London Daily

Focus on the big picture.
Wednesday, Nov 12, 2025

Court upholds right of male villagers to seek to build on Hong Kong land

Court upholds right of male villagers to seek to build on Hong Kong land

But right is an ‘inherently imperfect’ one because it has never had statutory basis and is subject to discretion of Lands Department, judges find.

Hong Kong’s top court has ruled that male indigenous villagers have a constitutionally protected right to apply to build small houses on their ancestral or government-granted land, ending the debate on the legality of the controversial policy.

Applicant Kwok Cheuk-kin had argued that the so-called ding right, which allows the villagers to apply for permission to build three-storey homes in the New Territories, was discriminatory on the basis of sex, birth or social origin.

But both the government and the Heung Yee Kuk, the rural powerhouse representing villagers’ interests, countered it was one of “the lawful traditional rights and interests of the indigenous inhabitants” protected by Article 40 of the Basic Law, the city’s mini-constitution.

Kwok Cheuk-kin outside the Court of Final Appeal earlier this month.


In dismissing Kwok’s challenge, the Court of Final Appeal on Friday acknowledged that calls to axe the policy, which the British colonial government created, were made in the run-up to the promulgation of the Basic Law.

“[Article 40] marked the rejection of these demands,” the 34-page judgment read.

But the court also noted that the protection only stood while the policy remained in force as it currently existed, adding the right was an “inherently imperfect” one because it had never had a statutory basis and was subject to the discretion of the Lands Department.

“Unless [Article 40] makes the small-house policy immutable (a question which we do not decide), [the policy] may change,” the judgment read.

Kwok said he was “rather surprised” by what he described as an unreasonable judgment as it upheld discrimination against women. Although the ruling brought to an end a battle he first started in 2015, he pledged to try one more option: writing to the National People’s Congress Standing Committee, China’s top legislative body, to ask for an interpretation of the Basic Law.

“This is for the entire country,” he said.

A spokesman for the Development Bureau said the government welcomed the court’s decision and authorities would continue to receive and process applications to build the small houses.

Kuk chairman Kenneth Lau Ip-keung said the group was “happy” with the ruling.

“We hope this will serve as a foundation to free up more land in the New Territories. Since these village lands are already in a very convenient area, next to MTR stations or next to the city, we’re willing to explore this opportunity to make use of the land to build more housing for Hong Kong,” he said.

Lau also urged the government to speed up processing of construction applications, noting about 10,000 applications were still pending approval. Only 200 requests were allowed in 2020, or about a fifth the usual number, he added.

Brian Wong Shiu-hung, a member of the Liber Research Community land concern group, said the ruling was a “victory” for the government but only a “partial win” for the kuk.

“Heung Yee Kuk wanted to argue that ding is their personal right or entitlement, but the court ruling says very clearly that they only have the right to apply [to build a small house]. Approval is based on government discretion, so the policy is still subject to control,” he said.

Formulated by the British colonial administration in 1972, the policy is widely seen as unfair in a city that is constantly starved for space. Kwok, a retired civil servant whose frequent challenges to the government has earned him the nickname of “king of judicial reviews”, applied for a judicial review in 2015 after 11 indigenous villagers were jailed for up to three years for a scam in which they sold their land rights for profit.

He scored a partial victory in 2019 when the Court of First Instance held that private treaty grants and exchanges – involving land granted by, or exchanged with, the government – were not protected by Article 40 and therefore unconstitutional. All of the parties appealed.

Earlier this year, the Court of Appeal concluded that the policy was constitutional in its entirety, overturning the findings in respect of private treaty grants and exchanges, while upholding as a traceable traditional right the licence to freely build on private land.

Kwok had almost given up his battle when the top court waived the HK$4.8 million (US$616,770) he needed to pay in security for costs, considering his bankruptcy and the public interest involved in the case.

At a hearing last month, Kwok’s lawyers had argued that the anti-discrimination provisions in the Basic Law and the Hong Kong Bill of Rights qualified and limited the scope of Article 40, while the respondents countered it was the other way round.

On Friday, the court concluded that the latter view was correct, given that “the specific prevails over the general” as a principle of statutory construction and Article 40 was a specific provision dealing with the special position of a particular class of people.

“Absent [Article 40], all the various advantages enjoyed by the indigenous inhabitants of the New Territories would be inherently discriminatory unless they can be objectively justified as being necessary in pursuit of a legitimate aim,” the court said.

As to what qualified as traditional rights, the judges said the lower appellate court was right in ruling that they referred to ones recognised as traditional in April 1990, when the Basic Law was promulgated.

“[The ding right was] traditional in 1990 not because they were traceable to any rights or interests … but because the beneficiaries were confined to members of long-standing and relatively immobile village communities which had been treated as a separate category throughout the period of colonial government, and because they had by then passed through the male line in the same families for nearly nine decades,” the judges continued.

But the court also dismissed suggestions from the respondents that the policy could not be challenged by a “busybody” such as Kwok after an exceptional delay, ruling he had sufficient standing because the only people who would have a greater interest in the matter were beneficiaries who clearly had no interest in challenging it.

“It cannot be right to allow the executive to continue to act unlawfully, simply because no one challenged it at the outset,” the judgment continued.

The five judges presiding over the appeal were Chief Justice Andrew Cheung Kui-nung, permanent judges Roberto Ribeiro and Joseph Fok, and non-permanent judges Patrick Chan Siu-oi and Lord Jonathan Sumption.

Newsletter

Related Articles

0:00
0:00
Close
UK Upholds Firm Rules on Stablecoins to Shield Financial System
Brussels Divided as UK-EU Reset Stalls Over Budget Access
Prince Harry’s Remembrance Day Essay Expresses Strong Regret at Leaving Britain
UK Unemployment Hits 5% as Wage Growth Slows, Paving Way for Bank of England Rate Cut
Starmer Warns of Resurgent Racism in UK Politics as He Vows Child-Poverty Reforms
UK Grocery Inflation Slows to 4.7% as Supermarkets Launch Pre-Christmas Promotions
UK Government Backs the BBC amid Editing Scandal and Trump Threat of Legal Action
UK Assessment Mis-Estimated Fallout From Palestine Action Ban, Records Reveal
UK Halts Intelligence Sharing with US Amid Lethal Boat-Strike Concerns
King Charles III Leads Britain in Remembrance Sunday Tribute to War Dead
UK Retail Sales Growth Slows as Households Hold Back Ahead of Black Friday and Budget
Shell Pulls Out of Two UK Floating Wind Projects Amid Renewables Retreat
Viagogo Hit With £15 Million Tax Bill After HMRC Transfer-Pricing Inquiry
Jaguar Land Rover Cyberattack Pinches UK GDP, Bank of England Says
UK and Germany Sound Alarm on Russian-Satellite Threat to Critical Infrastructure
Former Prince Andrew Faces U.S. Congressional Request for Testimony Amid Brexit of Royal Title
BBC Director-General Tim Davie and News CEO Deborah Turness Resign Amid Editing Controversy
Tom Cruise Arrives by Helicopter at UK Scientology Fundraiser Amid Local Protests
Prince Andrew and Sarah Ferguson Face Fresh UK Probes Amid Royal Fallout
Mothers Link Teen Suicides to AI Chatbots in Growing Legal Battle
UK Government to Mirror Denmark’s Tough Immigration Framework in Major Policy Shift
UK Government Turns to Denmark-Style Immigration Reforms to Overhaul Border Rules
UK Chancellor Warned Against Cutting Insulation Funding as Budget Looms
UK Tenant Complaints Hit Record Levels as Rental Sector Faces Mounting Pressure
Apple to Pay Google About One Billion Dollars Annually for Gemini AI to Power Next-Generation Siri
UK Signals Major Shift as Nuclear Arms Race Looms
BBC’s « Celebrity Traitors UK » Finale Breaks Records with 11.1 Million Viewers
UK Spy Case Collapse Highlights Implications for UK-Taiwan Strategic Alignment
On the Road to the Oscars? Meghan Markle to Star in a New Film
A Vote Worth a Trillion Dollars: Elon Musk’s Defining Day
AI Researchers Claim Human-Level General Intelligence Is Already Here
President Donald Trump Challenges Nigeria with Military Options Over Alleged Christian Killings
Nancy Pelosi Finally Announces She Will Not Seek Re-Election, Signalling End of Long Congressional Career
UK Pre-Budget Blues and Rate-Cut Concerns Pile Pressure on Pound
ITV Warns of Nine-Per-Cent Drop in Q4 Advertising Revenue Amid Budget Uncertainty
National Grid Posts Slightly Stronger-Than-Expected Half-Year Profit as Regulatory Investments Drive Growth
UK Business Lobby Urges Reeves to Break Tax Pledges and Build Fiscal Headroom
UK to Launch Consultation on Stablecoin Regulation on November 10
UK Savers Rush to Withdraw Pension Cash Ahead of Budget Amid Tax-Change Fears
Massive Spoilers Emerge from MAFS UK 2025: Couple Swaps, Dating App Leaks and Reunion Bombshells
Kurdish-led Crime Network Operates UK Mini-Marts to Exploit Migrants and Sell Illicit Goods
UK Income Tax Hike Could Trigger £1 Billion Cut to Scotland’s Budget, Warns Finance Secretary
Tommy Robinson Acquitted of Terror-related Charge After Phone PIN Dispute
Boris Johnson Condemns Western Support for Hamas at Jewish Community Conference
HII Welcomes UK’s Westley Group to Strengthen AUKUS Submarine Supply Chain
Tragedy in Serbia: Coach Mladen Žižović Collapses During Match and Dies at 44
Diplo Says He Dated Katy Perry — and Justin Trudeau
Dick Cheney, Former U.S. Vice President, Dies at 84
Trump Calls Title Removal of Andrew ‘Tragic Situation’ Amid Royal Fallout
UK Bonds Rally as Chancellor Reeves Briefs Markets Ahead of November Budget
×