Carrington Calder, Associate Member, Immigration & Human Rights Law Review
I. Introduction
Hong Kong has operated under the “one country, two systems” policy since 1997, which guarantees greater freedoms and human rights for Hong Kong than those in the People’s Republic of China (PRC).[1] At the core of these freedoms are the right to expression and assembly, guaranteed by the 1985 Sino-British Joint Declaration, which set the terms of Hong Kong’s handover from the United Kingdom (U.K.) and is valid until 2047.[2] However, Hong Kong has witnessed these rights diminished as a result of Chinese incursion beginning in 2014—well before the Joint Declaration’s expiration date.[3] Most recently, in March 2024, the Hong Kong Legislative Council unanimously enacted Article 23, a national security ordinance that further restricts the freedoms of Hong Kong citizens and has been demonstrated by a crackdown on political dissonance.[4]
This blog argues that the PRC’s policies towards Hong Kong including Article 23 violate Hong Kong’s traditional sovereignty under the Joint Declaration and protections for human rights under the International Covenant on Civil and Political Rights (ICCPR).[5] Part II provides background on the beginning of the “one country, two systems” policy and details the PRC’s restrictions imposed upon Hong Kong.[6] Part III discusses the PRC’s policies and how they violate the 1997 handover agreement and several provisions of the ICCPR. Part IV concludes by advocating the need for continued vigilance by the United Nations (U.N.).
II. Background
A. Turnover from British Rule in 1997
Hong Kong became a British territory in 1842 under the Treaty of Nanjing.[7] British control was later extended over the territory through an unconventional 99-year lease with China in 1898.[8] The expiration of this lease prompted the Sino-British Joint Declaration in 1985.[9] The Joint Declaration ceded Hong Kong to China while restricting China’s control over the territory until 2047.[10] By that time, China anticipated that Hong Kong would voluntarily integrate into the PRC.[11] The Joint Declaration led to the “one country, two systems” policy and promised to preserve Hong Kong’s traditional freedoms and autonomy of its judicial, legislative, and executive branches.[12] Specifically, the agreement guaranteed the freedoms of speech, press, assembly, and association.[13] This treaty was registered with the U.N. and is legally binding upon the PRC.[14]
B. Incursion by the P.R.C.
In 2019, large-scale protests erupted in Hong Kong in response to an extradition bill named the Fugitive Offenders and Mutual Legal Assistance in Criminal Matters Legislation.[15] Protestors feared that the legislation would enable the PRC to extradite and punish Hong Kong citizens.[16] The bill was introduced by Hong Kong Chief Executive Carrie Lam, who was elected by a committee largely composed of PRC loyalists.[17] This led to accusations that the bill aligned with the PRC’s agenda.[18] The protests, the largest in Hong Kong’s history, initially succeeded in achieving their goals.[19] The extradition bill was withdrawn and pro-democracy candidates experienced a landslide victory in the 2019 district council elections.[20]
However, in 2020, the National People’s Congress (NPC) of China retaliated by enacting a new security law that bypassed Hong Kong’s legislative council.[21] This was made possible due to the mechanisms of Article 18 and Annex III of Hong Kong’s Basic Law.[22] Article 18 states that PRC national laws shall not be in effect in Hong Kong except for those listed in Annex III.[23] However, the NPC Standing Committee, after consulting the Hong Kong Basic Law Committee, has the authority to determine what laws are included in Annex III.[24] The NPC adopted the measure with 2,878 votes in favor and just one against with no resistance from the Hong Kong Basic Law Committee.[25]
The new law established the Office for Safeguarding National Security, a NPC enforcement presence in Hong Kong.[26] The official intentions of the law was to prevent subversive and terrorist activities.[27] Lam praised it as a solution to the “social unrest which has troubled Hong Kong people for nearly a year.”[28] Those charged under the law could be denied due process as any proceeding would be allowed to take place behind closed doors.[29]
In 2024, under pressure from the PRC, Hong Kong enacted their own version of the national security law, which has drawn international attention due to recent arrests.[30] The law criminalizes “endangering national security” and names nine types of offenses including treason, insurrection, espionage, sabotage, external interference, secession, subversion, terrorist activities, and collusion with foreign powers.[31]
III. Discussion
The PRC has infringed upon Hong Kong’s rights in contravention of the Joint Declaration and the provisions of the ICCPR through (A) election interference, (B) censorship and other limitations on political rights, and this has resulted in (C) condemnation from foreign bodies.
A. Election Interference
The Joint Declaration established that the PRC has authority over Hong Kong while also promising Hong Kong a “high degree of autonomy,” except in matters of foreign affairs and defense.[32] Despite being a legally binding treaty registered with U.N., the Joint Declaration has been continuously disregarded by the PRC.[33] The Joint Declaration requires that the Hong Kong Chief Executive be appointed “on the basis of the results of elections or consultations to be held locally.”[34] Article 25 of the ICCPR also guarantees the right of every citizen “[t]o take part in the conduct of public affairs, directly or through freely chosen representatives.”[35]
The ICCPR is an international treaty promulgated by the U.N. that sets a benchmark for human rights.[36] China has signed the treaty but not ratified it.[37] However, the PRC agreed that the treaty still applies to Hong Kong in accordance with the Joint Declaration.[38] Both of these provisions are intended to ensure that citizens can participate in their own democracies to adequately provide redress for any harms.[39] However, evidence demonstrates that the PRC has hijacked the democratic process in Hong Kong.[40] Without the ability to fully participate in elections, Hong Kong citizens’ ability to change the status quo will remain limited.[41]
According to members of the election committee, during the 2017 Hong Kong Chief Executive election, a PRC advisor notified electors that China “would not approve the winner of the March 26 election if it deemed him or her unacceptable.”[42] The election resulted in the victory of pro-China candidate Carrie Lam.[43] Once elected, Lam banned the Hong Kong pro-Independence National Party, declaring it a threat to national security.[44] Lam also pledged her support for the 2020 national security bill.[45] Her belief that the law would help address recent “social unrest” was an implicit reference to the pro-Democratic protests.[46] Lam further remarked that some human rights were “not absolute” in the context of the new security law.[47]
Hong Kong citizens protested the incursions into Hong Kong elections by holding an unofficial primary election in 2020 that garnered 600,000 votes in the city of seven and a half million.[48] However, the authorities jailed forty-five of the election organizers under the 2020 national security law for subversion with one organizer receiving a ten-year prison sentence.[49]
During Lam’s term in office, the NPC added additional regulations for Hong Kong elections.[50] The alterations included a vetting system to ensure that any potential political candidates would respect the dictates of the national security law among other statutes.[51] One NPC party official stated that the power to administer laws should lie in the hands of “patriots” only.[52]
To counteract pro-democracy parties’ victories in the 2019 elections, the NPC responded by removing district council representative seats from the election committee, thus eliminating their ability to vote in the chief executive elections.[53] The number of individuals able to vote in choosing election committee members was severely reduced going from 257,992 in 2020 to 7,971 in 2021.[54] Voting sections made of longtime pro-democratic supporters, such as education and legal, suffered the most from the reduction in votes.[55] Hong Kong citizens responded to the changes in 2021 by holding a boycott of the election.[56] However, authorities arrested some individuals who advocated publicly for the boycott.[57] Due to these alterations, 2022 saw the election of pro-China candidate John Lee, who ran uncontested for chief executive in 2022.[58]
Policy decisions by the PRC that limit the political agency of Hong Kong citizens suggest that they have not afforded Hong Kong its “high degree of autonomy” as guaranteed under the Joint Declaration.[59] Chinese foreign ministry officials have stated that the treaty’s guarantees are “now history.”[60] These policies also violate Article 25 of the ICCPR, by removing the possibility of voting for any pro-democratic candidates, Hong Kong citizens lack the right to “freely” choose their representatives.[61] The NPC hid behind the guise of national security while it arrested and jailed political opposition and formed a culture of fear around political participation in Hong Kong.[62] By depriving Hong Kong citizens of representation that supports their interests, the PRC has curtailed their ability to apply for redress for human rights violations. [63]
B. Censorship
The new national security law demonstrates a broad definition of what constitutes “criminal offenses” against national security.[64] The first recorded arrests were of six individuals for social media posts referring to the Tiananmen Square massacre.[65] The Tiananmen Square massacre is one of the most heavily censored topics in China because it involves the killing of hundreds of student protestors by PRC troops on June 4, 1989.[66] Chow Hang-tung, one of the activists arrested, played a leading role in organizing a candlelight vigil to commemorate the anniversary.[67] Authorities charged Hang-tung and others with inciting subversion under the national security law.[68]
Hang-tung’s detainment implicates Articles 19 and 21 of the ICCPR, which guarantee the right to freedom of expression and the right to peaceful assembly.[69] Hang-tung’s conviction states that her crime was inciting others to take part in an “unauthorized assembly.”[70] The right to peaceful assembly under Article 21 of the ICCPR “protects the ability of people to exercise individual autonomy in solidarity with others.”[71] The U.N. explains that peaceful and political assemblies should be given the utmost protection and that any restrictions must be “content neutral.”[72] The PRC’s retaliation against Chow Hang-tung does not accord with these sentiments. Her arrest demonstrates a blanket restriction against organized protests that refer to the Tiananmen Square massacre.[73] Such a restriction is not “content neutral” meaning that the expression is repressed based on what is being said rather than how it is being said.[74]
Statements such as “[l]iberate Hong Kong, [the] revolution of our times,” have been met with significant prison sentences, with one individual receiving a year and two months.[75] Girls as young as fifteen have been arrested for possessing flags advocating Hong Kong’s independence.[76] Such arrests demonstrate that citizens have been targeted for political dissent under the pretext of protecting national security.[77] U.N. general comments on Article 21 of the ICCPR state that “[g]enerally, the use of flags, uniforms, signs and banners is to be regarded as a legitimate form of expression that should not be restricted, even if such symbols are reminders of a painful past.”[78] The U.N. general comment provides explanation on what conduct is prohibited to accord with the ICCPR.[79] The examples given prove that the PRC has disregarded its requirements.[80]
Further violating the right to free expression under the ICCPR, large media companies have been targets of the PRC.[81] Apple Daily, a pro-democracy newspaper, did not survive the PRC’s 2020 round of repression.[82] The company founder, Jimmy Lai, was arrested under the 2020 national security law and charged with conspiracy to commit collusion with foreign countries and external forces, along with sedition.[83] Lai has been held in solitary confinement since then.[84] Such detainments might intimidate others from exercising free speech thereby violating Article 9 of the ICCPR, which prohibits arbitrary arrest or detention.[85]
The repression of news organizations has resulted in a chilling of free speech. Press organizations have canceled annual human rights awards for fear of government retaliation.[86] Without freedom of the press, accurate reporting of Hong Kong’s situation becomes precarious, allowing human rights abuses to be hidden from view.[87] Under Article 19 of ICCPR, there are no permitted exceptions or restrictions to the freedom to hold opinions without interference.[88]
News organizations are not the only media hit with government censorship under the PRC. Books and movies have also suffered repression in Hong Kong.[89] Authorities censored pro-democratic books written by Hong Kong activists such as Joshua Wong. Wong stated that the national security law prompted their removal from libraries.[90] Documentaries such as Inside the Red Brick Wall, which depicts the 2019 Hong Kong protests have also been met with censorship.[91] Despite not being officially banned, theaters refused to screen Inside the Red Brick Wall due to fears of violating the national security law.[92] Other documentaries, such as Revolution of Our Times state in the documentary’s trailer that the film cannot be shown in Hong Kong.[93] The national security law allows for the restriction of these films, with the PRC stating that they will censor “any act or activity which may amount to an offence endangering national security.”[94]
The national security law also targets charitable organizations.[95] The 612 Humanitarian Relief Fund was an organization that provided medical and legal assistance to anti-government protestors.[96] In 2021, authorities used the national security law to demand operational information from the Fund.[97] After facing accusations of working for foreign agents and concerns of possible retaliation against donors, the fund decided to cease operations.[98] Such policies create a climate of fear for Non-Governmental Organizations (NGOs) and other charities, severely limiting their ability to operate in Hong Kong.[99] This chilling effect risks limiting international organizations from providing aid to Hong Kong citizens.[100] Without assistance from NGOs, human rights issues may be exacerbated under the NPC’s regime.[101]
C. Condemnation
Foreign nations have condemned the PRC’s actions in Hong Kong including the United States and the United Kingdom, as well as international bodies such as the U.N.[102] The PRC has met these condemnations with an intensely nationalistic stance.[103] For instance, the Chinese ambassador to the United Kingdom stated that the United Kingdom “should seriously reflect on the consequences of its words and deeds” after the country reminded China of its obligations under the Sino-British Joint Declaration.[104] Such rhetoric not only indicates that the PRC is unlikely to change its policies in the near future, but also hurts the potential for civil discourse on the topic with foreign powers.[105]
The ICCPR enshrines the right to liberty, due process, freedom from arbitrary interference, and freedom of speech, association, and assembly.[106] For its disregard of these human rights, the PRC justifiably deserves condemnation by the U.N. and continued sanctions by foreign nations.[107] International pressure should be applied to the PRC to help alleviate the plight of Hong Kong citizens.[108] The status of Hong Kong must continue to be monitored to ensure prompt responses from international organizations such as the U.N.[109]
IV. Conclusion
By law, Hong Kong is entitled to its autonomy and the freedoms associated with it.[110] However, in practice, the citizens of Hong Kong have witnessed their rights dissipate under the control of the PRC.[111] Since the institution of the one country, two systems policy, Hong Kong has experienced a precipitous decline in its ability for self-governance.[112] Through the PRC’s control of Hong Kong elections, Hong Kong citizens lack agency in their governance.[113] Without this agency the interests of Hong Kong citizens will not be adequately represented.[114] While in control of Hong Kong’s governance, the PRC has enforced a policy of censorship and repression.[115] For these actions the PRC should be condemned for their disregard of human rights in Hong Kong. The U.N. and foreign nations should continue to hold the PRC accountable for its violation of the Sino-British Joint Declaration and human rights violations under the ICCPR.[116]
[1] William H. Overholt, The Rise and Fall of “One Country, Two Systems”, Harv. Kennedy Sch. (2019), https://ash.harvard.edu/wp-content/uploads/2024/02/overholt_hong_kong_paper_final.pdf [https://perma.cc/3G6B-URV3].
[2] Tony Cheung, Too Soon to Talk About 2047? Legal Experts Split on When Hong Kong Should Debate its Future, S. China Morning Post (May 10, 2016, 6:36 PM), https://www.scmp.com/news/hong-kong/politics/article/1943075/too-soon-talk-about-2047-legal-experts-split-when-hong-kong [https://perma.cc/5YD8-TTA5].
[3] Hong Kong Hits ‘Pause’ on China Extradition Bill in an Attempt to Restore Calm, Nat’l Post (June 15, 2019), https://plus.lexis.com/api/permalink/5525dc3f-87af-4f39-bce6-4cf84e9c96a8/?context=1530671.
[4] Hong Kong: Arrests Under New National Security Law a ‘Shameful Attempt’ at Suppressing Peaceful Commemoration of Tiananmen Crackdown, Amnesty Int’l (May 28, 2024), https://www.amnesty.org/en/latest/news/2024/05/hong-kong-arrests-under-new-national-security-law-a-shameful-attempt-at-suppressing-peaceful-commemoration-of-tiananmen-crackdown/ [https://perma.cc/6QJ3-KDYP].
[5] Louisa Brooke-Holland, Hong Kong: The Joint Declaration, House of Commons Libr. (July 5, 2019), https://researchbriefings.files.parliament.uk/documents/CBP-8616/CBP-8616.pdf [https://perma.cc/8FN5-GQUF]; Xianggang Jiben Fa art. 39 (H.K.).
[6] Overholt, supra note 1.
[7] Treaty of Nanjing, Britannica, https://www.britannica.com/event/Treaty-of-Nanjing [https://perma.cc/VY9N-EQHP]. (last visited Jan. 16, 2025).
[8] Convention Respecting an Extension of Hong Kong Territory, The Am. J. of Int’l L. (Oct. 1910), https://www.jstor.org/stable/2212073 [https://perma.cc/M7T4-444Y].
[9] Overholt, supra note 1.
[10] Holland, supra note 5.
[11] Id.
[12] Id. However, this was not the first attempt to implement the “one country, two systems” model, as it was used in earlier attempts to annex Taiwan.
[13] Joint Declaration of the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the People’s Republic of China on the Question of Hong Kong, U.K.-China, art. 13, Dec. 19, 1984.
[14] Holland, supra note 5.
[15] Nat’l Post, supra note 3.
[16] Id.
[17] Id.
[18] Id.
[19] T.Y. Wang, Hong Kong and the 2019 Anti-Extradition Bill Movement, 58 J. Asian & Afr. Stud. 3, 3-7 (2023), https://doi.org/10.1177/00219096221124983 [https://perma.cc/7N32-Q6Q7].
[20] James Griffiths et al., Landslide Victory for Hong Kong Pro-Democracy Parties in De Facto Protest Referendum, CNN (Nov. 25, 2019, 6:05 AM EST), https://www.cnn.com/2019/11/24/asia/hong-kong-district-council-elections-intl/index.html [https://perma.cc/V96U-JMJE].
[21] Dang Yuan, Hong Kong Security Law: What Does China Want? DW (June 8, 2020), https://www.dw.com/en/hong-kong-security-law-what-does-china-really-intend/a-53735706 [https://perma.cc/UWB9-YBHC].
[22] Xianggang Jiben Fa art. 38 (H.K.).
[23] Id.
[24] Id.
[25] Yuan, supra note 21.
[26] Helen Regan, China Passes Sweeping Hong Kong National Security Law, CNN (June 30, 2020, 4:25 PM EDT), https://www.cnn.com/2020/06/29/china/hong-kong-national-security-law-passed-intl-hnk/index.html [https://perma.cc/CZ2Q-SCCC].
[27] Id.
[28] Id.
[29] Yuan, supra note 21.
[30] Amnesty Int’l, supra note 4.
[31] Hong Kong Adopts New National Security Ordinance: Article 23, Cong. Rsch. Serv. (Apr. 1, 2024), https://crsreports.congress.gov/product/pdf/IN/IN12341 [https://perma.cc/8BU4-6G6V].
[32] Brooke-Holland, supra note 5.
[33] Id.
[34] Id.
[35] U.N. General Assembly, International Covenant on Civil and Political Rights, United Nations, vol. 999, p. 171, (Dec. 16, 1966), https://www.refworld.org/legal/agreements/unga/1966/en/17703. [https://perma.cc/W9NH-M7LM].
[36] Id.
[37] UN Treaty Bodies and China, Hum. Rts. in China, https://www.hrichina.org/en/un-treaty-bodies-and-china#:~:text=Although%20China%20signed%20on%20to,specific%20provisions%20of%20the%20ICCPR. [https://perma.cc/Y3V2-ZF4P]. (last visited Jan. 16, 2025).
[38] Joint Declaration of the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the People’s Republic of China on the Question of Hong Kong, U.K.-China, art. 8, Dec. 19, 1984.
[39] UN Treaty Bodies and China, Human Rights in China, https://www.hrichina.org/en/un-treaty-bodies-and-china#:~:text=Although%20China%20signed%20on%20to,specific%20provisions%20of%20the%20ICCPR. [https://perma.cc/Y3V2-ZF4P]. (last visited Jan. 17, 2024).
[40] Joyce Ng and Jasmine Siu, Fairness of Hong Kong Chief Executive Poll Under Threat From Ex-Leaders Comments, Lawyers Say, South China Morning Post (Feb. 23, 2017), https://plus.lexis.com/api/permalink/b90be56b-e282-4c9f-84ae-fc8011df43a7/?context=1530671.
[41] Id.
[42] Id.
[43] Timeline: The Life and Career of Hong Kong Leader Carrie Lam, AP News (Apr. 4, 2022, 8:54 AM EST), https://apnews.com/article/hong-kong-government-carrie-lam-china-hong-kong-13fe19beb32152979f9523a33fd07ae0 [https://perma.cc/3YU4-LDM8].
[44] Alvin Lum, Hong Kong National Party Founders Lodge Separate Appeals Against Ban in Effort to Avoid Further Legal Action, S. China Morning Post (Oct. 24, 2018), https://plus.lexis.com/api/permalink/cf736d82-85a4-405b-bb3e-690ccf995aa6/?context=1530671.
[45] Regan, supra note 26.
[46] The Hong Kong Protests Explained in 100 and 500 Words, BBC (Nov. 27, 2019), https://www.bbc.com/news/world-asia-china-49317695 [https://perma.cc/ES2Y-Z777].
[47] Helen Davidson & Lily Kuo, Hong Kong: Hundreds Arrested as Security Law Comes into Effect, The Guardian (July 1, 2020, 8:44 EDT), https://www.theguardian.com/world/2020/jul/01/hong-kong-protesters-arrested-as-security-law-comes-into-effect [https://perma.cc/FAR5-U6VC].
[48] Jennifer Jett, 45 Hong Kong Pro-Democracy Activists Are Sentenced to Jail in City’s Biggest National Security Trial, NBC News (Nov. 19, 2024, 3:43 AM EST), https://www.nbcnews.com/news/world/hong-kong-47-democracy-activists-sentenced-national-security-rcna180290 [https://perma.cc/8KH3-7QR3].
[49] Id.
[50] Kelly Ho, Beijing Approves Resolution to Overhaul Hong Kong’s Elections – Candidates to be Vetted, H.K. Free Press (last updated Mar. 15, 2021, 20:25), https://hongkongfp.com/2021/03/11/breaking-beijing-approves-resolution-to-impose-electoral-overhaul-on-hong-kong/ [https://perma.cc/GT8V-FZMN].
[51] Id.
[52] Id.
[53] Candice Chau, Explainer: Hong Kong’s Election Committee Determines Who Leads the City – What Is It and How Does It Work,? H.K. Free Press (last updated May 8, 2022, 15:25), https://hongkongfp.com/2022/05/07/explainer-hong-kongs-election-committee-determines-who-leads-the-city-what-is-it-and-how-does-it-work/ [https://perma.cc/BBV4-CEGQ].
[54] Id.
[55] Id.
[56] Erin Hale, Hong Kong gears up for ‘patriots-only’ poll amid boycott calls, Al Jazeera (Dec. 15, 2021), https://www.aljazeera.com/news/2021/12/15/hong-kong-cracks-down-on-boycott-calls-ahead-of-legislative-vote [https://perma.cc/9YJN-N6WQ].
[57] Id.
[58] Chau, supra note 53.
[59] Brooke-Holland, supra note 5.
[60] Id.
[61] International Covenant on Civil and Political Rights, Dec. 16, 1966, 999 U.N.T.S. 171 [hereinafter ICCPR].
[62] Jett, supra note 48.
[63] Id.
[64] Cong. Rsch. Serv., supra note 31.
[65] Amnesty Int’l, supra note 4.
[66] Tiananmen Square Incident, Brittanica (Sept. 23, 2024), https://www.britannica.com/event/Tiananmen-Square-incident [https://perma.cc/J5JE-YJ8S].
[67] Hong Kong: Overturning of Chow Hang-Tung Tiananmen Acquittal Another Blow to Rule of Law, Amnesty Int’l (Jan. 25, 2024), https://www.amnesty.org/en/latest/news/2024/01/hong-kong-overturning-of-chow-hang-tung-tiananmen-acquittal-another-blow-to-rule-of-law/ [https://perma.cc/ZQT8-MDVZ].
[68] Id.
[69] ICCPR, supra note 61.
[70] Amnesty Int’l, supra note 67.
[71] Hum. Rts. Comm., General Comment No. 37 (2020) on the Right of Peaceful Assembly (Art. 21), U.N. Doc. CCPR/C/GC/37 (Sept. 17, 2020). https://documents.un.org/doc/undoc/gen/g20/232/15/pdf/g2023215.pdf. [https://perma.cc/84B8-WCSH].
[72] Id.
[73] Id.
[74] Id.
[75] James Lee, 1 year, 2 Months Jail for First Person Convicted Under Hong Kong’s New Security Law for ‘Seditious’ T-Shirt, H.K. Free Press (Sept. 19, 2024, 3:03 PM EST), https://hongkongfp.com/2024/09/19/breaking-1-year-2-months-jail-for-first-person-convicted-under-hong-kongs-new-security-law/ [https://perma.cc/9S28-AA7U].
[76] Helen Davidson & Lily Kuo, supra note 47.
[77] Id.
[78] Comm. No. 37 (2020) on the Right of Peaceful Assembly (article 21), U.N. Doc. CCPR/C/GC/37 (2020).
[79] Id.
[80] Id.
[81] Sum Lok-kei, A Year on from Apple Daily’s Closure, What’s Left of Hong Kong’s Free Press?, The Guardian (June 24, 2022, 1:01 PM EDT), https://www.theguardian.com/global-development/2022/jun/24/year-on-from-pro-democracy-apple-daily-closure-whats-left-of-hong-kongs-free-press [https://perma.cc/TQJ4-KJHV].
[82] Id.
[83] Id.
[84] Sven Hanson, Publisher Jimmy Lai Sentenced Again, Taz (Aug. 13, 2024, 7:18 AM), https://taz.de/Demokratieaktivist-in-Hongkong/!6026813/ [https://perma.cc/957N-6KJU].
[85] ICCPR, supra note 60.
[86] Helen Davidson, Hong Kong’s Human Rights Press Awards Scrapped Over Security Law Fears, The Guardian (Apr. 25, 2022), https://www.theguardian.com/world/2022/apr/25/hong-kong-human-rights-press-awards-foreign-correspondents-club-scrapped-security-law-fears [https://perma.cc/Q5M6-SPSC].
[87] Id.
[88] Comm. No. 34 Article 19: Freedoms of Opinion and Expression, 102nd Sess. (2011).
[89] Holmes Chan, Children’s Books With LGBTQ Themes Disappear From Shelves at Hong Kong Libraries Amid Pressure From Anti-Gay Group, H.K. Free Press (Mar. 31, 2020, 22:04), https://hongkongfp.com/2018/06/20/childrens-books-lgbtq-themes-disappear-shelves-hong-kong-libraries-amid-pressure-anti-gay-group/ [https://perma.cc/8YFR-PQCL].
[90] Democracy Books Disappear From Hong Kong Libraries, Including Title by Activist Joshua Wong, H.K. Free Press (July 4, 2020, 21:00), https://hongkongfp.com/2020/07/04/democracy-books-disappear-from-hong-kong-libraries-including-title-by-activist-joshua-wong/ [https://perma.cc/S6W3-RNUS].
[91] Vivienne Chow, Film Censorship in Hong Kong, Bundeszentrale Für Politische Bildung [Fed. Ctr. for Pol. Educ.] (Jan. 2, 2024), https://www.bpb.de/lernen/filmbildung/hongkongkino/541761/film-censorship-in-hong-kong/ [https://perma.cc/CPQ7-T3FR].
[92] Id.
[93] Id.
[94] Jessie Pang, Hong Kong to Censor Films Under National Security Law, Reuters (June 11, 2021, 6:23 AM EDT), https://www.reuters.com/world/asia-pacific/hong-kong-censor-films-under-national-security-law-2021-06-11/ [https://perma.cc/HT4Z-N4GU].
[95] Irene Chan, Hong Kong National Security Police Arrest 2 in Connection with Protester Relief Fund, H.K. Free Press (Aug. 29, 2023, 17:32), https://hongkongfp.com/2023/08/29/hong-kong-national-security-police-arrest-2-in-connection-with-protester-relief-fund/ [https://perma.cc/RB3Q-TAKV].
[96] Chris Lua, Hong Kong National Security Law: Protest Fund Facing Foreign Collusion Probe to Stop Taking Donations ‘Until Further Notice’, S. China Morning Post (Sept. 6, 2021), https://plus.lexis.com/api/permalink/84c5927d-fb60-4442-b97b-95396810bf6c/?context=1530671.
[97] Id.
[98] Id.
[99] Id.
[100] Id.
[101] Id.
[102] Hong Kong: Rushed Adoption of New Security Law a ‘Regressive Step’ – UN rights chief, United Nations (Mar. 19, 2024), https://news.un.org/en/story/2024/03/1147721 [https://perma.cc/FSM4-ZESA]; Congressional Rsch Serv., supra note 29; Brooke-Holland, supra note 5.
[103] Id.
[104] Id.
[105] Id.
[106] ICCPR, supra note 61.
[107] Cong. Rsch. Serv., supra note 31.
[108] Id.
[109] ICCPR, supra note 61.
[110] Brooke-Holland, supra note 5.
[111] Cong. Rsch. Serv., supra note 31.
[112] Amnesty Int’l, supra note 4.
[113] Ho, supra note 50.
[114] Id.
[115] Cong. Rsch. Serv., supra note 31.
[116] Brooke-Holland, supra note 5; ICCPR, supra note 61.
