Hong Kong Case Law: Decisions & Judgments

Topic

Interim receivership

Legal area

Court

23 Apr 2026

WONG PUI YIN GEORGEANNA (as the administratrix of the estate of WONG CECILIA PUI LUEN, deceased) v. CHEER CREATION LTD AND ANOTHER

Citation

[2026] HKCA 726
Court

Court of Appeal
Case number

CAMP352/2023

The Court of Appeal set aside the orders made by Harris J in the Originating Summonses for irregularity because the judge made substantive orders on matters not listed for hearing and without giving the intervener an opportunity to present evidence and submissions specific to those Originating Summonses; however the Court refused leave to appeal against dismissal of the stay applications, holding the judge had not misdirected himself in his exercise of case management discretion and there was no reasonable prospect of success on those proposed appeals.
13 Nov 2025

SUEN WAI MO v. LAM HONG KI AND OTHERS

Citation

[2025] HKCFI 5475
Court

Court of First Instance
Case number

HCA133/2020

The court held that the fraud exception was engaged given interconnected claims and allegations of dishonesty spanning the writ, so it had no jurisdiction to grant summary judgment (Order 14) in respect of the Panven claim; further, even absent the jurisdictional bar the materials disclosed triable issues so summary judgment would have been refused. The application for interim receivership was dismissed because the applicant failed to show a real risk of dissipation or that receivership was proportionate; the late additional affirmation evidence was refused and the expungement application was…
18 Sept 2025

TECHTERYX LTD v. FIRST DIGITAL TRUST LTD AND OTHERS

Citation

[2025] HKCFI 4023
Court

Court of First Instance
Case number

HCA161/2023

The court dismissed the interim receiver application because the existing protective regime (DIFC proprietary injunctions, worldwide freezing order and disclosure orders) adequately preserves the status quo and there is no demonstrated utility or superior protective effect from appointment of a receiver over FDT's interest; the court dismissed proprietary injunction applications and refused joinder of Glass Door because plaintiff failed to adduce reasonable evidence tracing USD 15.5M to Glass Door or Legacy and the proprietary/knowing receipt/dishonest assistance claims were insufficiently pa…
13 Aug 2025

BEIJING RENJI REAL ESTATE DEVELOPMENT GROUP CO., LTD v. ZHU MIN

Citation

[2025] HKCA 748
Court

Court of Appeal
Case number

CAMP82/2025

The court held the judge’s manifest intention at the 7 February 2025 hearing was to dismiss only the interim-interim relief; the judge had jurisdiction under Order 20 r.11 and inherent jurisdiction to amend the sealed order to correct the clerical slip and to give directions for further conduct of the summons; it was proper for the judge to deliver written Reasons for Decision subsequently; the refusal to grant interim-interim receivers was a discretionary decision within bounds of reasonableness and not plainly wrong; allegations of unfair hearing or apparent bias were unfounded; the new evi…
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.
23 May 2024

WONG PUI YIN GEORGEANNA (as the administratrix of the estate of WONG CECILIA PUI LUEN, deceased) v. HIROSHI TECHNOLOGIES LTD

Citation

[2024] HKCA 489
Court

Court of Appeal
Case number

CACV218/2023

The Court concluded there was a reasonably arguable procedural irregularity in the judge determining the originating summonses without giving the intervener an opportunity to file evidence and make submissions, and given the real prospects of success and potential prejudice to the intervener (loss of control of trading businesses), it was necessary to stay execution of the substantive orders pending determination of the appeals.
7 Sept 2017

MARRAKESH INVESTMENTS LTD v. TANGIERS HOLDINGS LTD AND ANOTHER

Citation

MARRAKESH INVESTMENTS LTD v. TANGIERS HOLDINGS LTD AND ANOTHER
Court

Court of First Instance
Case number

HCCW352/2016

Application to appoint an interim receiver was dismissed because the petitioner failed to demonstrate sufficiently clear and solid evidence of a real risk of dissipation or other imminent harm to the economic value of the company that would justify the intrusive and commercially damaging remedy of receivership; the balance of convenience favoured refusal and the alternative injunction was unjustified in light of section 182 and the existing validation order.
14 Jun 2017

LO SUI LIN v. CHAN HUNG FOOK AND OTHERS

Citation

LO SUI LIN v. CHAN HUNG FOOK AND OTHERS
Court

Court of First Instance
Case number

HCMP41/2016

The petition to wind up on the just and equitable ground was not a plain and obvious failure on its face because there is an arguable case that the company was a small family asset vehicle governed by an informal arrangement and that the respondent's conduct and proposed sale and board changes risked a loss of substratum; accordingly the strikeout was dismissed and an interim receiver was appointed to preserve assets pending a speedy trial of the petition; the s570 meeting application was deferred (no order) given the pending winding up petition and the need to preserve the status quo.