The comparative research will focus on the nature and scope of the basic structure doctrine in four jurisdictions (Germany, India, Turkey and Malaysia) to gain insights for the constitutional position of Hong Kong. These jurisdictions are chosen based on serval factors: 

  • The doctrine's roots in the German Basic Law;

  • A combination of civil law and common law jurisdictions;

  • Countries where the doctrine is explicitly incorporated in the constitutional text (i.e., Germany); and,

  • Countries where the doctrine is incorporated by courts through judicial interpretation (i.e., India).