CLH GROUP (HK) LTD AND OTHERS v. STANDARD CHARTERED BANK AND ANOTHER

bjbj HCA 1622/2016 IN THE HIGH COURT OF THE HONG KONG SPECIAL ADMINISTRATIVE REGION COURT OF FIRST INSTANCE ACTION NO 1622 OF 2016 BETWEEN CLH GROUP (HK) LIMITED 1st Plaintiff HUNTER SOCKS & APPAREL 2nd Plaintiff INTERNATIONAL LIMITED WU WING CHE DEVEN 3rd Plaintiff WU TIK YAN TERENCE 4th Plaintiff EASE KEEN INTERNATIONAL LIMITED 5th Plaintiff and STANDARD CHARTERED BANK 1st Defendant STANDARD CHARTERED BANK 2nd Defendant (HONG KONG) LIMITED AND HCMP 2687/2016 MISCELLANEOUS PROCEEDINGS NO 2687 OF 2016 IN THE MATTER of the property known as ALL THAT one equal undivided 2,450th part or share of and in ALL THOSE pieces of parcels of ground registered in the Land Registry as SUBSECTION 1 OF SECTION E OF NEW KOWLOON INLAND LOT NO 5087, SUBSECTION 2 OF NEW KOWLOON INLAND LOT NO 5087 AND SUBSECTION 3 OF SECTION E OF NEW KOWLOON INLAND LOT NO 5087 And of and in the messuages erections and buildings thereon TOGETHER with the right to the exclusive use occupation and enjoyment of ALL THAT FLAT B on the ELEVENTH FLOOR OF NO 86 BROADWAY ( the Mortgaged Property ) and IN THE MATTER of an Indenture of Tripartite Legal Charge/Mortgage dated the 22nd day of March 2010 and registered in the Land Registry by Memorial No 10032502390154 ( the Mortgage ) and IN THE MATTER OF a Deed of Variation dated the 11th day of August 2011 and registered in the Land Registry by Memorial No 11082901690266 ( the Deed of Variation ) and IN THE MATTER OF banking facility letters from the plaintiff to the 3rd defendant dated 25th y 2016 and IN THE MATTER of Order 88 and Order 28 The Rules of the High Court BETWEEN STANDARD CHARTERED BANK Plaintiff (HONG KONG) LIMITED and EASE KEEN INTERNATIONAL LIMITED 1st Defendant HUNTER SOCKS AND APPAREL 2nd Defendant INTERNATIONAL LIMITED HUNTER SOCKS KNITTING FACTORY 3rd Defendant (H.K.) LIMITED AND HCMP 2688/2016 MISCELLANEOUS PROCEEDINGS NO 2688 OF 2016 IN THE MATTER of the property known as ALL THAT the estate right title benefit and interest of and in ALL THOSE 1,367 equal undivided 25,901,816th parts or shares of and in ALL THAT piece or parcel of ground registered in the Land Registry as KOWLOON INLAND LOT NO 11080 ( the Land ) And of and in the entire development constructed or to be constructed upon the Land pursuant to the Government Lease ( the Development ) TOGETHER with the sole and exclusive right and privilege to hold use occupy and enjoy ALL THOSE FLAT on the 26th FLOOR of Tower VII and Car Parking Space No ant CHONG LUEN HING GARMENTS LIMITED 3rd Defendant (Heard Together) Before: Deputy High Court Judge Le Pichon in Chambers Date of Hearing: 23 October 2017 Date of Decision: 6 November 2017 DECISION There are 3 parallel applications by summonses issued in 3 llectively the applicants ). At the conclusion of the hearing the decision was reserved which I now give. Background facts On 20 June 2016, the plaintiffs, namely, CLH Group (HK) Ltd ( ), Hunter Socks & Apparel International Limited ( Hunter ), Wu Wing Che Deven ( ), Wu Tik Yan Terence ( ) and Ease Keen International Limited ( Ease Keen ) commenced the writ action against Standard Chartered Bank ( the London bank ) and Standard Chartered Bank (Hong Kong) Limited ( SCBHK ) for rescission and/or damages in respect of certain foreign exchange derivative agreements ( the FX derivative agreements ) into which either CLH or Hunter had entered with the London bank. P3 and P4 are siblings (collectively the siblings ). P3 is the sole shareholder and director of CLH a company incorporated in Hong Kong engaged in the business of trading garment products. The siblings were all times equal shareholders and directors of another Hong Kong company, Hunter, engaged in the business of trading knitted socks. The siblings are also directors of Ease Keen, a Hong Kong company which is their vehicle for holding investment properties. According to the plaintiffs, since about 2010 SCBHK has been one of the main bankers for CLH, Hunter and also their related companies, namely, Hunter Socks Knitting Factory (HK) Ltd ( Hunter Knitting ) the 3rd defendant in the 1st mortgage action and Chong Luen Hing Garments Limited ( Chong Garments ) the 3rd defendant in the 2nd ster Agreement following oral representations made by one of SCBHK s representatives (Ms Tracy Cheng). The counterparty to the Master Agreement was the London bank. Hunter entered into a similar agreement on 12 May 2012. It was said that the representations made orally were to the effect that the FX derivative product was of extremely low risk and would help their trading businesses through reducing foreign exchange costs ( the 1st set of representations ). According to CLH/Hunter, in fact the FX derivative product was highly risky with unlimited downside risks when potential returns were capped. On 22 March 2010, SCBHK as lender, Ease Keen as mortgagor and Hunter Knitting as borrower entered into a tri-partite legal charge over a flat in Mei Foo Sun Chuen ( the flat ) owned by Ease Keen to secure all indebtedness owing by Hunter Knitting to SCBHK. It was subsequently varied by a deed of variation dated 11 August 2011 adding Hunter as additional borrower for facilities granted to Hunter which confirmed that the flat was security for all monies owed by Hunter Knitting and Hunter to SCBHK. On the same day, 22 March 2010, SCBHK as lender, Ease Keen as mortgagor, CLH and Chong Garments as borrowers entered into a similar tri-partite legal charge over a flat and car park situated in The Waterfront, 1 Austin Road West ( the Waterfront property ). Then over the course of 2010 to 2014, a succession of SCBHK s relationship managers represented on various occasions that the FX products would not affect the trade facilities of, inter alia, CLH and Hunter with SCBHK, that they were tailored to suit their requirements to pay PRC suppliers in CNY currency, drew parallels with other SCBHK s customers in the manufacturing/trading industry and assured them that there would be no downside risk for CNY even if it depreciated over time. They represented that the London bank or SCBHK would be prepared to roll over the FX derivative products thus deferring FX losses arising from any depreciation ( the 2nd set of representations ). Those representations were also said to be false. When CLH found itself unable to meet certain settlement obligations in relation to certain FX derivative transactions in February 2016, SCBHK s representatives initiated negotiations with the siblings for settlement and assured them that whilst the negotiations were ongoing, SCBHK would continue to support CLH and Hunter s businesses and would defer enforcement of the banking facilities ( the Assurance ). In early March, SCBHK also agreed to restructure the facilities extended to CLH and Hunter so that their combined financial resources could be considered together ( the Common Agreement ). The proposed restructure was more complicated than had been anticipated. On 23 March 2016, SCBHK came up with a global settlement proposal (that is to say, one that encompassed both the London bank and SCBHK) and requested documents for credit review. Meanwhile, in reliance on the Assurance and the Common Agreement that existing trade facilities would continue, CLH and Hunter had accepted new orders. The following events then occurred: SCBHK abruptly terminated all banking facilities of CLH and Hunter without notice on 1 April 2016, and demanded immediate repayment by CLH/Hunter; the London bank unilaterally terminated on 29 April 2016, the outstanding FX derivative agreements as of 4 May 2016, unilaterally assessing (on 10 May 2016) early termination costs (which were significant) against Hunter and CLH respectively; and SCBHK wrongfully debited the accounts of the sib ey would have been able to pay or settle any indebtedness as may have fallen due. The alleged indebtedness of CLH/Hunter had in fact arisen out of the wrongful acts of SCBHK. Approximately 4 months after the commencement of the writ action, on 6 October 2016, SCBHK brought the 2 mortgage actions, one against Ease Keen (the mortgagor) and Hunter and Hunter Knitting (the borrowers) and the other against Ease Keen (the mortgagor) and CLH and Chong Garments seeking to enforce the mortgages. The 3 summonses The plaintiffs consolidation summons seeks an order: that the writ action be consolidated with the 1st and 2nd mortgage actions with the writ action being the lead action; or that the 3 actions be tried at the same time; or that the writ action be tried in such manner as the court should think fit. In the 1st mortgage action, Ease Keen and Hunter (being respectively P5 and P2 in the writ action) seek an order that: the 1st mortgage action be stayed pending determination of the writ action; or alternatively the 1st mortgage action be converted into a writ action and the actions consolidated with the writ action being the lead action; or the 3 actions be tried at the same time; or the 1st mortgage action be tried immediately after the writ action before the same judge; or as the court may deem fit. In the 2nd mortgage action, the defendants (being respectively P5, P1 and Chong Garments) seek relief that is similar to the relief sought in the 1st mortgage action. In brief, the applicants case for consolidation i mortgage actions arise out of the same series of transactions. Mr Kok, counsel for the applicants submitted that, in any case, the 2 mortgage actions should be converted into writ actions because of the factual disputes involved. The applicants relied heavily on the judgment of DHCJ Sakhrani in DBS Bank (Hong Kong) Limited v Hunter Socks & Apparel International Limited & Ors, HCMP 2241/2016 (unreported, 4 DBS case alongside the statement of claim in the writ action. While there are minor differences in one or two respects mentioned below, they are immaterial for present purposes. In the DBS case, the judge held that DBS s claim under the mortgage action by an originating summons could not be summarily determined and ordered that (i) the originating summons should be converted into a writ action and (ii) the mortgage action be consolidated with the writ action for the determination of the disputes as to the relevant FX derivative agreements. The applicants seek similar relief. The London bank s opposition Mr Li, counsel for the London bank, explained that SCBHK is not a branch of the London bank. There is no parent/subsidiary relationship between the London bank and SCBHK. Both the London bank and SCBHK are HK licensed banks, held separately under Standard Chartered plc the listed entity in London. Mr Li took issue with the applicants submission that the operation of the FX derivative agreements was inextricably linked to the banking facilities granted by SCBHK to CLH/Hunter for their trading business. He sought to demonstrate that there was no such linkage from the operations of the accounts. The Hunter facility letter for example showed that SCBHK offered Hunter facilities for (1) overdraft; (2) trade finance; and (3) ot appear in the customer s bank statements. Whilst I would accept that loans for trade financing would not necessarily be routed through the customer s account, it does not mean that it never happened. As Mr Li fairly acknowledged, CLH s USD savings account statement for November 2015 shows a deposit made on 23 November that corresponds exactly to the amount advanced by SCBHK under the facility for trade finance. 2 other entries made on 24 corded under the column headed Description in the bank statement as regards the 3 deposits referred to in 26 above appear to be transaction references. What is striking is that all the transaction references start with the initials followed by a series of numbers which (possibly because of the proximity of the dates) are sequential. The other striking feature is that one finds the digits immediately after the initials and that the same series of 5 alphabet/numbers appear in each of the 3 deposits to which reference was made. In fact, a perusal of CLH s USD savings account statements that constitute exhibit WWCD-8 to P3 s affirmation dated 8 February 2017 reveal many other transaction references that commence with TF315 . It may be coincidental but one possibility is that could well be an abbreviation for a trade finance transaction and the 3 numbers immediately following (315) being referable to CLH s account for trade financing. There is no evidence regarding this at this stage. No doubt, when the matter goes further, an explanation will emerge. The court was then shown a typical FX derivative transaction confirmation the London bank had sent Hunter. Clause 3 provided for payment to Hunter in accordance with standard settlement instructions currently held by [the London bank] or as otherwise notified by [Hunter]. Mr Li explained that a FX derivative transaction is a contract. The settlement under a particular transaction takes place on the settlement date specified. Meanwh e following day. There is a handwritten annotation alongside that reads Net US$ 193,507.92 linking that amount to those 2 entries. It was accepted that that was one single instance of settlement under the FX derivative transactions that was done through Hunter s USD current account with SCBHK. Mr Li emphasised that settlements for FX derivative transactions were not tied to a particular bank account. Since the hearing, I have had the opportunity of considering exhibit WTYT-9 to P4 s 1st affirmation dated 8 February 2017 more fully. It comprises 7 monthly statements for Hunter s CNY and USD accounts including that referred to in 30 above. Similar manuscript annotations of differing amounts appear on each of those statements. As no submissions were made to show that those other manuscript annotations should not be similarly interpreted or that they are wrong and ought to be disregarded, there was clearly more than a single instance of a FX settlement made through Hunter s accounts with SCBHK. It was said that Hunter/CLH have refused to pay early termination costs and other FX losses from unsettled derivative transactions (which undeniably are payable under the terms of the Master Agreement and the FX transactions). Pausing here, it is to be observed that early termination costs are not penalties but an assessment of the loss/gain of a particular derivative transaction had it not been brought to a premature end. It involved an assessment of inter alia market trends subsisting at the time. While the early termination losses and other FX losses that had already occurred formed the subject matter of the London bank s claim in the writ action, it is to be observed that first, unlike the situation in the DBS case, the present case does not involve the type of rollover discussed at 48 of the DBS judgment and, secondly, they do not form part of and have nothing to do with the indebtedness that founds the mortgage actions. In connection with the latter observation, reference was made to the 2nd affirmation of Steven Li filed on behalf of SCBHK affirming that the indebtedness for the mortgage actions is not related to FX transactions. Mr Li submitted that his client would be prejudiced if consolidation were ordered. It was said that it would be wrong in principle for the London bank to have to sit through another party s dispute but if consolidation were to be ordered, there are at least 2 that it had granted 3 types of facilities only to CLH/Hunter: for trade finance, short-term money market loans and overdraft. The claims made in the mortgage actions stand alone and are in respect only of debts due and owing under the general banking facilities granted. It was said that the operations of the accounts show that SCBHK had made no advances in respect of forex transactions. It was then contended that the DBS case is distinguishable. First, in that case, all the transactions involved only a single bank whereas the present case involves two banking entities, namely, the London bank and SCBHK. As earlier noted, they are separate entities, each of which has a banking licence to operate in Hong Kong. Second, the total indebtedness upon which DBS founded its claim in the DBS case incorporated a FX claim (in respect of an early termination amount payable under the Master Agreement in the sum of US$2.6 million odd). That is not the case here. Insofar as the two-bank argument is concerned, there is no evidence to show that the applicants had any direct interface with anyone from the London bank. The introduction to the FX products from inception were made by staff of SCBHK. All contact, interface and communication the applicants ever had concerning FX derivative agreements were with SCBHK staff and not staff of the London bank, whether based in London or Hong Kong (if any). Other than the London bank being a signatory as the formal contracting party to the Master Agreement with Hunter/CLH and the fact that transaction confirmations and termination letters originated from the London bank or were issued by the London bank to Hunter/CLH, there is nothing in the hearing bundles to show any face to face dealings/contact between the applicants and the London bank and its staff. Then there are the tripartite legal charges. The recital shows that SCBHK was covenanting as trustee for itself and the other Secured Parties . That term is defined as including every SCB Group Company SCB Group Company is itself defined to mean each of [SCBHK], Standard Chartered Bank (including all its branches), the parent or any subsidiary or associated company of Standard Chartered Bank . It was accepted that the London bank is a Secured Party for the purposes of the legal charges. In those circumstances, the fact that, technically, the London bank and SCBHK are separate legal entities is neither here nor there and is not a sufficient basis for distinguishing the DBS case. As to the second distinction sought to be made, it is clear from 18 of the DBS case that while the alleged indebtedness claimed in that case included the FX early termination amount, DBS only sought summary determination in respect of the outstanding banking facilities and interest, and not as regards the FX early termination amount because the latter being an assessed amount involved a factual issue. While the judge in the DBS case considered that the court s jurisdiction under the rules enabled it to grant summary judgment in relation to part of the claim only (at 19) such that it was open to the court to make a summary determination in respect of the outstanding banking facilities and interest part of DBS s claim, nevertheless, he declined to do so on the basis that there were triable issues ( 82). In my view, that fact necessarily undermines the relevance and significance of the second distinction SCBHK sought to make. In my judgment, the 2 distinguishing factors do not materially affect the relevance of the DBS case for present purposes. As earlier noted, the applicants dispute the alleged indebtedness under the mortgage actions because it arose out of SCBHK s wrongful acts. The borrowers in the mortgage actions maintain that the extent of indebtedness under each of the 2 mortgage actions cannot be crystallised unless and until the FX disputes are finally resolved. The applicants submitted that the observations made in 71 of the DBS case are particularly relevant in the present context. At the hearing, Mr Khaw s principal argument concerned the issue of equitable set-off and cross claims arising from the FX disputes. The court was referred to Mobil Oil Company Limited v Rawlinson (1982) 43 P CR 221 which established that the existence of a cross claim even if it exceeds the amount of mortgage debt will not defeat the right to possession of the legal chargee. That principle applies to a cross claim which is a mere counterclaim or a cross claim for unliquidated damages. Reference was then made to National Westminster Bank plc v Skelto do not propose to rehearse here. Suffice it to briefly state what each case decided. Skelton was a case where the mortgagee creditor sued the mortgagors and the borrower and claimed possession from the mortgagors. The mortgage in Skelton contained a deeming provision to the effect that the mortgage was to be deemed to be a primary security and the mortgaged property was to be deemed to stand charged with monies/liabilities secured as if they were primarily due from the mortgagor. Skelton decided that: (1) a mortgagor on being sued by a mortgagee creditor for possession cannot avail himself of any right to set off or counterclaim available to the borrower (at 79H); (2) the effect of the deeming provision is that in any dispute between the bank and the mortgagors, it is not open to the mortgagors to rely on any right of cross-claim or set-off to which the principal debtor might be entitled as against the creditor bank (at 80B C). True Peace was a mortgage action brought by the bank against the mortgagors (D1 and D2) and the borrower (D3). The defendants sought to rely on D3 s equitable set-off claim as one of their defences. Yuen J (as she then was) did not consider that there was any equitable set-off made out on the facts before her and that as against D1 and D2 (the mortgagors) the Mobil Oil principle applied such that even if there was an equitable set-off, that was not a defence to the bank s claim for possession. What is clear is that Skelton did not decide that the defence of equita h0_a h sl h sl h sl hr}g gd8xm gd8xm gd sl gd0_a h sl hr}g hr}g h0_a h0_a h sl h sl hr}g hr}g hr}g h sl gd0_a h0_a h0_a gd?? gdK7 gdK7 gdK7 gdK7 gdK7 gdK7 yuyqyqybyqy[ gdK7 gdK7 gdK7 gdK7 gdK7 xix_ h%Q; gdK7 heA| xgUg h?Nl h?Nl hefm h?Nl h?Nl h?Nl h?Nl gd,Z gd,Z gd,Z gd;G ble set-off and/or a cross-claim is not available to a borrower. True Peace also did not decide that a borrower s equitable set-off claim can never be a defence in the mortgage action brought against the mortgagor and the borrowers. In that case the borrower failed because the borrower was unable to make out a prima facie case that it had an equitable set-off claim. As Mr Kok submitted, the present application is not for summary determination; rather, the application is for consolidation and/or conversion of the originating summonses in the mortgage actions into writ actions. I am satisfied that the borrowers in the present case are not precluded by either Skelton or True Peace from raising equitable set-off and/or a cross-claim by way of defence in the 2 mortgage actions. I would add one further point: although it was not pursued in oral argument, SCBHK s written submissions suggested that the present applications are premature. But given the terms of the Master s order dated 20 April 2017 that provided f in the mortgage actions. The applicants contention that the operation of the FX derivative agreements was inextricably linked to the banking facilities granted by SCBHK to the borrowers (Hunter/CLH) for their trading business is sufficiently borne out by the following: for the purposes of the legal charges, both SCBHK and the London bank are Secured Parties within the definition of that term; although the London bank was legally the party with whom the FX accounts and derivative transactions were entered into, the representations concerning FX products/derivative transactions were made to Hunter/CLH by SCBHK staff; in making the 2nd set of misrepresentations SCBHK staff made reference to trade facilities already granted by SCBHK and gave assurances that the FX derivative agreements would not affect trade facilities already provided; in connection with Hunter/CLH s difficulties in settling FX liabilities in February 2016, SCBHK staff gave assurances that trade facilities granted would not be affected; and while the trade finance advances and FX transactions were not tied to specific bank accounts as such, a number of such transactions did go through Hunter/CLH s various accounts held with SCBHK. I agree with the applicants that on the facts of the present case, it would be wrong in principle to allow the mortgage actions to proceed and determined before the writ action. That course would prejudge the issues to be determined at trial. As to how the matter should not proceed, I have considered the various options open to the court and make the following order: the mortgage actions (HCMP 2687/2016 and HCMP 2688/2016) be converted into writ actions; the writ action and the mortgage actions be tried before the same trial judge in such order and manner as he shall direct. For the purposes of carrying into effect 1 of order made herein, it is directed that in each of HCMP 2687/2016 and HCMP 2688/2016, the plaintiff do file its statement of claim within 28 days of this order; the defendants do file their defence(s) and counterclaim(s) (if any) within 20 days thereafter; the plaintiff do file its reply and defence to counterclaim (if any) within 28 days thereafter. The parties do comply with the provisions of Order 25, rule 1 of the Rules of Civil Procedure within 28 days of the close of pleadings of the writ action and the mortgage actions. The trial judge will be in a better position to address Mr Li s concern (see 36 above) when directions are given for trial. There is to be an order nisi that costs be in the cause. (Doreen Le Pichon) Deputy High Court Judge Mr Martin Kok, instructed by Yung & Au, for the 1st 5th plaintiffs (in HCA 1622/2016), the 1st and 2nd defendants (in HCMP 2687/2016) and the 1st defendants (in HCMP 2688/2016) Mr Richard Khaw SC, leading Mr Adrian Wong, instructed by Tsang, Chan & Wong, for the 2nd defendant (in HCA 1622/2016) and the plaintiff (in both HCMP 2687/2016 and HCMP 2688/2016) Mr Laurence Li, instructed by Eversheds, for the 1st defendant (in HCA 1622/2016) No PAGE - PAGE \* MERGEFORMAT - A B C D E F G H I J K L M N O P Q R S T U V A B C D E F G H I J K L M N O P Q R S T U V A B C D E F G H I J K L M N O P Q R S T U V A B C D E F G H I J K L M N O P Q R S T U V hc:O gd,Z gd0_a }umeu h0_a h0_a h8xm gdOA, &`#$ gdGO rb[b[b[b[b[b[b[b[b[b[ h8xm & #$ & #$ & #$ & #$ [Content_Types].xml _rels/.rels theme/theme/themeManager.xml K Y, sQ}# theme/theme/theme1.xml $O}) Xp90 +PHI| PP yu 9xu5 fs+W VF7H q=. 8}d- qyI@ j!Q_ jyV` |PZ+ T ""p < 4V O&x$ A8>v ;EUC n 8r *~P(5 .}x E /,EE\} theme/theme/_rels/themeManager.xml.rels 5 6?$Q K(M&$R(.1 [Content_Types].xmlPK _rels/.relsPK theme/theme/themeManager.xmlPK theme/theme/theme1.xmlPK theme/theme/_rels/themeManager.xml.relsPK <?xml version="1.0" encoding="UTF-8" standalone="yes"?> <a:clrMap xmlns:a="http://schemas.openxmlformats.org/drawingml/2006/main" bg1="lt1" tx1="dk1" bg2="lt2" tx2="dk2" accent1="accent1" accent2="accent2" accent3="accent3" accent4="accent4" accent5="accent5" accent6="accent6" hlink="hlink" folHlink="folHlink"/> [Content_Types].xml dlyLho ;d]6 yJ.; _rels/.rels fLV:* ]m@= T;GI b9`5 drs/e2oDoc.xml )x6K9SFB 9/L%:0 O&6I 3#zj 1*;? 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