provision was held to be unconstitutional as while the age of consent for heterosexual couples is 16, male homosexual couples must reach 21 to have sex legally. Despite fierce opposition from church groups, on 16 December 2009, Hong Kong's Legislative Council passed a bill extending its Domestic Violence Ordinance to apply to same-sex couples. Despite the above victories of the homosexual community, same-sex marriage is not recognised in Hong Kong. There is also an absence of anti-discrimination legislation to create horizontal effect for the protection of homosexuals in human rights instruments, leaving homosexuals with no legal redress if discriminated against for their sexuality by private individuals. Indigenous people Hong Kong, despite being highly westernised, still retains Chinese culture and traditions, especially in the Region's New Territories. Such traditions are expressly protected in Article 40 of the Basic Law, which provides that the lawful traditional rights and interests of the indigenous inhabitants of the New Territories shall be protected. In Secretary for Justice and others v. Chan Wah and Others, the second respondent complained of having been excluded by electoral arrangements from standing as a candidate in village elections on the ground he was not indigenous, although he had lived there all his life. It was held that as the village representative would represent the whole village, not just indigenous persons, the restriction was not reasonable and electoral arrangements were held unconstitutional accordingly. The Hong Kong Government introduced the Small House Policy in 1972, which is an attempt to regularise village traditions. It allows indigenous male adult villagers, who is descended through the male line from a resident in 1898 of a recognised village, to be granted a plot of land at reduced premium in order to build a small house of specified dimensions within the 'V' zone and the environs or the village extension area of a recognised village. There have been demands to abolish this policy due to its being perceived as discriminatory, although such attempts have been strongly refuted by the Heung Yee Kuk. Gender In Secretary for Justice and others v. Chan Wah and others, the first respondent, who was non-indigenous and male and married to an indigenous and female villager, was excluded from voting in village elections. However, the arrangements were such that a non-indigenous, female villager married to an indigenous, male villager would have qualified as an indigenous villager with a right to vote. It