Yuen v Li & Anor [2026] EWHC 532 (KB) (10 March 2026)

Yuen v Li & Anor [2026] EWHC 532 (KB) (10 March 2026)

The torts of conversion and trespass to goods do not apply to Bitcoin or other digital assets under current English law, as they are not tangible property. The claim in conversion is struck out. The claim in trespass to goods is provisionally not struck out, but the Claimant is given seven days to apply to amend the pleading; otherwise, it will be struck out. The Claimant is permitted to amend the claim to add other causes of action, including unjust enrichment, breach of confidence, misuse of private information, causing loss by unlawful means, and proprietary restitution/constructive trust.

Citation
[2026] EWHC 532 (KB)
Parties
Claimant: Ping Fai Yuen; First Defendant: Fun Yung Li; Second Defendant: Lai Yung Li
Jurisdiction
England and Wales
Judgment Date
10 March 2026
Procedural Posture
Civil Tort / Property / Interlocutory Applications: Amendment of Claim, Strike Out/summary Judgment, Security for Costs, Substituted Service
Outcome
Claim in conversion struck out; claim in trespass to goods provisionally not struck out (pending amendment); application to amend claim allowed; other applications (security for costs, substituted service) not finally determined in this extract.
Legal Topics
Conversion, Trespass to Goods, Unjust Enrichment, Proprietary Restitution, Constructive Trust, Breach of Confidence, Misuse of Private Information, Causing Loss by Unlawful Means, Digital Assets as Property, Amendment of Pleadings, Strike Out Applications
Property Law Tort Law Digital Assets Civil Procedure Conversion Trespass to Goods Unjust Enrichment Proprietary Restitution +7 more

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 4 Authorities cited 19 Party arguments 2 Amounts and remedies 2
Sign in to unlock

Parties

Ping Fai Yuen

Claimant

Fun Yung Li

First Defendant

Lai Yung Li

Second Defendant

Procedural Posture

Civil Tort / Property / Interlocutory Applications: Amendment of Claim, Strike Out/summary Judgment, Security for Costs, Substituted Service

Legal Issues

  1. 1 Whether the torts of conversion and trespass to goods apply to Bitcoin and other digital assets under English law
  2. 2 Whether the claim for causing loss by unlawful means is maintainable on the pleaded facts
  3. 3 Whether the claim should be struck out in whole or in part for disclosing no reasonable grounds

Ratio Decidendi

The torts of conversion and trespass to goods do not apply to Bitcoin or other digital assets under current English law, as they are not tangible property. The claim in conversion is struck out. The claim in trespass to goods is provisionally not struck out, but the Claimant is given seven days to apply to amend the pleading; otherwise, it will be struck out. The Claimant is permitted to amend the claim to add other causes of action, including unjust enrichment, breach of confidence, misuse of private information, causing loss by unlawful means, and proprietary restitution/constructive trust.

Court Disposition

Claim in conversion struck out; claim in trespass to goods provisionally not struck out (pending amendment); application to amend claim allowed; other applications (security for costs, substituted service) not finally determined in this extract.

Orders

  • Claim in conversion (paragraphs 24-27) struck out.
  • Claimant given seven days to apply to amend particulars of claim as to trespass to goods; otherwise, claim in trespass to goods (paragraphs 28-29) will be struck out.