LAW504
LAND LAW I

FINAL ASSESSMENT

STUDENTS:
NAME NO ID/MATRIK
MOHD HAPIS BIN MANAN 2020190299
ANSWERS:
QUESTION 1 (a)(b)&(c)

GROUP CODE:   
NLWIK3AY 
 
LECTURER:  
PROFESOR MADYA ROHANI BINTI SAHAK
 
SUBMISSION DATE:
29 JULY 2021 BEFORE 11.00 AM

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ANSWER (a)

ISSUE
Whether Maju Bank had the duty to pay the rent under National Land Code (NLC)
1965 and to advice Maju Bank in order to protect its interest in the land.
LAW
National Land Code (NLC) 1965 introduce for amend, consolidate and uniform laws
relating to land in the state Johor, Kedah, Kelantan, Melaka, Negeri Sembilan, Pahang,
Pulau Pinang, Perak, Perlis, Selangor, Terengganu and Kuala Lumpur Federal Territory.
In Hj Abdul Rahman & Anor v Mohamed Hassan, all land deals must be in the
specified form and fully recorded with the relevant land registry. If you don't, the transactions
will be null and invalid. Section 5 define the words of dealings mean any transaction with
respect to alienated land effected under the powers conferred by Division 4 alienated land
dealings including charges.
In case of United Malayan Banking Corporation (UMBC) v Pemungut Hasil Tanah
Kota Tinggi, Privy Council held that NLC is a code of law that regulates land tenure in
Malaysia. In this case, the company Johore Sugar Plantation & Industries Bhd charged the
land to UMBC to secure the banking facilities given by UMBC. The company defaulted
payment of the rent. The collector of land gave notice in the prescribed form 6A under
Section 97(1) to pay rent within 3 month from the date of notice. The copy was served to the
UMBC as required by Section 98 (1). The company and the bank did not comply the notice.
The Collector declared the land forfeited to the State Authority under Section 100. A
notification was published in the government gazette on September 15, 1977.
Under NLC rent interpreted as including any annual sum payable to the State
Authority by way of rent, any other annual payment due to the State Authority which by any
written law is to be collected as if it were rent or land revenue and any fee due to the State
Authority in respect of arrears of rent by virtue of rules under section 14.
Under Section 93 If the money is not paid, it will be considered a debt owed to the
State Authority. Section 94 (1), rent is due at the start of the calendar year in which the land
is alienated, or at the start of the next calendar year if the land is alienated after September
30th of that year. Section 94 (2), on the first day of that year, the rent is payable in full. Rent
will be in arrears on the first day of June if it is not paid before the end of May. When rent is
due, it must be paid in full by the end of May of that year. The State Authority has no power
to send a notice of demand after it has been paid within that time frame. Section 95, rent
must be paid at the Land Administrator's office or any other location considered appropriate
by the Land Administrator’s.

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 Section 97(1) & (2), when payment rent is late, the proprietor will be served with a
notice of demand in Form 6A, along with a record of the notice's service on the register
document of titles.
In Pow Hing & Anor v Register of Titles Malacca, form 6A had been issued,
according to an undated and unsigned entry found by the appellant. The proprietor had been
given Form 6A for land rent arrears, but there had been no compliance with Section 97. The
court held, endorsement is a mandatory procedure, and not merely directory. The forfeiture
was declared unlawful due to a violation of Section 97(2).
Section 98 right of charges, to pay sum demanded. Under subsection (1) In addition
to the proprietor, any of the following individuals or entities may pay the money requested by
any notice under section 97 to the Collector within the period indicated in the notice, that is
to say (any individual or organisation with a recognised stake in the land including a charge
of any lease or sub-lease thereof, and accordingly, The Collector shall cause a copy of the
notice to be served on every such person or body as soon as possible after it is served on
the proprietor, along with the supplementary notice set forth in the supplement to Form 6A.
Under subsection (2) any sum paid by a chargee pursuant to subsection (1) shall be
added to, and deemed for all the purposes of this Act to form part of, the first payment
thereafter falling due to him under the charge. Stated under subsection (3) any sum so paid
by any other person or body, (a) shall be recoverable from the proprietor by civil action

APPLICATION

According in this recent situation, Maju Bank give a financial loan to Samad and for
the security Samad as a registered proprietor charged land in Section 7, Shah Alam as a
security to Maju Bank.
In order to established the legal right of Maju Bank, we have to see is there any
registration done by Samad including Maju Bank for the charge. From the fact given, Maju
Bank as a chargee was registered in Julai 2016 when Samad obtained the relevant approval
from Maju Bank for the creation of the lease between Samad, Ahmad and Ali on form 15A,
for that Form 15A was duly registered. By this fact, there are 4 names to the relevant
authority delivered the notice of Form 6A, not only Samad, but have to send a copy to Maju
Bank, Ahmad and Ali stated according to the Section 98 (1). This is violation conduct by the
relevant authority and set aside the right of chargees.
By referring United Malayan Banking Corporation (UMBC) v Pemungut Hasil Tanah
Kota Tinggi, The collector of land gave notice in the prescribed form 6A under Section 97(1)
to pay rent within 3 month from the date of notice. The copy was served to the UMBC as

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required by Section 98 (1). In this recent case. It goes same when the failure to serve come
from the relevant authorities.
From that we already notice that the relevant authority not send a copy of the notice
to be served on every such person or body as soon as possible after it is served on the
proprietor, along with the supplementary notice set forth in the supplement to Form 6A. By
referring Pow Hing & Anor v Register of Titles Malacca, the National Land Code must be
follow to dealing with the land. Failed to serve the copy of the notice Form 6A by relevant
authorities is another issue and subject to query.
After that, proactive action in order to protect Maju Bank as a chargee interest, must
quickly check about the quit rent that was pending for past three years, how much Maju
Bank need to pay actual amount with the rent plus penalty.
In Section 98 (1) the sum demanded through the notice in Form 6A may be paid by
Maju Bank other than Samad. When the notice in Form 6A is served upon Samad, it also
applies to Maju Bank who have an interest in the land. To settledown this issue, Maju Bank
have a duty to pay the rent within the time stated in notice Form 6A.
Section 98 (3) provides that any sum paid by Maju Bank other than Samad shall be
recoverable through civil action. In Section 99, Payment of the sum demanded within the
stipulated time will cause the notice in Form 6A to cease to have effect and the note
endorsed on the registered document of title will be cancelled and forfeit by the Land
Administrator under Section 100.

CONCLUSION

To conclude, there are mistake of the relevant authority not send a copy of Form 6A
to Maju Bank as a charge who have interest in the said land under Section 98 (1).
But then to protect Maju Bank interest in this case, I will advice that is better to Maju
Bank to pay the quit rent that was pending actual amount due with the rent interest for the
past three years within the time given on the notice of Form 6A to avoid further action from
the state authority.
Do not be afraid, because by applying Section 98 (3) Maju Bank can recover back
the paid of the quit rent and penalties through a civil action. Take an immediate action is a
must from effect to the land of being forfeiture because the quit rent was not paid in referring
Section 99 and afraid that action by forfeiture because failed to pay the rent imposed under
Section 100.

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ANSWER (b)

ISSUE
Whether Ali and Ahmad are entitled to remove the food warmer, the painting and the
door.
LAW
In Section 5 National Land Code land define land includes all things attached to the
earth, and all things permanently fastened and fixed to anything attached to it belong to the
land. This definition includes buildings and items that are permanently attached to buildings.
Landowners must determine what constitutes a fixture or chattel.
Fixture means items which are so affixed to the land or a building as to become part
of the land. Immovable items which pass on with the ownership of the property. Chattel
means if there are objects that are linked to the land but are not permanent and do not form
part of the land.
In case Holland v Hodgson, This is a precedent-setting decision that clarifies the
distinction between fixtures and chattels. In this case, Blackburn J introduce the degree and
object of annexation test. Two test that should be implement to determine whether the item
on the land is movable as below:

DEGREE OF ANNEXATION TEST

The question is whether the chattel can be removed readily without causing injury or
damage to itself or the property. The harm might be either physical or mental. If the harm is
physical, the degree of the damage must be determined. It's more likely that an object is a
fixture if it's tightly connected.
Adopting English case Holland v Hodgson to Malaysia land law, In Goh Chong Hin v
Consolidated Malay Rubber, the question was whether the proprietor's machinery fastened
to the property was a fixture. It was said that the apparatus was bolted and nutted to the
ground and had become a fixture, thereby becoming a part of the land.

PURPOSE/OBJECT OF ANNEXATION TEST

The reason for attaching the item is investigated. The goal of annexation takes
precedence over the degree of annexation, and it can be used to refute or enhance the
degree of annexation test. The object becomes a fixture if the goal of the attachment is to
improve the value of the land by permanently attaching to it. If the attachment is for the sole
purpose of enhancing the enjoyment of the chattel, it is still a chattel.
Both tests must be used on the object in order to determine if it is fixtures or chattel.

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 In Sungei Way Leasing v Lian Seng Propeties, the fact that a custom manufactured
air conditioning unit purchased under a hire purchase agreement was fastened to the
building relying on clause 11 of the hire purchase agreement stated the lessor was to stay as
the unit's owner and the lessee had no right to transmit title to a third party. Despite the fact
that the air conditioner was a permanent fixture, the court decided that the hire buy
arrangement must be honoured. As a result, the lessor had a greater claim to the air
conditioning equipment. Because there existed a retention of title provision in favour of
plaintiff, the charge was not entitled to the equipment affixed to the land.
In other case of MBF Finance v Global Pacific Textiles Sdn. Bhd. & Anor, There was
also a retention provision for the equipment rental and affixed to the land. Due to the
defendant's failure to pay the equipment rental, the lessor terminated the agreement and
attempted to remove the machines from the property. The defendant and chargee both
raised objections, arguing that the machines had become a part of the property. The
preservation of the clause, according to the court, allowed the machine to continue as
chattels, despite the fact that it was linked to the property. Because the equipment were only
briefly put in the facility, their departure did not result in any tangible damage to the land.
However, there are exception to the law of fixtures. Those exception are custom and
tenant fixtures. When a tradition prevails with regard to an object, it should be treated as a
chattel at all times. This item's owner has the power to remove it. The custom must be well-
accepted and followed by the community. The owner of this chattel must also wish to build a
similar structure in a different place. In Kiah v Som It was held that in this case, a Malay
traditional house was built on stilts, which could easily be dismantled and removed. That
house is considered a chattel. 
Tenant fixtures are things brought by a tenant to his rented premises that belong to
the tenant and are removable after a landlord-tenant relationship has been established. This
equipment must be removed before the end of the tenancy. If you don't, the items will be
turned over to the landlord. Only the renter's belongings are allowed to be removed;
anything that was there before the tenant moved in is not allowed to be removed.
When removing the items, the tenant must make sure that the removal of the fixtures
does not cause any major harm to the property. In Spyer v Phillipson In this instance, it was
determined that a tenant has the right to remove his fixtures if no significant damage to the
property has occurred.

APPLICATION

By applying the law and cases above to our current situation, Ali and Ahmad must
identify all of the item one by one to categorise it as either it falls under fixture or chattel and

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apply all test introduce by Blackburn J In case Holland v Hodgson, Two test that should be
implement to determine whether the item on the land is movable are the degree of
annexation test and object of annexation test.

FOOD WARMER

Background fact of the huge food warmer is obtained from Sen Hup Sdn Bhd. on a
hire purchase agreement, installed in the kitchen and attaching it to the floor with bolt and
nut.

The degree of annexation test.

Whether the food warmer can be removed readily without causing injury or damage
to itself or the property. The harm might be either physical or mental. If the harm is physical,
the degree of the damage must be determined. It's more likely that an object is a fixture if it's
tightly connected. Also in Goh Chong Hin said the apparatus was bolted and nutted to the
ground and had become a fixture, there becoming part of the land. RESULT : POSITIVE,
The food warmer is attaching to the floor with bolt and nut.

The purpose or object of annexation test

The reason for attaching the food warmer is investigated. The goal of annexation
takes precedence over the degree of annexation, and it can be used to refute or enhance
the degree of annexation test. The food warmer becomes a fixture if the goal of the
attachment is to improve the value of the land by permanently attaching to it. If the
attachment is for the sole purpose of enhancing the enjoyment of the chattel, it is still a
chattel. RESULT : NEGATIVE, The food warmer attaching not to improve the value of
the land, its for business purpose.

From the both test to determine the fixture or chattels was not satisfied. One of the
test result negative and become chattel. By referring case fact of the items with hire
purchase agreement, we can apply the case of Sungei Way Leasing v Lian Seng Propeties,
despite the fact that the food warmer was a permanent fixture, the hire purchase
arrangement must be honoured. As a result, the lessor had a greater claim to the food
warmer equipment. Because there existed a retention of title provision in favour of plaintiff.
Yes, there are hire purchase agreement between Ali, Ahmad and Sen Hup Sdn. Bhd.

In another case to be apply in case of MBF Finance v Global Pacific Textiles Sdn.
Bhd. & Anor, The preservation of the clause, allowed the machine to continue as chattels,
despite the fact that it was linked to the property. Because the equipment were only briefly

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put in the facility, their departure did not result in any tangible damage to the land. Yes, the
food warmer can be remove easily with the professional workers without harm to the land.

Ali and Ahmad also can argue that the exception can be applied to the law of fixtures.
The exceptions are tenant fixtures. Ali and Ahmad can take all the fixtures item belonging to
them since there are hire purchase agreement with Sen Hup Sdn. Bhd. Both of them must
remove it or bring along all this items when his expiry of tenancy comes. 

The test of the purpose or object of annexation test can be applied to food warmer.
This item can be considered as chattel. If the food warmer were removed from the land, it
will not cause a physical damage to the land. This is because mostly food warmer are used
as a restaurant business purpose. The case of Spyer v Phillipson also can be used by Ali
and Ahmad to defend his right to the food warmer.

From the fact and cases given, we can easily conclude that the food warmer is a
chattels and can be move to a new place by both of them.

THE PAINTING

Background fact of the huge painting and place it up on the wall. The painting was
mounted on a special panel which was nailed to the wall as they wanted to give the
restaurant a pleasant atmosphere.

The degree of annexation test.

Whether the painting can be removed readily without causing injury or damage to
itself or the property. The harm might be either physical or mental. If the harm is physical,
the degree of the damage must be determined. RESULT : NEGATIVE, The painting is
attaching on the wall with special panel and just only nailed to the wall.

The purpose or object of annexation test

The reason for attaching the painting is investigated. The goal of annexation takes
precedence over the degree of annexation, and it can be used to refute or enhance the
degree of annexation test. The painting becomes a fixture if the goal of the attachment is to
improve the value of the land by permanently attaching to it. If the attachment is for the sole
purpose of enhancing the enjoyment of the chattel, it is still a chattel. RESULT : NEGATIVE,
The painting attach not for improve the value of the land, it just placed to give the
restaurant a pleasant atmosphere and enhancing the enjoyment.

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 From the both test to determine the chattels was not satisfied. both test result
negative and become chattel.

Result of the test of the degree and purpose or object of annexation test satisfied.
The painting can be considered as chattel and as far as we concern that the painting is a
chattels and can be move to a new place by both of them.

THE DOOR

Background fact of the special designated door imported from Bali fixed and replace the
existing door of the main entrance.

The degree of annexation test.

Whether the door can be removed easily without causing injury or damage to itself or the
property. The harm might be either physical or mental. If the harm is physical, the degree of
the damage must be determined. RESULT : POSITIVE, The special door located at the
main entrance and not easy to remove and can harm the main entrance also replace
the earlier door.

The purpose or object of annexation test

The reason for attaching the door is investigated. The goal of annexation takes precedence
over the degree of annexation, and it can be used to refute or enhance the degree of
annexation test. The door becomes a fixture if the goal of the attachment is to improve the
value of the land by permanently attaching to it. If the attachment is for the sole purpose of
enhancing the enjoyment of the chattel, it is still a chattel. RESULT : POSITIVE, The
special designated door attach can improve the value of the land, it not just placed to
give the restaurant a pleasant atmosphere and enhancing the enjoyment but for the
safety and security requirement.

From the both test to determine the fixture was satisfied. both test result positive and
become fixture.

Result of the test of the degree and purpose or object of annexation test satisfied.
The door considered as fixture. This special door actually were attached to the main
entrance by screws in such a way that they could be dismantled without damage or difficulty.
Mostly, when the door was installed on the building, it will become part of the land due to
strong attachment to it. Any removable of this item can cause a physical damage to the wall
and tiles on the building.

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CONCLUSION

As a conclusion, after apply the both test and refer to the given case and authority,
Ali and Ahmad are entitled to remove the food warmer and the painting because its chattels.
But then for the special door from Bali at the main entrance affixed is a fixture. That was
decide in Goh Chong Hin that the item become a fixture is a part of the
land and can’t be remove. Ali and Ahmad the door intended to remain there.

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ANSWER (c)

ISSUE

Whether Form 16A submit by Ali and Rosni was fit for registration and why it was
rejected

LAW

Stated under Section 79(2) the State Authority (SA) after alienation of the land
approves shall determine Section 79(2)(f) the category of the land use and (g) the express
condition and restrictions in interest imposed.
Clearly stated for the use of land under Section 52(1) there are three categories in
the use of land which is agriculture, building and industries. Under Subsection (a) the SA
have to endorse one of the categories on the document the title.
When ownership is created under this act, the SA has a wide authority after
delivering possession, including the imposition of express terms and limitations of interest,
according to Section 120.
Section 89, subsection (b) on conditions, limits of interest, and other requirements,
following endorsement on the deed of title, the document becomes conclusive.
As per Section 52(1)(b)(i) the SA must specify the express conditions imposed
towards Section 121(1) if under agriculture land categories which is specify below
subsection (a) until (d) which is require cultivation, prohibit cultivation, fix the dates in any
year and limit use of land be occupied by house and other buildings.
National Land Code are implied term for agricultural land, provide under Section
115(1)(a) no building shall be erected other than those to be used for one or more purposes
specified under subsection (4)(a) which is used for agricultural purpose only.
For that, under agricultural land, the clearly provision set an obligation to a registered
proprietor to comply with the express and the implied condition stated by the SA. Stated
under Section 115, Buildings must be constructed for agricultural purposes, such as
extracting or processing raw materials for example imposed under Subsection 4. The land
must be farmed on a continual basis. The area must be kept in excellent working order.
Limitation imposed by SA when it approves alienation and common words “Tanah ini
tidak boleh dipindahmilik, dipajak atau digadai tanpa kebenaran Pihak Berkuasa Negeri” so,
if proprietor wishes to transfer, lease or charge his land, he must first get consent from the
SA
Stated under section 5, the restriction in interest, and the impact of the restriction is a
restriction on a proprietor's rights and abilities to freely deal with the land. If a landowner

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wants to do something with his property, he must first get the SA's permission. Failure to get
approval may render any transaction made by the proprietor invalid and render the proprietor
unable to register. In Wong Kim Swee v Tham Hock Cham, the court ruled that a leasing
arrangement without written consent and without the ability to register was a violation of the
code.
In Chin Tai v Siow Shiow & Ors , the transfer in favour of the purchaser was deemed
invalid for registration by the court. Unless the collector of land revenue's agreement was
obtained since the land's title contained a restriction requiring it.
Section 104 stated that all the restrictions imposed shall bind the proprietor an
anyone claiming interest of the land. Section 105(1) and (2) specified that all conditions and
restriction is imposed commence from the date of alienation and continue in force until the
land is reverted to SA.
In case of Dr Ti Teow Siew v Pendaftar Geran-Geran Tanah Negeri Selangor, the
court disagreeing with the applicant, and ruled that it is imperative to look at the date
alienation of the land was registered and must read together with Section 78(3) on how
alienation is effected to clearly the period of the restriction in interest begin to run.
Under Section 124 (1) (c), a land owner may apply to SA for alteration the rescission
of amendment of any express condition or restriction of interest to enable the landowner to
use or to developed his land accordingly and for purposed other than that allowed at
present.
And stated under Section 124 (4) (a), if the application was approved by the SA, The
SA will reply with the Form 7C for the amendment requested.
Next, it is an attestation of instrument of dealings. Section 211(1) any natural
person's execution must be attested by one of the officers listed in the Fifth Schedule. Any of
the offices or other individuals mentioned in this section, such as a Magistrate, State
Director, the Registrar, a Land Administrator, an advocate and solicitor, and a notary public,
can certify the instrument of transactions. For the attestation clause, it must be inserted in
Form 13B and pursuant to section 211(4), any officer who attests must sign the attestation
clause and affix his signature and seal of office to it.
The instrument of transactions to be given for registration must be stamped in line
with Section 294(1) of the Stamp Act 1949. The attestation clause must then be filed to the
land Office together with Form 16A. Section 294(1) states that any instrument of dealing
brought for registration must be accompanied by the registration fee and any other
documents required by section 294(2) and section 294(3) of NLC.
After the instrument has been submitted to the appropriate Land Office, the papers
will be examined to see if they are suitable for registration. An instrument must be fit for
registration, according to Section 301. There must be a valid instrument of dealing utilised,

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the instrument signed and witnessed, the dealings must not be in violation of any written
legislation or limitation of interest, the instrument must not declare or disclose the existence
of any trust, and the instrument must be legally stamped.
If an instrument is unsuitable for registration, it has an impact. Section 298 (1) states
that if the instrument is unfit for registration, the Registrar must reject it unless it is
exclusively due to a formal fault or electrical mistake. The rejected instrument must likewise
be returned to the body that provided it, according to Section 298 (4).

APPLICATION

By study the facts and applying the authority and cases given on the issue the Form
16A present was rejected by the Land Office, there is a reason on the rejection. Ali and his
sister Rosni forget about both land are subjected to a restriction in interest whereby the land
cannot be transferred, charged or leased without the consent of the state authority refer to
Section 79 (2)(g).
By applying Section 89, subsection (b) on conditions, limits of interest, and other
requirements, following endorsement on the deed of title, the document becomes
conclusive.
Stated under section 5, the restriction in interest, and the impact of the restriction is a
restriction on Ali and Rosni rights and abilities to freely deal with the land. If Ali and Rosni
wants to do something with his property, both of them must first get the SA's permission.
Failure to get approval may render any transaction made by both of them invalid and render
the proprietor unable to register.
By applying in case Wong Kim Swee v Tham Hock Cham, the court ruled that a
leasing arrangement without written consent and without the ability to register was a violation
of the code.
By applying in case Chin Tai v Siow Shiow & Ors , the transfer in favour of the
purchaser was deemed invalid for registration by the court. Unless the collector of land
revenue's agreement was obtained since the land's title contained a restriction requiring it.
Section 104 stated that all the restrictions imposed shall bind the Ali and Rosni an
anyone claiming interest of the land. Section 105(1) and (2) specified that all conditions and
restriction is imposed commence from the date of alienation in September 2017 and
continue in force until the land is reverted to SA and by applying In case of Dr Ti Teow Siew
v Pendaftar Geran-Geran Tanah Negeri Selangor, the court disagreeing with the applicant,
and ruled that it is imperative to look at the date alienation of the land was registered and
must read together with Section 78(3) on how alienation is effected to clearly the period of
the restriction in interest begin to run.

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 For that reason, Ali and Rosni must apply Under Section 124 (1) (c), stated a land
owner may apply to SA for alteration the rescission of amendment of any express condition
or restriction of interest to enable the landowner to use or to developed his land accordingly
and for purposed other than that allowed at present. If the application was approved stated
under Section 124 (4) (a), if the application was approved by the SA, The SA will reply with
the Form 7C for the amendment requested.
There is no issue under the attested signature by Salmi, their cousin who is
practising lawyer and follow the requirement under 211(1) and fifth schedule. But then from
5.00 pm to the next day 9.00 am the fact not mentioned about the instrument of transactions
given by them for registration stamped in line with Section 294(1) of the Stamp Act 1949.
The fact also not mentioned regarding Section 294(1) states that any instrument of
dealing brought for registration must be accompanied by the registration fee and any other
documents required by section 294(2) , A copy of the memorial of a registration is required
to be made on every instrument. All such instruments must be accompanied by a duplicate
which may be required under paragraph (b) of sub-section (1) of section 306. This includes
all documents required in connection with its registration and section 294(3) provides that
any instrument executed on behalf of a person or body under a power of attorney must be
accompanied by the supporting document It also states that all documents required by
section 309 of the Act must be in writing. Subsection 4 stated The fact that any instrument is
not accompanied by the documents required by this.section shall not be a bar to its entry in
the Presentation Book. The instrument will not be registered until the missing documents
have been produced or, in the case of any of the documents specified in sub-section (2) has
been dispensed with.

CONCLUSION

From my humble opinion after put the fact on application, the presentation of Form
16A charge rejected one of the main reason is because the mistake by Ali and Rosni apply
under Section 124 (1) (c) not get a consent from the state authority under Section 124 (4).
The such application by them also forget about the instrument of registration which is
must be stamped in line with Section 294(1) of the Stamp Act 1949.
Both of them also forget to attached supporting document needed as documents to
accompany instrument so presented under Section 294 (2) and (3).
By giving the said reason, ill conclude to advice both of them to fulfil all the
requirement needed by state authority by referring the law given before making a submission

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and manage properly with SukaHati Bank to create a charge under The National Land Code
1965.

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