Hong Kong Case Law: Decisions & Judgments

Topic

Disclosure order

Legal area

Court

9 Jan 2026

梁謂祺對香港上海匯豐銀行有限公司及另七人

Citation

[2026] HKDC 65
Court

District Court
Case number

DCMP4115/2024

The court found the third defendant had complied with the original disclosure order; the applicant's fresh requests arose from errors in the applicant's original particulars and were not properly pursued as amendments; the applicant failed to satisfy Order 24 rr.7,7A,8 that the further material was relevant, in the defendant's control, and necessary; the requested transaction‑trail and second‑tier account details were too broad and impracticable given mixing of funds. Therefore the further disclosure summons was dismissed and costs awarded to the third defendant.
16 Sept 2025

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

Citation

[2025] HKCFI 4327
Court

Court of First Instance
Case number

HCMP1080/2024

Because Hui had completely failed to comply with the Disclosure Order and thus prevented effective policing of the Mareva injunction, the court was satisfied there was a serious issue to be tried and a real risk that the injunction could not be enforced without receivership; applying the American Cyanamid framework the existing protective regime was ineffective and the balance of convenience favoured appointing receivers. The court therefore appointed the liquidators as joint and several receivers to identify, secure and preserve assets in terms of the draft order (with deletion of an unconst…
5 Sept 2025

FLAME ASIA RESOURCES PTE LTD v. FULL IDEA TRADING LTD AND OTHERS

Citation

[2025] HKCFI 4139
Court

Court of First Instance
Case number

HCA1483/2025

The Court continued the interim worldwide freezing and disclosure order for six months because Flame demonstrated a good arguable case on unlawful means conspiracy and procuring breach of contract, showed that there were insufficient assets in Hong Kong to satisfy the arbitral awards while material assets existed abroad, established a real risk of dissipation based on the timing and nature of the Three Transfers and the defendants' conduct, and because the balance of convenience favoured continuation to preserve the claimant's ability to enforce the awards.
20 Aug 2025

ZHANG YONGPING v. GAHOOD HOLDING COMPANY LTD AND ANOTHER

Citation

[2025] HKCFI 3735
Court

Court of First Instance
Case number

HCA1480/2025

There was a good arguable case of fraudulent misrepresentation, unjust enrichment, constructive trust and breach of a Quistclose trust; evidence and circumstantial factors established a real risk of dissipation (account suspension, property dispositions, prior judgments, impending auction); balance of convenience favoured preservation of assets; accordingly a Mareva injunction and disclosure order were necessary and granted, with costs in the cause.
1 Aug 2025

JACKY ZONG AND OTHERS v. KELLY FULI ZONG AND ANOTHER

Citation

[2025] HKCFI 3355
Court

Court of First Instance
Case number

HCMP2772/2024

The court held that the plaintiffs established serious issues to be tried on both the contractual and trust/fiduciary claims and that, applying the two-stage s21M test, it was just and convenient to grant a preservation order in aid of the PRC proceedings; accordingly a preservation order prohibiting withdrawal or encumbrance of the HSBC Account Assets and an ancillary disclosure order were granted, limited to preserving assets for determination by the PRC Court and without adjudicating merits of the foreign claim.
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.
30 Jun 2025

NTT DEVICES AMERICA, INC (formerly known as NTT ELECTRONICS AMERICA, INC) 對 QDE TRADE CO LTD 及另十六人

Citation

[2025] HKCFI 2732
Court

Court of First Instance
Case number

HCA1287/2023

D33's application to discharge was dismissed because D33 failed to provide sufficient, objective and contemporaneous evidence to bridge clear evidential gaps and to rebut the plaintiff's tracing of funds; the plaintiff had demonstrated the requisite thresholds (serious issue to be tried for the proprietary claim and a good arguable case for the freezing order) and D33 did not advance other substantive grounds (eg risk of dissipation or convenience) to justify discharge.
27 Jun 2025

JIA ASIA ASSET MANAGEMENT PTE. LTD. v. HONG KONG BARTER EXCHANGE LTD AND ANOTHER

Citation

[2025] HKCFI 2964
Court

Court of First Instance
Case number

HCA1188/2025

Interim interim relief refused because there was no sufficient urgency after a delay of over a year since the alleged transfers, the Hong Kong Police had informally frozen the recipient account (letter of no consent) reducing the need for immediate court-ordered relief, and fairness required maintaining the status quo and allowing defendants adequate time to file evidence; accordingly the summons is adjourned for substantive argument with directions on evidence and costs were awarded to defendants.
6 May 2025

CAPITAL CENTURY TEXTILE CO LTD v. LI DIANXIAO AND ANOTHER

Citation

[2025] HKCFI 650
Court

Court of First Instance
Case number

HCA263/2012

The ex parte post-judgment Mareva injunction was justified because secrecy and urgency were established by the defendant's history of dishonest convictions related to the subject matter and by the demonstrable BOC withdrawal showing real risk of dissipation; there was no material non-disclosure by the applicant; the estimated quantum of HK$17,000,000 was supported by the judgment debtor's outstanding accounts and known proceeds; the disclosure order was necessary for enforcement and policing of the injunction; the defendant failed to show cogent reasons to release frozen funds for litigation…
18 Oct 2024

YUEN SI HAY, ALAN AND ANOTHER v. TRAN MUOI (in her personal capacity And her capacity as the Administratrix of the estate of the Deceased)

Citation

[2024] HKCFI 2209
Court

Court of First Instance
Case number

HCMP669/2024

Applicants lacked a proprietary interest in estate assets prior to administration and failed to establish a good arguable case of misappropriation or undervalue sale or a real risk of dissipation; the survivorship presumption over joint accounts favoured the administratrix; consequently there was no basis for Mareva relief or ancillary disclosure and the summons was dismissed with costs to the defendant.