for investigation under Section 298A and the Sedition Act 1948.69 Following a show-cause letter from the Home Ministry and a follow-up meeting, the editor-in-chief and chief executive office were suspended indefinitely.70 It is noted that while the investigation was made in relation to a print publication, there was no demarcation that would suggest that the front page would have avoided similar punishment if it were published online.71 On the one hand, civil society has traditionally advocated for the use of these sections in lieu of the Sedition Act 1948 and the Communications and Multimedia Act 1998, as they are far more defined and not easily subjected to the whimsical interpretation of law by the government. However, unrestricted use of this legislation may well place it among the list of laws that unjustly and disproportionately criminalise freedom of expression. Other laws The Printing Presses and Publications Act 1984 (PPPA) is another law that is often utilised to criminalise and restrict freedom of expression in Malaysia. Traditionally, this law was invoked to restrict or criminalise print publications. However, there is no guarantee that this law would not be interpreted to restrict online publications (e‑books, etc). When we consider that the Sedition Act 1948 was not differentiated in its application to articles published online or in print media, there is a substantial possibility that the PPPA may be interpreted in a similar manner that could cut across the online and offline realms in the future. On the eve of the Bersih 4 rally in 2015, the t‑shirts and logo of Bersih 4 were declared illegal under the PPPA on the grounds of national security. At the same time, the Bersih website72 was also blocked by the MCMC through its powers under the CMA.73 The joint application of laws in such a manner also raises the possibility that the act of criminalisation of publications under the PPPA may be used as a “legitimate” excuse to compel ISPs to 69 Malaysia Kini. (2017, 30 May). IGP: The Star investigated for sedition, inciting religious enmity. Malaysia Kini. www. malaysiakini.com/news/383967 70 The Star Online. (2017, 31 May). Two top editors of ‘The Star’ suspended. The Star Online. www.thestar.com.my/news/ nation/2017/05/31/two-top-editors-of-the-star-suspended 71 The news which was published on the front page was similarly published online. 72 Malaysia Kini. (2015, 28 August). MCMC blocks four websites for promoting Bersih. Malaysia Kini. www.malaysiakini.com/ news/310322 73 Malaysia Kini. (2015, 28 August). Bersih website blocked ahead of rally? Malaysia Kini. www.malaysiakini.com/news/310207 block or remove the offending items from access under the CMA. However, it is noted that while the PPPA may have a strong influence that would easily compel print publications to follow an invisible line set by the government, the law itself may have very little repercussion for consumers and activists. For example, the novel 50 Shades of Grey has been subjected to a ban under the PPPA, but can still be found in bookshops across the country. Similarly, a quick search online would show that the book is still easily available in e‑book format on Google Play and other distribution channels. In addition to the PPPA, another worrying aspect arising in recent years is related to the Islamic laws and principles that have been gaining traction in the Malaysian legal system. With regard to Islamic or Sharia law, there is relatively wide power to regulate and criminalise freedom of expression. There are three identified manners in which Islamic or Sharia law has been applied to curtail freedom of expression. First, it can be used directly to criminalise freedom of expression, similarly to how the Sedition Act 1948 functions. This is seen in the case of Dr. Kassim Ahmad74 where he was charged for insulting Islam75 during a speech he delivered at a seminar. Furthermore, Islamic or Sharia law has been and can be used to restrict publications, as seen in the case involving Ezra Zaid,76 which raised substantial questions as to the scope of power afforded to Islamic law and whether these laws can affect, curtail and criminalise freedom of expression. Ezra Zaid and ZI Publications were charged under Section 16 of the Syariah Criminal Offences (Selangor) Enactment 1995.77 At the time of this report, the constitutionality of this section is still pending hearing in the civil courts. On top of the potential power to restrict publications, the power of the state religious authorities to issue a fatwa, which is not legally binding, raises an additional point of concern. While a fatwa does not necessarily hold legal sway, it can greatly affect public perception, which may lead to increasing 74 Siti Aziela Wahi. (2014, 27 March). Kassim Ahmad didakwa di mahkamah pagi ini. Sinar Online. www.sinarharian.com.my/ semasa/kassim-ahmad-didakwa-di-mahkamah-pagi-ini-1.264386 75 Section 7(b) of Shariah Criminal Offences (Federal Territories) Act 1997. 76 Lim, I. (2017, 26 April). Ezra Zaid allowed to continue challenge of Jais arrest, prosecution over book. Malay Mail Online. www. themalaymailonline.com/malaysia/article/ezra-zaid-allowed-tocontinue-challenge-of-jais-arrest-prosecution-over-boo 77 Section 16 deals with religious publication contrary to Islamic law. https://goo.gl/bzUxBa 90 / Unshackling Expression