HUMAN SACRIFICE IN WITCHCRAFT RITUAL: A NEED FOR THE ANTI WITCHCRAFT LAW

Witchcraft or black magic is among the ancient mystical ritual in the world. It involves the engagement of jinn and demons with specific purposes. Based on literature, there were cases of human sacrifice in witchcraft ritual. This study specifically seeks to explore the rituals of demonic worship and human sacrifice in witchcraft. This study applies library research particularly by analyzing history and legal background of the issue. In some court cases, it was proven that these practices of detestable witchcraft require certain organs of a human body, especially of a child, to be one of the devil's objects of worship. This study will also discuss illustration (a) of the section 364 of the Penal Code which specifically mentioned about crime of kidnapping or abducting any person to be murdered and presented to idolatry. The results of this study justify a proactive action need to be taken by the authorities specifically by enacting the law to fight against witchcraft. Keyword: Human Sacrifice, Witchcraft Ritual, Anti Witchcraft Law INTRODUCTION Witchcraft or black magic is known to be among the most ancient mystical rituals in the world. It involves jinn and demons with definite purposes such as getting rid of love between family members, separating husband and wife, causing insanity and diseases, and even up to the point, killing the victim (Mahyuddin, 2014). In Malaysia, the use of witchcraft was raised in several criminal cases at Civil Court. Among them were the case of Juraimi Bin Husin v PP, Mohd Affandi Bin Abdul Rahman & Anor v PP [1998] 1 MLJ 537, and the case of Sabarudin Bin Non & Ors v PP [2005] 4 MLJ 37. Unfortunately, the issues were not addressed correctly due to the absence of specific provosions as well as the legal procedure related to witchcraft (Mahyuddin, 2012). Journal of Fatwa Management and Research | Jurnal Pengurusan dan Penyelidikan Fatwa | ىواتفلا ثوحبو ةرادإ ةلجم Julai 2018 |Vol. 13| ISSN: 2232-1047 | eISSN: 0127-8886 28 METHODOLOGY This paper is a concept paper which mainly exploring the rituals of human sacrifice in witchcraft and how legal instrument may curb it. Thus, the method used is qualitative approach. Researcher focuses on library research to gather information related to the history of witchcraft practices particularly involving the use of human organs in demonic worship. References were made to related books, articles journal and official reports. The study will also examine criminal cases involving human sacrifice in witchcraft rituals that have been tried in Malaysian courts. The study will also examine the legal provisions as well as government policies related to this issue. FINDINGS Witchcraft is an association with Satan Witchcraft requires a witch to make an agreement with satan or devil. According to Al-Baly (2004), witchcraft (sihr) is “an agreement between a sorcerer (sahir) and an evil jinn or devil (satan) which stipulates that the sahir commit certain legal or polytheistic actions in return for the satan’s assistance and obedience in fulfilling the sahir’s request”. While Gordon (1993) defined witchcraft as “magic undertaken for destructive or selfish purpose; to dominate or harm others; to gain power, wealth or knowledge by necromancy or sorcery, traditionally by calling up demons or by blood-sacrifice”. Human Sacrifice in Satanic Worship There are various methods on how a witchcraft ritual is carried out. Some require the witches to utter charm or spell which contains specific name of satans by using specific manners and at specific places (such as at graveyard, jungle, haunted house etc). Some require the witches to do more than that i.e. human or blood sacrifice. Sacrifice requires blood and certain body parts including organs, limbs, genitals, eyes, teeth, fingers, the tongue or the heart. The process of removing these body parts often happens while the victim is still alive (KidsRights Report, 2014). According to Abdul Basir (1999), among other objects used in the ritual are skull, bone, heart, lungs, gall bladder, hair, nails, semen, saliva, blood etc. Such ritual actually has been practiced since thousand years ago and it is still going on nowadays. According to Borghouts (1995), witches in the ancient Egypt civilization performed human sacrifice for their god Osiris. They believed that the sacrifice will make the country more prosper. If they failed to do so or they did not perform it in a proper manner, the whole country will suffer. In Europe, witchcraft has been widely practiced around the 15th century, some of which have to do with the killing of children who have been Journal of Fatwa Management and Research | Jurnal Pengurusan dan Penyelidikan Fatwa | ىواتفلا ثوحبو ةرادإ ةلجم Julai 2018 |Vol. 13| ISSN: 2232-1047 | eISSN: 0127-8886 29 used as a sacrifice. For example, Summers (2011) described a trial of a nun name la Voisin during the reign of King Louis XIV in France as follows: “The child was held over the altar, a sharp gash across the neck, a stifled cry, and warm drops fell into the chalice... The corpse was handed to la Voisin, who flung it callously into an oven fashioned for that purpose which glowed white in its fierceness. It was proved that regular traffic had been carried on for years with beggar women and the lowest prostitutes, who sold their children for this purpose. At her trial, la Voisin confessed that no less than 2,500 babies had been disposed of in this manner.” Children were most likely to become victims of witchcraft ritual during the dark ages of Europe (Kieckhefer, 1990). This fact can be seen through the trial of one of these magicians: ...when a woman from the diocese of Novara was accused of witchcraft around the 1330s, the court sought advice from Bartolo of Sassoferrato, one of the most prominent lawyers of the day. In response, he first considered the woman’s religious crime of idolatory...Secondly, he considered the woman’s crime against humankind. She was accused of killing children by merely touching them. Is this in fact possible? The children’s mothers testified that she had bewitched them, and that the children did in fact die. Bartolo had heard certain theologians suggest that sorcerers can harm and even kill others with their touch or with the evil eye. In China and Taiwan, kidnapping and killing of children for internal organs such as the liver and spleen for the purpose of demon worship were rampant. Shaw (1975) recommended that a new law must be enacted to impose severe penalties on witches: “...It appears, this method of obtaining the services of supernatural entities that severe penalties had to be written into the law to prevent people from committing murder in order to obtain the necessary 'cosmic' ingredients.” During the Yuan Dynasty, heavy punishment including carving to death was prescribed to those who were found guilty for sacrificing human in idolatry worship. "The Penal Code of the Yuan (Mongol) Dynasty laid down that: " Whosoever plucks life out of a man or dismembers him with intent to procure a spectre to sacrifice to, shall be slowly carved to death with knives". Similar practices were mentioned in a Imperial Edict of 1846.” (De Groot, 1964). In Africa, such sacrificial rituals, and the subsequent wearing, burying or eating of a child’s body parts, are said to bring business success, personal prosperity and health. Middle-class clients often begin with standard herbal remedies and animal sacrifices but are subsequently persuaded by witch doctors to part with a large sum of money for “Big Blood”. This practice has Journal of Fatwa Management and Research | Jurnal Pengurusan dan Penyelidikan Fatwa | ىواتفلا ثوحبو ةرادإ ةلجم Julai 2018 |Vol. 13| ISSN: 2232-1047 | eISSN: 0127-8886 30 embedded itself within traditional customs in recent times and continue to rise. Such practice is also reported in Tanzania, Uganda, Nigeria, Switzerland, Liberia, Botswana, South Africa, Namibia and Zimbabwe. Child Sacrifice in Uganda’ (2011) reported child sacrifice is a growing problem in Uganda. The African Network for the Prevention and Protection against Child Abuse and Neglect (ANPPCAN) confirmed that child sacrifice has increased in Uganda over the last five years. According to the 2009 Uganda Police Report on human sacrifice, 15 cases of child sacrifice were reported, as compared with just 3 cases in 2007. But most cases did not find their way to police; the report notes that in 2009, out of 123 missing persons, 90 (73%) were children suspected to have become victims of human sacrifice (KidsRights Report, 2014). Human Sacrifice in Malaysian Criminal Cases The case of missing people especially children in Malaysia is quite alarming. Based on the statistics released by Royal Malaysia Police Headquarter Bukit Aman in 2018, there were 5,721 missing persons cases reported. Only 3,127 people were successfully found. When a person is missing, the authority will look into this matter as a an ordinary phenomena. It will be associated with several factors such as personal problem, stress, friends’ influence, family break-up and so on. Do we ever think that some of the cases might have connections with human sacrifice in witchcraft ritual? Based on court reports, there were witches who unmercifully slaughtered and cut off victim’s body for the purpose of sacrification. This can be seen in the the case of Juraimi Bin Husin v PP, Mohd Affandi Bin Abdul Rahman & Anor v PP [1998] 1 MLJ 537. It was reported that Mazlan Idris, a state assemblyman in the state of Pahang, wanted to boost his political career and sought the services of Mona for assistance. Mona and her husband promised to help Mazlan by giving him a talisman consisting of a cane and sbatmi headgear which were supposedly owned by former Indonesian President Sukarno. Mona convinced Mazlan that he would be "invincible" if he held the talisman. An appointment was made for cleansing rituals to be performed at Mona's house. Mazlan was told to lie on the floor face up while Mona placed flowers on him. She then told Mazlan to close his eyes and wait for the money to "fall from the sky". Juraimi then, using an axe, chopped Mazlan's head off. They also dismembered and partially skinned Mazlan's body. His body was found in 18 parts buried in a storeroom near Mona's house. In the case of Francis A/L Anthonysamy v PP [2003] 2 MLJ 49, the appellant was convicted of causing the death of a Bangladeshi national, Ali Ahammed bin Mohammed Ullah. He was found to have killed and beheaded the deceased with the intention of getting a human skull to be given to a shaman in satanic worship ritual in order to win the four-digit lottery. This case does not discuss further about the motive for the murder. The appellant indeed strongly Journal of Fatwa Management and Research | Jurnal Pengurusan dan Penyelidikan Fatwa | ىواتفلا ثوحبو ةرادإ ةلجم Julai 2018 |Vol. 13| ISSN: 2232-1047 | eISSN: 0127-8886 31 believed that by using a human skull and the help of a shaman, he would have won the lottery. Although the above case clearly shows the belief in witchcraft may induces a criminal conduct, no one can take any action against the shaman because using witchcraft is not a crime. Thus, a specific and special law should be enacted to address this issue. Some witches also believe that the purer the offering, the better. It will make their magical power stronger and stronger. The purer organs can be found in children which makes children more vulnerable to be sacrificed than adults. Furthermore, they are much easier to be lured into danger. In the case of Tan Mui Choo & Anor v Public Prosecutor [1987] 1 MLJ 267, the appellant and her husband were convicted of causing the death of two children. Appellant's husband, Andrian Lim, was an active shaman. The appellant and her husband were arrested after kidnapping and killing two children in a very cruel manner. The murder was carried out as a ritual for self reinforcement. “...The second appellant lured Agnes Ng Siew Hock drugged with Roche tablets and was sexually abused by Adrian Lim. Before they drowned her, Agnes Ng's finger was pierced and all three sipped the blood...The second appellant lured Ghazali bin Marzuki. They drowned him and again went through the ritual of drawing blood from the boy by means of a syringe and drank it from a glass. The two appellants scooped the blood from the glass and licked the blood.” Characteristics Of Victim Based on the study, there are some unique characteristics possessed by a victim who is suitable to be sacrificed in witchcraft ritual. In the case of missing person, the authority may venture into investigating the possible cause of abduction or murder by analysing these two points: (a) The birthday and sequence in family The most popular characteristic of a person to be sacrificed in satanic worship is the day he/ she was born and his/her sequence in family. The first child whose mother also the eldest and born on Tuesday is one of the most popular characteristic. Other than that, a woman who is the eldest and carrying her first child may also become a choice. The best example of the witchcraft work is anak kerak which is quite famous in southern Thai. According to Danny Lim (2008), anak kerak is is either a foetus or a stillborn baby killed before it has reached its first birthday. The most powerful Anak Keraks come from corpses of the first-born offsprings of parents who are first-born themselves. Ideally, the baby should be born on a Tuesday, and killed around the age 5 to 7 months. Journal of Fatwa Management and Research | Jurnal Pengurusan dan Penyelidikan Fatwa | ىواتفلا ثوحبو ةرادإ ةلجم Julai 2018 |Vol. 13| ISSN: 2232-1047 | eISSN: 0127-8886 32 (b) The conditions of victim upon found If the missing person is found murdered, the possible motive for the murder can be identified by looking at the body and internal organs of the victim. If the victim's body is torn apart and his organs such as the liver, spleen, kidneys or body are severely damaged or loss, the victim is likely to become an object in demon worship. KidsRights Report (2014) stated that sacrifice requires blood and certain body parts including organs, limbs, genitals, eyes, teeth, fingers, the tongue or the heart. The process of removing these body parts often happens while the victim is still alive. The victim’s condition of a witchcraft ritual can be seen in KidRights Report (2014): ”I took one glance at my child and couldn’t take another look. He didn’t have arms and his legs had been cut off, the head was on the other side from the body. I was crying uncontrollably, I imagined the pain he must have gone through. It made me sad as a mother that someone could kill an innocent child like that.” (Victim’s mother, Masaka District. Humaneafrica 2013) DISCUSSION From the analysis on human sacrifice and its relation to witchcraft, we may conclude that there is possibility that some murder cases are related to satanic worship in witchcraft ritual. Even the illustration (a) for Section 364 of the Malaysian Penal Code has special provision relating to human sacrifice, but yet no case has ever been tried under this section. This illustration provides: A kidnaps Z from Malaysia intending or knowing it to be likely that Z may be sacrificed to an idol. A has committed the offence defined in this section. The provision clearly illustrates the possibility of human abduction with intent to be sacrificed for idolatry, or more precisely the worship of Satan. No religion in this world legalizes the act of killing human beings for the purpose of worship. It is nothing but satanic worship as part of the ritual of witchcraft. The method of worship of devils and demons that accompanies the preparation of sacrifices has been practiced for thousands of years and it continues to this day. Such thing is not new, but has been practised by witches since long time ago. In 11th October 1993, the 33rd Fatwa Committee of the National Council for Islamic Religious Affairs of Malaysia has decided that the ‘relevant parties should provide legal provisions to punish witches who have been convicted for practicing witchcraft.’ The same is echoed in a number of conferences and seminars. But until now, this matter still remains unsolved and the Malaysian authority seems to keep silent on the issue of witchcraft law. Journal of Fatwa Management and Research | Jurnal Pengurusan dan Penyelidikan Fatwa | ىواتفلا ثوحبو ةرادإ ةلجم Julai 2018 |Vol. 13| ISSN: 2232-1047 | eISSN: 0127-8886 33 CONCLUSION Therefore, the authority should take proactive measures to curb the crime by introducing anti-witchcraft laws. Futher research also should be made to see whether the loss of person can be associated with the demand for their organs to be used in satanic worship. It is time for the government to gazzete witchcraft as a crime, and the witches, or those who use their service be brought before the court. As said by Mittlebeeler (1976), “if we accept the theory that the law of crimes developed from direct public action against a malefactor, witchcraft may have been the first of all crimes”. ACKNOWLEDGEMENT The authors would like to express their deepest gratitude to research funding provided by The Ministry of Education RDU 190166 (UMP reference number) represents FRGS grants number (FRGS/1/2018/WAB11/UMP/02/2). REFERENCES Abdul Basir Mohammed. (1999). Amalan Sihir dan Ayat-ayat Al Qur’an: Perbezaan Serta Kesannya Terhadap Amalan Perubatan. Kuala Lumpur: Jabatan Kemajuan Islam Malaysia (JAKIM), p. 99. Danny Lim. (2008). The Malaysian Book Of The Undead, Matahari Books. Emmet V. Mittlebeeler. (1976). African custom and Western law: The development of the Rhodesian criminal law for Africans, New York: African Publishing Company, p. 135. Gordon, S. (1993).The Encyclopedia of Myths & Legends. London: Headline Book Publishing Plc, p. Humane Africa. Child Sacrifice and the Mutilation of Children in Africa. (2013). Humane Africa. Online available at: http://www.whrin.org/wpcontent/uploads/2013/04/Child-Sacrifice-and-themutilation-of-childrenin-Uganda.pdf, 5th May 2021 J.J.M. de Groot (1964). The Religious Systems of China, Book 2, Vol. 5 (3), Literature House, Ltd, Taipei, Taiwan, p. 873. Jubilee Campaign and Kyampisi Childcare Ministries. Child Sacrifice in Uganda. (2011). Jubilee Campaign and Kyampisi Childcare Ministries. Online available at: http://www.jubileecampaign.co.uk/documents/ child-sacrifice-report.pdf KidsRights Report (2014). Child Sacrifice in Uganda, in a global context of cultural violence, KidsRights Foundation. p. 3-10. Kieckhefer, R. (1990). Magic in the middle ages. Great Britain: Cambridge University Press, p. 32 Mahyuddin Ismail. (2010). Kegiatan Jenayah Menggunakan Ilmu Sihir: Keperluan kepada Pembanterasan Melalui Mekanisma Perundangan. PhD Thesis, Law Faculty, University Kebangsaan Malaysia. Journal of Fatwa Management and Research | Jurnal Pengurusan dan Penyelidikan Fatwa | ىواتفلا ثوحبو ةرادإ ةلجم Julai 2018 |Vol. 13| ISSN: 2232-1047 | eISSN: 0127-8886 34 Mahyuddin Ismail. (2014). Bewitchment as a Defence in Divorce Cases According to Islamic Law. The Islamic Quarterly, Vol 58, No. 4, pp. 283292. Montague Summers. (2011). A Popular History of Witchcraft. 8th Ed. Routledge, London & New York. p. 172. Richard Kieckhefer. (1990). Magic in the Middle Ages, Great Britain: Cambridge University Press, p. 180. Wahid Abdussalam Al-Bali. (2004). Sword Against Witchcraft and Evil Magicians. Al-Firdous Ltd London. Penafian Pandangan yang dinyatakan dalam artikel ini adalah pandangan penulis. Jurnal Pengurusan dan Penyelidikan Fatwa tidak akan bertanggungjawab atas apa-apa kerugian, kerosakan atau lain-lain liabiliti yang disebabkan oleh / timbul daripada penggunaan kandungan artikel ini.


INTRODUCTION
Witchcraft or black magic is known to be among the most ancient mystical rituals in the world. It involves jinn and demons with definite purposes such as getting rid of love between family members, separating husband and wife, causing insanity and diseases, and even up to the point, killing the victim (Mahyuddin, 2014). In Malaysia, the use of witchcraft was raised in several criminal cases at Civil Court. Among them were the case of Juraimi Bin Husin v PP, Mohd Affandi Bin Abdul Rahman & Anor v PP [1998] 1 MLJ 537, and the case of Sabarudin Bin Non & Ors v PP [2005] 4 MLJ 37. Unfortunately, the issues were not addressed correctly due to the absence of specific provosions as well as the legal procedure related to witchcraft (Mahyuddin, 2012).

METHODOLOGY
This paper is a concept paper which mainly exploring the rituals of human sacrifice in witchcraft and how legal instrument may curb it. Thus, the method used is qualitative approach. Researcher focuses on library research to gather information related to the history of witchcraft practices particularly involving the use of human organs in demonic worship. References were made to related books, articles journal and official reports. The study will also examine criminal cases involving human sacrifice in witchcraft rituals that have been tried in Malaysian courts. The study will also examine the legal provisions as well as government policies related to this issue.

Witchcraft is an association with Satan
Witchcraft requires a witch to make an agreement with satan or devil. According to Al-Baly (2004), witchcraft (sihr) is "an agreement between a sorcerer (sahir) and an evil jinn or devil (satan) which stipulates that the sahir commit certain legal or polytheistic actions in return for the satan's assistance and obedience in fulfilling the sahir's request". While Gordon (1993) defined witchcraft as "magic undertaken for destructive or selfish purpose; to dominate or harm others; to gain power, wealth or knowledge by necromancy or sorcery, traditionally by calling up demons or by blood-sacrifice".

Human Sacrifice in Satanic Worship
There are various methods on how a witchcraft ritual is carried out. Some require the witches to utter charm or spell which contains specific name of satans by using specific manners and at specific places (such as at graveyard, jungle, haunted house etc). Some require the witches to do more than that i.e. human or blood sacrifice. Sacrifice requires blood and certain body parts including organs, limbs, genitals, eyes, teeth, fingers, the tongue or the heart. The process of removing these body parts often happens while the victim is still alive (KidsRights Report, 2014). According to Abdul Basir (1999), among other objects used in the ritual are skull, bone, heart, lungs, gall bladder, hair, nails, semen, saliva, blood etc.
Such ritual actually has been practiced since thousand years ago and it is still going on nowadays. According to Borghouts (1995), witches in the ancient Egypt civilization performed human sacrifice for their god Osiris. They believed that the sacrifice will make the country more prosper. If they failed to do so or they did not perform it in a proper manner, the whole country will suffer. In Europe, witchcraft has been widely practiced around the 15th century, some of which have to do with the killing of children who have been used as a sacrifice. For example, Summers (2011) described a trial of a nun name la Voisin during the reign of King Louis XIV in France as follows: "The child was held over the altar, a sharp gash across the neck, a stifled cry, and warm drops fell into the chalice… The corpse was handed to la Voisin, who flung it callously into an oven fashioned for that purpose which glowed white in its fierceness. It was proved that regular traffic had been carried on for years with beggar women and the lowest prostitutes, who sold their children for this purpose. At her trial, la Voisin confessed that no less than 2,500 babies had been disposed of in this manner." Children were most likely to become victims of witchcraft ritual during the dark ages of Europe . This fact can be seen through the trial of one of these magicians: …when a woman from the diocese of Novara was accused of witchcraft around the 1330s, the court sought advice from Bartolo of Sassoferrato, one of the most prominent lawyers of the day. In response, he first considered the woman's religious crime of idolatory…Secondly, he considered the woman's crime against humankind. She was accused of killing children by merely touching them. Is this in fact possible? The children's mothers testified that she had bewitched them, and that the children did in fact die. Bartolo had heard certain theologians suggest that sorcerers can harm and even kill others with their touch or with the evil eye.
In China and Taiwan, kidnapping and killing of children for internal organs such as the liver and spleen for the purpose of demon worship were rampant. Shaw (1975) recommended that a new law must be enacted to impose severe penalties on witches: "...It appears, this method of obtaining the services of supernatural entities that severe penalties had to be written into the law to prevent people from committing murder in order to obtain the necessary 'cosmic' ingredients." During the Yuan Dynasty, heavy punishment including carving to death was prescribed to those who were found guilty for sacrificing human in idolatry worship.
"The Penal Code of the Yuan (Mongol) Dynasty laid down that: " Whosoever plucks life out of a man or dismembers him with intent to procure a spectre to sacrifice to, shall be slowly carved to death with knives". Similar practices were mentioned in a Imperial Edict of 1846." (De Groot, 1964).
In Africa, such sacrificial rituals, and the subsequent wearing, burying or eating of a child's body parts, are said to bring business success, personal prosperity and health. Middle-class clients often begin with standard herbal remedies and animal sacrifices but are subsequently persuaded by witch doctors to part with a large sum of money for "Big Blood". This practice has embedded itself within traditional customs in recent times and continue to rise. Such practice is also reported in Tanzania, Uganda, Nigeria, Switzerland, Liberia, Botswana, South Africa, Namibia and Zimbabwe. Child Sacrifice in Uganda' (2011) reported child sacrifice is a growing problem in Uganda. The African Network for the Prevention and Protection against Child Abuse and Neglect (ANPPCAN) confirmed that child sacrifice has increased in Uganda over the last five years. According to the 2009 Uganda Police Report on human sacrifice, 15 cases of child sacrifice were reported, as compared with just 3 cases in 2007. But most cases did not find their way to police; the report notes that in 2009, out of 123 missing persons, 90 (73%) were children suspected to have become victims of human sacrifice (KidsRights Report, 2014).

Human Sacrifice in Malaysian Criminal Cases
The case of missing people especially children in Malaysia is quite alarming. Based on the statistics released by Royal Malaysia Police Headquarter Bukit Aman in 2018, there were 5,721 missing persons cases reported. Only 3,127 people were successfully found. When a person is missing, the authority will look into this matter as a an ordinary phenomena. It will be associated with several factors such as personal problem, stress, friends' influence, family break-up and so on. Do we ever think that some of the cases might have connections with human sacrifice in witchcraft ritual?
Based on court reports, there were witches who unmercifully slaughtered and cut off victim's body for the purpose of sacrification. This can be seen in the the case of Juraimi Bin Husin v PP, Mohd Affandi Bin Abdul Rahman & Anor v PP [1998] 1 MLJ 537. It was reported that Mazlan Idris, a state assemblyman in the state of Pahang, wanted to boost his political career and sought the services of Mona for assistance. Mona and her husband promised to help Mazlan by giving him a talisman consisting of a cane and sbatmi headgear which were supposedly owned by former Indonesian President Sukarno. Mona convinced Mazlan that he would be "invincible" if he held the talisman. An appointment was made for cleansing rituals to be performed at Mona's house. Mazlan was told to lie on the floor face up while Mona placed flowers on him. She then told Mazlan to close his eyes and wait for the money to "fall from the sky". Juraimi then, using an axe, chopped Mazlan's head off. They also dismembered and partially skinned Mazlan's body. His body was found in 18 parts buried in a storeroom near Mona's house.
In the case of Francis A/L Anthonysamy v PP [2003] 2 MLJ 49, the appellant was convicted of causing the death of a Bangladeshi national, Ali Ahammed bin Mohammed Ullah. He was found to have killed and beheaded the deceased with the intention of getting a human skull to be given to a shaman in satanic worship ritual in order to win the four-digit lottery. This case does not discuss further about the motive for the murder. The appellant indeed strongly believed that by using a human skull and the help of a shaman, he would have won the lottery. Although the above case clearly shows the belief in witchcraft may induces a criminal conduct, no one can take any action against the shaman because using witchcraft is not a crime. Thus, a specific and special law should be enacted to address this issue.
Some witches also believe that the purer the offering, the better. It will make their magical power stronger and stronger. The purer organs can be found in children which makes children more vulnerable to be sacrificed than adults. Furthermore, they are much easier to be lured into danger. In the case of Tan Mui Choo & Anor v Public Prosecutor [1987] 1 MLJ 267, the appellant and her husband were convicted of causing the death of two children. Appellant's husband, Andrian Lim, was an active shaman. The appellant and her husband were arrested after kidnapping and killing two children in a very cruel manner. The murder was carried out as a ritual for self reinforcement.
"…The second appellant lured Agnes Ng Siew Hock drugged with Roche tablets and was sexually abused by Adrian Lim. Before they drowned her, Agnes Ng's finger was pierced and all three sipped the blood…The second appellant lured Ghazali bin Marzuki. They drowned him and again went through the ritual of drawing blood from the boy by means of a syringe and drank it from a glass. The two appellants scooped the blood from the glass and licked the blood."

Characteristics Of Victim
Based on the study, there are some unique characteristics possessed by a victim who is suitable to be sacrificed in witchcraft ritual. In the case of missing person, the authority may venture into investigating the possible cause of abduction or murder by analysing these two points: (a) The birthday and sequence in family The most popular characteristic of a person to be sacrificed in satanic worship is the day he/ she was born and his/her sequence in family. The first child whose mother also the eldest and born on Tuesday is one of the most popular characteristic. Other than that, a woman who is the eldest and carrying her first child may also become a choice. The best example of the witchcraft work is anak kerak which is quite famous in southern Thai. According to Danny Lim (2008), anak kerak is is either a foetus or a stillborn baby killed before it has reached its first birthday. The most powerful Anak Keraks come from corpses of the first-born offsprings of parents who are first-born themselves. Ideally, the baby should be born on a Tuesday, and killed around the age 5 to 7 months.
(b) The conditions of victim upon found If the missing person is found murdered, the possible motive for the murder can be identified by looking at the body and internal organs of the victim. If the victim's body is torn apart and his organs such as the liver, spleen, kidneys or body are severely damaged or loss, the victim is likely to become an object in demon worship. KidsRights Report (2014) stated that sacrifice requires blood and certain body parts including organs, limbs, genitals, eyes, teeth, fingers, the tongue or the heart. The process of removing these body parts often happens while the victim is still alive. The victim's condition of a witchcraft ritual can be seen in KidRights Report (2014)

DISCUSSION
From the analysis on human sacrifice and its relation to witchcraft, we may conclude that there is possibility that some murder cases are related to satanic worship in witchcraft ritual. Even the illustration (a) for Section 364 of the Malaysian Penal Code has special provision relating to human sacrifice, but yet no case has ever been tried under this section. This illustration provides: A kidnaps Z from Malaysia intending or knowing it to be likely that Z may be sacrificed to an idol. A has committed the offence defined in this section. The provision clearly illustrates the possibility of human abduction with intent to be sacrificed for idolatry, or more precisely the worship of Satan. No religion in this world legalizes the act of killing human beings for the purpose of worship. It is nothing but satanic worship as part of the ritual of witchcraft. The method of worship of devils and demons that accompanies the preparation of sacrifices has been practiced for thousands of years and it continues to this day. Such thing is not new, but has been practised by witches since long time ago. In 11 th October 1993, the 33 rd Fatwa Committee of the National Council for Islamic Religious Affairs of Malaysia has decided that the 'relevant parties should provide legal provisions to punish witches who have been convicted for practicing witchcraft.' The same is echoed in a number of conferences and seminars. But until now, this matter still remains unsolved and the Malaysian authority seems to keep silent on the issue of witchcraft law.

CONCLUSION
Therefore, the authority should take proactive measures to curb the crime by introducing anti-witchcraft laws. Futher research also should be made to see whether the loss of person can be associated with the demand for their organs to be used in satanic worship. It is time for the government to gazzete witchcraft as a crime, and the witches, or those who use their service be brought before the court. As said by Mittlebeeler (1976), "if we accept the theory that the law of crimes developed from direct public action against a malefactor, witchcraft may have been the first of all crimes".