ACTING Chief Secretary Michael Leung Man-kin yesterday denied the Government's planned all-embracing broadcasting bill had been shelved. It was, he said, still in the drafting stage. Yet the day before, the Acting Secretary for Recreation and Culture, Fred Ting Fook-cheung, made it clear the bill had been put on hold. The two statements need not be contradictory: drafting can be a slow, stop-go process when the Government is in no hurry to complete the job. Yet the statements do point to problems in the Government's approach to the legislation - and to China. Mr Ting has clearly been told to leave future statements to the Government's public relations managers. But his warning to legislators not to hope the bill would be presented soon should probably still stand. Broadcasting legislation is complex, not least because of the sensitivity of such areas as media-ownership and freedom of expression. Broadcasting technology moves so quickly that regulators keep pace only by avoiding the technological side of programme delivery. Moreover, as Mr Ting indicated before he was silenced, the real difficulties start when the time comes to consult China. Getting to that stage demands a conviction which the Government lacks. The episode bears the hallmarks of an administration in disarray. With more than 180 pages already drafted, it is hard to believe the Government does not know which parts of the bill will be controversial. But the longer it hesitates, the more thoroughly the bill will have to be redrafted to take account of new developments. The alternative, at which Mr Leung hinted, is to put aside the idea of a consolidated broadcasting bill and focus on dealing with urgent developments through existing legislation. This pragmatic approach has a certain attraction. The question the administration (and China) should be asking, however, is whether confrontation is necessary in the first place. Mr Ting, at least, seems to think that in the current atmosphere of distrust, even the most innocuous legislation put to Beijing will take years to process. He may be right. But if the consultation process does not even begin until 1997, it will take until 1999, or later, to complete. The danger of that approach is that every department will stop work on any bill requiring consultation for fear of stonewalling from the Chinese. If that happened, accusations of Government paralysis would begin to ring true. If there are sensitive questions to discuss, then the sooner talks start, the better. However, to do so would require a more co-operative mood on both sides. At present the Chinese side does not even know what the bill is to cover. If the British Joint Liaison Group team dared to hope its Chinese counterparts might approach the draft in the workmanlike spirit in which it was intended, the drafting might be ready within weeks. But distrust breeds distrust; a spirit of co-operation may, eventually, breed co-operation. Suspending work on important legislation is not the best way to nurture that spirit.