Comparative Studies

The 20th anniversary of the hand-over of Hong Kong to China by the British triggered some thoughts of similarities between that David-and-Goliath pair and the EU-UK pairing. Hong Kong China-1

The Economist (TE) published an article on June 22 with the heading “Still on borrowed time”, which seems to fit the Article 50 deadline as well. Below we discuss some more points that TE makes about Hong Kong at its anniversary that have parallels in Europe.

Many people in Hong Kong are bitterly frustrated by their lack of say in how they are governed.” Perhaps the British don’t feel so bitter but they are certainly frustrated by the ways in which the EU has set itself up to override the governments they elect.

And the growth of a “localist” movement in Hong Kong over the past five years, demanding self-determination or even independence, has greatly angered a Communist Party for which absolute sovereignty—ie, the regime’s security—is the bottom line.”

Unity in diversityDisunity






The successful movement in Britain to leave the EU has certainly upset and angered a European Commission for which the regime’s security and unity are the bottom line.

Next we have an apparent difference that dissolves on closer examination:

China’s formula was intended to reassure Hong Kong that it could keep its capitalist economy, its independent courts and its politically liberal (if undemocratic) culture.”

While there is no issue over the capitalist economy (at least no issue between the EU and the UK) the European Court of Justice is senior to Britain’s courts and the EU seeks to unify its politically illiberal and undemocratic culture across all its member states.

But: “A striking feature … has been the growing sway and visibility of the central government’s organ in Hong Kong. … Some now divine a parallel government operating in the territory.”

Some (indeed many) now divine a parallel government operating in British territory. This is of course the objective of the European Commission as much as it is that of the Chinese Communist Party. 

Chinese Communist Party-1 European Commission

Just as they will be on July 1st, the people of Hong Kong were mere extras 20 years ago. They had not been consulted about the terms of the handover, including the drafting of the territory’s new mini-constitution…”

The people of Britain are mere extras in the EU, with a Parliament that notionally represents those who vote but does not wield power under its “mini-constitution”, the Treaty on European Union (Lisbon).

Lawyers fear an erosion of judicial independence caused by China’s efforts to make sure that the Basic Law is interpreted to suit the party’s political needs.”

The EU is ahead of China here. With the connivance of a sequence of UK governments, whose leaders signed the treaties that cover legal relations between member states and the Union, those treaties made EU law dominant over UK law. The EU proposes to continue this dominance even after Britain leaves the Union. For example, while Britain wants supervision of the rights of EU citizens who live in the UK to be under the Supreme Court, the EU insists that this supervision should be undertaken by the ECJ, thus overriding in perpetuity the relevance of the British legal system.

UK Supreme Court                                  ECJ-1

The greatest risk…is that political and business elites in Hong Kong, rather than strongly making the case for Hong Kong’s autonomy, fawningly cede it to the Liaison Office, or to the party in Beijing.”

Replace ‘Hong Kong’ with ‘the UK’, the Liaison Office with the European Commission and Beijing with Brussels and we have a neat summary of relations between British governments and the EU, until recently when there has been some dilution of the “fawning” by Britain’s “political and business elites”, some of whom feel obliged to take note of the majority view that Britain should leave the EU.

Inequality is rising, soaring property prices make it hard to afford a flat (nearly half of Hong Kongers live in public housing), and general satisfaction is sharply lower than it was a decade ago.”

Apart from “nearly half live in public housing”, this could apply equally well to the UK, though it may not be fair to attribute general dissatisfaction entirely to either China or the EU. Inequality-1

In Beijing, Hong Kong’s political mood is interpreted as rank ingratitude at best, treason at worst.”

Substitute Brussels for Beijing and Britain for Hong Kong and again we have a neat summary of the mood in the EU. Britain, like Hong Kong, has always been semi-detached from its over-sized neighbour and has never subscribed to the ideology of federal rule, although it has agreed to obey the rules.

For those Hong Kongers with the territory’s interests at heart, the past 20 years offer some lessons. One is that for all the Communist Party’s might, and a want of democratic representation, popular opinion—strongly expressed—counts for something.” EU-China Summit

Perhaps the past year, following the Referendum, offers some lessons in Europe along the same lines.

Of course there are many differences to note in the comparison: China is much larger, geographically, than the EU and Hong Kong is much smaller that the UK; China is one nation (give or take Taiwan, Hong Kong, Macau), the EU comprises many nations; China has been governed by one party since 1949 while the EU is not (yet) governed by one party; Hong Kong is not planning to leave China (and would not be allowed even to think it possible); China has unified military, police and intelligence structures, while the EU can only dream and proselytise; one has been hugely successful economically while the other continues to struggle; one is fully developed (and not seeking to develop much further), while the other is developing (and seeking to become fully developed in the near future); one declared itself to be “one country, two systems”, while the other is one system overseeing 28 countries; the smaller of the European pairing is seeking to leave its bloc and become a power in its own right, while the smaller of the Asian pair was taken back into its bloc after being governed by a foreign power.

Hong Kong dissidentsHowever, some similarities are striking: Hong Kong and the UK are small islands off the coast of much larger continents; governance in both China and the EU is founded on ideologies; both are more-or-less willing federations of several national and ethnic sub-regions; the bureaucracies that run both are dominant in their regions; both have dissidents who object to the diminution of their cherished local identities; both struggle to suppress any such signs of disunity; both have strict, centralised hierarchies that wield power and judicial oversight; both are valuable sources of insights in discussions of the purpose and point of democracy.

So what do we learn from this comparison? Given the differences between the circumstances of China and the EU, possibly little of immediate practical value. One broad and important lesson though is that attempts to deny a people the right to choose and throw out their government will give rise to strong and persistent opposition, with the possible outcome that some Davids will see the downfall of their Goliaths, sooner or later.




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