Hong Kong Case Law: Decisions & Judgments

Topic

Default judgment

Legal area

Court

8 May 2026

LI YIDONG AND ANOTHER v. CHEN PING AND OTHERS

Citation

[2026] HKCFI 2563
Court

Court of First Instance
Case number

HCA2495/2024

Relief from the sanction of the unless order was granted despite significant delay because, weighing all O.2 r.5 factors, the draconian consequence of debarment and the merits of defendants' proposed defence (draft DCC not a bare denial) outweighed the prejudice to plaintiffs; accordingly default judgment was refused. The ex parte varied injunction was not discharged because no material non-disclosure was established that would have compelled discharge, but the proprietary injunction against D3-D5 was discharged given admitted zero balances.
23 Apr 2026

庄跃进AND OTHERS v. 白平

Citation

[2026] HKDC 673
Court

District Court
Case number

DCCJ324/2025

On the pleadings the facts established that the Defendant held the Company shares as bare trustee for the Plaintiffs, service was properly effected at the Defendant's last known addresses and non-parties were given notice as directed; the Defendant filed no defence or acknowledgement; therefore default judgment for a declaration of trust and an order to execute transfer documents was justified and the court may nominate a solicitor under s38A DCO to execute transfers if the Defendant fails to do so.
22 Apr 2026

GLOBAL ENTERPRISES CORPORATION LTD v. TOMY INDUSTRIAL CO LTD AND ANOTHER

Citation

[2026] HKCFI 2280
Court

Court of First Instance
Case number

HCA2076/2023

The appeal is dismissed because the Master did not err in law or act unreasonably: the Master reasonably concluded a binding settlement was reached on the evidence and, alternatively, properly assessed the merits of the setting aside application; the Ladd v Marshall material was admitted but did not materially affect the outcome; accordingly the Master's Costs Order is upheld and the plaintiff must pay the defendants' costs of this re‑hearing in the sum awarded.
17 Apr 2026

YAM WING CHIU v. WONG YEE LING AND ANOTHER

Citation

[2026] HKDC 632
Court

District Court
Case number

DCCJ1047/2022

The published WhatsApp statements were defamatory and caused reputational harm and loss of volunteer status; having assessed gravity, limited audience (~60), absence of apology and the plaintiff's verified distress, compensatory general damages of HK$180,000 were appropriate; exemplary damages refused because there was no evidence of profit motive or outrageous contumelious conduct warranting additional punishment.
16 Apr 2026

DING HING HUI v. ZHENG NENGHUAN AND ANOTHER

Citation

[2026] HKCFI 2148
Court

Court of First Instance
Case number

HCA78/2026

The defence did not disclose any reasonable defence: the disciplinary decision did not support any finding or implication of bribery so the imputation of bribery was defamatory and not justified by truth or fair comment; qualified privilege did not apply because alleging bribery was not reasonably necessary to the occasion; the defendants failed to give a satisfactory explanation for the delay in filing A/S and Defence and leave was refused; accordingly default judgment was entered on the plaintiff's pleaded claims for orders to publish an apology and to procure withdrawal/clarification of th…
16 Apr 2026

WONG SAU CHUN PRISCILLA 對 MA KAM (BY TIN YUK HER GUARDIAN AD LITEM)

Citation

[2026] HKDC 615
Court

District Court
Case number

DCCJ2973/2021

Because the defendant had validly filed acknowledgements of service and defences before the appointment of a guardian ad litem and the plaintiff did not make any substantive amendment to the statement of claim, those earlier filings remained effective; the guardian's failure to instruct a solicitor was an irregularity that did not invalidate the prior filings, so default judgment was not appropriate and the court would not enter judgment against the defendant.
10 Apr 2026

DINGWAY INVESTMENT LTD (In Compulsory Liquidation) v. CHINA CITY CONSTRUCTION & DEVELOPMENT CO., (HONG KONG) LTD AND OTHERS

Citation

[2026] HKCFI 1976
Court

Court of First Instance
Case number

HCA309/2022

The court set aside the portion of the default judgment awarding US$45,076,164.38 for knowing receipt because, on the pleaded RASOC, P had no arguable proprietary interest in the Miami Land or the 2021 sale proceeds and therefore could not sustain a knowing receipt claim; however the court upheld liability for unlawful means conspiracy against D6 because P had pleaded compensable loss in the form of loss of the CCCC Shares and the repayment of shareholder loans and that claim was not barred by the reflective loss principle; consequentially enforcement garnishee and charging orders based solel…
2 Apr 2026

LEUNG CHUN WAH NICHOLAS v. CHIN SHIN DIAN AND OTHERS

Citation

[2026] HKDC 597
Court

District Court
Case number

DCCJ3986/2025

Default judgment on liability granted on the basis of the pleaded Statement of Claim; damages are unliquidated and must be assessed, not awarded as a fixed sum based on estimates; mandatory injunction refused because the proposed order was too vague and delegated remedial scope to plaintiff's Authorized Person, failing the required precision for a mandatory injunction.
25 Mar 2026

ORIENTAL FA LTD v. LAM CHOK LAI AND ANOTHER

Citation

[2026] HKCFI 1790
Court

Court of First Instance
Case number

HCA2301/2024

The appeal is dismissed because the defendants failed to raise any serious triable issue: their factual case was incredible and inconsistent with pleaded defence and contemporaneous correspondence; the no oral modification clause (incorporated into the Supplemental Agreement) bars the alleged oral variation and there was no acknowledgement of the formality requirement; and there was no sufficient detrimental reliance to found an estoppel.
24 Mar 2026

TAI KANG YING v. THE PERSONAL REPRESENTATIVE OF LESLIE FREDERICK CHARLES GUYATT, DECEASED

Citation

[2026] HKDC 482
Court

District Court
Case number

DCCJ3019/2024

The court refused to grant the declaratory relief sought by default judgment because the pleaded facts were insufficient to establish adverse possession and the requisite intention to possess; declarations of title based on unproven allegations in default of defence are inappropriate where factual issues (tenancy, actual occupation, acknowledgements, possible heirs) require investigation at trial. Procedural concerns about service and representation of the deceased's estate further counsel against entering declaratory judgment on the pleadings alone.