Hong Kong Case Law: Decisions & Judgments

Topic

Administration of estate

Legal area

Court

6 May 2026

CHANG WING KA JOHN v. CHANG WING DEE AND ANOTHER

Citation

[2026] HKCFI 2570
Court

Court of First Instance
Case number

HCMP1791/2016

The court held that Kroll and C S Wong were engaged in breach of the 2021 CFI Orders and their fees were therefore improperly incurred and not chargeable against the applicant; Canadian property taxes must be apportioned among the three siblings so only the applicant's 1/3 share is withheld; taxed costs of trial and appeal are to be set off against the Allocatur sum and, after set off, the net of the two sets of costs is payable to the applicant; accounting miscalculations were corrected and the court directed immediate payment of the appropriate net sums with a residual amount to be retained…
6 May 2026

POON LOI CHEUNG DESMOND v. POON LOI TAK

Citation

[2026] HKCFI 2571
Court

Court of First Instance
Case number

HCMP1174/2025

Plaintiff was the successful party having obtained the substantive relief sought; defendant breached his duties as administrator by prolonged failure to provide inventory and accounts and by poor conduct in negotiations; therefore costs follow the event, defendant must personally bear the plaintiff's costs; costs assessed on indemnity basis; total summary assessment HK$150,000 payable within 14 days; costs of argument assessed at HK$75,000 on indemnity basis and ordered nisi to become absolute unless varied within 14 days.
24 Mar 2026

NG CHU WOH, ADMINISTRATOR OF THE ESTATE OF NG TING KA, deceased v. LAI SHUK CHING, ADMINISTRATOR OF THE ESTATE OF NG KOON PONG, deceased AND OTHERS

Citation

[2026] HKCFI 1674
Court

Court of First Instance
Case number

HCMP751/2025

The Beddoe order was refused because all beneficiaries are adults and sui juris, there were no sufficient countervailing considerations to justify estate-funded contested litigation, and the administrator could be acting unreasonably with respect to the dispute; accordingly it is not unjust that he should personally bear the risk of adverse costs and the estate should not be directed to fund the contested proceedings.
28 Nov 2025

LAM KA WAI REBECCA AND ANOTHER v. LAM JENNY, the administrator of the estate of LAM KAM WAI AND OTHERS

Citation

[2025] HKCFI 5849
Court

Court of First Instance
Case number

HCMP1014/2021

The Administrators were justified in issuing the Production Summons and obtaining the consent order; the 2nd Defendant failed to demonstrate he lacked possession, custody or power of the Requested Documents and cannot rely on equivocal pre-summons correspondence to obtain costs; accordingly the 2nd Defendant's application for costs is dismissed and there shall be no order as to costs of the Production Summons between the Administrators and the 2nd Defendant, with directions for further limited submissions on costs of the present application.
22 Jul 2025

WONG PETER MING CHUNG v. LEE ED

Citation

[2025] HKCFI 3187
Court

Court of First Instance
Case number

HCAP6/2023

On the evidence the 2nd IOU was a replacement of the original IOU and did not evidence any separate Disputed Loan; factually interest was waived from 2004 and subsequent payments were gratuitous; legally any claim for repayment or interest accrued on or soon after the loans in 2000 and is time‑barred under the Limitation Ordinance, so the Estate cannot enforce repayment; accordingly double probate was granted to Peter and declaratory relief on the loans was refused as academic.
20 May 2025

ANG JIMMY TJUN MIN v. KHOO CHUN KIM AND OTHERS

Citation

[2025] HKCFI 2106
Court

Court of First Instance
Case number

HCA17/2021

The Administrator must participate in HCA 16 as an Interested Party (subject to funding, indemnity and any Beddoe directions). There will be no stay of HCA 1449 or HCA 863. The Administrator must file and serve a statement of claim to adopt HCA 1449 or propose consolidated pleadings within six months (three months if no Beddoe application). Mother’s deposition is ordered and scheduled in two sessions (24-26 November and 2-4 December 2025) with detailed procedural directions; Try Together summonses adjourned sine die with liberty to restore after the Administrator files the statement of claim…
15 May 2025

YOUNG YVONNE v. YOUNG ERIC

Citation

[2025] HKCFI 2097
Court

Court of First Instance
Case number

HCMP1103/2018

The court ordered payment out of the HK$5,200,000 in court because the funds were held to preserve the estate for beneficiaries, the Plaintiff and Eve Young were each entitled to one third of the estate and there was no good reason to retain the sale proceeds; the interest on the paid-out portions was allocated to the recipients of those portions while remaining funds and interest were allocated to the Defendant; leave to discontinue was granted and, in the exercise of the court's discretion and having regard to fairness and the effective resolution of the dispute, no order as to costs was ma…
14 May 2025

KAN YUK SUM v. KAN YUK SHING (in his personal capacity and as the executor of the estate of Tam Lee Yau)

Citation

[2025] HKCFI 1999
Court

Court of First Instance
Case number

HCMP268/2023

Leave to discontinue granted; because the defendant defaulted in discharging executor duties by delaying production of supporting documents, the defendant must pay 80% of the costs of these proceedings personally to the plaintiff (party and party basis) to be summarily assessed, while costs incurred by the defendant in preparing and providing the supporting documents are payable by the estate to the defendant on trustee basis and summarily assessed; plaintiff's entitlement reduced to 80% because irrelevant partnership issues unnecessarily increased costs.
27 Feb 2025

CHU YUET BING v. CHAN KWAI HUNG AND OTHERS

Citation

[2025] HKCFI 797
Court

Court of First Instance
Case number

HCMP2206/2021

The Grant contained a fundamental error because the deceased had made a Will; the court accepted the copy as the true last will in the absence of the original which could not be located after reasonable enquiries, and therefore revoked the Letters of Administration and directed probate be granted to the executrices named in the Will.
3 Feb 2025

CHAN SIU MUI, the Co-Administratrix of the Estate of TAM KAM FAI FRANCIS, Deceased 對 TAM KOK PO PEARL及另三人

Citation

[2025] HKCFI 552
Court

Court of First Instance
Case number

HCA432/2019

Court accepted applicant's proof that she did not receive certain distributive shares and apportioned the HK and PRC intestate estates under Intestates' Estates Ordinance s4(3); court found Chan Siu Mui did not breach her co-administrator duties to the extent of incurring vicarious liability for Tam Lan Chi's failure to pay Hong Kong and Chinese estate shares, but both co-administrators bear responsibility for the shortfall in the PRC estate allocation; Nu Look share allotment/transfer and Hung Ka Pak's appointment were found invalid on the evidence presented; costs awarded as ordered.