Article 105 confers upon individuals the right to compensation for lawful deprivation of their property. Statutory protection of the right to property is found in the criminal offence of theft and in the Copyright Ordinance (Cap. 528) and the Prevention of Copyright Privacy Ordinance (Cap. 544) etc. The town planning regime had been questioned as to its compatibility with this right. Whether zoning restrictions effected by the Outline Zoning Plans constitute a deprivation of property was considered by the Court of Appeal in Fine Tower Associates Ltd v Town Planning Board. The Conditions of Exchange limited the applicant's land use to industrial and/or godown, but the Draft Outline Zoning Plan designated 44% of the land as "Open Space" and 56% as "Other Specified Uses". The Court noted that a deprivation of land could occur not only by a formal expropriation of the land but also by an act which nullified any meaningful economic benefit in the land. It was held that the applicant had not lost all meaningful or economically viable use of the land, as it could still sell the land. The Court stressed that Article 105 had to be read in conjunction with Article 7, which authorises the government to manage the land in Hong Kong. No arbitrary arrest, detention, imprisonment, search or seizure Arbitrary arrest, detention, imprisonment, search or seizure are prohibited under Article 28 of the Basic Law and Article 5 of the Bill of Rights. No one shall be deprived of his personal liberty except on such grounds and in accordance with such procedure established by law. In practice, this area is governed by a mixture of common law and statutes. At common law, false imprisonment is recognised as both a tort and a crime. Kidnapping is a crime at common law and is codified in section 42 of the Offence Against the Person Ordinance (Cap.212). Power of arrest It was confirmed in the case R v. To Kwan Hang & Another that the common law power of arrest is applicable to Hong Kong. Any person has the right to take reasonable steps to stop someone from "breaking or threatening to break the peace", and that "reasonable steps in appropriate cases will include detaining him against his will". Bokhary JA, as he then was, explained that a breach of peace occurs when a person "unlawfully resorts to violence which injures someone or damages property, or