Historically, the disenchantment of many special educators and the concern of the efficacy of the prevailing approach (Ainscow, 1994; Meyen & Skrtic, 1995; Sorrells, Rieth & Sindelar, 2004; Stainback & Stainback, 1992) raised questions about how best to assure a quality and equitable education for students with disabilities and spawned the push for a more inclusive approach to special education programming. While these reforms were mandated in the United Nations Declarations and UNESCO’s Framework of Actions on special needs education of which Malaysia’s policy on inclusive education subscribes to, the focus on diagnosis, prescription, and intervention continued to be central to determining eligibility and making placement decisions. Thus, although special education practices had changed, the grounding assumptions of human pathology and organisational rationality (Biklen, 2000; Oliver, 1996; Skrtic, 1991) have not been critically examined. In this context, special education is used to maintain and legitimise exclusion of students with disabilities within a school culture and system characterised by competition and selection (Skrtic, 1995; Corbett, 1999; Slee, 2001; Kearney & Kane, 2006).