“131. Circumstan�al or presump�ve evidence is especially important in allega�ons of disappearances, because this type of repression is characterised by an a�empt to suppress all informa�on about the kidnapping or the whereabouts and fate of the vic�m." 75. Cases of enforced disappearances are usually characterised by a�empts to suppress all informa�on by the State. Typically, complainants in such cases do not have direct evidence to show that State agents are concerned in the disappearances and must rely on circumstan�al evidence. Complainants also typically do not have the means to iden�fy with precision the State agents concerned in the disappearances. 76. The evidence adduced before the Panel to show that the State was concerned in the disappearance is usually circumstan�al evidence which gives rise to the inference that State agents are involved in the disappearance. It is only through the exercise of the State's inves�ga�ve power, would the perpetrators, and their roles, be iden�fied with precision. 77. The considera�on in cases where evidence was en�rely circumstan�al was explained by the Court of Appeal in Chan Chwen Kong v Public Prosecutor [1962] 1 MLJ 307 at paragraphs E and F, page 307: “It must, however, be borne in mind that in cases like this where the evidence is wholly circumstan�al what has to be considered is not only the strength of each individual strand of evidence but also the combined strength of these strands when twisted together to make a rope. The real ques�on is: is that rope strong enough to hang the prisoner?24 78. In the course of the Public Inquiry, the Panel was en�tled as a ma�er of law to adopt a less constrained and flexible approach in the recep�on and admission of the evidence both oral and documentary, than would otherwise have been proper to admit in a civil and criminal trial. 24 See also Sunny Ang v Public Prosecutor [1963] 2 MLJ 195, where the appellant was convicted of murder even though the body of the deceased was not found and the prosecu�on relied on circumstan�al evidence. 29 PASTOR RAYMOND KOH that may be legi�mately considered. Circumstan�al evidence, indicia and presump�ons, may also be considered so long as they lead to conclusions consistent with the facts. Further, the court held: