OBJECTION 3
K.K. & Winston Chu
Solicitors & Notaries
32/F United Centre 95 Queensway Hong Kong
Telephone: 5-295675 5-291316 5-291318
Cable Address "KAKIMSOL" Hongkong
Telex: HX63610 KKCHU
徐嘉檢師 5-292286
徐徐 嘉嘉 慎傖
律
*K.K. Chu LL. B. (London)
Winston K.S. Chu LL B (London)
徐嘉龑 律師
* Henry S.S. Liang
#
5-291729
5-291931
Benjamin P. Chang LL.B. (London)
an 5-291715
Jeff T.K. Tse LL. M. (London)
BTW mop 5-292095
Our Ref:
WC/1333/85
Assistant Solicitors
Your Ref:
Uriah C.T. Tse LL. B. (Hon.) PC.LL..
謝澤業律師 5-297167
The Secretary for Lands and Works,
Murray Building, 20th floor,
Garden Road,
Hong Kong.
Attention: Mr. Chan Nai Keong
Dear Sirs,
8th January, 1986.
師事務所
Признан
We
Re: Stewart Road Footbridge
have been consulted by Ying Ming Development Company Limited, the registered owner of Sun Hung Kai Centre, No.30 Harbour Rod (I.L.8389) in relation to the Footbridge proposal as shown on plan No.80111/RO/02.
!
In Our view, the Government's conduct in undertaking the the footbridge is both irregular and unlawful for the
construction of following reasons:-
(a) The proposed footbridge has never been shown on any draft plan prepared by the Town Planning Board in relation to the Hong Kong Planning Area No.5 Wanchai in which our client's property is situated. This omission is an indication of the fact that either the Government has chosen to by-pass the provisions of the Town Planning Ordinance or that there was a breach by the Town Planning Board
its duties under Section 3 of the Town Planning Ordinance. Whatever may be the reason for such failure to advertise the proposed footbridge has client of their right to lodge objections to footbridge under the Town Planning Ordinance and is inequitable in the circumstances.
of
omission, the deprived Our the proposed
(b) In the plan annexed to the Conditions of Grant under which Our client's property is held from the Crown, the proposed Stewart
to be cont'd 2/
港金錄道九十五號 統一中心三十二樓 電話:五、二九五六七五瓦,二九一三一六五,二九一三一八 電報掛號:“KAKI:SOL” Hongkong Jotary Public
TEANSERS: HX63610 KKCHU