Hong Kong Case Law: Decisions & Judgments

Topic

Enforcement of arbitral awards

Legal area

Court

28 Apr 2026

A v. B1 AND ANOTHER

Citation

[2026] HKCFI 2444
Court

Court of First Instance
Case number

HCCT113/2024

The court dismissed both setting aside applications: the Tribunal complied with Article 43 (the EDP points were sufficiently identified in Ds' SOD and P had multiple fair opportunities to respond); no serious procedural breach or deprivation of the right to present the case was shown; the Tribunal's conclusions on construction and on the reasonableness of refusing the extension were within its permissible fact‑finding and discretionary domain and not manifestly incoherent or infra petita; the Costs Award was not vitiated by procedural unfairness because the Tribunal legitimately adopted a bro…
6 Feb 2026

AMP RESOURCES LTD v. INDAGRO SA

Citation

[2026] HKCFI 784
Court

Court of First Instance
Case number

HCMP1487/2025

The Court concluded there is a bona fide and substantial dispute as to the existence and validity of the arbitration agreement under PRC law because the applicability of Civil Code Article 490 to the parties' email and draft contract exchanges raises a legitimate issue for the Beijing Court; there was no material non‑disclosure in the ex parte application; substituted service was justified and the Defendant's summons to set it aside is dismissed; accordingly the continuation of the ex parte injunction is warranted and costs are awarded to the Plaintiff on an indemnity basis.
2 Dec 2025

CHINA NATIONAL GOLD GROUP HONG KONG LTD v. THE HONGKONG AND SHANGHAI BANKING LTD

Citation

[2025] HKCA 1068
Court

Court of Appeal
Case number

CACV862/2025

The Court allowed the appeal because there was evidence that HSBC had been mixed up in the alleged wrongdoing (notably the USD1.5m payment into Kehong Investment's HSBC account), CNG established a legitimate need to identify recipients and onward transfers to pursue tracing and proprietary claims and to identify further wrongdoers, and the disclosure sought from November 2013 was necessary and proportionate in all the circumstances; the judge below erred by focusing narrowly on whether the disclosure was needed merely for pending stay/arbitration applications and by treating the draft order a…
20 Oct 2025

CCC v. AAC

Citation

[2025] HKCFI 5023
Court

Court of First Instance
Case number

HCCT131/2024

Leave to appeal refused on grounds that were essentially factual or lacked reasonable prospects of success (participation/SMS receipt; alleged failure to consider issues), but granted on the discrete legal question whether service of notice of arbitration by SMS constitutes proper notice in the context of consumer/online arbitration because it raises a novel question of general principle suitable for determination by the Court of Appeal; enforcement of the award was stayed pending the appeal.
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.
18 Jul 2025

CCC v. AAC

Citation

[2025] HKCFI 2987
Court

Court of First Instance
Case number

HCCT131/2024

The court found on the evidence that the initial 16 October 2024 SMS notice from HKAS was received by the respondent and his denial was not convincing; the respondent failed to rebut the presumption of proper notice and did not demonstrate he was unable to present his case; allegations of fraud were unproved and did not engage public policy; accordingly the challenge under s.86 failed and the enforcement order stands, with costs adjusted to party-to-party due to a serious but unintended omission by the applicant in failing to provide supplemental agreements to the respondent.
18 Jun 2025

廈門新景地集團有限公司 formerly known as 廈門巿鑫新景地房地產有限公司 v. ETON PROPERTIES LTD AND OTHERS

Citation

[2025] HKCA 566
Court

Court of Appeal
Case number

CACV235/2024

The Court granted a stay of execution pending appeal on the same terms as the judge below because the appeal is at least reasonably arguable and there are additional reasons (a real/appreciable risk the plaintiff would not repay released funds) justifying a conditional stay; the judge’s award to pay out RMB180,000,000 was not arbitrary and the Court will not interfere with that discretionary exercise.
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.