03/02/2020
HKSAR v. CHAN YAU HEI [2014] HKCFA 18; (2014) 17 HKCFAR 110; [2014] 3 HKC 52; FACC 3/2013 (7 March 2014)
49. Finally, as Mr Wong rightly pointed out, the offence is in effect one of strict liability, and this
is a further reason to reject the respondent’s invitation to develop the common law by holding
that the offence can be committed in a virtual place.
50. Therefore, in my opinion, the first part of the public element of the offence does require that
the actus reus (whether it be something said, done or exhibited) be committed in a physical,
tangible place and not virtually in cyberspace by way of the internet. To hold that the internet is
a public place for the purposes of the offence would involve either dispensing with the first part
of the public element of the offence or substantially extending its meaning and would therefore
amount, impermissibly, to judicially extending the boundaries of criminal liability.
51. I turn to address the arguments advanced by the respondent and to the only other case
concerning this particular issue.
52. In the respondent’s written case, Webster v Dominick [2005] JC 65 is relied on to support
the submission by analogy that the offence of outraging public decency could be committed by
acts done on the internet.
53. Webster v Dominick is a Scottish case concerning a charge of the offence of shameless
indecency. The High Court of Justiciary held that shameless indecency was not a relevant
charge in the law of Scotland and that indecent conduct could be criminal where, as against an
individual victim, it constituted “lewd, indecent and libidinous practices” and where, as a crime
against public morals, it “causes … public offence” (§48). In respect of the former, the Lord
Justice-Clerk observed that it might be committed “by means of a lewd conversation with the
victim, whether face to face or by a telephone call or through an internet chat-room” (§49,
emphasis added).
54. I do not think this case supports the respondent’s submission. It is significant that the first
form of indecent conduct is criminal “whether committed in public or in private” and there is no
place element in the offence. The reference to the possibility of the offence being committed
“by means of a lewd conversation … through an internet chat-room” is not therefore to be seen
as indicating any location of the conversation but is merely a reference to the chat-room being
a medium through which the offence is committed.
55. There is also reliance, in the respondent’s written case, on a passage in Rook & Ward at
§14.45, commenting on Rose v Director of Public Prosecutions [2006] 1 WLR 2626. In that
case, a conviction for outraging public decency was quashed where the act (being sexual
activity carried out in the foyer of a bank in the early hours of the morning) was only proved to
have been seen by one other person other than the participants, namely a bank employee who
later observed the act on a CCTV recording. Stanley Burnton J (as he then was) applied the
proposition that, if in fact only one person saw the act or could have seen the act complained
of there was no offence (§25), and held that there was not a sufficient public element for the
offence to be established (§28). That was sufficient to dispose of the appeal. Although
therefore not having to decide the issue, Stanley Burnton J considered there was
“considerable force in [counsel’s] submission that the viewing privately of a private recording of
an act which had not previously been seen by any person is insufficient to constitute the
offence” (§29).
56. Rook & Ward suggest the court in Rose was right to doubt that the offence could be
committed by the replaying of a CCTV recording. However, they go on to state that “viewing of
the product of a camera ought to be sufficient where the viewing takes place in real-time, e.g.
where the product is broadcast over the internet or on live-feed CCTV.”
57. I do not regard that reference to the viewing of product broadcast over the internet as
supporting the proposition that the internet is a place for the purposes of the offence. Instead, I
understand the statement in Rook & Ward to be describing different means by which an
outrageous act may be perceived by members of the public.
https://www.hklii.hk/eng/hk/cases/hkcfa/2014/18.html
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