Hong Kong Case Law: Decisions & Judgments

Topic

Financial disclosure

Legal area

Court

24 Nov 2025

KYCE v. HA

Citation

[2025] HKFC 192
Court

Family Court
Case number

FCMP15/2015

On a broad‑brush assessment of N's reasonable needs and the parties' finances the court fixed monthly maintenance at HK$80,000, dismissed both the father's vary‑downwards and the mother's vary‑upwards applications, discharged specified consent‑order preamble undertakings (B, C, D, E) and replaced some obligations by express orders (direct payment of school fees, bus charges and specified insurance); the father retains ability to pay despite unsatisfactory disclosure and an adverse inference is drawn against late/incomplete disclosure but not of dishonesty.
26 May 2025

JTJ v. HGSH

Citation

[2025] HKFC 116
Court

Family Court
Case number

FCMC15810/2018

The applicant failed to establish any of the five grounds for varying the costs order nisi; the court applied the established principle that costs normally follow the event, found W to be the overall successful party on the ancillary reliefs, and declined to re-open or re-find factual matters already decided; accordingly H’s summons was dismissed, H ordered to pay W’s costs of the variation application and the costs order nisi was made absolute.
14 Oct 2024

潘對陳

Citation

[2024] HKFC 190
Court

Family Court
Case number

FCMC3648/2023

Applying Cap.192 s.7 factors and LKW v DD guidance, the court found both parties have sufficient means to support themselves (no spousal maintenance awarded), assessed the child's reasonable needs at approximately HK$9,500 per month, evaluated each parent's income and obligations (including respondent's caregiving constraints and applicant's government allowances), rejected allegations of undisclosed valuable assets for lack of evidence, and ordered respondent to pay child maintenance HK$800 per month and to transfer HK$10,900 in red-envelope funds to applicant for the child's benefit.
10 Apr 2024

YCWR v. YCW

Citation

[2024] HKFC 45
Court

Family Court
Case number

FCMC6604/2016

The court exercised its discretion to grant leave because the Husband provided a credible explanation for omission (lack of independent legal advice and reliance on a family understanding), the delay was promptly triggered by the daughter’s claim and therefore not inordinate, the Wife would not be unduly prejudiced, and the Husband demonstrated a seriously arguable case (possible adverse finding on the daughter’s beneficial ownership could create accommodation needs and there are disputed asset distributions).
20 Dec 2023

RE also known as ME v. POPM also known as P-M OPR

Citation

[2023] HKFC 255
Court

Family Court
Case number

FCMC1658/2020

Because the husband failed to provide full and frank financial disclosure, was repeatedly absent and the available evidence supported the petitioner's asset valuations, the court drew an adverse inference, accepted the petitioner's assessment of the matrimonial pot at HK$6,502,248, applied LKW v DD steps and departed from equal division to a 60:40 split in favour of the petitioner, awarding a lump sum of HK$3,901,349 and periodical payments of HK$15,000 per month backdated to April 2023 until the lump sum is paid, with costs to the petitioner.
19 Oct 2023

HYM v. LKK

Citation

[2023] HKFC 209
Court

Family Court
Case number

FCMC7571/2022

On a broad brush assessment the petitioner was not wholly financially dependent and has earning capacity beyond the claimed HK$2,000; she failed to prove entitlement to litigation funding under the Currey test; respondent demonstrated ability to pay a limited sum for accommodation and utilities; therefore a limited MPS of HK$16,500 per month was reasonable and ordered pending further order; costs of the summons reserved (costs order nisi to be made absolute in 14 days if not varied).
12 Oct 2023

潘對李

Citation

[2023] HKFC 199
Court

Family Court
Case number

FCMC10204/2021

Applying the broad‑brush approach the court balanced the parties' incomes and reasonable child needs, concluded the respondent was in financial difficulty and not the beneficiary of indefinite third‑party support, but could pay a sum higher than HKD 5,500; fixing interim child maintenance at 20% of respondent's monthly salary (HKD 6,266) together with applicant's available funds provides a fair maintenance budget until final hearing.
7 Jul 2023

鄭對孫

Citation

[2023] HKFC 132
Court

Family Court
Case number

FCJA3914/2018

The judge refused leave because the husband's grounds merely repeated trial arguments or relied on new assertions not raised at trial, he failed to explain non-disclosure of finances leading to adverse credibility findings, and appellate intervention is inappropriate where the trial judge made credibility-based factual findings absent a clear error; therefore the proposed appeal has no reasonable prospect of success.
15 Mar 2023

鄭對孫

Citation

[2023] HKFC 53
Court

Family Court
Case number

FCJA3914/2018

The court found the husband had not made full and frank disclosure and, on the evidence (including the social welfare report and wife's account), drew an adverse inference that the husband had additional undeclared income (likely trading activity). On that basis the court concluded the husband has the capacity to pay HK$3,000 per month and ordered that sum as child maintenance payable from 1 April 2023.
27 Feb 2023

VJM formerly known as HT v. JMM

Citation

[2023] HKFC 43
Court

Family Court
Case number

FCMC404/2022

On the available evidence the family business has been supporting the respondent's household expenses and thus constitutes a resource available to him; the respondent's assertions of incapacity were insufficiently tested; the court therefore assessed reasonable immediate recurring needs and ordered monthly MPS of HK$22,000 to the petitioner and interim maintenance of HK$10,450 for the child, with costs to the petitioner.