details if detainee’s illness was one of the factors contributing to the deaths in detention. The report studied five death cases under police custody including the case of Francis Udayappan who drowned in an attempt to escape from police custody on 16 April 2004. Observation and findings from these studies cover on how the police handled the investigation on death in detention, insensitivity showed towards the deceased family members and the responsibility of the police when detainees was not well. 1.23 Suara Rakyat Malaysia or SUARAM also highlighted the issue of deaths in police custody in SUARAM annual report, Human Rights Report, 2015 Overview, Civil and Political Rights. SUARAM report stated that until November 2015, they had recorded 11 death cases in detention. However, the total number of cases was based on media reports and there was no conclusive data on the stated deaths. SUARAM report concluded that the deaths would not happen if the ill detainees were sent to hospital for further treatment. 1.24 The annual report of Amnesty International Report 2014/15, The State of the World’s Human Rights touched on the violations of human rights by the police. The violations of human rights mentioned are death in detention, torture, inhuman treatment including the use of brutal forces and the use of firearms.16 1.25 At the international level, a number of studies have been done concerning deaths in police custody. This research makes reference to reviews on the procedures of previous studies in Commonwealth countries on deaths in police custody. Among the reports referred to in this research are Thematic Report: Deaths in Police Custody – A Ten Year Review17 in New Zealand; Death in or following police custody: An Examination of the cases 1998-99 – 2008-09,18 in United Kingdom and Monitoring Injuries in Police Custody: A Feasibility and Utility Study in Australia.19 Legal analysis and relevant findings from these studies are able to facilitate in providing recommendations for this research. 16 Country Entries, Malaysia (pp239-240). Independent Police Conduct Authority, New Zealand, 2012. 18 IPCC Research Series Paper: 17, Independent Police Complaints Commission, United Kingdom. 19 Sallybanks, J. Monitoring Injuries in Police Custody: A Feasibility and Utility Study, Technical and Bakcground Paper No. 15; Australian Insitute of Criminology (2008). 17 12