. The Certificate of Title includes all of the relevant ownership information. This
principle is intended to provide certainty and security in land transactions by simplifying the

6
Section 340(1) of National Land Code 2020
7
[1977] 2 MLJ 7
8
[1967] 1 AC 569

6
process of establishing ownership and interests in land. It means that if a person's ownership or
interest is properly registered, they are protected against competing claims that are not reflected
in the register.

This idea is reinforced by Section 89 of the National Land Code (Revised 2020), which
states: “Every document of title duly registered under this Chapter, shall, subject to the
provisions of this Act, be conclusive evidence – a) that title to the land described therein is
vested in the person or body for the time being named therein as proprietor,...” When there is
convincing evidence, one does not need to search elsewhere to be assured that the title is
legitimate. This principle is alluded to by Lord Buckmaster in Creelman & Anor v Hudson Bay
Insurance Company9 when he mentioned that;

“… to enable investigation to take place as to the right of the person to appear

upon the register when he holds the certificate which is the evidence of his title,
would be to defeat the very purpose and object of the statute of registration.”

The Torrens System's goal, according to the curtain principle, is to save those doing
business with registered proprietors the effort and expense of having to look beyond the register.
This was stated by the privy council in the long-ago case of Gibbs v Messer.10 This indicates that
the Torrens System's goal is to eliminate the necessity of following the chain of titles, like the
Deeds system did. It can be seen in the Malaysian recent case, which is Pushpaleela a/p R
Selvarajah & Anor v Rajamani d/o Meyappa Chettiar (and 2 Other Appeals)11, the chief judge,
Richard Malanjum CJ had observed that;

“Basically, under the Torrens system the land register is conclusive evidence of
the description of the land. A third-party conducting an inquiry of the land need
not go beyond the register to ensure that the land he or she is about to purchase
is not fraught with encumbrances.”

Insurance principle

The insurance principle has provided for compensation of loss if there are errors made
by the Registrar of Titles. It is essentially an assurance fund that provides compensation to those
who are defeated or deprived of their land due to no fault of their own. In other words, anybody
who suffers a loss must be placed in the same position, as far as money allows, as if the
reflection were true. This approach is an alternative if the mirror principle fails to provide a
completely correct reflection of the title and a defect exists on the part of the Registrar.
According to this idea, money from registration fees paid on the lodgement of instruments of
dealing from registration will be deposited into the fund. This approach, however, is not
applicable in Malaysia due to its impracticality.

9
[1920] AC 194
10
[1891] AC 248
11
[2019] 2 MLJ 553

7
Advantages of Torrens System

The Torrens system has emerged as a transformative force in the realm of land
registration. Its widespread adoption across the globe can be attributed to a host of advantages
that streamline land transactions, enhance transparency, and instill confidence in property
ownership. In this paperwork, we will delve into the key advantages of the Torrens system.

At the heart of the Torrens system lies its commitment to providing clarity and certainty
in land ownership as it aims to provide a clear and conclusive record of land ownership. This
clarity can reduce uncertainties and disputes related to property titles, offering greater certainty
to landowners and potential buyers. The centralized land register, a hallmark of this system,
serves as a reliable repository of information. The mirror principle ensures that the register
accurately reflects the true state of ownership and interests in land. This clarity significantly
reduces uncertainties and disputes related to property titles, fostering an environment conducive
to smooth transactions. Moreover, simplified transactions represent another major advantage of
the Torrens system. By streamlining the process of transferring and registering land titles, the
system eliminates much of the complexity associated with traditional deed registration. This
efficiency not only saves time but also reduces the likelihood of errors and disputes arising
during property transactions.

Efficient title verification is a crucial aspect of the Torrens system. The centralized
register, supported by government oversight, allows interested parties to rely on official
documentation without the need for exhaustive investigations into historical chains of title. This
streamlined verification process contributes to quicker and more reliable due diligence,
benefiting both buyers and sellers. Furthermore, The government guarantee of title further
reinforces the security provided by the Torrens system. Governments stand behind the accuracy
of the register, offering protection against errors, fraud, or other issues in the registration
process. This guarantee adds an extra layer of assurance for landowners, reinforcing the
credibility of the land registration system. This is because the title registration has apply a strict
verification procedures and the government-backed guarantee in order to against fraudulent
transactions. This assurance not only protects individual landowners but also contributes to the
overall integrity of the land registration process.

Additionally, indefeasibility of title is a key principle underpinning the Torrens system.

Once ownership is properly registered, it is considered indefeasible. This means that the
registered owner's title is secure and immune to easy challenge or set aside. This principle
enhances the security of property ownership and ensures that individuals can have confidence in
the integrity of their land titles. Therefore, operational under the principle of utmost good faith,
the Torrens system fosters a sense of trust among all parties involved in land transactions. Both
buyers and sellers, as well as the authorities responsible for registration, are expected to act
honestly and disclose all relevant information. This principle contributes to the overall integrity
of the system.

In conclusion, The global influence of the Torrens system is undeniable. Its success in
various jurisdictions has led to its widespread adoption and adaptation. Many countries have
recognized the advantages it offers and have integrated its principles into their land registration

8
practices. The Torrens system stands as a testament to the transformative power of efficient land
registration. Its advantages, including clarity and certainty, simplified transactions, efficient title
verification, fraud prevention, indefeasibility of title, government guarantee, and the principle of
utmost good faith, collectively contribute to a robust and reliable framework for managing land
ownership. As jurisdictions continue to modernize their land registration systems, the enduring
principles of the Torrens system continue to shape and influence the landscape of property
transactions worldwide.

Pitfalls: Exploring the downside in adopting Torrens System

Unquestionably, protecting property rights with the application of Torrens system in

land registration is a crucial first step in creating an open and effective system for property
ownership. However, in application, there are pitfalls and obstacles that will arise. These
complications result from a number of factors, including the actual use of the Torrens system
and possible ramifications for landowners, governmental bodies, and legal procedures. We will
examine these issues from several angles in this part, illuminating the difficulties involved in
implementing Torrens system for property rights.

Making the switch from conventional property registration methods to Torrens system
can be expensive. Property owners may have to pay for maintaining documents, obtaining legal
counsel, and making sure their titles are clear and tradable. The Torrens system must be set up
and maintained by governments, which includes hiring staff members and digitising outdated
documents. To illustrate the enormous financial commitment needed, the state of South
Australia, for example, spent more than AUD 50 million in the 1990s to convert its property
registration system to Torrens.

Although the Torrens system is intended to offer an unambiguous and definitive record
of property title, it does not ensure protection against legal challenges. Boundary disputes,
fraudulent transactions, and flaws in the Torrens system themselves are just a few of the
difficulties that might give rise to disputes. Some property owners might be discouraged from
fully adopting the new system because the process of settling these issues can be expensive and
time-consuming. Forgery can happen in the implementation of Torrens system as quoted by
Anthony Wong Fook Hin in the 15th Malaysian Law Conference 2010, in which he stated that
forgery cases include identity theft - identity of landowners are forged by fake identification
documents, fake signatures and attestations. In Goh Hooi Yin v Lim Teong Ghee & Ors12, to
prove cases of fraud, it is not enough to show deprivation of right to the plaintiff, the intention
of cheating must be proven and other intentions are considered immaterial. Fraud cannot be
presumed just because the party has knowledge of an unregistered claim or interest in land.

Establishing precise property lines is essential to the operation of Torrens system. It

might be difficult to draw precise boundaries when historical records are lacking or
ambiguous. In order to settle boundary disputes, property owners might need to hire surveyors
and other professionals, which would increase the transition's complexity and expense.

12
[1990] 3 MLJ 127

9
Concerns regarding data security and privacy are raised by the digital nature of Torrens
system. Storing sensitive property information online leaves it vulnerable to hacking and
unwanted access. Governments and agencies responsible for property registration need to make
significant investments in strong cybersecurity measures to safeguard this data and guarantee
that it stays private and unalterable.

There is a pitfall about the Torrens system's possible effects on underprivileged

communities, despite the system's goal of streamlining and increasing accessibility to property
ownership. Sometimes it can be difficult for people living in low-income areas to make the
move, which can result in problems with exclusion and unequal access to property rights. A key
component of its execution is persuading landowners, solicitors and the general public of the
benefits of Torrens system. It's a constant struggle to confront scepticism about the system's
dependability and effectiveness while also fostering trust in it. It might take a lot of outreach and
education to get support for the Torrens system in nations with a long history of deed-based
property registration. It can be difficult to integrate unregistered properties and older
records into the Torrens system. The transfer may be more difficult for these properties if they
have complicated ownership histories or are involved in legal issues. Authorities and
governments need to come up with plans to deal with these unresolved problems while
preserving the integrity of the new system.

Although Torrens Certificates present a viable avenue for safeguarding property rights,
there are numerous difficulties that come with putting them into practice. To guarantee a smooth
transition and enjoy all the advantages of an open and effective property registration system,
these problems must be resolved. As we delve deeper into the possibilities of Torrens system to
protect property rights, we must face these obstacles head-on with creative solutions and a
dedication to equity and diversity.

Moving forward : Advancement of Torrens System

It is worth to take note that the Torrens system has persistently to be a robust and
efficient land registration system, there will be always a room for improvement to adapt with the
evolving needs in order to overcome the challenges that come across in implementing the law.
There are some potential improvements that could be considered to the betterment of Torrens
system. Firstly, the system can be improved through technological integration where the
government or the authority may embrace and invest in modern technologies such as blockchain
and other secure digital platforms to enhance the efficiency, security, and accessibility of the
Torrens system. This could streamline processes, reduce paperwork, and improve data accuracy.
It can be understood that the Torrens system is a ‘title by registration’ system where the
registration is the most fundamental element in this system. The Torrens system also is a mode
of conveyancing whereby the title to land and interested in land depends upon registration and
not upon instrument inter-parties as the registration as being said earlier is to be given utmost
importance and it can be illustrated in the case of Teh Bee v K Maruthamuthu13 Some might
found the current system is lacking in its accessibility especially for those who actually did not

13
[1977] 2 MLJ 7

10
have proper access to the Land Office like those in the rural area. The improvement that can be
suggested is by introducing a proper online website to increase accessibility of registration that
allow us to enhance online access to the Torrens system registration to facilitate easier and
quicker verification of land titles. A user-friendly and secure online platform could benefit
various stakeholders, including legal professionals, real estate agents, and the general public.

In addition, with the aim to improvise and enhance the implementation of Torrens
system, it requires standardization across all the jurisdictions or states in Malaysia by
moving forward to a greater standardization of Torrens system practices across different
jurisdictions. While the principles remain consistent, standardization can help simplify
cross-states transactions and improve cooperation between inter-states specifically in our
country. Other than that, we can also improvise the system by continuous education and
outreach by executing an ongoing education and outreach programs to increase awareness and
understanding of the Torrens system among the public, legal professionals, and other
stakeholders. This could help in educating the public how the system works especially in
Malaysia with the guidance of our National Land Code 1965 and it allows us to build trust and
confidence of the society in the system. Moreover, the integration with land use planning
might also contribute to the advancement of the system. The State government may explore
ways to integrate the Torrens system with land use planning and development processes as this
could lead to a more cohesive approach in managing land information and promoting
sustainable development. There should be also environmental considerations in integrating
environmental information into the Torrens system registeration to provide a comprehensive
view of land use and potential environmental concerns as this could support sustainable land
management practices.

Rather than focusing on the role of the executive, we, on the other hand, might also rely
on the role of the legislative in enacting a more flexible law in handling law matters. The
legislative, Parliament may ensure the legal frameworks supporting the Torrens system remains
flexible enough to adapt to changing circumstances, technological advancements, and emerging
legal challenges. The legislative should prevent imposing a strict legal framework as it would be
rigid to the society in the governance of the land matters. Instead, they may conduct a regular
reviews and updates that may be necessary to keep the system relevant and updated. Lastly,
getting back to the responsibility of the authority, the encouragement of public participation
may also contribute to the enhancement of the implementation of Malaysian Torrens System by
encourage the public in the maintenance and verification of the Torrens register and this could
involve community-driven processes for reporting discrepancies or changes in land use,
fostering a sense of collective responsibility in order to achieve certainty and avoid errors in
handling land matters. In considering these improvements, it is important to involve various
stakeholders, including government agencies, legal professionals, technology experts, and the
public. A collaborative approach that takes into account diverse perspectives can contribute to
the ongoing success and relevance of the Malaysian Torrens system in the dynamic landscape of
land registration.

11
Conclusion

Malaysia’s land law and transactions are guided by the Torrens System, which ensures
that the land registry accurately reflects all vital details about the land’s registered owner. The
system has been implemented in Malaysia as it can be observed in our National Land Code
1965 that was enacted in accordance to the Torrens system in order to achieve uniformity of law
and administration of land matters in Malaysia. As per Section 89 of the National Land Code
1965, Malaysia’s land law and transactions are guided by the Torrens System, which ensures
that the land registry accurately reflects all vital details about the land’s registered owner.. The
Torrens system has successfully replacing the Deed system that was previously deemed as
inaccurate, complex, expensive and cumbersome system and the Torrens system has been
proven to be more efficient, secured and simpler. Notwithstanding to the good practicability of
the system, there are still rooms for improvement to the betterment of the implementation of the
system in order to achieve a good administration of land matters. It is important to recognize
that the Malaysian Torrens System maintains the principles of equity. This system is structured
to allow equity’s jurisdiction to intervene based on conscientious grounds, ensuring fair
treatment.

12
References

Statute

Section 89 of National Land Code 1965

Section 340 (1) of National Land Code 2020

Case law

Creelman & Anor v Hudson Bay Insurance Company [1920] AC 194

Dr Ti Teow Seo and Ors v Pendaftar Geran-Geran Tanah Negeri Selangor [1982] 1 MLJ 38

Frazer v Walker [1967] 1 AC 569

Gibbs v Messer [1891] AC 248

Goh Hooi Yin v Lim Teong Ghee & Ors [1990] 3 MLJ 127

Pushpaleela a/p R Selvarajah & Anor v Rajamani d/o Meyappa Chettiar (and 2 Other Appeals)
[2019] 2 MLJ 553

Sime Bank v Mohd Hassan bin Sulaiman [2000] 2 MLJ 158

Teh Bee v K Maruthamuthu [1977] 2 MLJ 7

Textbook

Maidin, A. J., Kader, S. Z. S. A., Ali, B. B. M., Noor, F. M., Mohamad, N. A., Sufian, A., &
Rosli, R. A. (2008). Principles of Malaysian land law. Lexis Nexis Malaysia, 39-54

Maidin, A. J., & Kader, Z. S. A. (2022). Malaysian land law and procedure.

Journal Article

Sood, Teo Keang. (1989). The Centenary of the Torrens System in Malaysia. Journal of
Malaysian and Comparative Law, 16, 199-208.

Sood, Teo Keang. (2002). Demise of deferred indefeasibility under the Malaysian Torrens
system. Singapore Journal of Legal Studies, 2002(1), 403-408.

Yong, Wong Siong. (1967). Equitable interests and the Malaysian Torrens system. Malaya Law
Review, 9(1), 20-37.

13
Wu, R., & Kepli, M. Y. Z. (2011). Implementation of land title registration system in Malaysia:
lessons for Hong Kong. Malayan Law Journal Articles. http://irep.iium.edu.my/29661/

14
Appendix

15
16