example if less than two third legislators of party defect then the Presiding Officer can use his discretion to either disqualify the legislators before a vote of no confidence is held or delay the decision on disqualification until after the "vote of no confidence" is held. In another example, if less than two third legislators of party defect together in more than one batch in such a way that the combined strength of the united defectors is more than two third before the decision on the defection is made, the Presiding Officer can use his discretion to either disqualify each batch of the defecting legislators or accept the combined batches of the defectors as the legal defection (no disqualification). This allows a possibility of the misuse by the Presiding Officer to benefit a specific party through further horse-trading (counter-defections), formation of unholy alliances or electoral fraud by exploiting the loopholes in the existing anti-defection laws. However, the decision of the Presiding Officer is subject to the judicial review by courts. Italy In Italy, party-switching is more common than in other Western European parliamentary democracies, with nearly 25% of members of the Italian Chamber of Deputies switching parties at least once during the 1996 to 2001 legislative term. A 2004 article in the Journal of Politics posited that party-switching in Italy "most likely is motivated by party labels that provide little information about policy goals and that pit copartisans against each other in the effort to serve constituent needs." Malaysia On 28 July 2022, in Malaysia, the Constitution (Amendment) Bill (No. 3) 2022 regarding the provision prohibiting members of the Dewan Rakyat from jumping parties was approved by a two-thirds majority vote of the members of the Dewan Rakyat. and thus Malaysia is also one of the countries that prohibits 'party hopping' or 'party cheating'. Similar law has also been passed by Penang, Perlis, Selangor, Kelantan, Sarawak, Negeri Sembilan and Perak state legislatures. New Zealand Party switching in New Zealand gained currency during the end of the 1980s, and even more so in the late 1990s after mixed member proportional representation was implemented. In particular, the phrase "waka-jumping" entered the public consciousness in 1998 when then-Prime Minister Jenny Shipley expelled the New Zealand First party from the ruling coalition government, and several New Zealand First MPs resigned from the party and stayed loyal to the government. In response to these defections,