CASPIAN RESOURCES DEVELOPMENT PTE LTD v. FORTUNE OIL PLC AND OTHERS

CASPIAN RESOURCES DEVELOPMENT PTE LTD v. FORTUNE OIL PLC AND OTHERS

The appeal is allowed: the default rule on foreign law did not apply because Singapore law was not pleaded; the relevant parts of the Hong Kong Companies Ordinance are domestic and do not automatically bar continuation of taxation against a foreign company struck off abroad; the exercise of judicial discretion...

Source-derived case information.

Citation
CASPIAN RESOURCES DEVELOPMENT PTE LTD v. FORTUNE OIL PLC AND OTHERS
Parties
Plaintiff: Caspian Resources Development Pte Limited; 1st Defendant: Fortune Oil Plc; 2nd Defendant: Giant Global Development Limited; 3rd Defendant: George Howard Richmond (also known as Giorgi Mgaloblishvili)
Court
Court of First Instance
Jurisdiction
Hong Kong
Judgment Date
13 October 2015
Case Number
HCA605/2012
Procedural Posture
Civil Taxation of Costs and Company Deregistration Issue / Appeal From Master's Decision
Outcome
Appeal allowed
Legal Topics
Deregistration/striking Off, Restoration of Company, Default Rule on Foreign Law, Security for Costs, Taxation of Costs
Source Language
en
Company Law Conflict of Laws Civil Procedure Costs and Taxation Deregistration/striking Off Restoration of Company Default Rule on Foreign Law Security for Costs +1 more

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Parties

Caspian Resources Development Pte Limited

Plaintiff

Fortune Oil Plc

1st Defendant

Giant Global Development Limited

2nd Defendant

George Howard Richmond (also known as Giorgi Mgaloblishvili)

3rd Defendant

Procedural Posture

Civil Taxation of Costs and Company Deregistration Issue / Appeal From Master's Decision

  1. 1 Whether court may proceed with taxation against a foreign company struck off the register without restoration
  2. 2 Whether the court should exercise its discretion to stay proceedings or enter judgment despite deregistration
  3. 3 Whether the default rule (presuming foreign law equals lex fori when foreign law not proved) applies where foreign law is not pleaded

Ratio Decidendi

The appeal is allowed: the default rule on foreign law did not apply because Singapore law was not pleaded; the relevant parts of the Hong Kong Companies Ordinance are domestic and do not automatically bar continuation of taxation against a foreign company struck off abroad; the exercise of judicial discretion favored permitting the defendants to proceed with taxation and related applications rather than requiring restoration in Singapore given the plaintiff's conduct and the inutilty and cost of requiring restoration.

Court Disposition

Appeal allowed

Orders

  • Leave to appeal out of time granted
  • Taxation proceedings and all incidental applications are permitted to be carried on