The Summit Subang Usj Management Corporation v 1. Koh Kim Beng (BA-11BNCVC-20-08/2016)

AUDREY OI YOKE … RESPONDENTS (SHAH ALAM MAGISTRATE’S COURT IN THE STATE OF SELABNGOR DARUL EHSAN SUIT NO.: A772NCVC-189-01/2015 BETWEEN THE SUMMIT SUBANG USJ MANAGEMENT CORPORATION (Registration No.: SEL: 2059/08) … PLAINTIFF

AUDREY OI YOKE … DEFENDANTS) 2 GROUND OF JUDGMENT Introduction [1] This is an appeal against the decision of the Magistrate which dismissed the Appellant’s (Plaintiff) claim for a sum of RM 32,959.60 being the contribution to the management fund for the purposes of refurbishment works against the Respondents (Defendants). [2] Before the hearing of the appeal before this Court, preliminary objection was submitted by the Defendants that the Record of Appeal is incomplete where the Notes of Proceedings of the witnesses, Plaintiff’s SP4 (one of the owners of Premise and secretary for Plaintiff) and Defendant’s SD1 (the Defendant, being one of the owners of the Premise) are missing. The Plaintiff’s counsel argued that the Record of Appeal was filed within the time frame following Order 55 Rule 4(1)(6) of Rules of Court 2012 (ROC 2012) and admitted that the Plaintiff’s counsel missed out the Notes of Proceedings of the two witnesses but averred that it is not prejudicial to the Defendants and not fatal. This Court referred to Order 55 Rule 4 of ROC 2012 and decided that the delay in submitting the remaining Notes of Proceedings is not a sufficient ground to adjourn the case as it is not prejudicial to the Defendants and directed that the matter proceeded for hearing and the said Notes of Proceedings be submitted to this Court as a supplementary record of appeal. [3] In this judgment, the parties will be referred as they were at the Magistrates Court. At times, the term ‘the Defendants’ and ‘the Defendant’ will be used interchangeably. 3 [4] Having read both counsels’ written submissions, the pleadings and documentary evidence adduced and having heard the oral submissions on the main grounds of this appeal, I allow the appeal with cost. My full written judgement of the main grounds are set out below. Background Facts [5] The relevant factual background leading to this appeal based on both counsels’ written submissions can be summarised as follows:

The Plaintiff is a management corporation (Management Corporation) formed under the Strata Title Act 1985 (STA 1985) with its registered address at F4.09, Level 4, The Summit Subang USJ, Persiaran Kewajipan, USJ 1, 47600 UEP, Subang Jaya, Selangor Darul Ehsan;

The Defendant is an individual and his address is at No. 5, Jalan Helang Dua, Bandar Puchong Jaya, 47150 Puchong,

The Plaintiff, at all material time, is the Management Corporation for the Shopping Complex and the Defendant is one of the owners of the Shopping Complex for the Lot No. G.0.60, The Summit Subang USJ, Persiaran Kewajipan, USJ 1, 47600 UEP, Subang Jaya, Selangor (Premise). This fact is not disputed by the parties in this case; 4

The Plaintiff claimed that the Defendant as the owner of the Premise has the obligation to contribute to the management fund for the purpose of refurbishment works (Contribution) based on the apportionment of the share units which was duly approved by the majority owners during Plaintiff’s Annual General Meeting (AGM). In addition, the Defendant is also obliged to pay among others, interests and other payments concerning the Premise to the Plaintiff under the said STA 1985 (Payment).

The Plaintiff claimed that on 15 December 2012, the 1st AGM discussed and agreed about rebranding of the retailers (pages 525 – 531 of Appeal Record (3)). The motion was voted (page 530 of Appeal Record (3)) where 2,353 share units voted against rebranding while 824,839.50 voted for rebranding.

The Plaintiff claimed that the 2nd AGM was held on 15.3.2014 (pages 670 – 675 of Appeal Record (3)) where a resolution by majority owners was passed on the refurbishment Contribution based on costs per share unit in the sum of RM178.16. The Plaintiff claimed that the Defendant has 185 share units and the Contribution payable by the Defendant is RM32,959.60 based on the calculation of RM178.16 times with 185 share units.

However, the Defendant, to date, has failed, refused and/or neglected to pay the said Payment to the Plaintiff which 5 amounts to RM34,628.06 as of 30.12.2014 (Outstanding Sum).

In view that the Defendant has failed, refused and/or neglected to pay the Outstanding Sum despite numerous reminders, the Plaintiff instructed its solicitors, Messrs Han & Partners to issues a letter of demand dated 8.12.2014 to the Defendant for the Outstanding Sum. Plaintiff’s case [6] The learned counsel for the Plaintiff advanced several grounds for the appeal and started off by submitting on the background facts. Prior to the 2nd AGM, the Management Corporation, signed by the General Manager, wrote to the Commissioner of Building (COB) dated 27.11.2013 (at page 532 of Appeal Record (3)). The COB replied to the letter (dated 4.12.2013, page 669 of Appeal Record (3)) that the refurbishing for rebranding purpose should be for the shopping mall only. The Plaintiff’s counsel submitted that the opinion of the COB which is the authority had been obtained by the Management Corporation. [7] It was explained by the Plaintiff’s counsel that the motion at the 2nd AGM of 15 March 2014, 287,432.50 share units owners voted for the refurbishment for the tender price of RM70,480.868.00 (page 3 of 2nd AGM, page 672 of Appeal Record (3)) and declared that the resolution was duly approved. [8] The Plaintiff’s counsel submitted that the Magistrate had erred in deciding that the AGM was invalid on the basis that the applicable law is 6 the STA 1985 and not the Strata Management Act 2013 (SMA 2013). The counsel for the Plaintiff averred that the 1st AGM was in December 2012 which is pursuant to STA 1985 and the 2nd AGM which was held on 15.3.2014 is after the enforcement of the new SMA 2013. [9] The Plaintiff’s counsel submitted that the resolutions for the Contribution were passed before the SMA 2013 and it is the intention of the law that a Management Corporation is allowed to collect contribution for the purpose of refurbishment works. It is also highlighted that the learned Magistrate at paragraph 22 of its written judgment (Supplementary Appeal Record) held that the Plaintiff is prohibited from refurbishment works under the SMA 2013 and referred to section 46(1)(b) of SMA 2013 instead of section 46 of STA 1985. It is argued by the Plaintiff’s counsel that the Magistrate’s decision to pause the resolution to two years down the road has a far-reaching effect and cannot be the law. [10] The Plaintiff’s counsel further averred that the SMA 2013 allows the Plaintiff to claim against the Defendant for the Outstanding Sum based on the provisions of section 51(2), section 52(1), section 59 (1) and (2) of SMA 2013. It is further averred that the Defendant has the obligation to pay and did admit during cross-examination that he has the duty to pay. [11] The counsel for the Plaintiff averred that at paragraph 23 of the Magistrate’s written judgment in relation to the restriction of membership of council members of the three years period, it was not pleaded by the Plaintiff. 7 [12] It is submitted that the Magistrate invoked the adverse inference principle of section 114(g) of Evidence Act 1950 for failure of the Plaintiff to call the Chairman of the Management Corporation. The Plaintiff submitted that the Secretary and the General Manager of Management Corporation was called to testify and was able to confirm on the facts, however the Magistrate held that the failure to call the Chairman shows that the Plaintiff failed to prove. It is the averment of the Plaintiff’s counsel that the letter and the minutes of the meeting including the 2nd AGM’s minutes were signed by the Secretary and the General Manager. [13] The Plaintiff’s counsel averred that based on the Defendant’s testimony, SD1, it was admitted that he has to pay but the question is “how much” (page 103 of Second Supplementary Appeal Record). It is submitted that the Defendant also agreed that there is a duty to pay Contribution (page 104 of Second Supplementary Appeal Record). The Plaintiff’s counsel submitted that the Defendant’s testimony on the duty to pay is never challenged and the payment is decided by the resolution. It is highlighted that the Defendant did not plead for the resolution to be validated. In relation to the complaint of the tender process for the refurbishment works, it is further averred that the finding by the Magistrate is substantially erred as there is nothing to suggest that the tender project is done through telephone. Defendants’ case [14] The learned counsel for the Defendants submitted that the submission will be based on four areas: 8

the letter of COB;

(ii) whether the 1st and 2nd AGM is valid;

(iii) whether Appellant has power to collect under SMA 2013;

(iv) whether the collection by the Plaintiff is ultra vires. [15] The Defendants’ counsel pointed to the letter to COB (page 532 of Appeal Record(3)), whether the letter consist about the whole building or the mall and cross-referred to page 669 of Appeal Record (3) where COB replied dated 4.12.2013 that the cost is to be borne for shopping mall only. The witness from COB stated about the letter (at page 068 of Appeal Record (1)) in reference to “bangunan membeli-belah sahaja” (page 069 of Appeal Record (1)), that is the benefit is shared by the shopping mall proprietors only. It is submitted that the COB’s witness testified that the COB’s letter is a matter of opinion which has no binding effect and it was not a directive. [16] It is submitted that the 1st AGM (page 530 of Appeal Record (3)) and the 2nd AGM (page 672 of Appeal Record (3)) where the voting result was 287,432,50 share units but was not explained. It is submitted that the 1st AGM’s minutes that the Contribution was for all but the 2nd AGM passed resolution for Contribution on shopping mall only and further averred that the Plaintiff should have obtained a declaration from this Court for it to be valid. [17] The Defendants’ counsel submitted that the Plaintiff does not have the power to do refurbishment by way of resolution. The Defendants’ counsel referred to section 43 of STA 1985 to be read with section 46 of STA 1985 and submitted that the Management Corporation has no power to do refurbishment. It is also submitted that the Management 9 Corporation had abused its powers and rely on the case of Perbadanan Pengurusan Endah Parade v Magnificent Daigraph Sdn Bhd [2013] 6 MLJ, CA, referring to pages 351, 353, 356 and averred that there was no express provision for the Plaintiff to do refurbishment. [18] The Defendants’ counsel submitted that the Plaintiff never tendered evidence as to how the principal amount of RM 70,480,868.00 was reached and the basic calculation of RM178.16 per unit share was reached. The Defendants’ counsel further submitted that it should not decide as to how the testimony was given suffice that the Magistrate had the audio-visual observation of the witness’s demeanour and relied on the Privy Council case of Tay Kheng Hong v Heap Moh Steamship Co. Ltd (1964) 1 MLJ 87: “ …. The principles upon which an appellate Court should act in reviewing the decision of a judge of first instance were stated by Lord Thankerton in Watt or Thomas v Thomas [1947] AC 484,

“1. Where a question of fact has been tried by a judge without a jury, and there is no question of misdirection of himself by the judge, an appellate court which is disposed to come to a different conclusion on the printed evidence, should not do so unless it is satisfied that any advantage enjoyed by the trial judge by reason of having seen and heard the witnesses, could not be sufficient to explain or justify the trial judge’s conclusion; ……..” 10 [19] In relation to the argument by the Plaintiff’s counsel on the members of the Council being not pleaded, the Defendants’ counsel averred that the members had been serving for more than three years and referred to section 11 of Building and Common Property (Maintenance & Management) Act 2007 on joint management committee, submitting that the Plaintiff did not object to this and the Magistrate can take cognisance to the illegality even if the illegality is not pleaded, based on a Court of Appeal case of Tan Ah Kek & Anor v Wong Thang Song & Anor [2016] 2 MLJ 686. [20] It is submitted that there was a typo error by the Magistrate where she should be referring to the Building and Common Property (Maintenance & Management) Act 2007 rather than the STA 1985 and SMA 2013. However the counsel for Plaintiff objected to this submission. [21] On the issue of the tender process by phone, it is submitted that the Magistrate decided that the tender process should be transparent and the resolutions are invalid as the task force committee are not qualified to manage the tender process for the refurbishment works. [22] The Defendants verily believed that the Chairman of the Management Corporation should have been called pursuant to section 114(g) of Evidence Act 1950 to determine whether he is a material witness when he takes the stand. Plaintiff In Reply [23] In reply to the Defendants’ counsel, taking the last argument, the Plaintiff’s counsel briefly submitted that it is not the law to use section 11 114(g) of Evidence Act 1950 to test the witness whether he is a material witness or otherwise. In relation to the task force committee, there is no legal requirement to have a task committee and the task committee based on their AGM is an extra step to ensure proper procedure and is acting in good faith. It is submitted that there is no source about the tender by telephone, this finding was not supported by any evidence and is prejudicial to the Plaintiff. [24] The Plaintiff’s further submitted that in relation to the typo error submitted by Defendants’ counsel, averred that it is speculative and merely a concoction especially when there is no correction made by the learned Magistrate. The Plaintiff’s counsel pointed out to the explanation for the amount RM70, 480,868.00 (page 553 of Appeal Record (3)). [25] It is submitted that section 46 of SMA 2013 allows for the refurbishment and referred to the words in the provision which refers to the word “repair”. It is also submitted that the resolution found 90% of the retail shop owners/share units agreed to the Contribution. [26] The Plaintiff’s counsel further submitted that it would be erroneous for Plaintiff to apply for declaration as Plaintiff is asking for the Contribution which is mandated by law. It is also submitted that the Defendants never pleaded that the Resolution was invalid. The Plaintiff’s counsel further averred that the COB had given its opinion but the decision was made on resolution by the retail shop owners who voted for the refurbishment. 12 APPEAL [27] The dispute before me is in relation to the Contribution under the STA 1985 and SMA 2013 by the Management Corporation from Premise owners. I viewed that the heart of the matter is whether the Plaintiff has the right to claim from the Defendants that is whether the Plaintiff has the power under the law to collect the Contribution for the purpose of refurbishment, from the Defendants. [28] In essence, when it comes to managing and administering involving building of strata titles, the law stipulated under the Building and Common Property (Maintenance & Management) Act 2007 (Act 663) must also be referred to other than STA 1985 and SMA 2013. The SMA 2013 repealed the Building and Common Property (Maintenance & Management) Act 2007. [29] The facts and evidence adduced before this Court is unfold into factors, plainly, the proposal to refurbish the Premise (shopping mall) was first tabled in the 5th AGM of the Joint Management Body which was referred to as the Complex that includes the shopping mall and at the 1st AGM of the Management Corporation (Plaintiff’s counsel’s letter of 7.7.2014 to Defendants’ counsel, page 551 of Appeal Record (3)). [30] It was at the 2nd AGM of the Management Corporation where the resolution was passed to approve the tender price for the refurbishment works. The Plaintiff also wrote to the Developer and Housing Board where it is explained that the Defendants did not attend the 1st AGM and 2nd AGM. It is also not disputed that the Defendants are not against the rebranding of the shopping mall by carrying out the refurbishment works. 13 Analysis [31] Let us turn to the law. The Management Corporation taking over the Joint Management Body’s duties, functions and powers, are mandated to collect the maintenance and charges under section 39 of STA 1985 upon its establishment. Following section 41 of STA 1985, it is the duty of the original proprietor to convene the first annual general meeting within one month after the expiration of the initial period and failure to comply will be an offence. The agenda for the first annual general meeting includes “to determine the portion of contribution to the management fund to be paid into the special account to be maintained under section 46”: section 41(5)(ba) of STA 1985. [32] Under the STA 1985, the duties of the Management Corporation are clearly laid out under section 43(1) and the powers are as stipulated under section 43 (2). The special account shall be maintained by the Management Corporation is based on section 46 which “shall be paid such portion of the contribution to the management fund as may be from time to time determined under paragraph (ba) of subsection 41(5) by special resolution for the purposes of meeting its actual or expected liabilities in respect of the following matters:

for painting or repainting any part of the common property which is a building or other structure;

for the acquisition of any movable property…..;

for the renewal or replacement of any fixtures or fittings comprised in any common property and any movable property….; and 14

for any other expenditure not being expenditure incurred under subsection 43(5) to meet liability for maintenance or for settling any defaults in payment by a proprietor.” [33] The Second Schedule of STA 1985 following section 39 of STA 1985 prescribed the manner and the procedure for the establishment of the management corporation and general meetings. The manner in deciding questions at general meetings is by way of resolution which shall be decided on a show of hands unless a poll is demanded by a proprietor or his proxy: paragraph 13(1) of Second Schedule of STA

[34] It is clearly provided in the Second Schedule of STA 1985 that the resolution carried out on a show of hands shall be conclusive evidence. Paragraph 13(2) of Second Schedule STA 1985 clearly stated that, “13. …

Unless a poll is demanded, a declaration by the chairman that a resolution has been carried on a show of hands, shall be conclusive evidence of the fact without proof of the number or proportion of votes recorded in favour of or against the resolution.” (emphasis added) [35] My view is that the STA 1985 provides the manner in casting the votes either personally or by proxy following paragraph 14 of Second Schedule. In this case, the Defendant was not present at the Plaintiff’s AGM. Accordingly, there was no participation from the Defendant in the resolution that had been carried out according to the statutory 15 requirements. The Defendant could not then object to the same resolution. [36] The establishment of the Joint Management Body is governed by section 4 of Building and Common Property (Maintenance & Management) Act 2007 (Act 663), taking over the functions and responsibilities from the developer. The Act 663 is intended to put in place a legislative scheme to ensure the proper management and maintenance of a strata development pending the opening of a book of strata register and the coming into being of the management corporation: speech of Minister for Housing and Local Government at the tabling of Building and Common Property (Maintenance & Management) Bill 2006, Dewan Rakyat, 12.12.2006. [37] I have touched on the purpose of enacting the Strata Management Act 2013 in two of my decisions last year, in the case of Saujana Triangle v JMB Perdana No.Rayuan Sivil: 12ANCVC-77- 08/2016 and in the case of Anwar Yeoh Abdullah v Perbadanan Pengurusan CBD No. Rayuan Sivil: BA-12ANCVC-114-12/2016. In the former, it is a summary judgment claim and the latter is a striking out application under Order 18 rule 19 Rules of Court 2012 where Hansards, the debates at the Parliament (the Second Reading of the Strata Management Bill 2012 of 29.9.2012 and at the Senate of 19.12.2012) were referred. [38] The lacuna was identified in the implementation of the Building and Common Property (Maintenance and Management) Act 2007 (Act 663). The Strata Management Bill 2012 was tabled with the Strata Titles (Amendment) Bill 2012 to ensure that the amendments in both 16 legislations are synchronised. The Minister for Housing and Local Government had stated, among others, “… Selain daripada itu juga, rang undang-undang ini juga telah pun mengambil kira peralihan akaun secara automatik kepada jawatankuasa baru JMB atau pun MC yang telah dipilih dalam tempoh tiga bulan bagi mengelakkan sebarang urusan dan transaksi berkaitan penyelenggaraan dan pengurusan bangunan terganggu yang akhirnya memberi kesan kepada penghuni secara keseluruhannya; …” [39] In interpreting the provisions governing the powers and duties stipulated in a statute, we must look at section 93 of the Interpretation Acts 1948 and 1967 where it is stated,

“Construction of provisions as to exercise of powers and duties

Where a written law confers a power or impose a duty, then unless the contrary intention appears, the power may be exercised and the duty shall be performed from time to time as occasion requires.

Where a written law confers a power or imposes a duty on the holder of an office as such, then, unless the contrary intention appears, the power may be exercised and the duty shall be performed by the holder of the office for the time being or by a person duly appointed to act for him. 17

(deleted by Ord. No. 41 of 1953).” [40] Statutorily, the Plaintiff has the powers pursuant to section 43(2) and section 46 of STA 1985 where in the latter, shall maintain a special account for matters as stated in paragraphs (a) and (d), to which the latter refers to subsection 43(5). Section 43(2)(e) of STA 1985 allows the Management Corporation to collect during the initial period by way of contributions from proprietor in proportion to the share units. [41] This Court also had the benefit of perusing the Third Schedule of STA 1985 where the reading of it stated that the duties of proprietor, among others, at paragraph 2(1)(a), shall permit the management corporation and its agents for the purpose of maintaining, repairing or renewing, in connection with the enjoyment of any other parcel and under the same paragraph 2 part (1)(c), to repair and maintain to keep it in a state of good repair. The functions of the management corporation is also meted out in paragraph 5 of Third Schedule to STA 1985. [42] Following the definition of ‘refurbish’ based on Oxford Dictionary & Thesaurus, Third Edition, 2009, it is generally defined as “redecorate and improve a building or room” and the synonyms are among others, to ‘renovate’, ‘recondition’ and ‘restore’. I viewed that the statutory provisions of STA 1985 and the new SMA 2013 (effective 1 June 2015, P.U.(B) 231/ 2015) provide the Plaintiff the statutory responsibility to carry out the refurbishment works which includes the responsibility in maintaining, repairing and renewing of any of the parcel as specifically provided under paragraph 2(1)(a) and (c) of Second Schedule of STA

18 [43] Based on the fact finding and the legal analysis above, this Court viewed that the burden of prove on the Plaintiff following section 101 of Evidence Act 1950 and the Federal Court case of Letchumanan Chettiar Alagappan @ L Alagappan (as executor to SL Alameloo Achi alias Sona Lena Alamelo Acho, deceased) & Anor v Secure Plantation Sdn Bhd [2017] 4 MLJ 697, had been discharged by the Plaintiff. [44] In addition, it has brought to this Court’s attention and based on the evidence adduced, the Defendants are not against the rebranding but only on the Contribution amount (letter of Defendants to Plaintiff dated 25.4.2014, pages 546 – 548 AR (3)). This Court viewed that such evidence is an admission to the Plaintiff’s statutory responsibility and powers which shifts the burden of proof to the Defendants. Such admission of the Defendant extinguishes the averment of ultra vires on Plaintiff’s part. [45] The agreed refurbishment works was convened at the earlier annual general meetings. The annual general meetings procedure are provided in the Second Schedule of STA 1985. It was not disputed that the Defendants did not attend to the 1st AGM and 2nd AGM of the Management Corporation (letter by Plaintiff to Housing and Developer Board, dated 3.3.2015, page 534 of Appeal Record (3)) and that no complaints had been received by other unit owners. [46] Reverting to the facts, at page 672 of Appeal Record (3), paragraph 7, the Chairman of the Annual General Meeting presented the tender price, based on the lowest tenders, as recommended by the Management Council where the cost to be borne is RM70,480,868,00 19 stating that it is about 3% more than the earlier estimate of RM68,000,000.00 as presented in the 1st AGM on 15.12.2012 and was duly confirmed by COB that it is for the Shopping Mall and the costs per share unit amounted to RM178.16 or an equivalent of RM83.57 per square foot. Financial arrangements were also proposed at one lump sum or 12 equal monthly payments and a late payment penalty at the rate of 10% per annum will be imposed. The poll result was 287,432,50 share units voted for the resolution and 4,260.21 voted against it and the Chairman declared that the resolution was duly approved. [47] I viewed that the facts and evidence clearly fulfilled the statutory requirement of the process for the Management Corporation to carry out its statutory obligation for the benefit of the Premise owners following the Second Schedule and Third Schedule of STA 1985. There was sufficient notice given to the proprietors of Premise following the requirement to notify under Section 39 and Second Schedule of STA

Evidently, the decision was made by way of resolution attended by proprietors of Premise at the general meeting and the Plaintiff has the powers to collect the Contribution and Payment. [48] Flowing from the analysis above, pertaining to the Defendants averment that a declaration ought to be sought by the Plaintiff or that the AGM was invalid, are issues that were not pleaded. It is trite law that parties are bound by their pleadings: Dato Tan Chin Woh v Dato’ Yalumallai @ M. Ramalingam S/O V. Muthusamy [2016] MLJU 641. It has been decided by the apex court that can be found in a number of authorities that where issues that were not raised by parties in their pleadings but were decided by the trial judge, the appeal must be 20 allowed: Janagi v Ong Boon Kiat [1971] 2 MLJ 196 and Yew Wan Leong v Lai Kok Chye [1990] 2 MLJ 152, Supreme Court. [49] It is this Court’s finding that the Magistrate was plainly wrong in law in deciding that the STA 1985 and SMA 2013 do not provide the functions and powers of a management corporation and failed to make reference to the relevant legislations and in deciding issues that were not pleaded by the Plaintiff that warrants this Court’s intervention: Gan Yook Chin v Lee Ing Chin [2005] 2 MLJ 1. In light of the above reasons, I allow the appeal with cost. Dated: 30 April 2018 (ZALITA BINTI DATO’ ZAIDAN) Judicial Commissioner Shah Alam High Court 21 COUNSEL FOR THE APPELLANT PHANG SOON MUN Messrs. Han & Partners Advocates & Solicitors Unit 20. 23-8 1001, Jalan Sultan Ismail Menara Permata Damansara No. 685, Jalan Damansara 6000 Kuala Lumpur [Ref: No: LKH/2480/15/PS/rc] Tel: 017-300 4133/ 017-300 Fax: 03-2856 9215 COUNSEL FOR THE RESPONDENT C. NATARAJAN Messrs. C.N. Rajan & Co. Advocates & Solicitor Kamar 568-10-16 & 17 Tingkat 10, Kompleks Mutiara Batu 3 ½ Jalan Ipoh 51200 Kuala Lumpur [Ref: No:CNR/LT/1333/2015]