Hong Kong Case Law: Decisions & Judgments

Topic

Committal

Legal area

Court

6 May 2026

LI XIAO YI v. TANG CHUNG WAH (also known as ALAN CHUNG WAH TANG)

Citation

[2026] HKCFI 2649
Court

Court of First Instance
Case number

HCMP406/2025

The defendant failed to demonstrate exceptional circumstances to justify adjourning the trial because the pending appeal applications were not pursued diligently, their outcomes were unlikely to materially affect the contempt issues, the recusal application had already been dismissed as not reasonably arguable, and the interests of timely determination and court scheduling outweighed the defendant's grounds for delay; accordingly the adjournment application was dismissed and costs nisi ordered.
6 Mar 2026

嘉信大廈業主立案法團 v. 張笑媚

Citation

[2026] HKCA 312
Court

Court of Appeal
Case number

CACV33/2026

Section 50 of the High Court Ordinance applies to appeals from the Lands Tribunal in contempt cases so no leave was required; on the evidence the only reasonable and irresistible inference was that the respondent remained in control, custody or possession of the IO documents and properties and intentionally disobeyed the Delivery Up Order, therefore contempt was proved beyond reasonable doubt; the sentencing exercise was not wrong in principle and the custodial sentence was justified; costs awarded on indemnity basis.
13 Feb 2026

SECRETARY FOR JUSTICE v. MAN’S (ASIA) DEVELOPMENT LTD AND ANOTHER

Citation

[2026] HKCFI 774
Court

Court of First Instance
Case number

HCMP128/2025

The court held that the Statement of Facts was sufficiently particular, any non-disclosure was not material to the grant of leave, D1 breached the demolition and vacant possession order and D2, as sole director, wilfully failed to take reasonable steps to ensure compliance by D1 (inadequate supervision and failure to ensure statutory approvals were obtained), and accordingly contempt was established against both D1 and D2.
11 Dec 2025

LAM SIU SUN DENNIS AND ANOTHER v. TAM MAN CHUN AND ANOTHER

Citation

[2025] HKCFI 6197
Court

Court of First Instance
Case number

HCMP1092/2024

The originating summons was dismissed because (1) the ex parte leave to commence committal related only to breaches existing at the time of the leave and the specific discovery order as first made did not bear a penal notice, so the procedural prerequisites for enforcement were not met and the committal proceedings were misconceived; and (2) independently, the alleged non‑compliance and affirmational inaccuracies were trivial, not shown to be dishonest or to cause serious prejudice, and committal would be oppressive and disproportionate; costs were awarded to defendants on indemnity basis.
31 Oct 2025

YAN MEI and YAN DONG the Joint and Several Administrators of the Estate of FONG LAP CHUNG GEORGE, Deceased AND ANOTHER v. FONG LAP SHAN

Citation

[2025] HKCFI 5287
Court

Court of First Instance
Case number

HCA1562/2022

The court refused to grant an unless order that would dismiss the plaintiffs' claim because the defendant had not first sought less draconian enforcement measures and unless orders should be a last resort; nevertheless, because the 1st Plaintiff repeatedly breached the interim payment order and provided no adequate excuse, the court ordered payment of the outstanding sum of HK$460,538 within 21 days and refused the plaintiffs' application to file further affirmation.
10 Oct 2025

CREATE TOGETHER TECHNOLOGY CO., LTD v. KONG HOK FUNG

Citation

[2025] HKCFI 4965
Court

Court of First Instance
Case number

HCMP2295/2024

The Defendant committed deliberate breaches of the Mareva injunction by intentionally causing withdrawals and transfers from Welltec accounts while the injunction was in force; he admitted contempt; mitigation was limited to admission and apology; immediate custodial sentence is justified and appropriate; Defendant sentenced to 2 months' imprisonment and ordered to pay the Plaintiff's costs assessed at HK$500,000 payable within 28 days.
2 Oct 2025

CHOI WAI KWONG v. CHOI WAI KEUNG

Citation

[2025] HKDC 1596
Court

District Court
Case number

DCMP1525/2025

On construction the injunction clearly restrained obstructing the path; CCTV and supporting evidence proved beyond reasonable doubt that the Respondent parked vehicles encroaching on the path over a sustained period and his conduct was not accidental (he was observed checking the vehicle positions); Respondent failed to adduce rebutting evidence despite leave to do so; therefore the elements of civil contempt (breach plus knowledge/non-accidental conduct) are established and guilty verdict is warranted.
22 Jul 2025

K v. A

Citation

[2025] HKCFI 3602
Court

Court of First Instance
Case number

HCMP2186/2021

Respondent knowingly disobeyed two injunction orders protecting HVD; Count 1 was partly purged (purge dated 2 July 2021) reducing the starting custodial sentence from one month to two weeks; Count 2 was not purged and was more serious so the starting point of two months was reduced to six weeks; sentences to run concurrently; costs of sentencing to be paid by respondent to applicant on an indemnity basis and bail granted pending appeal.
10 Jul 2025

AU TZE PUI v. CHOW WING MAN

Citation

[2025] HKCFI 2995
Court

Court of First Instance
Case number

HCMP68/2025

Because the defendant voluntarily gave a simple undertaking and deliberately breached it without evidence of inability to comply, failed to purge the contempt despite multiple opportunities and produced no credible proof of means to repay, a short custodial sentence (six weeks) is necessary to punish and coerce compliance; the sentence should not be suspended and costs are to be assessed on an indemnity basis at HK$350,000.
11 Jun 2025

AU TZE PUI v. CHOW WING MAN

Citation

[2025] HKCFI 2526
Court

Court of First Instance
Case number

HCMP68/2025

The undertaking was clear: hold HK$1.1 million on trust and not use it. Mr Chow admitted on multiple occasions to spending the money on legal and personal expenses, was legally represented when giving the undertaking, understood its effect, and refused to pay the funds into Court; these facts establish beyond reasonable doubt that he breached the undertaking and had the requisite state of mind for contempt. Defences of fraud, duress and that the spending protected the company are matters for trial or were unmeritorious; contempt established and matter adjourned for mitigation and sentencing w…