Hong Kong Case Law: Decisions & Judgments

Topic

Bank disclosure orders

Legal area

Court

11 Mar 2026

LEUNG YIN MING v. BANK OF COMMUNICATIONS (HONG KONG) LTD AND ANOTHER

Citation

[2026] HKCFI 1594
Court

Court of First Instance
Case number

HCMP2/2026

Court granted disclosure because there was cogent prima facie evidence of fraud, a real prospect that the requested bank statements and last known addresses would materially assist in tracing and preserving the misappropriated HK$4,712,235.82, the documents sought were specifically defined and limited to the relevant transfer period, and the balance of interests (including the Banks' neutral position) favoured disclosure.
14 Jul 2025

CHAN CHING MAN v. LIVI BANK LTD

Citation

[2025] HKDC 1097
Court

District Court
Case number

DCMP1499/2025

The court exercised jurisdiction under s21 of the Evidence Ordinance and, applying the established s21 criteria, found the plaintiff had shown a real prospect that disclosure would lead to locating or preserving the allegedly misappropriated funds, that the documents sought were sufficiently specific, and that the public and private interests favored disclosure; accordingly a disclosure order was granted in the terms specified in the draft order.
12 Nov 2024

JIN ZIKAI v. GRIFFIN INTERNATIONAL HOLDING LTD AND ANOTHER

Citation

[2024] HKDC 1914
Court

District Court
Case number

DCMP480/2024

The court granted the s21 disclosure order because there was strong documentary evidence of fraudulent transfers from the plaintiff to the first tier account and onward to defendants, the requested information was specific and targeted to tracing and preserving assets, and the Bank adopted a neutral stance without substantive objection apart from a reasonable compliance period; the balance of interests favoured disclosure.
10 May 2024

ATLAS CORP v. LI XIONGHUA AND ANOTHER

Citation

[2024] HKDC 750
Court

District Court
Case number

DCCJ2408/2024

The court found the s21 criteria satisfied: the requested bank records were specified with sufficient particularity, there was a real prospect they would lead to the location or preservation of assets subject to the plaintiff's proprietary claim, and the balance of prejudice favored disclosure; accordingly the disclosure orders against the three banks were granted (with the relevant date fixed at 19 March 2024) and the proprietary and top-up Mareva injunctions were continued until and including 5 July 2024; costs of the summons were reserved.
2 May 2024

BAI LING XIN v. LEUNG HO KWAN AND ANOTHER

Citation

[2024] HKDC 732
Court

District Court
Case number

DCCJ2129/2022

The court found cogent and compelling evidence from prior disclosure and remittance records that plaintiff's funds were transferred into the named bank accounts; the documents sought were specific and necessary to trace and preserve assets; the banks raised no substantive objection and took neutral stances; balancing privacy and burden against the plaintiff's legitimate proprietary claim, disclosure orders under s21 EO or Norwich Pharmacal were justified and should be granted with costs directions.
4 Dec 2019

SBM BANK (MAURITIUS) LTD v. WARNER TRADING LTD AND OTHERS

Citation

[2019] HKCFI 2956
Court

Court of First Instance
Case number

HCA2416/2018

On the pleaded facts and evidence the court was satisfied the money received by the defendants originated from the plaintiff by fraud and that the defendants either participated or held the sums on constructive trust; default judgment and declarations were necessary to protect the plaintiff's proprietary rights and enable tracing; vesting orders under s52 TO and joinder of banks were appropriate to give effect to the proprietary claim where direct compliance by defendants might not occur; uncertainty as to current balances in accounts held with Heng Sang Bank required adjourning orders as to…

Hong Kong Case Law

LEUNG YIN MING v. BANK OF COMMUNICATIONS (HONG KONG) LTD AND ANOTHER

CHAN CHING MAN v. LIVI BANK LTD

JIN ZIKAI v. GRIFFIN INTERNATIONAL HOLDING LTD AND ANOTHER

ATLAS CORP v. LI XIONGHUA AND ANOTHER

BAI LING XIN v. LEUNG HO KWAN AND ANOTHER

SBM BANK (MAURITIUS) LTD v. WARNER TRADING LTD AND OTHERS