吳家俊 對 黃嘉錫及黃嘉霖破產人的產業共同及各別受託人

吳家俊 對 黃嘉錫及黃嘉霖破產人的產業共同及各別受託人

The trustees' assessment was amenable to variation because they failed to provide a reasonable allowance for the bankrupt's children and made a material factual error; the court will intervene to adjust the child maintenance allowance to HKD3,000 and increase approved monthly expenses to HKD17,346, as this is a...

Source-derived case information.

Citation
[2022] HKCFI 3401
Parties
Applicant (bankrupt): 吳家俊; Respondents (joint and Several Trustees): 黃嘉錫及黃嘉霖
Court
Court of First Instance
Jurisdiction
Hong Kong
Judgment Date
14 November 2022
Case Number
HCB6701/2021
Procedural Posture
Bankruptcy—application Under Bankruptcy Ordinance S83 / Hearing and Ruling (application to Vary Trustee's Assessment)
Outcome
Application allowed in part; trustees' assessment varied to increase child maintenance and approved expenses.
Legal Topics
Trustees' Discretionary Decisions, Assessment of Bankrupt's Income and Expenses, Child Maintenance Allowance, Judicial Review of Trustee Actions Under S83
Source Language
ch
Bankruptcy Family Law Civil Procedure Trustees' Discretionary Decisions Assessment of Bankrupt's Income and Expenses Child Maintenance Allowance Judicial Review of Trustee Actions Under S83

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Parties

吳家俊

Applicant (bankrupt)

黃嘉錫及黃嘉霖

Respondents (joint and Several Trustees)

Procedural Posture

Bankruptcy—application Under Bankruptcy Ordinance S83 / Hearing and Ruling (application to Vary Trustee's Assessment)

  1. 1 Whether the trustees' assessment of the bankrupt's monthly income and expenses (and resulting monthly contribution to the estate) was unreasonable such that the court should intervene under s83
  2. 2 Whether the amount allowed for child maintenance should be increased given the bankrupt's factual circumstances and trustees' error

Ratio Decidendi

The trustees' assessment was amenable to variation because they failed to provide a reasonable allowance for the bankrupt's children and made a material factual error; the court will intervene to adjust the child maintenance allowance to HKD3,000 and increase approved monthly expenses to HKD17,346, as this is a reasonable correction within the court's supervisory role under s83.

Court Disposition

Application allowed in part; trustees' assessment varied to increase child maintenance and approved expenses.

Orders

  • Increase child maintenance allowance from HKD0 to HKD3,000 per month
  • Approve total monthly expenses at HKD17,346