believe that the events which have taken place during the passage

of time since 6th December 1985 have given to such passage of

time a quality or significance leading to the conclusion that any

proceedings or trial in Hong Kong will amount to prima

violations of the Bill in important

further

facie and irremediable

aspects

such that it would be unjust or oppressive to return me

to Hong Kong.

GUARANTEE TO TRIAL WITHOUT UNDUE DELAY UNDER THE BILL

11.

incarceration

on

During the 5 years and 7 months of my

remand since the said date of arrest, the Hong Kong government

has embarked upon a course of conduct in this case which has led

inexorably to my being denied the guarantee to a trial without

undue delay under the Bill.

following acts or omissions:-

Such course of conduct includes the

(1) The Hong Kong government has, during the lapse of the

said period of time, failed to collect any prosecution evidence

Malaysia, evidence upon which the Hong Kong government has

admitted it must rely to found the prosecution of the BMFL trial;

in

(2)

collected

government

evidence

has

In respect of prosecution evidence which has been

from the United States ("U.S."), the Hong Kong

adopted a defective procedure such that the

collected from the state of New York was ordered to

be

suppressed on 2nd July 1991 by a U.S. District Court with the

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