K.K. & Winston Chu, Solicitors & Notaries

The Secretary for Lands and Works, Hong Kong.

2

8th January, 1986.

Road

(c)

Road Footbridge was not shown whereas the Tonnochy Road Footbridge annexing to our client's property was clearly shown. In reliance upon this representation and in anticipation that all pedestrian traffic from the southern side of Gloucester Road to the Wanchai Pier area would flow through the Sun Hung Kai Centre lot, our client acquired the property at a very high cost, expended a substantial amount of money in construction costs thereon and adopted a design of the building which encompassed shops on the Ground and First Floors and restaurants on 2nd Floor level with the Tonnochy Road Footbridge connecting directly to the 1st Floor of the Sun Hung Kai Centre. The proposed Stewart Road Footbridge will divert a significant portion of the pedestrian traffic flow from the Tonnochy Road Footbridge and would have the effect of reducing substantially the pedestrian traffic flow on the Tonnochy Road Footbridge and thereby adversely affecting the value of the said shops and restaurants of Sun Hung Kai Centre. In our view, this constitutes a derogation from the Grant of the aforesaid site to our client and a breach of contract on the part of the Government;

The erection of the footbridge also constitutes a material deviation from the draft Plan prepared by the Town Planning Board for the relevant area.

In the circumstances, the construction of the proposed Stewart Footbridge should not be proceeded with. Please note that if the work is not stopped immediately, our client will take such legal action as they may be advised without further notice.

discuss

Before resorting to litigation over this matter, we would suggest that an urgent meeting between yourself and our clients be held to this matter. We look forward to your prompt reply.

BC/al.

c.c. client.

Yours faithfully,

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