1. ) ALAN KNOWLES 2. ) ALEXANDRA FRANCES MARY KNOWLES v 1. ) KETUA PENGARAH JABATAN PENDAFTARAN NEGARA 2. ) MENTERI DALAM NEGERI MALAYSIA 3. ) Kerajaan Malaysia

wa-24-19-03-2023 High Court (Mahkamah Tinggi) 27 November 2025 • WA-24-19-03/2023 • 25 min read

9 cases cited (0 SG, 9 foreign)

Catchwords

Constitutional Law: Citizenship – By operation of law – Article 14(1)(b) read with section 1(a) of Part II and section 19B of part III of the Second Schedule of the Federal Constitution – Burden of proof – whether evidence supports fact of ‘a newly born found exposed’ to invoke presumption under section 19B-Article 14(1)(b) read with section 1(e) read with section 2(3) of Part II of the Second Schedule of the Federal Constitution – Burden of proof – whether requirement of jus sanguinis satisfied if identity of biological parents unknown

Practice Areas

Constitutional Law: Citizenship

Judges (1)

Alice Loke Yee Ching Delivered

Counsel (3)

Mah Weng Kwai & Associates Firm Algalya J. Munusamy Counsel Plaintiff Zulkiefli bin Sulaiman Counsel Defendant

Parties (5)

KETUA PENGARAH JABATAN PENDAFTARAN NEGARA Respondent Kerajaan Malaysia Respondent Menteri Dalam Negeri Malaysia Respondent Alan Knowles Applicant Alexandra Frances Mary Knowles Applicant

Case Significance

1. ) ALAN KNOWLES 2. ) ALEXANDRA FRANCES MARY KNOWLES v 1. ) KETUA PENGARAH J... is a High Court (Mahkamah Tinggi) decision dated November 27, 2025 (citation: wa-24-19-03-2023). <p>British adoptive parents sought a declaration that their adopted child Lucie Suwara Knowles is a Malaysian citizen by operation of law, relying on s.19B (foundlings) and s.1(e) (statelessness) of the Second Schedule of the Federal Constitution. The High Court dismissed the application, finding the child was not a 'newly born found exposed' as she was handed over by her mother to a care centre, and the biological parents' citizenship could not be established to satisfy the jus sanguinis requir The case was decided by Alice Loke Yee Ching. Counsel appearing: Algalya J. Munusamy (counsel for plaintiff), Zulkiefli bin Sulaiman (counsel for defendant).

Summary

British adoptive parents sought a declaration that their adopted child Lucie Suwara Knowles is a Malaysian citizen by operation of law, relying on s.19B (foundlings) and s.1(e) (statelessness) of the Second Schedule of the Federal Constitution. The High Court dismissed the application, finding the child was not a 'newly born found exposed' as she was handed over by her mother to a care centre, and the biological parents' citizenship could not be established to satisfy the jus sanguinis requirement.

What was the outcome of 1. ) ALAN KNOWLES 2. ) ALEXANDRA FRANCES MARY KNOWLES v 1. ) KETUA PENGARAH J...?

<p>British adoptive parents sought a declaration that their adopted child Lucie Suwara Knowles is a Malaysian citizen by operation of law, relying on ...

Statutes Cited

Births Deaths and Registration Act 1957

s 9

Evidence Act 1950 (Cap 56)

s 103

Federal Constitution

Cases Cited (9)

AU (1)

[2004] HCA 43

MY (8)

[2008] 3 MLJ 625 [2008] 5 CLJ 42 [2016] 7 MLJ 717 [2017] 3 MLJ 308 [2017] 5 MLJ 662 [2018] 6 MLJ 548 [2021] 4 MLJ 236 [2022] 1 MLJ 71