Hong Kong Case Law: Decisions & Judgments

Topic

Forced sale valuation

Legal area

Court

27 Jan 2026

RE LIU FU ON

Citation

[2026] HKCFI 619
Court

Court of First Instance
Case number

HCB5057/2025

There was no bona fide dispute over the sums claimed; the Debtor failed to produce credible evidence that payment of at least the admitted debt would be forthcoming within a reasonable time (the desktop valuation and assertions were insufficient and, even optimistically, any surplus from sale of the mortgaged property would not cover the unpaid sum); accordingly the Debtor was unable to pay his debts and a bankruptcy order was warranted.
13 Jun 2002

WO KEE TRADING CO LTD v. THE SECRETARY FOR TRANSPORT

Citation

WO KEE TRADING CO LTD v. THE SECRETARY FOR TRANSPORT
Court

Lands Tribunal
Case number

LDMR28/2000

The Tribunal found the Applicant failed to prove that the resumption caused the alleged losses except for a narrow head relating to fixtures where credible expert evidence supported a small loss; most claimed losses arose from market fluctuations and management decisions and/or were avoidable by reasonable mitigation, the Applicant's valuation and apportionment evidence was unreliable or unsupported, therefore only $60,273 was awarded for loss of fixtures and reinstatement and all other claims were dismissed with professional fees, interest and costs reserved.
10 Nov 2000

Wong Hoi Nung v. The Secretary For Transport

Citation

Wong Hoi Nung v. The Secretary For Transport
Court

Lands Tribunal
Case number

LDMR1/2000

Profit rent was denied because the actual unit rent paid for the claimed lot exceeded market rent; no goodwill awarded because tax accounts showed no profit trend and Applicant failed to prove understatement; compensation for fixtures and site improvements denied where works contravened lease and renovation payment treated as loan repayable to landlord; forced sale stock loss accepted using Applicant's wholesale valuation less realized proceeds and apportioned to the claimed area, producing total compensation of HKD 279782.50 (excluding agreed severance).
20 May 1996

Tsang Ling chu v. Director of Lands

Citation

Tsang Ling chu v. Director of Lands
Court

Lands Tribunal
Case number

LDLR23/1994

Under s.10(2)(d) the applicant is entitled to compensation to restore the business to the position had there been no resumption; goodwill assessed by total wages of three long‑term employees at HK$15,000/month with a 13th month, 20% employer margin and multiplier 2, fixed at HK$1.4m; the four excavators were necessary business assets and included in replacement valuation; auction proceeds of HK$520,000 were multiplied by 5 to estimate market/replacement value HK$2.6m, yielding forced sale compensation HK$2,080,000 after deducting auction proceeds; profit rent assessed at HK$40,000 and other a…
23 Jan 1996

WONG Sau Hing and Others (t/a Shing Kee Metal Dealer) v. Director of Lands

Citation

WONG Sau Hing and Others (t/a Shing Kee Metal Dealer) v. Director of Lands
Court

Lands Tribunal
Case number

LDLR20/1994

Tribunal awarded compensation on basis that trading stock, machinery and equipment must be valued at replacement value at time of forced sale; accepted auction proceeds of $2.4m as reflecting a forced bulk sale and applied a multiplier of 3.5 (informed by Callwin precedent and circumstances) to derive a market-replacement value of $8.4m, less auction proceeds yields $6.0m for forced-sale losses; goodwill assessed at $800,000 annual potential x multiplier 3 = $2.4m; profit rent and fixtures assessed at $118,000 and $200,000 respectively; miscellaneous proven auction and transport costs allowed…

Hong Kong Case Law

RE LIU FU ON

WO KEE TRADING CO LTD v. THE SECRETARY FOR TRANSPORT

Wong Hoi Nung v. The Secretary For Transport

Tsang Ling chu v. Director of Lands

WONG Sau Hing and Others (t/a Shing Kee Metal Dealer) v. Director of Lands