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desirable that such provision should not duplicate remedies in existing law. It is therefore undesirable to provide that such rights shall be actionable as torts. We propose a modification whereby action to enforce rights under the Bill would be worthwhile

only if remedies under existing law (eg law of defamation, false imprisonment) are inadequate. This provides for full implementation of the Covenant but encourages reliance on existing legislation in the first instance as regards third party rights.

Amendment to Letters Patent

13. At our suggestion, Hong Kong agreed in March that

"entrenchment" of the Bill of Rights should be achieved by amending

the Letters Patent to include a new article similar to Article 39 of

the Basic Law which would provide for constitutional guarantees in Hong Kong for the Bill of Rights up to 1997. This removed the need

for any entrenchment provision in the Bill of Rights itself which

might cause the Chinese to reject the Bill as inconsistent with the

provisions in the Basic Law for legislative voting on Bills and

motions.

14. Hong Kong have now proposed a wording for the amendment to the

Letters Patent. We are unhappy with it mainly because it does not

mirror Article 39 of the Basic Law. Our main concern is with the

Chinese attitude: we know they would rather see the Bill of Rights

scrapped. If the constitutional basis for it before 1997 is as

close as possible to that in the Basic Law, they will find this more

difficult to do. We have therefore suggested wording which follows more closely that of Article 39. This wording deliberately avoids the ambiguity to which Martin Lee refers (paragraph 16 of Hong Kong telno 1583). We think it more prudent to spell out our obligations

and what we interpret Article 39 of the Basic Law to mean rather

than reproduce the ambiguity and rely on the courts for clarity.

Freeze period

15. Hong Kong want to provide in the Bill for a "freeze period" of

two years during which the Bill of Rights would operate as regards

executive action but would not invalidate existing law. During this

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CONFIDENTIAL

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