Subramaniam a/l Murugan v Pendakwa Raya

The appellant, Subramaniam a/l Murugan, was convicted of two charges under Section 165 of the Penal Code 1950 and sentenced to 4 months imprisonment by the Sessions Court at Shah Alam. The High Court dismissed his appeal. While his appeal to the Court of Appeal was pending, he passed away. His widow, Madam S. Ponnamah a/p Sinnappan, applied to substitute him as the personal representative to continue the appeal, citing her pecuniary interest in the outcome due to potential loss of pension rights. The Court of Appeal allowed the substitution, ruling that the appeal did not automatically abate upon the appellant's death and that the widow had sufficient legal interest to continue the appeal.