Amendments introduced by individual provisional legislators to government bills are invalid and likely to be challenged in the courts, Gladys Li told the appeal judges. She said this was one of the consequences of the shadow body's failure to comply with requirements set down in a decision by the National People's Congress in 1990. In order for the changes to bills to be valid, they must have been voted on by legislators elected in functional and geographical constituencies, Ms Li said. 'This emphasises how the provisional legislature on the face of it is a body which is invalid, incompetent and unable to pass or to fulfil the requirements of procedures for the making of bills,' she told the court. The decision of the NPC, included in an annexe to the Basic Law, set out voting procedures for the first legislative council of the SAR. The decision says: 'The passage of motions, bills or amendments to government bills introduced by individual members of the Legislative Council shall require a simple majority vote of each of the two groups of members present.' These groups are defined as 'members returned by functional constituencies and those returned by geographical constituencies through direct elections and by the Election Committee'.