13 Mar 2026
MAN CHUNG LAP v. MAN SHUI TONG WUI with MAN PING-NAME and MAN TAI-SANG as Managers
- Citation
- [2026] HKCFI 1495
- Court
- Court of First Instance
- Case number
- HCA1736/2024
Where a business tong includes a tso as a member, members of that tso hold direct equitable interests in the properties of the business tong and therefore each birth of a new tso member creates a new equitable interest that restarts the limitation period under the Limitation Ordinance; consequently Leung Kuen Fai applies to business tongs with tso members and a claimant cannot establish adverse possession as a matter of law if the requisite limitation period has not run against all living beneficial owners.