the Hong Kong Courts can now conduct the Marbury v. Madison type of judicial review to review the legislative and executive acts of the Hong Kong Special Administrative Region. This power exists before the handover since Hong Kong was governed by the Letters Patent, as opposed to Britain which has an unwritten constitution and where Parliament is sovereign. In the landmark case of Ng Ka Ling and Others v. Director of Immigration, Chief Justice Andrew Li declared in emphatic terms: The approach of the courts towards the review of the constitutionality of legislation was laid down in R v. Sin Yau Ming, which adopted the Canadian approach in R. v. Oakes. Once there is a prima facie violation of a protected right, the government bears the burden of justifying the breach by showing: The impugned provisions pursue a sufficiently important objective which is related to pressing and substantial concerns in a free and democratic society There is a rational connection between the objective and the means chosen The means adopted causes minimal impairment to the right of freedom in question The effects on the limitation of rights and freedoms are proportional to the objective However, controversies exist over whether the courts have the power to conduct a constitutional review of a legislative act of the National People's Congress or its Standing Committee. The Court of Final Appeal stated in Ng Ka Ling that the courts do have such a power. However, this declaration provoked heavy criticisms from the mainland authorities and developed into a constitutional crisis. Civil and political rights under domestic law Right to life The right to life is protected under Article 28 of the Basic Law and Article 2 of the Bill of Rights. In practice, the right to life is mainly protected by the criminal law (murder and manslaughter). No capital punishment has been carried out since 1966 and it has been formally abolished for all crimes in 1993. Freedom of expression The freedom of expression is protected under Article 27 of the Basic Law and Article 16 of the Bill of Rights. It is regarded as a fundamental right, but the Bill of Rights (and hence the ICCPR) provides that restrictions to it are justifiable provided that the restrictions are provided by law and are necessary for respect of the rights or reputations of others; or for the protection of national security or of public