9 The present application was, as I have already mentioned, premised on an alleged contravention of r 13. However, when the defendant submitted its skeletal submissions, it referred to a whole host of other alleged incurable non-compliances with the PER in so far as the present proceedings were concerned. In summary, these included the following arguments: (a) that the plaintiff, in citing the Attorney-General as the defendant, had in fact named the wrong defendant (and citing the Malaysian High Court decisions of Ramely bin Mansor v Suruhanjaya Pilihanraya Malaysia [2000] 2 MLJ 500 and Dr Lee Chong Meng v Abdul Rahman bin Hj Abdullah, Returning Officer [2000] 6 MLJ 98); (b) that there had been a failure on the part of the plaintiff to state (in her affidavit supporting her application under s 90 of the Act) her right to apply within s 93 of the Act – a requirement set out under r 5(1)(a) of the PER; (c) that there had been a failure on the part of the plaintiff to state (in her affidavit supporting her application under s 90 of the Act) the holding and result of the election – a requirement set out under r 5(1)(b) of the PER; (d) that there had been a failure on the part of the plaintiff to state (in her affidavit) the grounds upon which she was relying to sustain the relief sought (which grounds are set in ss 90(a) to 90(e) of the Act) – a requirement set out under r 5(1)(b) (and citing the Malaysian High Court decision of Norbert Choong Kai Chong v Mohamed Idris bin Haji Ibrahim [1980] 1 MLJ 316 (“the Norbert Choong case”)); (e) that there had been a failure on the part of the plaintiff to state (in her affidavit) the relief sought – a requirement apparently raised by virtue of r 5(4) of the PER. 10 It is immediately apparent that the arguments set out above – in particular the first – are substantive arguments in their own right (this is accentuated by the fact that the relevant case law was also invoked, as noted above). The problem, as I perceived it, was that it would have been unfair to have allowed the defendant to rely upon them in the present proceedings without more. Let me elaborate. 11 In the first instance, the present application was made pursuant to r 13(4) of the PER. It was a specific application focusing on non-compliance with a particular provision requiring that the plaintiff provide security for costs. In order, therefore, for the defendant to rely on the other arguments just referred to, it was incumbent on it to apply for an amendment of the present application to include these arguments. Counsel for the defendant, Mr Jeffrey Chan Wah Teck, immediately pointed to the potential pitfall in adopting such an approach. There was, he argued, a risk of mixing the applications inasmuch as an application under r 13(4) would (if successful) result in a dismissal of the plaintiff’s substantive application, whereas if the other grounds were successfully established, this would result in the plaintiff’s substantive application being rendered a nullity for non-compliance. 12 I did point out, however, that yet another alternative approach which avoided the pitfall just mentioned would be for the defendant to take out a separate application focusing on the other arguments from non-compliance. Both the present as well as the new application could then be heard together. 13 I also pause to note that Mr Ravi was not averse to having the other grounds being heard by this court as well, provided that he was given a short adjournment.