qualitative approach through document analysis, including the Federal Constitution, State Enactment,

government agency reports, and relevant scholarly literature. The findings indicate that although religious

freedom is guaranteed under the Federal Constitution, broad interpretations and legal inconsistencies between

federal and state laws pose challenges in effectively managing apostasy cases. In the context of Terengganu, the

issue of religious freedom remains relatively well-managed, with no recorded applications for apostasy among

Malay Muslims. Therefore, in the short term, implementing a religious freedom policy is not deemed a pressing

priority for the state. However, the study recommends that such a policy could be formulated as a complementary

framework to the existing legal structure, serving as a strategic guideline for long-term governance without

In the context of the state of Terengganu, where most of the population is Muslim and where a distinct religious

administrative structure is in place, discussions surrounding religious freedom are often viewed as sensitive and

require a cautious and nuanced approach. Nevertheless, the need to formulate a state-level religious freedom

policy should be examined, particularly considering the challenges posed by a modern and increasingly open

society. Such challenges include issues related to religious propagation, the establishment of houses of worship,

and the provision of religious education for minority communities. This article seeks to evaluate the necessity of

a religious freedom policy in Terengganu by examining the Christian demographic profile, the existing legal and

administrative frameworks, the prevailing issues and challenges, as well as the potential for establishing a

balanced and inclusive policy that does not compromise the status of Islam as the official religion of the state of

safeguarding the rights of citizens as outlined in Part II of the Federal Constitution, which includes fundamental

liberties and the principle of equality without discrimination based on race, religion, or gender (Meerangani, K.A

& Ramli, R. 2016). These rights are enshrined in Article 11(1) of the Federal Constitution, which provides that

every person has the right to profess, practise, and propagate his or her religion subject to legal restrictions

permitted under Clause (4). This clause prohibits the propagation of non-Islamic religions to Muslims, in line

with the recognition of Islam as the religion of the Federation under Article 3(1) (Najib, N.A.M & Ismail, A.M.,

The constitutional position of Islam is a crucial issue, as it is closely linked to the beliefs and identity of most of

the Malaysia’s population. It is also a sensitive matter, as many Malays perceive Islam to be inseparable from

their daily lives (Muslim, N. & Buang, A.H., 2012). Although Islam is accorded a special status, the Constitution

Overall, constitutional provisions demonstrate that while Malaysia retains Islam as the official religion, the rights

of adherents of other religions are respected and protected, so long as they do not contravene constitutional

This article’s discussion of religious freedom in the current context of Terengganu focuses on three main aspects:

demographics, the presence of churches, and historical interactions between Islam and Christianity within local

society. From a demographic standpoint, accurate data is relatively difficult to obtain, as Christianity remains a

small minority religion in comparison to the overwhelming Muslim Malay majority. According to the

Department of Statistics Malaysia (2020), religious affiliation in Terengganu comprises six categories: Islam

(97.3%), Buddhism (2.0%), Christianity (0.3%), Hinduism (0.2%), other religions (0.0%), and those with no

Malaysia, the shortage of pastors, and the influence of local sociopolitical issues (Zain, A.D.M., et al., 2025).

under the state Islamic administration enactments, including in Terengganu, as outlined in the Ninth Schedule,

List II of the Federal Constitution, which governs Islamic affairs. Conversely, the construction of non-Muslim

houses of worship such as temples and churches is regulated under the Town and Country Planning Act 1976

and the Street, Drainage and Building Act 1974. These controls fall under the Ninth Schedule, List III, where

In Terengganu, the construction of non-Muslim houses of worship typically requires approval from the respective

local authorities, such as the City Council, District Council, or Municipal Council. The approval process

considers building plans, parking facilities, and safety, especially in emergencies like fires. For instance, in Kuala

Terengganu, which has the highest number of Christian adherents, any church construction must be approved by

the Kuala Terengganu City Council (MBKT). However, there are churches that have long operated without

in Besut. These sources clearly provide the church names, denominations, contact numbers, and locations. As

In terms of inter-religious relations between Islam and Christianity in Terengganu, historical records indicate

that the presence of Christianity began as early as 1828 through missionary efforts led by W. Medhurst. Fluent

in the Chinese language, he engaged in religious discussions with the local Chinese community and once held

direct dialogue with Sultan Abdul Rahman Shah (1826–1831). The presence of Christian missionary movements

is seen as the initial point of Christianisation efforts in Terengganu. This development continued during the reign

of Sultan Zainal Abidin III (1881–1918), when the British and Foreign Bible Society submitted a request to

distribute the Bible in Jawi script to the locals. Although the Sultan did not officially prohibit missionary

activities, he took firm and wise measures by enforcing state laws to curb the spread of Christianity. This ensured

propagation of non-Islamic teachings among Muslims, the Federal Constitution guarantees freedom for

adherents of other religions, including Christians, to practice their beliefs and build places of worship. As a result,

despite Christians being a small minority compared to Muslims, they have successfully established 14 churches

As a state that upholds Islam as the official religion, Terengganu remains subject to the principles of the Federal

Constitution, which guarantees individuals the right to profess, practise, and propagate their religion, provided

it does not contravene the laws in place. In this context, the legal foundation for religious freedom in Terengganu

involves a combination of provisions from the Federal Constitution, the Control and Restriction of the

Propagation of Non-Islamic Religions Enactment 1980 (Amendment 2013), and the roles of the Terengganu

(1) Islam is the religion of the Federation; but other religions may

(1) All persons are equal before the law and entitled to the equal

(1) Every person has the right to profess and practise his religion

Rights in respect of

(2) Every religious group has the right to establish and maintain

institutions for the education of children in its own religion, and

there shall be no discrimination on the ground only of religion in

any law relating to such institutions or in the administration of any

in the religion of Islam and incur such expenditure as may be

religious tension or conflict that may disrupt local social harmony. Accordingly, several states including

Kelantan, Terengganu, Negeri Sembilan, Kedah, Pahang, Melaka, Johor, and Perak have enacted the Control and

Restriction of the Propagation of Non-Islamic Religions Enactment as a preventive measure against sensitive

maintaining the status of Islam as the official religion of the state. Although religious freedom is recognised

under the Federal Constitution, the enactment provides specific guidelines and restrictions to ensure that the

propagation of non-Islamic religions does not offend Muslim sensitivities or disrupt interreligious harmony.

Figure 2 below outlines 14 sections within this enactment pertaining to the control and restriction of religious

positive emotions and social engagement strengthens interest and commitment, consistent with Vygotsky's

the implementation of Islamic laws, managing institutions of marriage and the Syariah judiciary, and serving as

However, religious freedom issues such as apostasy or disputes over places of worship occurring in the West

Coast if not well-managed and left unchecked could potentially influence Terengganu society in the future.

a religion practiced only in official ceremonies. This interpretation has often been used by lawyers to challenge

the primacy of Islam in the Malaysian Constitution. In the case of Lina Joy v Federal Territory Religious Council,

the same interpretation was used to reject Islam's privileged position and to invoke the principle of equality

among Malaysians as guaranteed by Article 8(1) of the Federal Constitution. Thus, the issue of constitutional

The second issue is the inconsistency in state laws and the lack of specific provisions, which leads to weaknesses

in the management system of apostasy cases. This inconsistency exists because six states still do not have specific

legal provisions on this matter. These states are Selangor, the Federal Territories, Kedah, Perlis, Sarawak, and

Johor. Generally, two approaches have been adopted by different states in dealing with this issue. The first

The lack of clear legal provisions on the freedom to choose religion, and the absence of such provisions in

existing laws such as the Administration of Islamic Law (Federal Territories) Act 1993, also contribute to

conflicts between the Civil and Shariah Courts. This inconsistency has caused prolonged legal disputes, such as

in the cases of Lina Joy, Subashini, and Shamala, with jurisdictional issues being repeatedly debated, thus

creating injustice for those involved. This situation highlights the need for a clear affirmation of the right to

choose one's religion in Malaysia (Halim, R. et al., 2018). In this regard, a key question arises: can the

inconsistency in apostasy-related laws across states be resolved through the introduction of a religious freedom

policy? Is such a policy, particularly in Terengganu, a strategic necessity for managing apostasy cases? To what

extent is a religious freedom policy necessary as an administrative mechanism to support the implementation of

scope of the existing legal framework. In terms of approval, policies are not passed by the State Legislative

Assembly (DUN) but are drafted and approved through meetings of the State Executive Council (EXCO).

Typically, a specific committee is appointed to monitor policy implementation, but it does not have enforcement

powers like laws do. Therefore, in terms of strength, drafting process, and implementation effectiveness, policies

are not equivalent to laws. Moreover, the Christian demographic in Terengganu currently does not pose a threat

However, in the long term, a religious freedom policy can be considered a necessary measure to safeguard the

faith of Muslims alongside existing legal provisions. This is because Muslims increasingly face the challenge of

diverse religious proselytization efforts, including Christianity, which are disseminated in various subtle forms.

For instance, the issue of open Christian evangelical efforts targeting Malays in Kuala Lumpur (Firdaus Wong’s

function well unless every Muslim individual strengthens a key internal aspect: their faith in God. Faith and

confidence in one’s religion are the strongest fortresses against any form of threat or religious proselytization

In conclusion, the constitutional and state legal provisions on religious freedom, such as those in Terengganu,

are indeed aimed at protecting the faith of Muslims from apostasy. However, the legal reality indicates that loose

interpretations of the Constitution and the inconsistency among state laws have created serious challenges in

managing apostasy cases. The variety of state-level approaches and differing court decisions show that

weaknesses remain in the current system, highlighting the need for an additional mechanism to more

In the context of the Christian demographic in Terengganu, the establishment of a long-term religious freedom

policy can serve as a strategic and complementary step. Although policies do not have the same enforcement

This project was supported by Universiti Sultan Zainal Abidin (UniSZA) under Dana Penyelidikan Universiti