Hong Kong Case Law: Decisions & Judgments

Topic

Chabra injunction

Legal area

Court

6 Feb 2026

北京誠義豪泰投資管理有限公司 v. ZHANG YUPING (also known as CHEUNG YU PING) AND ANOTHER

Citation

[2026] HKCFI 925
Court

Court of First Instance
Case number

HCCT1/2025

Given unexplained timing and nature of the transfers of the Subject Shares to Fung, evidence that the 1st Defendant was insolvent or rendered insolvent, and a real risk that completion of the acquisition would enable dissipation of the Subject Shares, the court found sufficient merits and urgency and the lower risk of injustice lay in granting an interim-interim Chabra injunction against Fung pending substantive resolution.
28 Nov 2025

FREMERY RESOURCES LTD AND ANOTHER v. CHAN KAM PING AND ANOTHER

Citation

[2025] HKCFI 5899
Court

Court of First Instance
Case number

HCA1727/2025

The court held that the 1st Plaintiff had a good arguable case that the Husband, by diverting commissions into entities and accounts he controlled, breached fiduciary duties and misappropriated company assets; there was a real risk of dissipation and the balance of justice favoured preservation. Accordingly the court granted a local and worldwide Mareva injunction against the Husband for USD 12,293,822.50, a Chabra injunction against the 2nd Defendant for USD 12,293,822.50, and an interlocutory proprietary injunction in favour of the 1st Plaintiff over USD 7,440,496.50 (being the diverted US$…
1 Aug 2025

CHINA EVERGRANDE GROUP (IN LIQUIDATION) v. HUI KA YAN AND OTHERS

Citation

[2025] HKCFI 3470
Court

Court of First Instance
Case number

HCA551/2024

On the materials before the Court the plaintiff established a good arguable case that the assets registered in Ms He's name are in reality owned, funded and controlled by CEO Xia, that those assets would be amenable to process enforceable against him, and that there is a real risk of dissipation; accordingly the Court exercised its Chabra jurisdiction, granted leave to join Ms He as 8th defendant, made the Chabra injunction and related orders including service out of jurisdiction and confidentiality measures.
30 Jul 2025

成都浣花驿科技有限公司 v. LI JIE AND ANOTHER

Citation

[2025] HKCFI 3261
Court

Court of First Instance
Case number

HCMP1035/2025

Because the Mainland judgment had been registered and was enforceable in Hong Kong, the plaintiff demonstrated a good arguable case, identifiable assets within Hong Kong (net sale proceeds of the Property), and an objectively real risk of dissipation based on D1's control of D2 and adverse enforcement history; accordingly the court exercised its Mareva and Chabra jurisdictions to freeze assets and order disclosure, balancing convenience in favour of the judgment creditor.
29 Apr 2025

周惠明 v. KWOKPING SUN

Citation

[2025] HKCFI 1503
Court

Court of First Instance
Case number

HCCT99/2024

On the evidence the court was satisfied there was a real risk of dissipation and inadequate disclosure by Sun and Noxin (including suspicious post‑award transfers, non‑disclosure of proceeds and securities, and failure to cooperate with Special Managers); Zhang prima facie held shares as nominee for Sun; therefore the Mareva injunction should be continued, Chabra relief granted against Zhang, interim receivers should be appointed over the relevant assets to preserve them for enforcement, and the Setting Aside Summons dismissed with indemnity costs.
29 Apr 2025

周惠明 v. 挪信新能源科技 (南通) 有限公司 AND ANOTHER

Citation

[2025] HKCFI 1503
Court

Court of First Instance
Case number

HCCT96/2024

In a post-judgment context and on the balance of probabilities at an interlocutory stage the Court accepted that Zhou established a real risk of dissipation by reason of inadequate and inaccurate disclosure, evidence of actual disposals and transfers timed after the awards, failures to cooperate with Special Managers and opaque asset positions corroborated by the Special Managers’ Report and auditors' disclaimed opinions; the existing Mareva injunctions were therefore inadequate to protect the judgment creditor and it was just and convenient to continue the Mareva injunctions, grant Chabra re…
29 Apr 2025

周惠明 v. KWOKPING SUN AND ANOTHER

Citation

[2025] HKCFI 1503
Court

Court of First Instance
Case number

HCCT97/2024

On the evidence, including the Special Managers' Report and conduct of Sun and Noxin (opaque and incomplete disclosure, suspicious transfers to nominee entities, unexplained disposal and withholding of sale proceeds), there is a genuine risk of dissipation and the existing Mareva injunctions are inadequate to protect enforcement; accordingly the Mareva injunctions were continued and interim receivers appointed over Sun and Noxin’s assets and over Zhang’s interests in Bright Praise and Right Victory; the Setting Aside summons was dismissed and indemnity costs awarded to the applicant.
7 Mar 2025

深圳澳銀天使創業投資企業 (有限合伙) AND ANOTHER v. LIU XIAOLONG AND ANOTHER

Citation

[2025] HKCFI 959
Court

Court of First Instance
Case number

HCMP1801/2023

Court found plaintiffs demonstrated a good arguable case and real risk of dissipation by the 1st and 2nd defendants; continued and granted a Mareva injunction against the 1st defendant up to RMB 11,897,850.91; refused to vary the Mareva injunction to permit maintenance payments absent cogent evidence; granted a Chabra injunction against the 2nd defendant limited to the 1st defendant's half share of the property with specified relaxations (rental income allowed) and procedural steps to agree final wording; dismissed the 2nd defendant's summons and made costs orders on a nisi basis.
17 Feb 2025

DIAMOND TREASURE LTD v. MAN KAM LEUNG AND ANOTHER

Citation

[2025] HKDC 264
Court

District Court
Case number

DCCJ4419/2014

The court joined the 1st respondent for costs purposes (first stage) because the application was not an abuse or unduly delayed, but on the second stage dismissed the plaintiff's application: the plaintiff failed to prove the 1st respondent was the real party or that there was serious impropriety/bad faith causatively linked to incurring the costs; adverse possession defence had legal foundation; allegations of asset dissipation were disputed and outside the litigation period and could not support a non‑party costs order in the interest of justice; therefore no non‑party costs order made agai…
17 Mar 2023

CINDA FUND MANAGEMENT CO LTD v. YIHUA LIFESTYLE TECHNOLOGY CO LTD AND ANOTHER

Citation

[2023] HKCFI 1110
Court

Court of First Instance
Case number

HCMP370/2023

Because the evidence as to the defendants' available funds and disclosures was incomplete and because removing §§11 and 12 risked depriving D2 of the opportunity to defend the injunction, the court declined to vary those provisions at this stage and instead continued the injunction and imposed a strict timetable and directions to enable substantive resolution.