23 October 2016
Hong Kong and Chinese flags are displayed at a ceremony. Leung Chun-ying told a Basic Law seminar that "one country, two systems" is a rare, exceptional arrangement. Photo: Internet
Hong Kong and Chinese flags are displayed at a ceremony. Leung Chun-ying told a Basic Law seminar that "one country, two systems" is a rare, exceptional arrangement. Photo: Internet

Mr. Leung, one country, multiple systems is everywhere

Chief Executive Leung Chun-ying makes it a point to mention that no one ever said a word about civil nomination during the drafting of the Basic Law.

Now we have veteran democrat Martin Lee disproving that claim.

Lee says the third of five election methods discussed during the drafting process stipulates that a chief executive candidate “can be nominated by any 50 permanent residents”.

It’s ironic that Leung, who served as secretary general of the Basic Law consultative committee in the 1980s, could be so slapdash and so wrong about the facts in his latest comments on the matter.

Leung didn’t stop there. He made a shocking assertion by saying that “one country, one system is the international standard”.


Leung could be forgiven for his ignorance. After all, he started his professional career as a surveyor, not a politician seasoned in history and international affairs.

One country, multiple systems is the norm

Examples abound about diversity and differences in race, culture and language in countries where there are ethnic minorities and where geographical separations are usually enshrined in the constitution.

These special administrative regions normally enjoy a certain degree of autonomy and have their own political and legal systems. Some have their own currencies.

“One country, multiple systems” can be found in the United States, Canada, Australia, Britain, Russia, France, Italy, Spain, India, Indonesia and so on.

Many of them are federal states but there are exceptions in Italy and Spain, which are unitary nations.

Other federal nations such as Germany, Brazil and Argentina do not have designated “special regions” but there are perceivable differences in the political and legal systems among many federal states and provinces.

The only major power that has “one country, one system” is Japan.

One country, four systems in the US

In the US, three additional legal and administrative systems co-exist.

The first one consists of 562 Indian nations, tribes and semi-autonomous Native American-governed territories in 34 states.

The largest such nation is the 71,000 square kilometer Navajo Nation which occupies portions of Arizona, Utah and New Mexico.

The nation has a population of 300,000 and exercises independent judicial power and final adjudication over all offenses by tribal members.

Besides English, Navajo is the official language. The nation’s governance structure is a hybrid of traditional tribal and modern US political elements.

Navajo people can democratically elect their president and Washington recognizes the nation’s constitutional status as a “dependent domestic sovereignty” free from interference from any other state.

The second special administrative entity is the state of Louisiana.

The southern state was a French and Spanish colony before Washington purchased it in 1803.

Since it became a federal state in 1812, Louisiana has adopted a European civil law system as opposed to the British common law system in all other states.

Thus, legal professionals trained in other states cannot practice in Louisiana and vice versa.

In politics, nomination of candidates for all non-federal elections is open with no limits on the number of candidates. Instead of being segregated by political party, all candidates in election primaries (non-partisan blanket primary) run against each other at once in Louisiana.

The third system is the US unincorporated territories including Guam, the US Virgin Islands and so on. These entities have their respective autonomous governance structures.

One country, three systems in Canada

Hongkongers are familiar with the 10 Canadian provinces in the federation. Each province has a great deal of power and jurisdiction relative to the federal government.

Canada’s three federal territories, namely, Yukon, Nunavut and Northwest Territories are all autonomous entities with powers delegated by Ottawa.

The executive head of these territories is the prime minister, elected by the legislature with members from all tribes in the region.

Modeled on the Navajo Nation, the northernmost Nunavut region has seen some pro-independence activists push for a more independent constitutional status in recent years.

A referendum law went into effect last year. The results of the general vote by Nunavut’s 31,900 native Inuit people can be legally binding.

Apparently, these indigenous minorities have broader political rights than their counterparts in China like Tibetans. Hongkongers compare poorly to the Inuit people in civil rights.

Another different system is Quebec. Like Louisiana, the eastern province maintains a civil law system. Although English is one of the official languages there, French is more predominantly used in government and business.

Pro-independence sentiment has flourished among Quebecers in recent years. In 2003, the National Assembly of Quebec voted unanimously to affirm “that the people of Quebec form a nation”.

Shortly after taking office in 2006, the House of Commons passed a symbolic motion by Prime Minister Stephen Harper which recognized that Quebecers form a nation within a united Canada.

One country, three systems in India

Under a federal structure, India’s 29 states exercise a high degree of autonomy featuring an independent legislature and election. New Delhi can only appoint a ceremonial governor to head each state and represent the Indian president.

Also, India has seven union territories, five of them directly under the central authorities, while the other two are quasi-states with narrower autonomy.

These three systems have been in place for almost 60 years.

Beijing politicians pandered to Deng Xiaoping after he proposed the “one country, two systems” principle in the early 1980s, saying it was “pioneering and without precedent in history”.

There have been equally bald-faced assertions since then including “there is no international standard or model of democracy”.

These notions are elaborately spun to prevent Hongkongers from drawing on the experience of other places where multiple systems work.

This article appeared in the Hong Kong Economic Journal on April 9.

Translation by Frank Chen

[Chinese version 中文版]

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Leung Chun-ying (right), seen greeting guests at a Basic Law reception dinner, has been making outrageous claims about governance systems. Photo: GIS

Former full-time member of the Hong Kong Government’s Central Policy Unit, former editor-in-chief of the Hong Kong Economic Journal

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