Hong Kong Case Law: Decisions & Judgments

Topic

Centre of main interests (comi)

Legal area

Court

10 Mar 2026

RE KEVIN BRIAN LAWRENCE, THE LIQUIDATOR OF LUXHOLDCO GARDIEN S.C.A. (IN LIQUIDATION IN LUXEMBOURG)

Citation

[2026] HKCFI 1472
Court

Court of First Instance
Case number

HCMP276/2026

The court recognized the liquidator's appointment and granted the requested ancillary powers because the Company's voluntary liquidation in Luxembourg is a collective insolvency proceeding, the Company's COMI is in Luxembourg, the assistance sought was necessary to administer the Company's Hong Kong assets, and the powers sought were consistent with Hong Kong substantive law and public policy and aligned with the standard-form order.
11 Dec 2025

RE DOINGCOM INTERNATIONAL LTD (in liquidation)

Citation

[2025] HKCFI 6221
Court

Court of First Instance
Case number

HCMP2076/2025

The court concluded that all Cooperation Mechanism criteria were satisfied (applicants are Hong Kong liquidators; Xiamen is a pilot area; Doingcom’s COMI is Hong Kong; substantial assets and records are in Xiamen; assistance is necessary) and therefore it was appropriate to issue a letter of request to the Xiamen Bankruptcy Court to recognise the liquidators and to seek assistance to exercise the stated statutory powers under Hong Kong law in the Mainland to enable performance of their duties.
11 Dec 2025

RE ECOGREEN FINE CHEMICALS GROUP LTD (in creditors’ voluntary liquidation)

Citation

[2025] HKCFI 6222
Court

Court of First Instance
Case number

HCMP2075/2025

The court granted the letter of request because the Liquidators satisfy the requirements for a Mainland pilot‑court request: they are duly appointed Hong Kong liquidators, Hong Kong is the COMI, the requested court (Xiamen) is a pilot area where the principal assets and disputed accounts are located, and recognition and assistance are necessary for the Liquidators to secure assets, access books and records, investigate significant discrepancies and participate in Mainland insolvency proceedings; the proposed powers sought are consistent with CWUMPO and prior Hong Kong authorities and therefor…
15 Jul 2024

RE PPLIVE SPORTS INTERNATIONAL LTD (in liq)

Citation

[2024] HKCFI 1850
Court

Court of First Instance
Case number

HCMP612/2024

The court granted the letter of request because the liquidators met the Cooperation Mechanism criteria: they are Hong Kong liquidators seeking assistance from a Mainland pilot court; the Company’s COMI is Hong Kong for more than six months; the Company holds principal assets and potential claims in Shanghai; and recognition and assistance are necessary to obtain information, secure assets and pursue recoveries in the Mainland where banks and parties will not cooperate without a Mainland court order.
25 Nov 2022

RE JOINT AND SEVERAL PROVISIONAL LIQUIDATORS OF RZ3262019 LTD (IN PROVISIONAL LIQUIDATION IN THE BRITISH VIRGIN ISLANDS)

Citation

[2022] HKCFI 3602
Court

Court of First Instance
Case number

HCMP1775/2022

The Hong Kong court will grant a limited degree of recognition and assistance to provisional liquidators appointed in the BVI even where the company's COMI is not in the BVI, on the basis of private international law; accordingly the court recognised the BVI-appointed joint provisional liquidators as authorised agents of the company in Hong Kong with the specific powers set out in the order and directed that the costs of the application be paid as an expense of the provisional liquidation.
5 Aug 2022

RE SILVER BASE GROUP HOLDINGS LTD

Citation

[2022] HKCFI 2386
Court

Court of First Instance
Case number

HCCW385/2021

The court exercised its discretion under section 327 Cap 32 to order the winding up of Silver Base Group Holdings Limited in Hong Kong because the three core criteria were satisfied: the company’s listing in Hong Kong gave a sufficient connection, there was a reasonable prospect that a Hong Kong winding up would benefit the petitioner (assets and cash in bank in Hong Kong and the Cayman liquidators accepting Hong Kong liquidation), and there were creditors in Hong Kong over whom the court can exercise jurisdiction; accordingly the winding up order was made and cost orders were given; no order…
5 Aug 2022

RE CHAN PUI SZE AND OTHERS

Citation

[2022] HKCFI 2386
Court

Court of First Instance
Case number

HCMP859/2022

The Court ordered the company wound up in Hong Kong under section 327 Cap 32 because the three core criteria were satisfied: the company’s listing on the Hong Kong Stock Exchange established sufficient connection; there was a reasonable prospect that a Hong Kong winding up would benefit the petitioner because assets and cash are in Hong Kong and the Cayman liquidators considered a Hong Kong liquidation necessary; and there are creditors within Hong Kong over whom the Court can exercise jurisdiction. The Court also declined to make any order in relation to the Recognition Application and order…
4 Jul 2022

RE THE JOINT PROVISIONAL LIQUIDATORS OF SEAHAWK CHINA DYNAMIC FUND (in provisional liquidation in the Cayman Islands)

Citation

[2022] HKCFI 1994
Court

Court of First Instance
Case number

HCMP503/2022

Because the appointment concerned a solvent liquidation, the common law principles derived from modified universalism were not engaged; instead principles of private international law govern and permit recognition of the Cayman Court appointment so that the JPLs may act as the company's agents in Hong Kong. COMI considerations relevant to foreign insolvency recognition do not apply to recognition of powers of liquidators of a solvent company. Accordingly the Hong Kong court granted the declaratory and ancillary relief sought confirming the JPLs' Hong Kong powers as set out in the Cayman appoi…
23 Jun 2022

PROVISIONAL LIQUIDATOR OF GLOBAL BRANDS GROUP HOLDING LTD (IN LIQUIDATION) v. COMPUTERSHARE HONG KONG TRUSTEES LTD AND ANOTHER

Citation

[2022] HKCFI 1789
Court

Court of First Instance
Case number

HCMP644/2022

The court recognised the Bermuda provisional liquidator and granted limited assistance—powers to secure documents and to receive and transfer the Hong Kong bank balances—because the liquidator’s authority as the company’s lawful agent under private international law and the principles of modified universalism entitled him to managerial assistance to collect local assets; full statutory powers under the Ordinance cannot be conferred by the common law, and future common law recognition and assistance should be primarily guided by the company’s COMI subject to narrow exceptions.
6 Apr 2022

RE HONG KONG FRESH WATER INTERNATIONAL GROUP LTD (IN LIQUIDATION) (“COMPANY”)

Citation

[2022] HKCFI 924
Court

Court of First Instance
Case number

HCMP300/2022

The Court granted the letter of request because the Liquidators demonstrated a pressing need to obtain recognition and assistance in Shanghai to protect and collect the Company's substantial Mainland assets, the Cooperation Mechanism and SPC Opinion requirements were met, and the Company's COMI was properly situated in Hong Kong, thereby justifying issuance of the letter of request under the Court's inherent jurisdiction.