Memory Is Not a Crime — Statement on the Convictions of Chow Hang-tung, Lee Cheuk-yan, and Albert Ho

Date: 21 August 2026

Statement by Lady Liberty Hong Kong on the verdict against three former leaders of the Hong Kong Alliance in Support of Patriotic Democratic Movements of China (Hong Kong Alliance).

On the morning of 21 August 2026, the Court of First Instance of the High Court of Hong Kong (HCCC 155/2022 / [2026] HKCFI 4794), sitting as a panel of three National Security Law designated judges — Alex Lee Wan-tang, Andrew Chan Hing-wai, and Anna Lai Yuen-kee — convicted the Hong Kong Alliance and three of its former leaders of "incitement to subversion of state power" under Articles 22 and 23 of the National Security Law.

Lee Cheuk-yan (D2), former Chair of the Hong Kong Alliance: pleaded not guilty and was convicted after trial.
Albert Ho Chun-yan (D3), former Chair: pleaded guilty before trial; his conviction was confirmed today.
Chow Hang-tung (D4), former Vice-Chair: pleaded not guilty and was convicted after trial.
Hong Kong Alliance (D1), the corporate defendant: convicted under the principle of attribution, with the three defendants treated as its "directing mind and will."

The sentences will be handed down at a later date. The three have already spent approximately 1,700 days in detention since their arrests in September 2021.

What the Judgment Establishes

In its 206-page reasons for verdict released today, the Court held that the Constitution of the People's Republic of China forms part of Hong Kong's constitutional order. Under the Constitution, the socialist system is the fundamental system of the state, and the leadership of the Chinese Communist Party is a principal component of that fundamental system. On this reasoning, "overthrowing or undermining" CCP leadership amounts to overthrowing or undermining the "fundamental system" protected by Article 22 of the National Security Law.

At the same time, the Court rejected the prosecution's first basis — that the CCP's leadership position cannot lawfully be altered in any way under the Constitution. The National People's Congress retains the power to amend the Constitution, the Court noted (para. 141).

The Court instead accepted the prosecution's second basis: that CCP leadership is a principal component of the fundamental system, and that speech or conduct intended to "overthrow or undermine" it may therefore constitute an offence under the National Security Law.

At the centre of the case was one of the Hong Kong Alliance's Five Operational Goals: "End One-Party Dictatorship" (結束一黨專政).

The defendants argued that the slogan called for political reform within the constitutional framework and did not express an intention to "overthrow or undermine" the state system. The Court rejected that argument, finding that "ending" one-party rule carried the meaning of "overthrowing or undermining" it, and that the continued articulation of this position after the National Security Law came into force supported the convictions.

The judgment therefore establishes that advocating an "end to one-party dictatorship" may, depending on the intention attributed to the speaker, be treated by Hong Kong courts as incitement to subversion of state power.

This was the fourth of the Five Operational Goals publicly upheld by the Hong Kong Alliance for three decades from 1990 onward.

The Court stated that this was "not a political trial" and that it was not deciding the merits of the June Fourth Tiananmen crackdown or of China's political system itself. Yet statements and activities concerning June Fourth throughout the Alliance's thirty-year history were extensively relied upon as evidence of the defendants' political "intent."

On the eve of the verdict, Chow Hang-tung wrote from prison:

"Justice resides in the hearts of the people. There is no need to look up to a judgment handed down from above. One judgment is no great matter."

These words capture the significance of today's judgment beyond the courtroom.

Physical Restraints During Prison Transport

In a Patreon post published on 20 August, Chow revealed that since the beginning of the trial, she has been transported from Tai Lam Centre for Women to court while restrained with handcuffs, ankle shackles, a waist chain, and leg chains, leaving her joints immobilised.

She described how physical restraint can itself become a means of suppressing thought and resistance. Yet she reaffirmed that the treatment had only strengthened her determination to continue demanding democracy, human rights, and institutional change.

Earlier, on the 37th anniversary of June Fourth, Chow wrote that what the Chinese government fears is not only that people refuse to forget, but that they refuse to remain silent.

"They may imprison us, but they cannot control our souls."

Lady Liberty Hong Kong's Position

Memory is not a crime.

"Commemoration," "vindication," "hunger strike," "candlelight" — words and practices used openly by Hong Kong civil society for more than three decades are now being reinterpreted by Hong Kong courts as evidence relevant to "incitement."

Today's judgment goes further. It makes clear that the political demand to "End One-Party Dictatorship" can be treated by Hong Kong's judiciary as incitement to subversion of state power.

By incorporating the Chinese Constitution into Hong Kong's constitutional order and treating the leadership of the Chinese Communist Party as a principal component of the constitutionally protected "fundamental system," the judgment has implications far beyond the commemoration of June Fourth. It concerns the boundaries of permissible political speech in Hong Kong itself.

We believe that citizens everywhere — in Hong Kong, in China, and throughout the world — should have the right to choose those who govern them and the right to remove them from power through peaceful political processes. Where citizens have no meaningful means to replace those in power, political choice is fundamentally constrained. To criminalise the very demand to "End One-Party Dictatorship" is to deny this basic right.

The question at stake is therefore not simply whether one particular slogan is permissible. It is whether citizens may openly argue that those who hold political power should no longer hold it.

Today's judgment gives that question an increasingly stark answer.

Yet memory cannot be imprisoned. The time and freedom that Chow Hang-tung, Lee Cheuk-yan, and Albert Ho have given — and continue to give — remind us that neither memory nor the demand for political change can be completely erased by state power.

What We Will Continue to Do

Lady Liberty Hong Kong will continue to:

Follow the sentencing of Chow Hang-tung, Lee Cheuk-yan, and Albert Ho and report developments as they are confirmed.
Document their conditions in detention, the voices of their families, and the efforts of their supporters.
Share international efforts calling for their release and for the judgment against the Hong Kong Alliance to be reviewed.
Analyse and explain the legal implications of today's judgment, particularly its treatment of the demand to "End One-Party Dictatorship" and its consequences for freedom of expression and political participation in Hong Kong.
Preserve and transmit the memory of the June Fourth Tiananmen crackdown and Hong Kong's democracy movement through exhibitions, publications, public education, policy advocacy, and engagement with civil society.

Finally, we ask one thing:

Please share this statement, and continue to share the stories of those imprisoned for refusing to forget and refusing to remain silent.

The authorities may restrict speech, assembly, and political organisation. They cannot prevent memory from passing from one person to another.