Page:HKSAR v. Tong Ying Kit (Verdict).pdf/4

-4- A. Introduction

1. The Defendant in this case faces two offences (the 1st and the 2nd count) under the National Security Law (“NSL”) and another offence of “causing grievous bodily harm by dangerous driving” (“the 3rd count”), which is laid as an alternative to the 2nd count, as follows:

First Count STATEMENT OF OFFENCE Incitement to secession PARTICULARS OF OFFENCE TONG Ying-kit, on the 1 day of July, 2020, in the area from Eastern Harbour Crossing to the junction of Jaffe Road and O’Brien Road, Wanchai, in Hong Kong, incited other persons to organise, plan, commit or participate in acts, whether or not by force or threat of force, with a view to committing secession or undermining national unification, namely separating the Hong Kong Special Administrative Region from the People’s Republic of China or altering by unlawful means the legal status of the Hong Kong Special Administrative Region. Second Count STATEMENT OF OFFENCE Terrorist activities PARTICULARS OF OFFENCE TONG Ying-kit, on the 1 day of July, 2020, in the area from Eastern Harbour Crossing to the junction of Jaffe Road and O’Brien Road, Wanchai, in Hong Kong, with a view to coercing the Central People’s Government or the Government