reasons. The Anglican and Roman Catholic churches in Hong Kong freely appoint their own bishops, unlike in mainland China. Cardinal Joseph Zen, the immediate past Bishop of Hong Kong, was outspoken about religious freedom and human rights in China. Right to equality The right to equality is protected by Article 25 of the Basic Law and Article 22 of the Bill of Rights. A number of Ordinances have been enacted in order to give horizontal effect to the equality provisions in the Basic Law and the Bill of Rights. Examples include the Sex Discrimination Ordinance, the Disability Discrimination Ordinance, the Family Status Discrimination Ordinance and the Race Discrimination Ordinance. The Equal Opportunities Commission is a statutory body set up to implement these legislations and eliminate discrimination. The Race Discrimination Ordinance sparked fierce debates in Hong Kong because the definition of race as "race, colour, descent or national or ethnic origin of the person" left Mainland Chinese immigrants unprotected. It was remarked by the Court that not all differential treatments constitute discrimination. If the differential treatment pursues a legitimate aim, is rationally connected to the legitimate aim and is no more than necessary to accomplish the aim, the differential treatment is justified and does not constitute discrimination. Only when the differential treatment is unjustified will it be deemed as discrimination. Sexual orientation Gay sex was legalised in Hong Kong in 1991. However, the Crimes Ordinance (Cap. 200) shows a tendency to discriminate against the gay community by stipulating different ages of consent for homosexual and heterosexual relations, and has been challenged for a number of times. In Secretary for Justice v. Yau Yuk Lung Zigo, the constitutionality of section 118F(1) of the Crimes Ordinance was challenged. The section provides that it is an offence for a man to commit buggery with another man otherwise in private. The Court of Final Appeal unanimously held that the section was discriminatory as it constitute unnecessary differential treatment on the ground of sexual orientation. All persons, irrespective of sexual orientation, are subject to the common law offence of committing an act outraging public decency. In Leung TC William Roy v Secretary for Justice, the constitutionality of section 118C of the Crimes Ordinance, which provides that a man who commits or suffers to commit buggery with a man under the age of 21 is liable on conviction on indictment to imprisonment for life, was challenged. The