In short, the ICPPED provides guidelines on iden�fying elements of an enforced disappearance and clearly outlines the role of the Government in inves�ga�ng the offence and other related offences. 194.3. The Government should u�lise ICPPED to produce a framework for the introduc�on of legisla�on to criminalise enforced disappearance as well as to fill up the missing components in Malaysia’s legisla�on. 195. Further, Malaysia has also not ra�fied the Interna�onal Covenant on Civil and Poli�cal Rights 1966. This treaty obligates its members to protect and preserve basic human rights, such as: the right to life and human dignity; equality before the law; religious freedom and privacy; freedom from torture, ill-treatment, and arbitrary deten�on; gender equality; the right to a fair trial; right to family life and family unity; and minority rights. 196. Following the ra�fica�on of the interna�onal trea�es above, the Government should take further steps to give legal validity to ICPPED and ICCPR in Malaysia to be�er enable agencies to resolve the issue of 'enforced disappearance'. 197. In conclusion, the Panel reiterates that in carrying out the Public Inquiry, SUHAKAM was discharging its duty to inquire into infringements of human rights under sec�on 4(1)(d) of the Human Rights Commission of Malaysia Act 1999, and that the recommenda�ons in this report are made in exercise of SUHAKAM’s powers under sec�on 4(2)(b) of the Act which provides that SUHAKAM may “advise the Government and/or the relevant authori�es of complaints against such authori�es and recommend to the Government and/or such authori�es appropriate measures to be taken.” 198. The findings and recommendations herein are the unanimous findings and recommenda�ons of the Panel of Inquiry. J. Addressing the Terms of Reference 199. The Panel has reached the following conclusions in rela�on to its Terms of Reference: 199.1. In response to paragraph (a): ● The disappearance of Pastor Raymond Koh was a case of enforced disappearance as defined under the Interna�onal Conven�on for the Protec�on of All Persons from Enforced Disappearance; and 67 PASTOR RAYMOND KOH 194.2.