of the NHRAP, including the planning, development, implementation and
monitoring stages. However, during the development of the NHRAP by the
consultant, the Commission had only met twice with the consultant. Given
the status of the Commission as the National Human Rights Institution, the
Commission felt that there should be more engagement with the Commission
in developing the NHRAP.
In Maklum Balas Kerajaan Terhadap Laporan Tahunan SUHAKAM 2016, it was
stated that the NHRAP draft was finalised through a roundtable discussion
with all stakeholders, and that the said draft would be tabled for cabinet
approval. The Commission would like to put on record that no discussion was
held with the Commission after the consultant concluded its consultation
session with all stakeholders although the Commission had put forward it
request to the consultant. The Commission was also not involved during the
shortlisting of issues received from the stakeholders and only had access to
the NHRAP draft after it was finalised by the consultant.
Having said that, the Commission still forwarded it views and recommendations
based on the NHRAP draft prepared by the consultant which includes the
following:
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i)
Cultural Relativism vs Universality of Human Rights
The Commission is concerned with the use of cultural relativism element
which would restrict the concept of human rights according to local
culture and religious norms. Hence, the concept of ‘universal’ UDHR will
be limited.
ii)
Language used in NHRAP does not reflect action-oriented and is general
in nature
Most of the proposed action plans outlined in the NHRAP do not take
into consideration the ‘S.M.A.R.T.’ (Specific, Measurable, Achievable,
Reasonable, Time Bound) criteria. As such, the Commission is of the view
that they are general and difficult to evaluate.
iii)
NHRAP and other Government Action Plans
The Commission also recommended that other action plans such as
Women Action Plan, Children Action Plan and Person with Disability
Action Plan and other action plans which would be developed by the
government should complement the NHRAP as human rights issues are
inter-related and inter-dependent.
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