In the annals of the spread of the common law to other lands and other ways, Malaya may deserve a modest place, but, as the selection here no doubt shows, so far it has made no significant contribution to the intellectual content of that law. It has neither produced nor harboured a Cardozo or a Dixon. At best, its judges have applied common law principles simply but soundly; they have never, at least in tort, been subtle or illuminating. Its legal history is of interest for its own sake; its legal achievement awaits us in the future, not in the past.
A. E. S. Tay & J. H. M. Heah, Some Notes on the Malayan Law of Negligence, 9 Clev.-Marshall L. Rev. 490 (1960)