Three Former Undangs Set To Test the Limits of Negeri Sembilan’s Royal Authority Under the Undang-undang Sungai Ujong

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Three former Undangs charged with treason under Negeri Sembilan’s customary law. Dewan Keadilan ruling tests royal authority and adat law enforcement in modern Malaysia.

A ruling by the Dewan Keadilan on September 14, 2026, has named the conduct of at least three former Undangs as treasonous under adat law — a verdict measured against one of Negeri Sembilan’s oldest written legal texts.


The Dewan Keadilan’s September 14, 2026 ruling placed the actions of several ousted adat chiefs squarely within the category of penderhakaan — treason under Negeri Sembilan’s customary law system — and handed the matter to police for determination of criminal liability. The ruling follows months of coordinated conduct by Mubarak Dohak, the deposed tenth Undang of Luak Sungai Ujong, who was dismissed by the Waris and Ibu Soko in April 2026, alongside former Undangs from Rembau and Jelebu, and the sitting Undang of Johol. Together, the four have pursued a concerted effort to unseat Yamtuan Besar Negeri Sembilan, Tuanku Muhriz Tuanku Munawir. What the Dewan Keadilan’s determination now makes plain is that their conduct does not exist in a legal vacuum. It is measured against a written body of customary law — the Undang-undang Adat Sungai Ujong — that anticipated precisely this kind of conduct, and named its consequences, centuries before any of the principals were born.


Four Days Out and the Dewan Keadilan’s Ruling Is Already Reshaping the Political Conversation

With the Dewan Keadilan’s September 14 decision now public, the legal and political architecture surrounding the penderhakaan case against Tuanku Muhriz’s detractors has shifted decisively. What began in April 2026 as the dismissal of a single Undang — Mubarak Dohak of Sungai Ujong — has expanded into a documented pattern involving at least four adat chiefs acting in concert. Police have been formally requested to assess the criminal dimensions of their conduct.

This is not a simple internal adat dispute.

It is simultaneously a constitutional question about royal authority, a textual dispute over the meaning of muafakat, a matter of criminal liability under the Penal Code, and a test of whether Negeri Sembilan’s unique customary law framework retains enforceable force in a modern federal state.

The political dimension is equally charged. The column published by legal and literary scholar Faisal Tehrani, on which this report is based, explicitly names several political parties and public figures as having manipulated the narrative for electoral advantage — a charge that, if substantiated, extends the penderhakaan case beyond the adat chiefs themselves.


From Ancient Textual Authority to a September Ruling, Months of Legal Architecture Are Now in Place

The Undang-undang Adat Sungai Ujong is not a ceremonial document. It was formally recorded by scholars Richard Winstedt and Josselin de Jong in 1954, drawing on precolonial legal tradition. Sungai Ujong is the largest Luak in Negeri Sembilan, and its Undang holds the senior position within the adat hierarchy. The written law of Sungai Ujong is correspondingly treated as the primary reference text for adat practitioners across the state.

According to the text’s own framing, the Undang-undang Sungai Ujong is not primarily a political constitution but a document of Islamic moral law, customary procedure, and spiritual accountability — what Faisal Tehrani describes as containing strong elements of tasawuf, or Sufi ethics. It opens with the premise that humans must understand their proper station in order to be safe in this world and the next.

On the question of royal authority, the text is unambiguous. It states: “Jikalau berseliseh segala negeri atau teluk atau laras dan lagi beting rantau, maka kusut yang akan menyelesaikan, kerok yang akan menjernihkan, hilang yang akan mencari hanyalah daulat Yang Dipertuan.” In translation: when disputes arise across territories and districts, only the sovereign Yang Dipertuan resolves, clarifies, and recovers what is lost. Every chief and warrior follows the Raja alone; all authority derives from the Raja and from no other source.

The text explicitly addresses the Adat Perpatih concept of muafakat, which the deposed Undangs have invoked to justify collective action. According to the Undang-undang Sungai Ujong, muafakat is not popular consensus. It is the product of deliberation by qualified scholars and informed leaders, and it is ultimately referred back to the Raja — whose word “melimpahkan”, or overflows with authority, sets the frame within which all other voices operate. The general public — and, by implication, social media commentary — falls outside the definition of those whose voice constitutes legitimate muafakat.

On the hierarchy of wrongdoing, the text draws a precise distinction: “Salah pada Raja mati, Salah pada penghulu berutang.” An error against the Undang incurs a debt. An error against the Raja incurs death. The conduct of the four adat chiefs is classified under daga — active resistance and obstruction — and dagi — manipulation, distortion, and deception. Both are named treasonous categories in Adat Perpatih and in the Sungai Ujong text.


Behind the September Ruling Is an Experiment in ‘Adat Accountability’

The real story here is not the removal of a single Undang, but the question of whether a pre-colonial customary legal text can generate enforceable accountability in a 21st-century legal system.

What the Dewan Keadilan’s September 14 determination does is establish that the conduct of Mubarak Dohak and his associates constitutes treason under adat law, conduct warranting police referral, potential criminal liability under federal statute, and a documented breach of the written customary framework they were appointed to uphold.

The pathway to formal sanction runs through three legal channels. First, the Penal Code: Section 121 provides for the death penalty or life imprisonment for waging, attempting to wage, or conspiring to wage war against the Yang di-Pertuan Agong, a Raja, or a Yang di-Pertua Negeri. Section 121A addresses actions intended to overthrow or undermine the royal institution. Section 121B provides for life imprisonment or up to 20 years’ imprisonment and a fine for actions intended to impair the sovereignty of the Yang di-Pertuan Agong or any Raja. Second, the Sedition Act 1948 (Act 15) covers acts, speech, publications, or transmissions — including social media content — that tend to excite hatred, contempt, or disloyalty toward a Raja or government. Third, the referral mechanism of the Dewan Keadilan itself, which has now formally engaged law enforcement.

The strategic ambition of the September ruling, read in full context, is to shift the definition of acceptable opposition to a Yamtuan Besar from a contested political question into a settled matter of law — both adat and statutory.


The Undang-undang Sungai Ujong’s Moral Architecture Gives the Penderhakaan Case a Verified Textual Base

The choice of legal authority is itself a strategic decision worth noting.

By grounding the penderhakaan determination in the Undang-undang Adat Sungai Ujong rather than solely in federal statute, the Dewan Keadilan and its commentators establish that the case against the deposed Undangs is not a political prosecution dressed in legal language. It is a finding that the accused have violated the very legal tradition from which their own authority derived.

Faisal Tehrani’s analysis distinguishes between what the sourcing materials project and what is confirmed. The Undang-undang text itself was recorded and published in 1954 by Winstedt and Josselin de Jong — this is a verifiable bibliographic fact. The text’s characterisation of royal authority, of muafakat, and of the categories of daga and dagi are drawn directly from the published record. What remains in progress at the time of writing is the police determination of criminal liability, the formal legal proceedings under any of the three statutory channels, and the political response of the parties Faisal Tehrani has named as complicit in narrative manipulation.

Public information confirms that the Dewan Keadilan’s ruling was issued on September 14, 2026, and that Mubarak Dohak was dismissed as Undang of Luak Sungai Ujong by the Waris and Ibu Soko in April 2026. What is attributed to the ruling and to Faisal Tehrani’s analysis should be read as such, and not as confirmed legal findings pending formal court proceedings.


Frequently Asked Questions About Penderhakaan and the Undang-undang Sungai Ujong

What is penderhakaan under Negeri Sembilan adat law? Penderhakaan refers to treason against a Raja under Negeri Sembilan’s customary law system, Adat Perpatih. Under the Undang-undang Adat Sungai Ujong, it encompasses conduct classified as daga — active resistance and obstruction of royal authority — and dagi — manipulation, deception, and distortion of the law. The Dewan Keadilan ruled on September 14, 2026, that efforts to unseat Yamtuan Besar Tuanku Muhriz constitute penderhakaan.

Who is Mubarak Dohak and why was he removed? Mubarak Dohak was the tenth Undang of Luak Sungai Ujong, the largest Luak in Negeri Sembilan. He was dismissed by the Waris and Ibu Soko — the customary governing body with authority over the position — in April 2026. Following his dismissal, he continued to act in concert with former Undangs from Rembau and Jelebu, and the Undang of Johol, in a coordinated effort to remove Yamtuan Besar Tuanku Muhriz Tuanku Munawir.

What is the Undang-undang Adat Sungai Ujong? The Undang-undang Adat Sungai Ujong is a written body of precolonial customary law governing Luak Sungai Ujong in Negeri Sembilan. It was formally recorded and published by scholars Richard Winstedt and Josselin de Jong in 1954. It is considered the primary written reference for adat practice across Negeri Sembilan and covers royal authority, the meaning of muafakat, moral accountability, and the consequences of disobedience to a Raja.

What does the Undang-undang Sungai Ujong say about the Yamtuan Besar’s authority? The text states that when disputes arise across territories, only the Yang Dipertuan — the Yamtuan Besar — has the authority to resolve, clarify, and recover what is lost. All chiefs and warriors derive their authority from the Raja alone. The text also states explicitly: “Salah pada Raja mati, Salah pada penghulu berutang” — an error against a chief incurs a debt, but an error against the Raja incurs death.

What criminal laws apply to those found guilty of penderhakaan in Malaysia? Under the Penal Code, Section 121 provides for the death penalty or life imprisonment for waging or conspiring to wage war against a Raja. Section 121A addresses acts intended to overthrow the royal institution. Section 121B provides for life imprisonment or up to 20 years’ imprisonment and a fine for impairing royal sovereignty. The Sedition Act 1948 (Act 15) also applies to acts, speech, or online content tending to excite disloyalty or contempt toward a Raja.

What is the correct definition of muafakat under the Undang-undang Sungai Ujong? According to the Undang-undang Sungai Ujong, muafakat is not popular consensus or public opinion. It is the product of deliberation by learned and qualified individuals, and its results are then referred to the Raja, whose authority frames all other deliberation. The text expressly excludes the general public — described as those who merely listen and follow — from constituting legitimate muafakat.

What has the Dewan Keadilan decided, and what happens next? The Dewan Keadilan issued its ruling on September 14, 2026, determining that the effort to remove Yamtuan Besar Tuanku Muhriz constitutes penderhakaan under adat law. The matter has been referred to police to determine criminal liability. Formal legal proceedings under Penal Code Sections 121, 121A, and 121B, and potentially the Sedition Act 1948, remain in progress at the time of publication.


A Ruling That Closes One Chapter While Opening Several Others

The Dewan Keadilan’s September 14, 2026 determination is, in the words of the analysis by Faisal Tehrani, intended to serve as a closing point on what he describes as the most audacious, organised, and deliberate act of penderhakaan in modern Malaysian history. That it was enabled by political actors who manipulated the narrative for electoral advantage — if that claim is substantiated — makes the case materially more serious than a dispute among adat chiefs.

The Undang-undang Adat Sungai Ujong did not anticipate political parties or social media. But it did anticipate leaders who would confuse their own authority with the authority of the Raja, who would substitute daga for legitimate dissent, and who would mistake dagi for muafakat. For those, the text already had language ready: leaders who cook in the wrong vessel and grind in the wrong mortar are a sign that a country has become disordered and its chiefs unjust.

For more information on the Dewan Keadilan ruling and the penderhakaan proceedings concerning Yamtuan Besar Negeri Sembilan, readers may refer to:

This article is based on the published column by Faisal Tehrani and reflects the views expressed therein. It does not constitute legal advice, and the criminal proceedings referenced remain ongoing at the time of publication.

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