Hong Kong Case Law: Decisions & Judgments

Topic

Contempt of court

Legal area

Court

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.
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.
27 May 2025

ANZ COMMODITY TRADING PTY LTD v. CHEUK KWAN HUNG

Citation

[2025] HKCFI 2292
Court

Court of First Instance
Case number

HCMP489/2021

The defendant was found to have deliberately and willfully breached the discovery orders and thus guilty of contempt; however, because of her limited role, personal and family circumstances, four days already spent in custody and belated attempts to purge contempt, a custodial sentence is not warranted; the appropriate penalty is a financial order of contribution to the plaintiff's costs (HK$50,000) payable into court within 21 days, with a default term of 2 days' imprisonment; bail conditions discharged.
25 Oct 2024

嘉信大廈業主立案法團 v. 張笑媚

Citation

[2024] HKLdT 87
Court

Lands Tribunal
Case number

LDMP6/2023

The Tribunal concluded there was admissible, compelling circumstantial and direct evidence from which no reasonable tribunal could fail to infer that the respondent had possession, custody or control of IO’s properties during the relevant period and wilfully refused to comply with the Previous Judgment; the criminal standard was correctly applied; there was no error of law in the reasoning; and the one‑month custodial sentence was within proper principle and proportion given contumacious, intentional breach and absence of mitigation, so leave to appeal lacked reasonable prospect of success.
3 Sept 2024

SECRETARY FOR JUSTICE 訴陸志榮

Citation

[2024] HKCA 834
Court

Court of Appeal
Case number

CAMP134/2024

Leave to appeal was refused because the applicant's grounds were speculative, in many respects novel and not raised below, and did not show a realistic prospect of success or other compelling reason to hear the appeal; the trial judge acted within proper case management and discretionary bounds; costs were awarded to the respondent; and the filed originating summons was struck out.
29 Aug 2024

MCYP v. CWYW

Citation

[2024] HKFC 165
Court

Family Court
Case number

FCMC11432/2018

Given the prolonged, large and contumacious breach, the contemnor's late payment did not negate contumacious intent or remorse; a fine would be inadequate and prejudicial to the respondent; imprisonment is therefore appropriate but suspended to reflect partial mitigation; indemnity costs with certificate for two counsel are ordered.
18 Jul 2024

WONG TO YICK WOOD LOCK OINTMENT LTD v. IMPERIAL CHARITY HALL MEDICINES LTD AND ANOTHER

Citation

[2024] HKCFI 1867
Court

Court of First Instance
Case number

HCIP13/2022

Proper service (including substituted service) was effected and the defendants wilfully failed to file the required affirmations as ordered; contempt was therefore proved beyond reasonable doubt. The 2nd Defendant was sentenced to 4 months' imprisonment; leave was granted to the Plaintiff to issue a Writ of Sequestration against the 1st Defendant; costs awarded to Plaintiff on an indemnity basis.
11 Jun 2024

HARSEN INDUSTRIES LTD v. WONG YEE CHUK

Citation

[2024] HKCFI 1563
Court

Court of First Instance
Case number

HCA193/2018

The petitions fail because, although the companies operated as a group and the relationship had quasi‑partnership characteristics, the claimant failed to prove the asserted Consent Requirement or that Lo/Pan’s conduct was unfairly prejudicial; many complained acts were justified responses to NHEL’s cashflow crisis caused principally by Wong’s misconduct (notably causing Yibao not to pay and withholding assistance to obtain necessary licences). Conversely, Wong was found to have breached fiduciary duties by transferring HIL trademarks to his vehicle, registering competing marks and permitting…
8 May 2024

SECRETARY FOR JUSTICE v. PERSONS CONDUCTING THEMSELVES IN ANY OF THE ACTS PROHIBITED UNDER PARAGRAPH 1(a), (b), (c) OR (d) OF THE INDORSEMENT OF CLAIM

Citation

[2024] HKCA 442
Court

Court of Appeal
Case number

CAMP303/2023

The Court of Appeal allowed the appeal and granted an interlocutory contra mundum injunction because (1) the Chief Executive's NSL s47 certificate and the evidence established the 4 Acts posed national security risks, (2) a civil injunction is a permissible and necessary supplementary preventive measure where prosecutions alone would be inadequate to safeguard national security, (3) the court, while giving considerable deference to the executive on national security assessment, must itself decide the legal question of necessity and utility, and (4) concerns about unfairness, conflicts with cr…
18 Jul 2023

SECRETARY FOR JUSTICE v. CHEUNG CHI HO

Citation

[2023] HKCFI 2099
Court

Court of First Instance
Case number

HCMP598/2022

The defendant posted two deliberate comments that breached the inter partes injunction; he was properly treated as having notice by substituted service and media reporting; he is liable for civil contempt; the court will issue a warrant for committal to secure his attendance for submissions on penalty and will set a long stop date after which the court may proceed to sentencing in his continued absence; costs are awarded on the indemnity scale.