In terms of case law, the landmark case of CCH & Anor. v Pendaftar Besar bagi Kelahiran dan Kematian, Malaysia (2021) set the precedent that an abandoned child is entitled to citizenship by operation of law by virtue of Article 14(1)(b) and Section 1(a) of Part II read with Section 19B of Part III of the Second Schedule. First, the court concluded that Section 19B must be interpreted in the broadest possible sense to encompass the plight of abandoned new born children in order to meet the original intention of the provision to prevent statelessness. This means the Court should give the widest possible meaning to words in the provision to guarantee a fundamental right to life and personal liberty contained in Article 5(1). Therefore, a wider interpretation of “any new born child found exposed in any place” must include “new born children who are left and discovered in a place without any trace of their biological parents.” They further define places of abandonment as “dumpsites, baby hatches, public or school toilets, places of worship, and so on”. Secondly, to address the jus sanguinis concept within Section 19B (“until the contrary is shown, to have been born there of a mother permanently resident there”), the Court concluded that if an abandoned child fulfils the jus soli requirements of Section 1(a) of Part II which requires the child born within the Federation to be born of at least either one parent who is a citizen or resident in the Federation, it automatically satisfies the jus sanguinis aspect of Section 1(a) and Section 19B, unless anyone claiming to the contrary can prove otherwise. In this case, the abandoned child was born in a hospital in Malaysia with proof of the Adoption Order and birth certificate. Thirdly, the case sets precedent for how the KDN, JPN, and Registrar-General of Births and Deaths should deal with future cases of abandoned new born children. It explicitly states that the “burden is on the respondent (The Government) to undertake proper investigations to determine the status of such child’s biological parents or mother” and that if the abandonment is true, the Government “is obligated by the highest law of the land in Section 19B of Part III to recognise that new born child’s citizenship by operation of law, unless where there is evidence to the contrary” on the child’s parentage. The latest decision in the Court of Appeal in March 2022 that granted Malaysian citizenship to an abandoned child follows the decision in CCH & Anor. v Pendaftar Besar bagi Kelahiran dan Kematian, Malaysia, which was heard at the Federal Court in November 2021 (Lim, 2022). At the Court of 77