and the ISA, the High Court in Teo Soh Lung had the opportunity to reassert the principles set down in Chng Suan Tze. However, it declined to strike down the amendments, instead holding that the amendments were constitutional because, among other reasons, Parliament had satisfied the formal requirements laid down in the Constitution for making the amendments. The view has been expressed that the Court took a "thin" and positivist approach, and that this reasoning seems to imply that the courts will not question any legislation as long as it is procedurally sound, a regression from Chng. Confining judicial review to ensuring compliance with procedures set out in the ISA diminishes the protective role of the Judiciary, and the Court failed to consider whether the safeguards in the ISA are sufficient once judicial supervision is removed. Whether judicial review can be excluded through executive decision remains a live issue because the 1989 amendments to the ISA reverted the law on judicial review applicable to the ISA to the date that Lee Mau Seng was decided. However, Lee Mau Seng appears to be bad law since it was overruled by the Court of Appeal in Chng Suan Tze. Furthermore, as a High Court decision, Lee Mau Seng may not be the final word on judicial review of action taken under the ISA. In addition, if detainees allege procedural impropriety, this allows a court to consider if there are procedural defects in the Executive's decision-making process, such as the taking into account of irrelevant considerations. Finally, ouster clauses are not barriers to judicial review in modern administrative law because courts can still step in to prevent jurisdictional errors of law. It is difficult to reconcile the Government's attempt to freeze the law relating to judicial review of acts and decisions taken under the ISA as at 13 July 1971 with doctrines such as the rule of law, judicial independence and the separation of powers. One academic view is that courts should not assume that the ISA has frozen the entirety of the law on judicial review as at 13 July 1971. This is because the statute "does not substitute a new, detailed regime covering all the various issues, such as grounds of review, the rules of natural justice, the meaning of ultra vires, remedies and locus standi". The further development of such matters in the common law should not be ignored. Furthermore,