- 44 A B - otherwise agree with his analysis and conclusion on proportionality. As is entirely consistent with the Secretary’s stance throughout that he does A B not seek to ban the Song per se but only targets the 4 Acts, Mr Yu fairly C D accepts that the injunction should contain exceptions to make it crystal clear that legitimate acts and activities in connection with the Song will not C D be prohibited. E E D2.5 With contra mundum effect binding on newcomers F G 78. The fifth aspect of the injunction is its contra mundum effect. F G For it to be truly effective, the injunction applies to everyone in Hong H I Kong. It binds not only the Defendants but also “newcomers”, that is, persons who are not parties to the proceedings. They are neither the H I Defendants nor identifiable, and who have not yet committed or threatened J to commit the prohibited acts, but may do so in the future. K K 79. L M J In this regard, Mr Chan draws our attention to the perceived lack of opportunity for a non-party to be heard and make contrary representations prior to being made subject to the injunction, and possible L M liability for contempt irrespective of whether he knows of its contents when N it has been served by alternative means. His submissions largely echo the O Judge’s concerns summarized at [12] above. P 80. Q In Wolverhampton, after reviewing the authorities of the lower courts, some of which support the Judge’s and Mr Chan’s concerns, such N O P Q as Canada Goose UK Retail Ltd v Persons Unknown [2020] 1 WLR 2802 R S (CA), the UK Supreme Court clarified the law in relation to newcomer injunctions and authoritatively put them on a firm juridical basis in equity. R S For present purposes, the following main points made by the Supreme T Court will suffice: T U U V V