Hong Kong Case Law: Decisions & Judgments | LexChat

Hong Kong Case Law

Construction of statutory words
  • 12 Aug 1997

    HKSAR v. LAM SHING FAI and Others

    Citation
    HKSAR v. LAM SHING FAI and Others
    Court
    Court of First Instance
    Case number
    HCMA128/1997

    The court held that s.48 of Cap.109 is penal and must be strictly construed; the phrases "used" and "made use of" in s.15(1) and s.48(2) require direct use in the commission of the offence and do not extend to items merely facilitating patronage; karaoke equipment were not directly used to commit sale/possession offences and therefore were not liable to forfeiture under s.48; accordingly the magistrate had jurisdiction under s.102 Cap.221 to order return of the items to lawful owners and to impose ancillary conditions; s.102(6) did not preclude the order because Cap.109 did not apply.