 One part of Raja Azlan Shah's judgement, which stated that "the individual has certain fundamental rights upon which not even the power of the State may encroach" was subjected to criticism for "hardly (holding) substance" in light of certain legislation, such as the RRE and the Internal Security Act (ISA), that allegedly encroach on human rights.This part of the judgement in "Loh" has been described as "no more than judicial rhetoric".Legal scholars have suggested that the decision in "Loh" made Article 4(1) insufficient with regard to ensuring the constitutionality of laws passed by Parliament, as