Persatuan Bertindak Pilihan Raya Bebas dan Saksama (Tindak) expresses deep concern over the Electoral Commission’s continued failure to improve the allocation of polling centres in the Luyang state constituency (Kota Kinabalu).
The latest Government Gazette: Notice of Contested Election – Legislative Assembly for the State of Sabah, published on 21 November, confirms that no meaningful corrections have been made.
This represents a clear missed opportunity by the commission to ensure smooth and convenient voter movement in a long-established urban constituency.
Under Malaysia’s electoral system, every constituency is divided into polling districts, each of which is assigned to one or more polling centres such as schools, halls or temporary facilities.
Section 7 of the Elections Act 1958 outlines the formation of polling districts and their association with polling centres. A polling district determines where a voter casts their ballot.
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However, Section 7 remains silent on the requirement that polling centres must be geographically located within their respective polling districts.
As a result, a polling district can be assigned a polling centre situated outside its boundaries, and multiple polling districts may share a single polling centre.
Tindak highlighted these problems (through Tindak Malaysia banner) to the Electoral Commission as early as 2019, shortly after Sabah’s redrawing of constituency boundaries was passed in Parliament.
Our analysis at the time showed significant criss-crossing of voter movement caused by the commission’s flawed allocation of polling centres in the Sabah assembly seat of Luyang. Refer to the map below:

Figure 1: 2019 allocation of polling centres (school sign) to polling districts (coloured polygons) of the Sabah assembly seat of Luyang. Black arrows shows how the voters should get to the polling centres. This map was submitted to the Electoral Commission in 2019
Only one polling district – Kepayan Ridge – had an appropriately placed polling centre (Maktab Sabah Secondary School).
In several other districts, voters were expected to travel outside their Sabah assembly constituency, and even outside the Kota Kinabalu parliamentary constituency to cast their votes.
This is inconsistent with the 13th Schedule, Section 2(b) of the Federal Constitution, which requires constituencies to be drawn with consideration for voter registration and polling machines.
In 2019, Tindak submitted a detailed proposal to streamline polling-centre allocation in Luyang, aiming to reduce unnecessary cross-district travel and ensure all voters could vote within their own assembly seat boundaries. We had hoped meaningful improvements would be implemented for the 2020 Sabah assembly election and subsequent polls.
Unfortunately, our review found that only minimal changes were made in 2022, and these failed to address the core issue of voter accessibility.
In October 2025, we again reminded the Electoral Commission of the unresolved issues in Luyang and were informed that our suggestions were forwarded to the commission’s Sabah office. The table in our report shows how, from 2019 to 2025, problematic polling-centre allocations remained largely unchanged.
| Polling district (DM) | Polling centre | 2019 | 2020 | 2022 | 2025 | Notes |
|---|---|---|---|---|---|---|
| Jalan Rumah Sakit | Tadika Peak Nam Toong | Yes | Yes | Yes | Yes | Polling Centre in DM Lido |
| Luyang | Sekolah Kebangsaan (Cina) Anglo Chinese | Yes | Yes | Yes | Yes | Polling Centre in DM Jindo |
| Foh Sang | Institut Pendidikan Guru, Kampus Gaya | Yes | Yes | Yes | Yes | Polling Centre in DM Jalan Kebajikan (DUN Api-Api) |
| Foh Sang | Dewan Serbaguna Wisma Pertanian | N/A | N/A | Yes (Introduced for 2022 general election) | Yes | Polling Centre within DM Foh Sang |
| Jindo | Dewan Serbaguna Luyang | Yes | Yes | Yes | Yes | Polling Centre in DM Taman Fu Yun |
| Bukit Padang | Dewan Foochow | Yes | Yes | Yes | Yes | Found in DM Cenderakasih (Inanam assembly seat, Sepanggar parliamentary seat) |
| Kepayan Ridge | Sekolah Menengah Maktab Sabah | Yes | Yes | Yes | Yes | Polling centre within DM Kepayan Ridge |
| Taman Fu Yun | Sekolah Menengah Kebangsaan Taman Tun Fuad | Yes | Yes | Yes | Polling centre found in DM Nosob (Kepayan assembly seat, Penampang parliamentary seat) | |
| Jalan Penampang | Sekolah Kebangsaan Sri Gaya | Yes | Yes | Yes | Yes | Polling centre found in DM Foh Sang |
| Lido | Sekolah Menengah Kebangsaan Tinggi Kota Kinabalu | Yes | Yes | Yes | Yes | Polling centre found in DM Kepayan Ridge |
The map below shows the expected voter movements during polling day for Sabah assembly seat of Luyang (for the 2025 Sabah assembly elections)

Figure 2: Current allocation of polling centres to polling districts of the Sabah assembly seat of Luyang (reflective of the 2022 general election and 2025 Sabah assembly election). Black arrows point to the movement of voters for the various polling districts
Since 2019, Tindak has communicated these concerns to the Electoral Commission through formal submissions, including our Pemerhati (Monitoring) reports (such as Pulai 2023) and a comprehensive briefing with the full commission leadership on 14 January 2025.
During this meeting, we stressed that every polling district should be designed with at least two in-district polling centres (meaning polling centres must be within the polling district).
Because polling districts define where voters cast their ballots, it is crucial that the Electoral Commission plans them carefully to minimise voter inconvenience and eliminate unnecessary cross-boundary movement.
While this statement focuses on Sabah assembly seat of Luyang, we believe similar issues may affect other constituencies in Sabah and across Malaysia.
Despite our repeated engagements through proper channels, the commission has not acted on its fundamental responsibility: to facilitate ease of voting.
On 22 November, we have asked the commission to explain its inaction despite clear evidence and recommendations. As the commission has failed to address these issues since 2019, Tindak has no choice but to bring this matter to the attention of the public.
We call on the Electoral Commission and all its state offices to take decisive steps to rectify polling-centre allocations in Luyang and beyond. With the redrawing of constituency boundaries pending for Sarawak, overdue for Sabah, and expected for the peninsula, the commission must first fix the foundation: the polling districts.
Only with well-designed and accessible polling districts can we ensure that constituencies remain accessible, representative and equitable.
Failure to address these issues will continue to undermine public confidence in the commission and its role as the nation’s election management body. – Tindak
Sources:
- 2019 polling district and polling centre allocation
- 2025 polling district and polling centre allocation
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