Hong Kong Sends Undercover Agents Into a Bookstore

Last November, a fire tore through Wang Fuk Court — a residential estate of eight high-rise towers in Hong Kong — killing 168 people and displacing all 1,984 households. Hearings over the past few days have revealed only fragments of what went wrong. Residents had complained, repeatedly and to multiple government departments, about the renovation works long before the fire. None of it was enough to prevent the disaster.

Whether anyone should be held responsible is for the independent commission to determine; the public should not rush to judgment. While we wait for the findings, however, it may be worth turning to another case — one that shows just how proactive the Food and Environmental Hygiene Department (FEHD) can be when it sets its mind to enforcement, and which may serve as an instructive example for other government departments.


Hong Kong law requires anyone running a “place of public entertainment” to hold a licence, with criminal penalties for failure to do so (Cap. 172, s. 4). On 29 June last year, Book Punch — an independent bookstore in Sham Shui Po — hosted a graduation showcase for the third cohort of its in-house stand-up comedy class. The event ran across two sessions, pay-what-you-wish. No licence had been obtained. Yesterday, the bookstore and its owner were each found guilty on two counts and fined HK$3,000 per summons (case nos. KCS37515 & KCS37516/2025).

I attended both the trial in the morning and the verdict in the afternoon at Kowloon City Magistrates’ Courts. Watching how this case was successfully built and prosecuted, I noticed at least three commendable details that other government departments would do well to study.

Proactive Enforcement: Scrolling Facebook in the Midst of a Busy Schedule

According to the Agreed Facts, two FEHD Health Inspectors I came across a social media post by Book Punch about the upcoming event on 25 June 2025, and from that moment began their investigation.

In other words — assuming I have understood correctly — between their routine inspections and their handling of public complaints, FEHD officers nevertheless found time in their busy schedules to spot, on Facebook, that an independent bookstore was hosting what looked like a public entertainment event without the relevant licence, and to swing into action. This kind of proactive, public-safety-minded enforcement stands in stark contrast to the popular stereotype of bureaucracies — that they go strictly by the book, that doing less means erring less. It is a model worth emulating across the rest of government.

Infiltration and Cunning: Undercover Agents, Cash in the Cardboard Box, Floor Plans from Memory

The Agreed Facts go on to state that the two FEHD inspectors signed up via the registration link in the Facebook post. On the evening of the event — 29 June last year, around 6:00 p.m. — the two inspectors arrived in plain clothes. There were about 50 audience members. Six performers took turns delivering jokes and using physical comedy, to frequent laughter from the audience. At 8:00 p.m., after a group photo, the event came to a close.

According to the case, the two undercover inspectors not only documented the event in detail and took 11 photographs — they each also dropped HK$100 into the cardboard box being passed around, like the moles in classic Hong Kong cinema who, to win the trust of the boss, are willing to dirty their own hands by committing the very crime they are investigating. The day after the event, the two inspectors drew, from memory, the floor plan of Book Punch — the key piece of evidence that cracked the case.

Those of us raised on Hong Kong cinema, with its long tradition of cop-and-mole thrillers — the kind that gave us Infernal Affairs, later remade by Scorsese as The Departed — tended to assume undercover work was reserved for triads and drug lords. It turns out it is also reserved for stand-up comedy nights.

Statutory Interpretation: A Bookstore Without a Stage Is a Stage After All

The prosecution and defence agreed on what happened. The dispute was over what the law meant.

Mr. Lawrence Lau Wai-chung SC, for the defence, argued that the Ordinance regulates “stage performance” — not “performance” as such. Citing both the Oxford English Dictionary (“a raised floor or platform… on which actors, musicians, etc. perform”) and the Cihai Chinese dictionary, he submitted that since Book Punch had no stage, what took place that day was not a “stage performance” within the meaning of the Ordinance. The narrowest interpretation, he argued, should apply — both because every word in a statute is presumed to have meaning, and because cultural activities enjoy constitutional protection under Hong Kong’s Basic Law.

After more than four hours of deliberation, Magistrate Mok Tsz-chung was unpersuaded. The legislation, he ruled, exists to protect public safety; reading it too narrowly would defeat that purpose. So long as a performance draws an audience, whether or not there is a literal stage is beside the point. He convicted on both summonses.


The Wang Fuk Court fire killed 168 people. Even though residents had complained beforehand about contractors colluding on tenders, district councillors collecting large numbers of authorised votes, scaffolding netting failing to meet standards, flammable enclosures, and construction workers smoking on site, no one was prosecuted on any of those counts and the disaster was not prevented. Some have accused various government departments of passing the buck and going through the motions. Yet the Book Punch case demonstrates so amply the initiative and execution of these very departments that any criticism of government incompetence collapses on its own.

Don’t take a single case as too small to reveal what these departments are capable of. This is, in fact, the third successful prosecution of Book Punch — after earlier convictions for selling alcohol without a licence and operating an unlicensed school (the latter for hosting a Spanish-language interest class). Each time, in matters that ordinary citizens would consider harmless trifles, the FEHD, the Education Bureau and others have managed to unravel the threads, descend on the premises by surprise, and — twice now — send in undercover agents. The judiciary, for its part, has played its part in securing convictions every time.

A fourth charge is pending. In March, Book Punch was raided again — this time by the National Security Police — over its sale of The Troublemaker, a biography of Jimmy Lai, the jailed pro-democracy media mogul whose own trial under the National Security Law has drawn international attention. Pong Yat-ming and three staff members were arrested for “knowingly selling a publication with seditious intention” and released on bail. Given the impressive performance government departments have shown in recent months, and their evident determination to safeguard public safety, what kind of future remains for Book Punch — and for Hong Kong’s other independent bookstores — is something the public can simply look on and see.

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