Dalam kes Ngeow Voon Yean v. Sungai Wang Plaza Sdn Bhd/Landmarks Holding Bhd [2006] 5 MLJ 113, Sit Norma Yaakob FCJ memutuskan di 123 – “In Malaysia, the general rule governing the doctrine of superior orders is nothing more than the duty of obedience that is expected of an employee. The most fundamental implied duty of an employee is to obey his employer’s orders. The classic modern statement of that duty is found in the judgment of Lord Eversherd MR in Laws v London Chronicle (Indicator Newspapers) Ltd [1959] 2 All ER 285 to be as follows: It is, no doubt, therefore, generally true that wilful disobedience of an order will justify summary dismissal, since wilful disobedience of a lawful and reasonable order shows a disregard — a complete disregard — of a condition essential to the contract of service namely the condition that the servant must obey the proper orders of the master and that, unless he does so, the relationship is, so to speak, struck at fundamentally. Working as instructed is the employee’s basic consideration under a contract of employment just as providing remuneration is the basic consideration of his employer. However the employee’s duty to comply is confined to all the lawful and reasonable orders of his employer in respect of the performance of such functions that falls within the scope of his contract of employment.”