The Federal Court reinforced the meaning of Article 121 (1A) of the Federal Constitution that was made in 1988 to avoid conflicts between decisions of syariah and civil courts.

In his 33-page written judgment in the S Deepa vs N Viran @ Irwan Abdullah case, Court of Appeal president Md Raus Sharif said the conflict arose in this case because Izwan had taken his case to the Syariah High Court.

However, Justice Md Raus said, as shown in the cases of R Subashini vs T Saravanan and Tang Sung Mooi vs Too Miew Kim, the Law Reform (Marriage & Divorce) Act 1976 (LRA) continues to bind the ex-husband's application to dissolve his civil marriage with the ex-wife.