Constitutionalism in Asia in the Early Twenty-First Century

(Greg DeLong) #1

but, on the contrary, contributed to it.
44
Not surprisingly, when the conservative


GNP returned to power after the 2007 presidential election and 2008


parliamentary election, even the first regulation on cross-ownership of media that


had survived constitutional review in 2006 was repealed by the revision of the


Newspapers Act in 2009 so that newspaper companies were able to own broad-


casting companies.


In the meantime, the KCC considered controversial cases of freedom of assem-


bly and demonstration, such as theNighttime Outdoor Assembly Prohibitioncase.


Article 10 of the Assembly and Demonstration Act used to prohibit outdoor assem-


bly across the country between sunset and sunrise unless the head of police granted


permission to hold assembly under certain conditions. On September 24 , 2009 , the


KCC reversed its previous position,^45 declaring that such regulation was incompat-


ible with the Constitution because, on the one hand, as the five majority reasoned,


such regulation could be seen as a de facto assembly-licensing system banned by


Article 21 ( 2 ) of the Constitution and, on the other, as the two concurring justices


recognized, it was excessive restriction on the freedom of assembly beyond


necessity.
46


The right to property


Article 23 of the Constitution provides that a general right to property is guaran-


teed according to the law prescribing the content and limit of such right.


The Roh Moo-hyun administration made efforts to solve the epidemic realty


speculation problem across the nation and regarded tax reform as an effective


means to control such a socioeconomic problem. The comprehensive real-estate


tax is a key policy tool introduced for such a purpose, targeting the owners of


houses in overheated speculative zones. Not surprisingly, those hit by the new tax


filed a constitutional complaint which lasted two years. One year after the 2007


presidential election that resulted in the victory of the opposition GNP candidate


Lee Myong-bak, who pledged to repeal the comprehensive real-estate tax, the


KCC invalidated a couple of key provisions of estate tax law. For example,


the provision imposing comprehensive real-estate taxes on housing was declared


not to conform to the Constitution as it violated property rights of a certain group


of taxpayers who “have held the housing for a certain period of time or who have


yet to retain for the set period but have low or de facto no taxpaying capacity due


to lack of specific properties or income other than the housing subject to


(^44) Constitutional Court Decision 2005 Hun-Ma 165 , June 29 , 2006 ,Korean Constitutional
Court Reports, Vol. 18 ,No 1 , Part 1 , 337.
(^45) Constitutional Court Decision 91 Hun-Ba 14 , April 28 , 1994 ,Korean Constitutional Court
Reports, Vol. 6 ,No 1 , 281 , 302.
(^46) Constitutional Court Decision 2008 Hun-Ka 25 , September 24 , 2009 ,Korean Constitutional
Court Reports, Vol. 21 ,No 2 , Part 1 , 427.


Upgrading constitutionalism 91

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