ABSTRACT
The jurisdictions of the Pearl River Delta (PRD) region of the southern part of the People's Republic of China (PRC) are geographically connected but legally separate. As a result of the ‘one country, two systems [three legal orders]’ situation, other than in relation to constitutional interpretation, the Hong Kong (HK) and Macau Special Administrative Regions (SARs) were almost completely severed from mainland China in legal terms, bringing challenges for free trade and the regulation of environmental protection (Hills and Roberts 2001: 459). These ‘three legal orders’ are socialist law (PRC), common law (HK) and civil law (Macau). Although there are some similarities between the codified nature of European civil law (as practised in Portugal, the earlier colonial sovereign of Macau), and Chinese socialist law (in the PRC), there are many differences. The addition of Taiwan as a fourth legal region has also been suggested in the literature (Huang and Qiang 1994–1995: 289; Zhu 2002: 615; Chan 2010: 1).
