at the same time. Common Law Before the enactment of the Hong Kong Bill of Rights Ordinance, the protection of human rights in Hong Kong has largely relied on the common law of England. Civil liberties protection have a long history in English common law and are generally transcribed as human rights in modern time. Under Articles 8 and 18 of the Basic Law, the laws previously in force in Hong Kong includes the common law rules which did not contravene the Basic Law and are part of the laws of HKSAR. Since colonial Hong Kong law defines "common law" as "the common law of England", civil rights principles found in the English law are now part of Hong Kong laws as "laws previously in force in Hong Kong" by operation of Articles 8 and 18 and as "common law in force in Hong Kong" pursuant to section 3 of the current Interpretation and General Clauses Ordinance (Cap. 1). Those common law principles include those of statutory interpretation, such as the presumption that statutes do not operate retroactively (also codified in the Hong Kong Bill of Rights Ordinance), the doctrine that criminal enactments are to be strictly interpreted, the presumption that mens rea is required in a criminal offence, and the presumptions against a derogation of vested rights, ousting the court's jurisdiction, deprivations of private property without compensation and the presumption that the Legislature does not intend to legislate contrary to the State's international obligation. By virtue of Article 81 of the Basic Law, the Hong Kong SAR also inherits a common law jurisdiction which emphasises on due procedure, nature justice, fair trial without delay, the presumption of innocence, the right of silence, the right of bail, the right against double jeopardy, the right against self-incrimination, and the duty to exercise a statutory power fairly. These subjects matter often found in judicial review proceedings in Hong Kong, a significant and noticeable feature of human rights protection framework in Hong Kong. Judicial Review Article 11 of the Basic Law provides that "no law enacted by the Legislature of the Hong Kong Special Administrative Region shall contravene this Law." This Article has the effect that any Ordinance that contravenes the Basic Law shall be null and void. Hence, any legislation that contravenes Article 39 of the Basic Law, which entrenches the ICCPR, is also null and void. It is well established that