laws of the Hong Kong SAR in accordance with the Decision of the Standing Committee of the National People's Congress on 23 February 1997. Even so, the entrenched status of the ICCPR (and subsequently the HKBORO) in the constitutional framework of Hong Kong continue with the effect of article 39 of the Basic Law, while the Basic Law itself consisted of provisions of fundamental rights and freedoms of Hong Kong residents. The Court of Final Appeal has recognized that provision on rights in HKBORO continue to override contravening laws: Significance The enactment of HKBORO in 1991 provided the foundation for constitutional guarantees of rights and freedom in Hong Kong. Albert Chen Hung-yee described the enactment of the Ordinance as “the first constitutional revolution” in Hong Kong. Before its enactment, human rights protection was exclusively reliant on judge-made common law principles; courts were not empowered to conduct constitutional review of legislations for the lack of relevant provisions on human rights protection in the Hong Kong Letters Patent. With the advent of HKBORO, the courts of Hong Kong embarked upon an era of meaningful constitutional review. In early days the Courts were concerned with whether pre-8 June 199l legislation had been repealed by the HKBORO for inconsistency. The period from 8 June 1991 to 1 July 1997 was described as one during which the courts of Hong Kong produced a valuable if not very large body of human rights jurisprudence and gained a useful six years of pre-handover experience of meaningful constitutional review. After the Handover Article 39 of the Basic Law creates a part of the post-handover tripartite framework on human rights protection, where: Any restrictions on rights and freedoms stipulated the ICCPR (and subsequently the HKBORO) must be prescribed by law and justified, according to Chief Justice Andrew Li in Gurung Kesh Bahadur v Director of Immigration (2002) 5 HKCFAR 480. Subsequently, the proportionality test was developed in Leung Kwok Hung v HKSAR(2005) 8 HKCFAR 229: Notable applications and case law The HKBORO enabled Hong Kong to enter the era of judicial review of legislations. The practice of utilizing constitutional review of legislation flourished. Constitutional review principles like proportionality have since been developed. The first Bill of Rights case, R v Sin Yau Ming [1992] 1 HKCLR 127, decided by the Court of Appeal concerning the presumption of innocence. Restrictions on peaceful assembly provided in the Public Order Ordinance, such