IN THE HIGH COURT OF THE HONG KONG SPECIAL ADMINISTRATIVE REGION

COURT OF FIRST INSTANCE

BETWEEN

REJUVENATION AIRWAYS (HONG KONG)

Plaintiff

and

PERSONS, GROUPS AND ENTITIES

Defendants

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APPLICATION FOR AN INJUNCTION EX PARTE

TO: The Registrar of the High Court of Hong Kong Special Administrative Region

FROM: Rejuvenation Airways (Hong Kong)

Rejuvenation Airways (Hong Kong) (hereby referred to as "the Plaintiff"), hereby applies for an
injunction ex parte against Persons, Groups, and Entities (hereby referred to as "the Defendants") to
prohibit the playing or singing of the song titled "Glory to Hong Kong" (or "《願榮光歸香港》",
hereby referred to as "the Song") on flights and in facilities operated or partly operated by the
plaintiff.

1) BASIS FOR APPLICATION:

This application is based on the following grounds:

a. The Song has been ruled by the Court as inciting subversion and secession, as seen in the case of
Secretary for Justice vs Persons Conducting Themselves In Any of the Acts Prohibited Under
Paragraph 1(a), (b), C) or of the Indorsement of Claim (HCA 855/2023) and it further contains the
lyrics “Liberate Hong Kong, Revolution of our Times” which was found to have unlawful connotations
endangering national security in HKSAR v Tong Ying-Kit.

b. The playing or singing of the Song on flights and in facilities operated or partly operated by the
Plaintiff may cause tension and disharmony between people due to its seditious and unlawful
connotations as outlined in (1)(a), disrupting normal operations due to its obvious potential to cause
physical or verbal conflict arising from the tension and disharmony it causes..

c. The Song has been mistakenly presented as the "national anthem of Hong Kong" (instead of the
correct one "March of the Volunteers") repeatedly, which not only insults the national anthem but
also causes serious damage to the country and the HKSAR, contrary to section 7 of the National
Anthem Ordinance.

d. The Song's dissemination is contrary to the Law of the People's Republic of China on Safeguarding
National Security in the Hong Kong Special Administrative Region (National Security Law) and the
Crimes Ordinance, particularly Article 21 of the National Security Law and section 9 of the Crimes
Ordinance.

e. The Plaintiff relies on the Common Law principle that freedom of speech cannot unduly affect the
freedom of speech of others. This principle has been established in case law, such as the landmark
case of R v. Oakes (1986) wherein it was held that "the limits prescribed by law upon the exercise of a
right or freedom must be demonstrably justifiable in a free and democratic society". Given the
seditious, subversive and separatist nature of this song and its likely potential of causing discomfort
and disharmony on flights and disruption of the normal operations of Rejuvenation Airways. The
plaintiff considers it reasonable to prohibit the playing, singing and distribution of this song on flights
operated or partly operated by Rejuvenation Airways.

2) REQUESTED RELIEF:

The Plaintiff requests that the Court grant the following relief:

a. An injunction ex parte restraining any person, group and entities from performing any acts relating
to the song, including but not limited to the performance, playing and distribution of this song on
flights and in facilities operated or partly operated by Rejuvenation Airways.
b. An injunction ex parte restraining any person, group and entities from assisting, causing,
procuring, inciting, aiding and abetting others to commit or participate in any of the acts set out in
paragraph (2)(a)

c. An injunction ex parte restraining employees of Rejuvenation Airways' and its sister companies
from committing, causing, procuring, inciting, aiding, and abetting others to commit or participate in
any of the acts set out in paragraph (2)(a) and (2)(b)

d. Any other relief that the Court deems just and proper.

The Plaintiff believes that this injunction is consistent with the Bill of Rights and necessary,
reasonable, and legitimate for safeguarding national security and preserving the dignity of the
national anthem.

DATED: This 2nd day of August 2023