reprint for the first time. Containing 162 Articles and three schedules, this reprint was published in the Government Gazette of 31 March 1980. Prior to the issuance of the 1980 Reprint, the Constitution had been criticized for being inaccessible due to its fragmented nature. The former Chief Minister of Singapore, David Marshall, commented that Singapore had "the untidiest and most confusing constitution that any country has started life with", while constitutional scholar R.H. Hickling acknowledged that "the problem of the layman is ... to ascertain what a Constitution says". In 1979, Parliament amended the 1963 State Constitution to give authority to the Attorney-General of Singapore to "cause to be printed and published a consolidated reprint of the Constitution of Singapore, as amended from time to time, amalgamated with such of the provisions of the Constitution of Malaysia as are applicable to Singapore, into a single, composite document". To achieve this task, the Attorney-General was given discretion to merge the existing provisions of the two Constitutions and make modifications that might be necessary or expedient due to Singapore's independent status; to rearrange the provisions; and to omit duplicated, inappropriate or inapplicable ones, among other things. Pursuant to this, the 1980 Reprint of the Constitution was issued. In addition, the President was empowered to authorize the Attorney-General to publish further reprints incorporating all constitutional amendments in force at the date of the authorization. While some commentators have noted that the 1980 Reprint created theoretical issues, to date no practical problems have arisen in the application of the Constitution. In Heng Kai Kok v. Attorney-General (1986), a claim for wrongful dismissal by a police sergeant, one issue arising was whether a constitutional provision introduced in 1970 had impliedly repealed an existing provision. Judicial Commissioner Chan Sek Keong decided the case on other grounds, but observed on an obiter basis that this argument was no longer relevant because only the 1970 provision appeared in the 1980 Reprint of the Constitution, and Article 155(3) of the Reprint states that "[a]ny reprint of the Constitution ... shall be deemed to be and shall be, without any question whatsoever in all courts of justice and for all purposes whatsoever, the authentic text of the Constitution of the Republic of Singapore in force as from the date specified in that reprint until superseded by the next or subsequent reprint". A revised edition of the Constitution was published as