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One Country, Two Systems: The Decisions to Investigate and Prosecute in China and the Special Administrative Region of Hong Kong [HKSAR]

NCJ Number
Evena Chan
Date Published
14 pages
This document addresses the agreement between China and the Special Administrative Region of Hong Kong (HKSAR) that allows Hong Kong to operate under a different legal system from that of the Mainland.
Prosecutorial authority in Mainland China is vested in the People’s Procuratorates, while in Hong Kong it is vested in the Department of Justice. The article discusses the various similarities and differences in the role of prosecutors, how prosecutorial discretions are exercised, and how victim’s rights are safeguarded. Following a comparison of the ways in which the investigation of cases, imitation of prosecution, and supervision of cases differ under the Basic Law of Hong Kong and the laws of Mainland China, the article describes similarities in the ways that cases are conducted in court and in the handling of the appeals process. After describing similarities in victims’ right to be informed, right to initiate action, and right to participate in the legal process, the author contends that although the legal systems in Mainland China and HKSAR are different, both systems are based on similar principles and share common values and goals.


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