In Amalan Tepat Sdn Bhd v Hew Foong Hin & Anor  MLJU 408, it was held by the Court of Appeal that:-
"... Clause 22(2) provided that if the appellant fails to comply with clause 22(1) then the appellant shall pay immediately to the respondents liquidated damages to be calculated day to day at the rate of 10% per annum of the purchase price. Once the date for delivery of vacant possession had passed, the appellant's liability to pay liquidated damages calculated in accordance with the formula prescribed by the SPA became immediate. There was no further onus on the respondents to prove damages. Gopal Sri Ram JCA (as he then was) said as follows in Sentul Raya Sdn Bhd v. Hariram Jayaram & Ors and other appeals  4 CLJ 618 :
On its proper construction, the clause makes a housing developer immediately liable to a purchaser in liquidated damages once the date for completion passes. Put differently, cl. 22(2) excludes the operation of s. 56(3)..."