JIU RONG HOLDINGS LTD v. SIU CHI MING

JIU RONG HOLDINGS LTD v. SIU CHI MING

The defendant failed to provide full particulars of assets as at 25 September 2023 (notably the Bank of China securities account balance and the Bank of China savings account balance as at that date); his explanations were inadequate and the omission persisted for over two years, warranting an unless order requiring a further affirmation by 12 December 2025 and the sanction of striking out the Defence if non‑compliant; costs to be paid by the defendant (order nisi and summary assessment).

Citation
[2025] HKCFI 5847
Court
Court of First Instance
Jurisdiction
Hong Kong
Judgment Date
28 November 2025
Case Number
HCA1331/2023
Procedural Posture
High Court Interlocutory Proceedings: Ancillary Disclosure Application Under Mareva Injunction / Paper Disposal; Application for Unless Order and Sanctions
Outcome
Unless order made: defendant ordered to file Further Affirmation by 4pm on 12 December 2025; failure to comply will result in striking out of the Defence; costs ordered nisi in favour of the plaintiffs with summary assessment on paper.
Legal Topics
Unless Order, Ancillary Disclosure, Striking Out for Non Compliance, Non Party Disclosure
Source Language
EN
Civil Procedure Injunctions (mareva/freezing) Disclosure/discovery Costs Unless Order Ancillary Disclosure Striking Out for Non Compliance Non Party Disclosure

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Procedural Posture

High Court Interlocutory Proceedings: Ancillary Disclosure Application Under Mareva Injunction / Paper Disposal; Application for Unless Order and Sanctions

Legal Issues

  1. 1 Whether there has been full compliance with the Disclosure Order dated 11 September 2023
  2. 2 Whether an unless order is appropriate as remedy for non-compliance
  3. 3 What sanction is proportionate (including whether to strike out the Defence)

Ratio Decidendi

The defendant failed to provide full particulars of assets as at 25 September 2023 (notably the Bank of China securities account balance and the Bank of China savings account balance as at that date); his explanations were inadequate and the omission persisted for over two years, warranting an unless order requiring a further affirmation by 12 December 2025 and the sanction of striking out the Defence if non‑compliant; costs to be paid by the defendant (order nisi and summary assessment).

Court Disposition

Unless order made: defendant ordered to file Further Affirmation by 4pm on 12 December 2025; failure to comply will result in striking out of the Defence; costs ordered nisi in favour of the plaintiffs with summary assessment on paper.

Orders

  • Defendant to file and serve by 4pm on 12 December 2025 a Further Affirmation giving value, location and details of all assets in Hong Kong of individual value HK$50,000 or more as at 25 September 2023 and particulars of any dealings/dispositions/encumbrances since 25 September 2023.
  • Unless the defendant complies with the Disclosure Obligation by 4pm on 12 December 2025, his Defence shall be struck out and the plaintiff shall be at liberty to enter judgment against the defendant.