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meet the criticisme/beveled

"Justice"; to incorporate into the Ordinance

certain provisions of emergency legislation (see paragraph 1 above) and
to ameliorate certain other provisions of the Ordinance which had pre-

viously been taken from emergency legislation. The Bill goes a long way
towards achieving its

objects, but there are a few outstanding points for which, after
discussion with the Legal

Advisers, we consider that the Bill should

provide. These points were set out in our

Saving Despatch to Hong Kong No. 208 of 22 May, 1969, (copy attached),
to which we still await-a

reply.

Hong Kong Dept

October, 1969

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14.

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Type 1 +

From

Telephone No. & Ext.

Department

Noty No

STARY OF STATE

VISIT OF DEPUTY UNDER-SECRETARY OF

(SIR LESLIE MONSON,

TO HONG KONG, OCTOBER, 1969

EMERGENCY LEGISLATION AND THE

PUBLIC ORDER ORDINANCE

The background subjeck is oot out in the Annex-to

Suote.

Data Points to be raised

There are no matters calling for comment so far

as emergency legislation is concerned.

5

Matters now in issue are related to the Public

Order Ordinance and are confined to those raised in our

6 ਦ Saving Despatch No. 208 (see copy attached). (The point

dealt with in paragraph 2 of the Saving Despatch has

already been resolved since Lord Shepherd agreed, during

his visit to Hong Kong in June, to accept the Governor's views.) It is
likely that the Hong Kong authorities will

resist some, at least, of the remaining proposals in our

despatch. There is reason to believe that differences

of opinion have arisen between the Attorney General and

the Commissioner of Police on these points, the latter

being more likely to offer the stronger resistance. 14. A reply to our
Saving Despatch has now been out-

(during part of which the Attorney Gearch has been on me) standing for
more than four months and we are anxious

18 / an

that the amending Bill should become law as soon as possible, to avoid
renewed criticism of the legislation

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in Hong Kong and here in Parliament. We

recognise, however, that further consideration

may have been left in cuspense during the

Attorney General's absence on leave (he has

just retumed-te Hong Kong). In the cireuz-

stances we do not propose to press for a reply

The present time; but If a suitable opportu-

nity arises in Hong Kong, it might be asked

[receive a reply.)

when we may expect to t

27. Briefing material has not been supplied

for detailed discussion of the outstanding

points. In our view such discussions should

be avoided since much of the argument turns on

technical legal considerations and any counter-

arguments advanced by Hong Kong would have to

be carefully considered by Legal Advisers here.

Hong Kong Depor. Debus, 1969.

Mu

29

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14

11

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28

Note No. 7A

VISIT OF DEPUTY UNDER-SECRETARY OF STATE

(SIR LESLIE MONSON)

TO HONG KONG, OCTOBER, 1969

EMERGENCY LEGISLATION AND THE PUBLIC ORDER ORDINANCE

This Note, with the following attachments, are in amplification of Note
No. 7:-

2.

(a) A copy of the Public Order Ordinance 1967 (see

paragraph 2 of Note No. 7).

(b) A copy of the draft amending Bill (see paragraph

3 of Note No. 7)

(c) A copy of the Attorney General, Hong Kong's

comments on (b) (see references in Foreign and Commonwealth Office
Saving Despatch No. 208).

In paragraph 5 of Note No. 7 it is stated that the matters

now in issue are confined to those raised in our Saving

Despatch No. 208. The following arguments were adduced in

support of the comments contained in that Saving Despatch on

each of the individual matters concerned (references are to paragraphs
of the Saving Despatch):-

(a) Paragraph 3:

Section 7 of the Ordinance concerns the licensing of public meetings and
processions. "Justice" had commented

that the licensing system under this Section was inappropriate for
funeral gatherings; and that the period

of seven days which was required under this Section to elapse between an
application for a licence and the holding of the meeting was much too
long in the case of funerals. Clause 4 of the Bill accordingly amends
the Section by reducing the period of notice required from seven to two
days in the case of a funeral procession; the Clause also exempts
funeral meetings and meetings held for social purposes in a restaurant,
from the need to be licensed at all. These amendments represent a

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/ definite

Polic

Craustuves delay

48 hat

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definite amelioration of the provisions of the existing Section; but
there remains some doubt whether it would always be practicable to apply
for a licence to hold a funeral procession two days before such
procession; and it is considered that the Commissioner of Police's
powers under Section 7 (4) to refuse such a licence are too wide and in
some cases inappropriate in relation to funeral processions. The
Governor has accordingly been asked to give further consideration to
these aspects.

(b) Paragraph 4:

Section 11 (2) of the Ordinance confers on a police officer of or above
the rank of Inspector the power to prevent, stop or disperse public
processions or meetings if such are "in his opinion likely to cause or
lead to a breach of the peace". "Justice" objected to the words
underlined on the grounds that they conferred an absolute discretion on
the police which could not be challenged in the courts. Clause 6 of the
draft Bill is accordingly designed to remedy this situation by deleting
the words "in his opinion" and substituting the words "if he reasonably
believes that the same is" However, the Governor has asked if this
amendment may be dropped because the Commissioner of Police has argued
strongly that the test of reasonable belief would place a very heavy
burden on police officers when deciding whether a particular meeting
might reasonable be expected to lead to a breach of the peace. It is not
considered that the Commissioner's argument should be accepted because:-

(1) the principle involved in this amendment has already been accepted
by the Governor in

relation to a similar amendment to Section 3

of the Ordinance by Clause 3 of the draft

Bill;

(ii) the police officer concerned must be of or

above the rank of Inspector and therefore experienced enough to take
decisions of this

/ nature

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nature without undue difficulty;

(iii) the police officer has the backing of the

indemnity provided by Section 53 of the

Ordinance.

(c) Paragraph 5:

Section 12 (3) of the Ordinance makes it an offence if anyone "forms or
continues to form part of" any unlawful assembly. "Justice" criticised
the inclusion of these words on the grounds that they made it possible
for an innocent bystander, who had been caught up in an unlawful
assembly, to be guilty of an offence although he may have had no guilty
intent. Clause 7 (b) of the Bill amends Section 12 (3) of the Ordinance
by making it a defence for an accused person to show that he did not
know that it was an unlawful assembly. However, the proposed amendment
would not cover the case of an innocent person caught up in an unlawful
assembly and unable to escape from it because of pressure from the
crowd. The proposed amendment could therefore give cause for further
complaint from "Justice" who might claim that the substance of their
original criticism had clearly been accepted but that the measures taken
to deal with it were inadequate. Governor has accordingly been asked to
give further thought

to this matter.

(d) Paragraph 6:

The

"Justice" had suggested that the words "noisy, disorderly or
intimidating" might be added before "manner" in the second line of
Section 18 (1) of the Ordinance. We had originally suggested that it
would be preferable to refer to conduct in a "disorderly manner", on the
ground that the word "noisy" was too vague and might be caused by
cheerful spirits and not evil intent; and that "intimida- tion" is
covered by the word "disorderly". The Commissioner of Police has pointed
out that a group of persons could conduct themselves other than in a
dis-orderly manner and

yet ...

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yet still cause other people reasonably to fear a breach of the peace.
The suggestion in paragraph 6 of our Saving Despatch is intended as a
reasonable compromise and it is considered that the use of the phrase
"in a disorderly or intimidating manner" would meet the point.

(e) Paragraph 7:

Section 19 of the Ordinance provides that when any person taking part in
an unlawful assembly commits a breach of the peace, the assembly becomes
a riot and

all the persons assembled are guilty of riot. "Justice"

have pointed out that this seems a somewhat drastic

modification of common law under which only persons who are turbulent
can be guilty of riot and that under this Section a person could be
guilty without possessing any criminal intent. The difficulty here is a
practical

one: the police, when confronted with an unruly mob, order it to
disperse and those who remain must expect to be treated as active
participants; and if the police are forced to separate spectators from
participants when handling a riot there might be a dangerous hesitation
in dealing with a critical situation. The Governor therefore considers
that this particular Section should be allowed to stand as it is.
However, it is considered that the "unlawful assembly" referred to in
this Section should be confined to that defined in Section 18 (1) and
should not include the wider and less serious form of unlawful assembly
defined in Section 12 (2). Such an amendment would go some way towards
meeting the criticism of this

Section.

(f) Paragraph 8:

Section 37 of the Ordinance deals with permits to enter and leave a
closed area. "Justice" suggested that the

Section should be amended so as to require that reasonable notice should
be given in the event of the cancellation of any such permit. Clause 18
of the draft Bill makes such

/ an

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an amendment in respect of Section 31 (in relation to the cancellation
of permits issued to persons authorising them to be out of doors after
the imposition of a curfew) and we have accordingly suggested that a
similar provision should be made in relation to the cancellation of
permits

issued under Section 37.

I set in a meeting or Gitt. on 17/4/64 where

Counlock

paper containing setting out him

contrary crews of AG. Ponce on 5(7) and 5(4/2

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After ouplander the Police withdrew objections

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The amending bill was

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28 derder

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Hong Kong Department October, 1969

branch of Justes.

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(119281) Dd. 391599 1,500 2/69 H.

NOTHING TO BE WRITTEN IN THIS MARGIN

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SECURITY CLASSIFICATION

DRAFT

TODANIK

XXOOX

Confidential,

KUKEKIRKKI.

PRIVACY MARKING

In Confidence

To:-

12

CONFIDENTIAL

Spacup

Type 1 +

From

28

Telephone No. & Ext.

Department

Note No. 7A

7.10.69.

27

VISIT OF DEPUTY UNDER-SECRETARY OF STATE

SIR LESLIE MONSON

TO HONG KONG, OCTOBER. 1969

EMERGENCY LEGISLATION AND THE PUBLIC ORDER ORDINANCE

This Note, with the following attachments, are in

amplification of Note No. 7:-

(a) A copy of the Public Order Ordinance 1967 (see

paragraph 2 of Note No. 7).

(b) A copy of the draft amending Bill (see paragraph

3 of Note No.

7).

(c) A copy of the Attorney General, Hong Kong's

comments on (b) (see references in Foreign and

Commonwealth Office Saving Despatch No. 208).

2. In paragraph 5 of Note No. 7 it is stated that the

matters now in issue are confined to those raised in

our Saving Despatch No. 208. The following argumente

have been adduced in support of the comments contained

in that Saving Despatch on each of the individual

matters concerned (references are to paragraphs of

the Saving Despatch):-

(a)

Paragraph 3 j

Section 7 of the Ordinance concerns the licensing

of public meetings and processions. "Justice" had

commented that the licensing system under this Section

M

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was

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W{B}L, 51-7406

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was inappropriate for funeral gatherings; and

that the period of seven days which was required

under this Section to elapse between an applica-

tion for a licence and the holding of the meet-

ing was much too long in the case of funerals.

Clause 4 of the Bill accordingly amends the

Section by reducing the period of notice required

from seven to two days in the case of a funeral

procession: the Clause also exempts funeral

meetings and meetings held for social purposes

in a restaurant, from the need to be licensed

at all. These amendments represent a definite

amelioration of the provisions of the existing

Section; but there remains some doubt whether

it would always be practicable to apply for a

licence to hold a funeral procession two days

before such procession; and it is considered

that the Commissioner of Police's powers under

Section 7 (4) to refuse such a licence are too

wide and in some cases inappropriate in relation

to funeral processions. The Governor has

accordingly been asked to give further considera.

tion to these aspects.

(b)

Paragraph 4

Section 11 (2) of the Ordinance confers on

a police officer of or above the rank of

Inspector the power to prevent, stop or dis-

perse public processions or meetings if such are

"in his opinion likely to cause or lead to a

breach of the peace". "Justice" objected to

the words underlined on the grounds that they

conferred an absolute discretion on the police

which could not be challenged in the courts.

Clause 6 of the draft Bill is accordingly

designed to remedy this situation by deleting

/the

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the words "in his opinion" and substituting the

words "if he reasonably believes that the same

is". However, the Governor has asked if this

amendment may be dropped because the Commissioner

of Police has argued strongly that the test of

reasonable belief would place a very heavy burden

on police officers when deciding whether a parti-

cular meeting might reasonably be expected to

lead to a breach of the peace. It is not con-

sidered that the Commissioner's argument should

be accepted because:-

(1) the principle involved in this amendment

has already been accepted by the Governor

in relation to a similar amendment to

Section 3 of the Ordinance by Clause 3 of

the draft Bill;

(11) the police officer concerned must be of

Therefore

or above the rank of Inspector and experienced enough to take deacious
of this nature with and endure cbifficulting s (iii) the police officer
has the backing of the

indemnity provided by Section 53 of the

Ordinance.

(c) Paragraph 5 1

Section 12 (3) of the Ordinance makes it an

offence if anyone "forms or continues to form

part of any unlawful assembly. "Justice"

criticised the inclusion of these words on the

grounds that they made it possible for an inno-

cent bystander, who had been caught up in an

unlawful assembly, to be guilty of an offence

although he may have had no guilty intent. Clause 7 (b) of the Bill
amends Section 12 (3)

of the Ordinance by making it a defence for an

accused person to show that he did not know that

it was an unlawful assembly.

However, the pro-

posed amendment would not cover the case of an

/ innocent

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innocent person caught up in an unlawful assem-

bly unable to escape from it because of

pressure from the crowd. The proposed amendment

could therefore give cause for further complaint

from "Justice" who might claim that the substance

of their original criticism had clearly been

accepted but that the measures taken to deal

The Governor has

with it were inadequate.

accordingly been asked to give further thought

to this matter.

(d) Paragraph 6 *

"Justice" had suggested that the words

"noisy, disorderly or intimidating" might be

added before "manner" in the second line of

Ordinance

We

Section 18 (1) of the Bill. I had previously originally

been suggested that it would be preferable to

refer to conduct in a "disorderly manner" on

the ground that the word "noisy" was too vague

and might be caused by cheerful spirits and not

evil intent; and that "intimidation" is covered

by the word "disorderly". The Commissioner of

Police has pointed out that a group of persons

could conduct themselves other than in a dis-

orderly manner and yet still cause other people

reasonably to fear a breach of the peace. The

suggestion in paragraph 6 of our Saving Despatch

Cit is considered is intended as a reasonable compromise and] that

the use of the phrase "in a disorderly or inti-

midating manner" would meet the point. (e) Paragraph 7:

Section 19 of the Ordinance provides that

when any person taking part in an unlawful assembly commits a breach of
the peace, the assembly becomes a riot and all the persons

assembled are guilty of riot.

"Justice" have

/ pointed

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Hang Kang

Ditor,

DEAV

1969

pointed out that this seems a somewhat drastic

modification of common law under which only

persons who are turbulent can be guilty of riot

and that under this Section a person could be

guilty without possessing any criminal intent.

The difficulty here is a practical one: the

police, when confronted with an unruly mob,

order it to disperse and those who remaine

must expect to be treated as active participants;

and if the police are forced to separate specta-

tors from participants when handling a riot

there might be a dangerous hesitation in dealing

with a critical situation. The Governor there-

fore considers that this particular Section

should be allowed to stand as it is. However,

it is considered that the "unlawful assembly"

referred to in this Section should be confined

to that defined in Section 18 (1) and should not

include the wider and less serious form of unlaw-

ful assembly defined in Section 12 (2). Such an

amendment would go some way towards meeting the

criticism of this Section.

(f)

Paragraph 8;

Section 37 of the Ordinance deals with

permits to enter and leave a closed area.

"Justice" suggested that the Section should be

amended so as to require that reasonable notice

should be given in the event of the cancellation

of any such permit. Clause 18 of the draft Bill

makes such an amendment in respect of Section 31

(in relation to the cancellation of permits

authorises issued to persons to permit them to be out of

doors after the imposition of a curfew) and we

have accordingly suggested that a similar pro-

Alte can colletion the

vision should be made in relation to/permits

issued under Section 37.

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2600027

CS. 20A (Rev.)

SAVING DESPATCH

From the Governor, Hong Kong

297

To the Secretary of State for Foreign and Commonwealth Affairs

No.

1262

Repeated to:-

Repeated to:-

No.

No.

Date.....

November, 1969

My Reference........CR 3285/57

.II

Your Reference

Your saving despatch No. 208 of 22nd May, 1969.

Public Order Ordinance.

I enclose a copy of a revised draft of the Public Order (Amendment)
Bill. The revised draft takes into account the contents of your saving
despatch No. 208.

2.

The revised draft has been approved by the Executive Council,
subject to reconsideration in Executive Council if any substantial
points are raised by the Hong Kong Bar Association, the Law Society of
Hong Kong or the Hong Kong branch of "JUSTICE" to all of whom copies of
the Bill have been sent for comment.

AT:ek

encl.

RIVED IN

¦R. GISTRY No.51

20NOV 1969

HKK 14/15

CONT

LAST

22

FAL

Short title.

1

212

A BILL

To

Amend the Public Order Ordinance and to make consequential amendments

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