Jailed democracy activist Chow Hang-tung accused Hong Kong's courts on Tuesday of criminalising speech and helping authorities erase the Tiananmen crackdown as she was convicted a second time for inciting people to commemorate the deadly event.

Chow, a 36-year-old lawyer who has represented herself at multiple court hearings with often fiery denunciations from the dock, is a former leader of the Hong Kong Alliance.

The now-disbanded group used to organise the city's huge annual candlelight vigils to mourn those killed in Beijing on June 4, 1989 when China sent troops to crush democracy protests.

Hong Kong police banned the last two vigils citing the coronavirus and security fears and the courts have already jailed multiple activists who defied that ban in 2020, including Chow.

Chow was also arrested on the morning of June 4 last year over two pieces she published calling on residents to light candles and mark the crackdown anniversary.

On Tuesday, a court sentenced her to 15 months in jail after ruling that her articles amounted to inciting others to defy the police ban.

"The message this verdict sends is that lighting a candle is guilty, that words are guilty," Chow told the court.

"The only way to defend free speech is to continue to express," she added.

"The real crime is to cover for murderers with laws and to delete victims in the name of state".

Hong Kong was formerly the only place in China where mass commemoration of Tiananmen was tolerated but Beijing has been remoulding the city in its authoritarian image after huge and sometimes violent democracy protests in 2019.

- History erased -

Chow has proved an outspoken defendant throughout her prosecutions.

She used her mitigation on Tuesday to read from the memoirs of families of people killed at Tiananmen.

That sparked a dressing down from magistrate Amy Chan, followed by applause among some in the public gallery. Chan then ordered police to take down the identity numbers of those who had applauded.

"The law never allows anyone to exercise their freedom by unlawful means," Chan ruled.

"She (Chow) was determined to attract and publish attention for the purpose of calling on the public to gather," she added.

During sentencing, magistrate Chan said Chow was "self-righteous", showed no remorse and used the courtroom to air her political views.

Chow was already serving a 12 month sentence for her earlier Tiananmen-related conviction but she will now be jailed for 22 months in total under the court's new calculation.

She has also been charged for national security crimes which carry up to life in prison.

Hong Kong Alliance leaders, including Chow, are among dozens of activists being prosecuted under the national security law which has criminalised much dissent.

A museum the group ran has been shuttered while multiple statues commemorating June 4 have been pulled down in recent weeks from university campuses.

An official campaign has also been launched to purge the city of "anti-China" elements and people deemed unpatriotic.

School and university courses are being rewritten to foster greater patriotism towards China while critical media outlets have raided by police and have shuttered.

In mainland China, censors have long scrubbed what happened at Tiananmen Square, both online and in the real world.

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