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26. In our judgment, the fact that the Explanation and Decision referred to “any” activities, not simply activities relating to the use of force or threat of force reinforced our view that a narrow interpretation of “other unlawful means” put forward by the defence would be contrary to the legislative purpose of the NSL.
27. It would not be difficult to anticipate that the operation of the legislature could be paralysed by a variety of ways and in different forms and methods other than the use of force or threat of force. The operation of the LegCo could come to a complete halt because of, for example, a cyber-attack on its infrastructure such as its information technology system, communication system or power supply system. Members and staff of the LegCo could also be subjected to attack by biological, chemical and radioactive agents.
28. Thirdly, the defence’s interpretation was also inconsistent with the wording of NSL 22 in that a careful examination of the prohibited acts listed out in its sub-paragraphs (1)–(4) showed that not all of them would necessarily involve the use of “force or threat of force”.
29. Sub-paragraph (1) prohibited any undermining of the basic system of the People’s Republic of China as established by its constitution, whilst sub-paragraph (3) prohibited any serious interference in the performance of the legal duties and functions of the HKSAR. Neither of them would necessarily involve the use or the threat of use of force.
30. Sub-paragraph (4) prohibited the attacking or damaging of premises and facilities used by the HKSAR in performing its normal
