The question of family formation has emerged as the core of the struggle for gay rights, as evidenced by recent cases on same-sex marriage around the world. Long before the marriage debate, however, courts were already engaging with the relationship between homosexuality and family. This paper draws on theories of gay visibility to re-examine the Hong Kong case of Cho Man Kit v. Broadcasting Authority, and probes the ways in which the court's conceptualization of the family impacts upon its reasoning.
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