Chu Kheng Lim v Minister for Immigration
Key Principle
Executive detention of aliens must be non-punitive; punitive detention is exclusively a judicial function under Chapter III
Established the 'Lim principle' — that the executive power to detain aliens under the aliens power (s 51(xix)) is limited to detention that is reasonably necessary for purposes such as processing or deportation. Punitive detention can only be imposed by the judiciary under Chapter III. This principle became the foundation for all subsequent constitutional challenges to immigration detention, including Al-Kateb and NZYQ.