objectively or subjectively. During that period, the scope of judicial review was expanded by common law developments but was subsequently curtailed by legislative and constitutional amendments. Before 1988: Lee Mau Seng v. Minister for Home Affairs Prior to 1988, the Singapore case of Lee Mau Seng v. Minister for Home Affairs (1971) was authority for the application of the subjective discretion test for judicial review of executive power exercised under the ISA. The subjective test precludes the court from inquiring into the facts and grounds that are relied upon by the executive body in exercising its discretion. It is based on the literal interpretation of the words "[i]f the President is satisfied" that appear in section 8 of the ISA, such that no more is required than the subjective satisfaction of the President. This reasoning applies similarly to section 10 of the ISA, which requires the Minister's satisfaction for the suspension of detention orders. 1988–1989: Chng Suan Tze v. Minister for Home Affairs In the case of Chng Suan Tze v. Minister for Home Affairs (1988), the Court of Appeal expanded the scope of judicial review by adopting an objective test when reviewing the exercise of executive discretion. In contrast to the subjective test, the objective test permits the court to examine whether the decision-maker's satisfaction was based on objective facts which fell within the scope of the purposes specified by the ISA. The subjective satisfaction or mere ipse dixit of the executive body is insufficient. However, the adoption of this objective test was only part of the obiter dicta of the case. The ratio decidendi of the case was based on narrower technical grounds. The subjective test was rejected for several reasons by the Court of Appeal. It held that applying the subjective test to sections 8 and 10 of the ISA would render the provisions unconstitutional. The word law in Article 12(1) of the Constitution was held in Ong Ah Chuan v. Public Prosecutor (1980) to encompass fundamental rules of natural justice. Hence, Parliament cannot pass legislation which authorizes the executive to exercise power in breach of these fundamental rules or to exercise power in an arbitrary manner. If the subjective test were to be adopted, it would in effect allow the executive to exercise arbitrary powers of detention, therefore rendering sections 8 and 10 of the ISA inconsistent with Article 12(1). When the case was decided, Article