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and 3. Owners of sections or subsections which front only on

Shanghai Street.

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TO ADD WAR on heaztë noitamelosh or a data aber

Section 12 of the Ordinance limits the compensation payable in respect of injuries caused to our clients in two

ways. 1. By limiting it to injuries caused by reason of the access to the sea from their properties being interfered with and 2. By confining the right to recover even this limited amount of compensation to those owners of sections or sub-

sections whose property fronts upon Reclamation Street.

7.

It is quite obvious that the works under the Ordinance

do and will seriously affect the property of our clients in

many other ways besides interfering with their access to the

sea.

8.

The right of access to the sea is enjoyed by all the

owners of sections or subsections of the Marine Lots in

question whether fronting on Reclamation Street or on Shanghai Street in a greater or less degree and accordingly if it were not for the arbitary limitation of the right to compensation to owners whose sections or subsections front upon Reclamation

Street, the owners of sections or subsections fronting on

Shanghai Street would be entitled to compensation for such

injury as they could prove to have been inflicted upon them.

As it is they are entitled to no compensation at all even in

the case of an owner who could prove conclusively that his

business was entirely destroyed by the works under the

Ordinance.

9.

The Ordinance in the matter of dealing with the rights

of owners of property on Shanghai Street is inconsistent. For

as it stands, the owners of sections or subsections which run

right through from Reclamation Street to Shanghai Street can

recover compensation for the injury done to the whole of their

property including the portion fronting on Shanghai Street,

-2-

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