The ‘Rule Of Law’ in Hong Kong: Identity Construction and Political Instrumentalisation of the Territory’s ‘Social Imaginary’

Unpacking the role of the discourse of law in the construction of the Hong Kong identity and underlying power relations

By Charlotte Monroe, student at Sciences Po Law School and exchange student at Harvard Law School

A few days ago, the trial of Hong Kong pro-democracy activists, charged with public nuisance and incitement over the Umbrella Movement, ended, with the court’s judgement expected to be issued in April 2019. Described as a politically motivated prosecution[i], the trial immixed law and politics – similarly to the way the 2014 Umbrella Movement was addressed.

While pro-democracy protestors had resorted to a rights-inspired discourse to legitimise their actions, the Hong Kong Special Administrative Region (HKSAR) government characterised the movement as an ‘illicit campaign,’ contending that the protestors were threatening the community’s most praised value – the rule of law. Through the use of competing legal discourses, the Umbrella Movement epitomises the manipulation of the territory’s identity attachment to the rule of law in the context of power struggles in Hong Kong.

Initially imposed by the British colonial rule as a tool for colonial legitimisation and governance, the rule of law continues to act as a tool of ‘manufacture of consent’,[ii] having acquired the status of a grand narrative. Used as a coercive force as well as a consensual source of political legitimacy, the rule of law narrative is a powerful hegemonic ideology, to the extent that it has constructed the Hong Kong ambiguous identity throughout the past century. Although the post-1997 era has witnessed the rising assertiveness of its people, Hong Kong continues to observe an ‘unwavering commitment to the rule of law.’[iii]

This paper seeks to explore the intersections between the social production of identity and the perpetuation of power structures, by unpacking the construction of the Hong Kong identity through the discourse of law (I) and by unveiling the underlying power relations and means of control emanating from this hegemonic narrative (II).

I. The Construction of the Hong Kong ‘Self’: Law at the Centre of Hong Kong’s ‘Social Imaginary’

Initially used ‘as a tool to suppress dissent and to prohibit any movement for democracy or independence for Hong Kong’[iv] during the British colonial rule, the law was then used to forge a Hong Kong identity, and thus progressively became a sacrosanct principle central to the territory’s identity.

1950s-1970s: Local ‘Self’ in the making

By the 1950s and the 1960s, a Hong Kong sense of local identity had not yet emerged amongst the city’s inhabitants. The massive inflows of immigrants from Chinese Mainland did not allow for the creation of an identity, and the city was only considered as a relatively open refugee society. The politics of local identity only developed in the 1970s, when a sense of ‘Othering’ was formed by the colonial government, thus allowing a ‘Self’ to emerge.

In the case of Hong Kong, law played a fundamental role in the creation of a ‘Self’ and an ‘Other.’ During the 1970s, the colonial government spoke of a ‘lack of social cohesion’[v] amongst a crowd of temporary residents. In an attempt to reorganise the people, ‘the government of the 1970s deconstructed their dispersed cultural identities, splitting them between an identification with a backward Mainland China and a modern Westernised Hong Kong identity.’[vi]

In the 1970s, the colonial government became less lenient in accepting illegal immigration from Mainland China and other parts of Asia. A sense of identity was created through the regulation of the territory, thus marking the collective space of the society.

The legal creation of a sense of membership enabled the development of the local identity. In 1971, local immigration law added the notion of the ‘Hong Kong belonger’, a new category thus marking a shift from a negative definition toward a positive affirmation of a local identity in law, policy and politics. The translation of the Hong Kong people as a collective community into legal terms empowered the imaginary of difference between Hong Kong and the Mainland, as the ‘Hong Kong belonger’ was distinguished from ‘Chinese resident’ and ‘resident United Kingdom belonger’. The identity category of ‘Hong Kong belonger’ thus became ‘a means of breaking up the remnants of older social ties, of dissolving the identity of the Chinese.’[vii]

Another source of construction of the ‘Self’ and the ‘Other’ can be identified in the establishment of ideological and cultural differences through law. For instance, the 1971 Marriage Reform Ordinance, which banned Chinese customary marriage and Chinese modern marriage and made registered marriage the only legal form of marriage, legally bound Hong Kong people to the adhesion to ‘modern’ and ‘liberal’ Western norm of monogamy and the rejection of ‘backward’ and ‘barbaric’ Mainland values. ‘Alterity’, at the core of the construction of identities, was thus institutionalised through law, the ‘alter’ being China. By the 1970s, a sense of local identity and distinction, deeply interwoven with law, had thus emerged.

In parallel to the construction of the local identity through law, the end of the 1970s witnessed the emergence of a discourse of prosperity and progress. The economic prosperity Hong Kong started to encounter in the 1970s fuelled a feeling of locality and a sense of distinctiveness vis-à-vis the People’s Republic of China, whose communist system was perceived as a synonym to economic backwardness:

‘The new narrative included a keen awareness of the community’s newly achieved prosperity and stability, an alertness to any threat to its collective achievement in society, a strong sense of Hong Kong identity, a feeling of resentment toward the illegal immigrants for posing such a threat, and, most important, a determined will that Hong Kong succeed economically and politically.’[viii]

This new discourse provided the basis for the formation of the ‘rule of law’ narrative, which emerged fully during the transitional period.

1980s-1990s: Transitional period and the construction of the ‘Rule of Law’ discourse

‘Preoccupation with legalities, and with the legal subject, comes to be salient in a dimension of postcolonial dis/order and its mass-mediated representation.’[ix]

In the context of the much mediatised transitional period and the fears it inspired, as well as the social panic instilled by the 1989 Tiananmen incident, the ‘rule of law’ narrative emerged, envisioning the British inherited ‘walled space of legality’ as a bulwark against the looming lawlessness represented by the transition of sovereignty to China. According to such myth, the British colonial rule had ‘brought order out of chaos, establishing legal institutions and the rule of law, vanquishing corruption and containing the shadowy netherworld of triads and organised crime.’[x] Concern over Hong Kong’s legal future stemmed from the fear that ‘China-style disorder and corruption will transfer with China’s sovereignty’[xi] and will ‘rip the rule of law into shreds’[xii], as warned by Martin Lee, former chairman of the Democratic Party of Hong Kong.

In a time of change, uncertainty and looming lawlessness associated with the handover to the ‘city of tanks’, underscored by the ‘traumatic effect’[xiii] of the 4 June 1989 events, the fears associated with the transition of sovereignty led the people of Hong Kong to relish the symbols of rule and order and demonstrate an unprecedented attachment to their legal system. In such a crucial moment, during which the Hong Kong identity became intimately intertwined to the rule of law, it was also the law ‘which was in this moment offered to Hongkongers as their salvation in the face of oppression.’[xiv]

In addition to the emergence of a discourse of rights, the rule of law narrative became intertwined with a discourse of prosperity and progress, which had emerged in the 1970s, as Hong Kong was being recognised as one of the Four Little Dragons of the ‘East Asian Miracle’. The perception that the rule of law is one of the keys to the ‘barren-rock-turned-capitalist paradise’[xv] success, further entrenching such narrative within the sentiment of local identity, is viewed as a consensus: in 1996, 75% of overseas investors perceived the rule of law as one of the favourable factors for investment in Hong Kong.

The mystification of the rule of law, considered as essential to the preservation of rights and the maintenance of the territory’s liberal capitalist-led economic prosperity, had been discursively entrenched by the last colonial governor, Chris Patten. By over-lexicalising the rule of law – characterising it as ‘the guardian angel of Hong Kong’s decency and the engine of Hong Kong’s success’, portraying it as ‘the bedrock of your way of life’, and calling it ‘this community’s most prized possession,’[xvi] Chris Patten played an important role in the creation of the ‘rule of law’ myth, which, ‘by appealing to common features of culture or group […] provides a sense of individual and communal identity.’[xvii]

The perpetuation of such ideology, which creates consent and consensus to the point that it becomes integrated to the citizens’ sense of identity, reflects the uncontested prevalence of a hegemonic discourse.

II. Political Instrumentalisation of the Discourse of Law

Reproduction of oppression: Parallels between colonial and re-colonial instrumentalisation of law

Many have worried about the preservation of the rule of law under the ‘one country, two systems’ principle, as established in the handover agreements, and the fulfilment of the promise that ‘the current social and economic systems will remain unchanged, and so will the life-style,’[xviii] as inscribed in the Sino-British Joint Declaration on Hong Kong. Western media denounce the ‘creeping interference by Beijing’: ‘China bullies Hong Kong,’ writes The New York Times; ‘Menaces sur l’autonomie de Hongkong,’ (Threats to Hong Kong’s autonomy), read a Le Monde headline; ‘Rule of law has become non-existent in Hong Kong’ declared The Guardian.

While portraying the post-1997 period as increasingly authoritarian times, Western journalists and scholars tend to depict the British colonial legacy in an overwhelmingly positive light: ‘a much celebrated British “gift” to Hong Kong has been the rule of law, which with an independent and impartial judiciary, supposedly delivers fair and equal justice to all.’[xix] However, the binary framing of a valuable British legacy of rights and freedom and Mainland autocratic manipulation of the law extensively neglects the instrumentalisation of law during the British colonial rule.

Focusing blindly on the 1980s and 1990s discourse of democratic values, rights and rule of law, Western media and academia obliterate the coercive use of law preceding the handover period. In the context of the upcoming 1997 handover and the growth of the human rights norm on the international scene, the last colonial government developed a discourse emphasising democracy, rights and the rule of law,[xx] which led many to forget that the ‘law and order’ and ‘rule by law’ discourses, which re-emerged under the SAR administration, had been the tool of the British for decades.

The historian Richard Klein documents the century-and-a-half long British colonial rule over Hong Kong and demonstrates how ‘the British have utilised the legal and legislative systems to stifle and oppress those who opposed or desired to reform the governance of the Colony.’[xxi] Prohibiting ‘any Chinese public meeting,’[xxii] as association of people was judged ‘incompatible with the peace and good order of the Colony,’[xxiii] the 1888 Ordinance ‘Regulation of Chinese’ was extensively used in the by colonial government, when its authority was challenged.

Faced with a series of strikes by the Seamen’s Union in the 1920s, the government declared martial law, outlawed the Seamen’s Union and closed down its headquarters. In the context of the 1925-1926 Hong Kong-Guangzhou strikes, police was ordered to deport all strikers and idlers. In 1950, a crowd of 10,000 supporting the striking tramway men, dispersed by the police’s use of tear gas, led the Government to issue the Expulsion of Undesirables Ordinance, which provided for the expulsion of any person ‘suspected of being likely to cause a disturbance of the public tranquillity.’[xxiv] The 1966 riot against the increase in the Star Ferry fare led the Government to decide to subject the Colony to the special constables of the Peace Preservation Ordinance, which provided that ‘any justice of the peace may enter […] without a warrant […] using force in either case, if necessary, into any dwelling house or other building, or into any place into which he may have reasonable cause to suspect that persons lately riotously assembled or engaged on any unlawful purpose.’[xxv] Nearly 1,500 were arrested, but were not legally represented.[xxvi] During the 1997 protestations against the colonial rule, the British government continued to instrumentalise law as a coercive force to restore order: the government empowered judges to exclude the public from the court, fearing that court sessions would trigger the organisation of more protests.[xxvii] The government was empowered to implement ‘any regulations whatsoever which [it] may consider desirable in the public interest.’[xxviii] Through heavy policing and an abundance of legislation designed to regulate behaviour, law was used as an instrument of coercion throughout the colonial years.

In a similar way to the colonial government, the post-1997 pro-Beijing government used the law as a coercive political instrument. As argued by Yash Ghai, the Basic Law, Hong Kong’s mini-constitution, is ‘about control, not autonomy’[xxix]: in fact, ‘the Basic Law of Hong Kong contains “many mechanisms” through which the SCNPC [Standing Committee of the National People’s Congress] and the central government can “interfere” with the affairs of the HKSAR.’[xxx] Article 158 of the Basic Law vests the power of interpretation in the National People’s Congress Standing Committee (NPCSC): ‘the Standing Committee of the National People’s Congress shall authorize the courts of the Hong Kong Special Administrative Region to interpret on their own, in adjudicating cases, the provisions of this Law which are within the limits of the autonomy of the Region.’[xxxi] In February 1997, the Chinese authorities decided to repeal laws deemed inconsistent with the Basic Law, many of which had been established in the final years of the colonial rule by Governor Patten. The parallel with the pre-transitional colonial rule is unequivocal: the NPCSC ‘removed several recent laws that were more consistent with the Basic Law than the older colonial laws […], showing its preference for restrictive colonial laws over the reforms that carried forward the Basic Law provisions.’[xxxii] This rational-legal approach and statist interpretation of the rule of law and the anchoring of the ‘law and order’ framework mirrors the pre-transitional British colonial instrumentalisation of law. Consent, core to hegemonic dominance, is thus seen as diluting, revealing the coercive power residing under this ‘mask of consent.’

However, the ‘law and order’ discourse was not used independently from the ‘rule of law’ narrative; rather, the postcolonial government strategically associated the two competing legal discourses, as a way of satisfying both Beijing and the Hong Kong people. At the Ceremony celebrating the establishment of the HKSAR on 1 July 1997, Tung Chee-Hwa, the first Chief Executive of the HKSAR, built on Patten’s discourse about the importance of ‘equality before the law’ and the independence of the executive, legislative and judicial branches of the government, but adds ‘law and order’ undertones: ‘we strive for liberty, but not at the expense of the rule of law.’[xxxiii] By linguistically opposing the dyad of ‘liberty’ and ‘rule of law’, Tung alters the meaning of the rule of law, substituting Chris Patten’s rights-infused and democratic concept by a mere euphemism for ‘order’. The shifting discursive formation of the rule of law is further exemplified in Tung’s address at the APEC CEO Summit in Shanghai, in 2001, where he declared that Hong Kong would continue to have ‘a government that stresses rule of law, safeguarding of the freedoms that its citizens enjoy, and public security especially in times that demand heightened vigilance.’[xxxiv]

The opposition between the ‘rule of law’ rights-inspired narrative and the ‘law and order’ discourse is played out in the context of social protests, which oppose the government to the civil society.

Civil society versus Government: Politics through Competing Legal Discourses

The parallel between the pre- and post-transitional administrations becomes unequivocal in the analysis of the discursive strategies in the context of protests and their repression.

In his address to the Legislative Council following the general strike of 1925, the Governor of Hong Kong Sir Reginald Stubbs associated unlawful activities to chaos and deprivation of economic growth: ‘the present movement is nothing less than an attack on existing standards of civilisation as represented by Hong Kong […] We are faced with a deliberate attempt to destroy, in the interests of anarchy, the prosperity and the very existence of the community.’[xxxv]

This discourse, stressing stability, law and order, which had been replaced in the 1980s-1990s by a rights-inspired discourse of democratic values and rule of law, resurfaced after the SAR government was implemented, as evidenced in the context of the June 2000 protest or the 2014 Occupy Central. Because discourses are subject to diachronic change, hegemonic ideologies are constantly constructed and deconstructed: while the postcolonial government took an authoritarian turn – demonstrated by the pervasive use of ‘law and order’ undertones to the ‘rule of law’ narrative, it nonetheless required consent on the behalf of an increasingly rights-aware population – reflected through the perpetuation of the legal discourse.

The 2014 Occupy Central protest (also called the Umbrella Movement) was framed in a similar way: the government used the ‘law and order’ concept in an attempt to suppress the dissenters, which managed to rally support from a large part of the public opinion, whereas the protestors resorted to the rights-inspired rule of law discourse to legitimise their actions. During 79 days in autumn 2014, tens of thousands of people joined the Occupy Central movement, a political protest where many expressed their discontent with the upcoming elections of the Chief Executive due in 2017. While Article 45 of Hong Kong’s Basic Law stipulates that ‘the ultimate aim is the selection of the Chief Executive by universal suffrage upon nomination by a broadly representative nominating committee in accordance with democratic procedures,’[xxxvi] the NPCSC issued on 31 August 2014 the decision to pre-screen the candidates for the position of Chief Executive, thus ensuring the maintenance of a pro-Beijing SAR government. As a reaction, pro-democracy supporters occupied the Central District in Hong Kong. In an attempt to dissipate the political underpinnings of the protest, the government addressed it through a legal lens, arguing that these non-law-abiding citizens were undermining the rule of law, by placing themselves above the law. Supporters of the protest inevitably fell into the legal debate addressed by the government, contending that ‘it is part of their right to protest.’[xxxvii]

The debate was reiterated by the media and throughout the academic literature. Global Times, a nationalist newspaper, portrayed Occupy Central as an ‘illicit campaign’, supported by ‘radical activists’, with the potential of ‘jeopardising the global image of Hong Kong’ and ‘erod[ing] the authority of the rule of law.’[xxxviii] Although 2014 Occupy Central was a pro-democracy protest, it was framed as a ‘civil disobedience’ movement by the local media and government, emphasising on legalistic terminology while eclipsing the protestors’ political motivations and demands. The debate revolved around the legal validity of the citizens’ actions or their responsibility in jeopardising the rule of law and continues to be addressed as such.

Still today, under the ‘Occupy Central’ categorisation of news articles and archives of the South China Morning Post, a leading liberal newspaper in Hong Kong, news related to the pro-democratic protests of Autumn 2014 continue to be framed as a law-related matter. ‘Occupy leaders are arrested and charged,’[xxxix] ‘Outrage at two-year prison terms for Hong Kong policemen who beat up political activist,’[xl] ‘Lawyers say Occupy protests are undermining Hong Kong’s rule of law,’[xli] ‘Occupy protests breaking law, but not undermining Hong Kong’s rule of law’[xlii] – these headlines from the South China Morning Post encapsulate the legalistic debate taking place, thus reflecting the discrepancy between the object of the protests and the meaning attributed to them.

With the opening of the trial of nine pro-democracy activists, charged with public nuisance over the Umbrella movement[xliii], in November 2018, the Occupy Central movement continues to be addressed in relations to law rather than politics.

These competing discourses of ‘law and order’ and rule by law, and of rights and ‘rule of law’ highlight the dichotomy amongst the Hong Kong territory, where pro-Beijing and pro-democracy individuals co-habit. Although popular to pro-democracy supporters as well as to pro-establishment advocates, the rule of law entails different meanings. Pro-democracy Hong Kongers value the rule of law for its underlying rights-inspired and democratic significance, whereas pro-establishment individuals perceive the rule of law as a source of stability and prosperity, and as a conservation of the status quo. 

Conclusion

The Hong Kong identity – and whether it actually possesses one – has been the subject of controversy, especially since the People’s Republic of China resumed sovereignty over the territory in July 1997. ‘Hybrid identity’, ‘fluid identity’, ‘an identity caught between China and the West’ – the terms vary to characterise the conflicted Hong Kong sense of distinctiveness. However, although Hong Kong’s identity is complex and controversial, one thing is sure: the rule of law is seen by all as fundamental to the territory’s social imaginary. This paper has sought to address the interplay between the social production of identity and the perpetuation of power structures in relations to the hegemonic discourse of law in Hong Kong, with reference to concepts emanating from Gramscian theoretical legacy, in particular ideology and hegemony. The construction of the Hong Kong identity is deeply intertwined with the emergence of the hegemonic myth of the rule of law, whose competing sub-discourses instrumentalised by the colonial and post-1997 governments, in an attempt to disguise coercion through consent, and increasingly by the thriving civil society characterised by a growing rights awareness, reflect the distribution of power.

It is essential to reflect upon these issues, especially in the context of the aftermath of the 2017 Chief Executive elections, where a pro-Beijing candidate was elected. The profound politicisation of the territory’s legal system and ideology, as well as the strong legal strings attached to the citizens’ political identity predict mixed assumptions in regards to Hong Kong’s democratic future. 

[i] Amnesty International Report, ‘Umbrella Movement: End politically motivated prosecutions in Hong Kong’ 16 November 2018

[ii] Antonio Gramsci, Selections from the Prison Notebooks of Antonio Gramsci (New York, International Publishers, 1971).

[iii] Karen M. Y. Lee, ‘Defending the Rule of Law and the Role of Civil Society’, Public Administration and Policy, 2013, p.35.

[iv] Richard Klein, ‘The Empire Strikes Back: Britain’s Use of Law to Suppress Political Dissent in Hong Kong’, Boston University of International Law Journal, Vol. 15, No. 1 (1997), p. 1.

[v] 1966 Report, p. 141.

[vi] C. Jones, ‘Politics Postponed’, 1999, p. 54.

[vii] C. Jones, ‘Politics Postponed’, 1999, p. 54.

[viii] A. Ku, ‘Immigration Policies, Discourses, and the Politics of Local Belonging in Hong Kong,’ 2004a, p. 350

[ix] Jean Comaroff and John Comaroff (eds.),‘Introduction’, in Law and Disorder in the Post-Colony (Chicago: University of Chicago Press, 2006), p. 21.

[x] C. Jones, Lost in China? 2015, p. 40-41.

[xi] Martin Q. C. Lee, ‘Business and the Rule of Law in Hong Kong’, The Columbia Journal of World Business (Summer 1995), p. 29-30.

[xii] Martin Lee, ‘Courting Disaster’, South China Morning Post, 14 June 1995.

[xiii] ‘Reports of the Sittings of the Legislative Council of Hong Kong (Hong Kong: Government Printer, 1989/90), p. 15.

[xiv] C. Jones, Lost in China? 2015, p. 55.

[xv] Tak-Wing Ngo, Hong Kong’s History: State and Society Under Colonial Rule (1999), p. 120.

[xvi] Chris Patten, cited in John Flowerdew, Critical Discourse Analysis in Historiography: The Case of Hong Kong’s Evolving Political Identity, (Palgrave Macmillan, 2012) p. 57.

[xvii] J. Flowerdew, Critical Discourse Analysis in Historiography, 2012, p. 43.

[xviii] Sino-British Joint Declaration on the Question of Hong Kong, paragraph 3(5), 1984.

[xix] Ming K. Chan ‘The Legacy of the British Administration of Hong Kong: A view from Hong Kong’, The China Quarterly, No. 151 (September 1997), p. 567.

[xx] A. Ku, ‘Immigration Policies, Discourses, and the Politics of Local Belonging in Hong Kong,’ 2004a.

[xxi] R. Klein, ‘The Empire Strikes Back’, 1997, p. 2.

[xxii] Ordinance No. 3 of 1888, part VII, paragraph 51, cited in R. Klein, 1997, p. 3.

[xxiii] Ordinance No. 8 of 1920, paragraph 3(c), cited in R. Klein, 1997, p. 3.

[xxiv] Expulsion of Undesirables Ordinance, Laws of Hong Kong, chapter 242, paragraph 4(f), cited in R. Klein, 1997, p. 12.

[xxv] Peace Preservation Ordinance, Ordinance no. 10 of 1886, Part II, section 9(3), (emphasis added), http://oelawhk.lib.hku.hk/items/show/623

[xxvi] R. Klein, 1997, p. 30

[xxvii] Emergency Courts Regulations 1967, Hong Kong Government’s Gazette, Legal Supp. No. 2, chapter 241, paragraph 3, 4, 23 May 1967, cited in R. Klein, 1997, p. 40.

[xxviii] Emergency Regulations Ordinance, paragraph 2(1), cited in R. Klein, 1997, p. 42.

[xxix] Yash Ghai, ‘The Political Economy of Interpretation’, in Hualing Fu, Lison Harris, and Simon N. M. Young (eds.) Interpreting Hong Kong’s Basic Law: The Struggle for Coherence (Palgrave Macmillan US, 2007), p. 128

[xxx] Sonny Shiu-Hing Lo, Hong Kong’s Indigenous Democracy: Origins, Evolution and Contentions (Palgrave Macmillan, 2015), p. 75.

[xxxi] Basic Law, Chapter VIII, Article 158 (emphasis added). Accessible: http://www.basiclaw.gov.hk/en/basiclawtext/chapter_8.html

[xxxii] Y. Ghai, ‘The Political Economy of Interpretation’, 2007, p. 132.

[xxxiii] Tung Chee-hwa, 1997, cited in J. Flowerdew, ‘Identity politics and Hong Kong’s return to Chinese sovereignty’, 2004, p. 1570 (emphasis added).

[xxxiv] Tung C. H., 2001, cited in J. Flowerdew, 2004, p. 1557 (emphasis added).

[xxxv] Meetings of the Legislative Council of Hong Kong, 1925, emphasis added

[xxxvi] Article 45, Section 1, Chapter IV: Political Structure, The Basic Law of the Hong Kong Special Administrative region of the People’s Republic of China Law, http://www.basiclaw.gov.hk/en/basiclawtext/chapter_4.html

[xxxvii] Chi-chun Lai, ‘Goodstadt in HK to support “Occupy Central,” signaling interference,’ China Daily, 22 March 2013, http://epaper.chinadailyasia.com/focus-hk/article-157.html

[xxxviii] ‘Street Movement ruins Hong Kong image,’ Global Times, 29 September 2014, http://www.globaltimes.cn/content/884080.shtml

[xxxix] ‘Occupy leaders are arrested and charged,’ South China Morning Post, 28 March 2017, http://www.scmp.com/video/hong-kong/2082690/occupy-leaders-are-arrested-and-charged

[xl] Jasmin Siu and Eddie Lee, ‘Outrage at two-year prison terms for Hong Kong policemen who beat up political activist,’ South China Morning Post, 17 February 2017, http://www.scmp.com/news/hong-kong/law-crime/article/2071703/two-years-jail-seven-policemen-who-beat-occupy-activist-ken

[xli] Thomas Chan and Joyce Ng, ‘Lawyers say Occupy protests are undermining Hong Kong’s rule of law,’ South China Morning Post, 3 November 2014, http://www.scmp.com/news/hong-kong/article/1631147/lawyers-say-occupy-protests-are-undermining-hong-kongs-rule-law

[xlii] Michael Davis, ‘Occupy protests breaking the law, but not undermining Hong Kong’s rule of law,’ South China Morning Post, 7 November 2014, http://www.scmp.com/comment/insight-opinion/article/1634329/occupy-protests-breaking-law-not-undermining-hong-kongs-rule

[xliii] ‘Hong Kong activists on trial for pioneering the ‘Umbrella’ protests’, BBC News, 19 November 2018, https://www.bbc.com/news/world-asia-china-46257578