Constitutionalism in Asia in the Early Twenty-First Century

(Greg DeLong) #1

reputation of the Court of Final Appeal and the judiciary of Hong Kong. Independ-


ence of the judiciary is further buttressed by various systemic guarantees in the


Basic Law, including the system of appointment, promotion and removal of judges.


As discussed above, the first interpretation of the NPCSC posed one of the first


major challenges to the independence of the judiciary in Hong Kong. There were


concerns that a political organ could easily reverse the considered judgment of the


Court of Final Appeal. There were also concerns whether, as a result, a judge


would always have to look over his shoulder to take into account how his decision


would be received by the central government. InChong Fung Yuenv.Director of


Immigration, the court dispelled such concerns by emphasising the independent


judicial power and its exclusive role of interpreting the law, subject only to the limit


on the court’s jurisdiction.^24 It was held that these principles flow from the doctrine


of separation of powers; they are the basic principles of the common law that


have been preserved and maintained in Hong Kong by the Basic Law. The chief


justice further explained this common-law approach to interpretation as an object-


ive process that is not influenced or dictated by the intent of the lawmaker or by any


extrinsic factors other than the intent of the legislature as expressed through the


language of the legislation:


The courts’ role under the common law in interpreting the Basic Law


is to construe the language used in the text of the instrument in order to


ascertainthe legislative intent as expressed in the language. Their task is


not to ascertain the intent of the lawmaker on its own. Their duty is to


ascertainwhat was meant by the language usedand to give effect tothe


legislative intent as expressed in the language. It is the text of the


enactment which is the law and it is regarded as important both that


the law should be certain and that it should be ascertainable by the


citizen.^25


In the same case, the court tried to minimise the influence of the NPCSC by


labelling the process a legislative process no different from other legislative pro-


cesses.^26 Subject to any constitutional constraint, the legislature is free to reverse a


judgment of the court that the legislature considers unacceptable politically,


socially or economically. This phenomenon is a consequence of a separation of


powers, and the check against legislative abuse lies in the representative legislature.


Thus, if necessary, the Constitution can be amended. The only difference is that


the Basic Law can be amended or ‘interpreted’ in a way that is not familiar to the


(^24) ( 2001 ) 4 HKCFAR 211 at 223. (^25) Ibid., italics original.
(^26) While this explanation of distancing the NPCSC interpretation from the judicial process
helps preserve the independence of the judiciary, it does not work well in the case of
judicial referral. For more detail, see J. Chan, ‘Basic Law and constitutional review’ ( 2007 )
37 Hong Kong Law Journal 407 at 415 – 19 ; Chan and Lim,Law of the Hong Kong Consti-
tution, paras. 2. 077 – 2. 090 , 10. 061 – 10. 063 and 16. 017 – 16. 022.


180 Chan

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