evidence: The 1991 Additional Articles of the Constitution of the Republic of China stated that "the handling of people's rights and obligations and other affairs between the free area and the mainland can be specially stipulated by law", and used the legal term "mainland area" without defining its geographical boundaries.[22] The 1992 Regulations on the Relations between the People in Taiwan and the Mainland defined "Taiwan" as areas controlled by the ROC and "mainland" as "the territory of the Republic of China."[23] The related Cross-Strait Act called those under PRC jurisdiction - excluding those in Hong Kong and Macau - as "people of the mainland area", and used "free area of the Republic of China" to describe areas under ROC control.[24] The issue on the mainland's territory also stated in the Judicial Yuan Interpretation No. 328 in 1993.[3][25] In 2012, the Supreme Court of the Republic of China's judgment #900 labeled the Macao Special Administrative Region as the "Mainland's Macau Area".[26] The 2002 amendments to the Implementation Rules of the Regulations on People Relations between Taiwan and mainland China defined the mainland as areas claimed but not controlled by the ROC, corresponding to "areas under control of the Chinese Communists" (within