In March 2026, a group of Australian authors published Secession by Western Australia, a provocative work that does not merely speculate on independence, but lays out a detailed constitutional, legal, and economic blueprint for a new sovereign state. Grounded in historical grievances and contemporary political tensions within the Australian federation, the book reflects a broader reality: in liberal democratic contexts, the idea of secession remains a legitimate subject of public debate and academic inquiry. This raises a more difficult question when considered beyond such contexts. If secession can be openly theorised and even advocated in places like Western Australia, what does this reveal about other territories with contested political trajectories?

Hong Kong’s constitutional position has long been shaped by the unresolved tensions embedded in the 1984 Sino-British Joint Declaration and its subsequent institutionalisation in the Basic Law, Hong Kong’s mini-constitution. While the post-1997 framework promised a high degree of autonomy and a path toward democratic reforms, these promises are yet to be fulfilled. The political crises surrounding the 2014 Umbrella Movement and the 2019 protests, followed by the imposition of the National Security Law, have further narrowed the space in which alternative constitutional futures can be publicly articulated.

Yet the contraction of political space does not eliminate constitutional imagination; rather, it displaces it (Wong 2026, 2). Increasingly, debates over Hong Kong’s future have migrated into academic and policy-oriented spheres, where more radical or previously marginal ideas can be explored with greater conceptual freedom. Among these is the re-emergence of proposals that draw on the United Kingdom’s constitutional traditions, particularly the model of Crown Dependencies, as a way of rethinking Hong Kong’s political status.

If one were to take seriously the logic of constitutional self-determination in light of Hong Kong’s historical grievances and contemporary constraints, what forms might such a reconfiguration plausibly take? Drawing on the Western Australian case, this article examines whether a Crown Dependency model, potentially situated on British soil, can be understood as a coherent, if highly contingent, constitutional possibility. This study revisits secession not as a call for immediate independence, but as a framework to examine how Hong Kong could maintain representative governance and political agency outside the PRC, with the Crown Dependency model offering a potential pathway. In doing so, the article traces the evolution of such ideas from late colonial debates in the 1980s to their re-articulation in the aftermath of 2019, arguing that the very impossibility of openly pursuing self-determination within Hong Kong has contributed to their increasing sophistication in diasporic discourse.

Relocating Hong Kong: Charter City Proposals from the 1980s to the Post-2019 Era

Proposals to relocate Hong Kong or recreate it abroad are not new. Across different historical moments, typically in response to political threats from China, various academics, policymakers, and entrepreneurs have explored the idea of establishing a “new Hong Kong” in the United Kingdom. These proposals, while diverse in form, share a common premise: that Hong Kong’s economic and political system could be transplanted to a different territorial setting under British sovereignty.

One of the earliest such proposals emerged during the Sino-British negotiations. In October 1983, a news article titled “Ulster to Adopt Hong Kong?” cited sociologist Christie Davies, then lecturer at the University of Reading, who argued that Hong Kong’s capitalist system had no viable future under Communist rule. Anticipating that Britain would ultimately concede sovereignty and that any guarantees might not endure beyond the handover, Davies suggested the creation of a Hong Kong city-state in Northern Ireland. Economically, such a transplant was envisioned as a stimulus for the region; politically, it would be separated in a way that would not disrupt existing communities.

The proposal prompted internal discussion within the British government. Correspondence between officials in the Northern Ireland Office and the Republic of Ireland Department reveals a cautious assessment of its potential implications. While the plan might reassure Unionists of Britain’s continued commitment to Northern Ireland and simultaneously address Hong Kong’s uncertain future, it also risked alienating the Catholic minority and complicating the already fragile sectarian balance. Questions were also raised about the legal status of Hong Kong Chinese under British nationality law and their potential access to the European Community, with precedents such as Gibraltar and the Falklands being considered.

The officials ultimately identified significant obstacles. Concerns included the precedent such a scheme might set for other postcolonial populations, the risk of displacing local communities, and uncertainty over the territorial scope of any proposed “transplant”. More broadly, the idea of introducing a third political identity into Northern Ireland raised doubts about the viability of existing devolution arrangements. Given the historical sensitivities of plantation and land ownership, such a proposal risked exacerbating tensions during the period of the Troubles.

A second proposal emerged following the Tiananmen Square Massacre. In 1989, Scottish policymaker Douglas Mason’s report A Home for Enterprise argued for the establishment of a new Hong Kong in Scotland. While acknowledging Hong Kong’s economic success under British rule, Mason highlighted growing anxieties among Hongkongers regarding their future under Chinese sovereignty. At a time when the British government debated a limited citizenship scheme for Hong Kong, the report addressed a central practical issue: even if full rights of abode were granted, Britain lacked the capacity to absorb Hong Kong’s population within its existing urban infrastructure.

Mason’s solution was to identify Scotland as a potential site for a new Hong Kong, citing its liberal traditions, economic potential, and available land. The proposal emphasised the replicability of Hong Kong’s economic model, arguing that a low-tax, deregulated environment could reproduce its success. Like Davies, however, Mason did not fully articulate the governance structure of such a settlement, implicitly assuming a continuation of British administrative oversight. This raised the possibility that such schemes would resemble a form of renewed colonial governance rather than a genuinely self-governing polity.

These early proposals rested on a broader assumption about the........

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