Thio Li-ann has commented that the Minister's clarification "dealt the "quietus est" to the High Court's odd pronouncement in "Taw Cheng Kong v. Public Prosecutor"". On 18 January 1966, shortly after Singapore's independence, the President appointed a Constitutional Commission led by Chief Justice Wee Chong Jin to consider how the rights of racial, linguistic, and religious minorities in the nascent nation should be protected. In its report on 27 August 1966, the Commission recommended entrenching the right to vote as a "fundamental right" in the form of "the right to elect a government of their choice as expressed in general elections held at reasonable periodic intervals by secret vote". The chief justification for this proposal was the relatively infant or immature culture of democracy in a newly independent nation that was "barely one year old". The report noted that citizens had only exercised the right to vote twice in general elections, in 1959 and 1963 respectively. Hence:  However, Parliament decided not to entrench the right to vote, instead relegating voting rights to statutory regulation under the Parliamentary Elections Act. During the 2009 parliamentary debate on the right to vote's status, Thio Li-ann proposed that, to avoid doubt, the right should be specifically set out in the Constitution. She argued that entrenching the right to vote through an Article in the Constitution would provide the opportunity to protect the details of the right. Currently, voting is regulated by the PEA. As it is an ordinary statute, it can be altered with a simple parliamentary majority by future governments seeking to amend or restrict voting rights. Thio said that expressing the right to vote clearly in the Constitution would allow aspects of that right such as voter secrecy and the universality and equality of votes to be protected from unjust manipulation. However, the Minister for Law said the Government was of the opinion that as the right to vote is an implied right in the Constitution, it was unnecessary for the Constitution to be amended to expressly mention the right. Articles 65 and 66 of the Constitution would be entrenched once Article 5(2A) is brought into force. That Article, which has remained in abeyance since it was introduced in 1991, provides that a bill that seeks to amend, among other things, Article 65 or 66, must be supported at a national referendum by not less than two-thirds of the votes cast, unless the President consents to the amendment. Shanmugam went on to state that the concerns of the 1966 Constitutional Commission were now moot, as Singapore had since experienced ten general elections with a 95% voter turnout each time.