Hong Kong Case Law: Decisions & Judgments

Topic

No reflective loss

Legal area

Court

9 Mar 2026

陳戈理 (又名陳為) 對柯伍陳律師事務所及另一人

Citation

[2026] HKCFI 1444
Court

Court of First Instance
Case number

HCA1211/2025

The appeal is dismissed because the plaintiff lacks standing to sue for reflective losses of the company; the core factual issues (receipt signed and non-payment of instalments) are final by the winding‑up proceedings and re-litigation is an abuse of process; the amended pleadings fail to disclose any reasonable cause of action against the defendants (including no duty by the solicitor to the plaintiff) and the defects are incurable; accordingly the strike-out order was correctly made and fresh evidence is not admitted.
14 Nov 2025

陳戈理（又名陳為）對思謀集團有限公司及另一人

Citation

[2025] HKCFI 5403
Court

Court of First Instance
Case number

HCA1051/2025

The appeal is dismissed because the plaintiff lacks standing to sue for losses that are those of the company (application of the no‑reflective‑loss rule), the statement of claim fails to disclose any reasonable cause of action against the defendants personally, and the central issues (delivery receipt and non‑payment) are final in the prior winding‑up proceedings such that relitigation would be an abuse of process; accordingly the statement of claim is struck out and the proceedings are dismissed with costs.
8 Jun 2021

AGRITRADE RESOURCES LIMITED THROUGH THE JOINT PROVISIONAL LIQUIDATORS NG KIAN KIAT, OON SU SUN AND E. ALEXANDER WHITTAKER AND ANOTHER v. ASHOK KUMAR SAHOO

Citation

[2021] HKCFI 1605
Court

Court of First Instance
Case number

HCA1660/2020

The court found the defendant failed to show reasonable prospects of success on the proposed appeal because the judge properly distinguished Landune on the facts, the plaintiffs had established a good arguable case of misappropriation and a non‑fanciful quantum justifying interim relief, the selective production of bank statements was not material non‑disclosure given the material pages were produced and the ex parte judge was informed, and there was credible evidence of risk of dissipation; accordingly leave to appeal was refused.
7 Jan 2020

WAH NAM GROUP LTD v. RODERICK JOHN SUTTON AND ANOTHER

Citation

[2020] HKCA 30
Court

Court of Appeal
Case number

CACV215/2017

Leave to appeal was dismissed because WN’s pleaded loss was purely reflective of losses of its subsidiaries GSP and CS; the subsidiaries’ causes of action remained live so the no reflective loss principle barred the shareholder’s action regardless of any dispute about the companies’ underlying causes of action or the capacities in which the defendants were sued.
7 Mar 2006

WADDINGTON LTD v. CHAN CHUN HOO THOMAS AND OTHERS

Citation

WADDINGTON LTD v. CHAN CHUN HOO THOMAS AND OTHERS
Court

Court of First Instance
Case number

HCA3291/2003

Costs follow the event; the 1st Defendant was successful on the strike out application and there was no impropriety justifying depriving him of costs so the costs order nisi is made absolute as to him (with deletion of reference to the 2nd Defendant who did not participate); the 3rd Defendant, having been summoned and reasonably attending, is entitled to its costs to be paid by the Plaintiff; Playmates Holdings and Playmates International are not necessary or proper parties where no relief is sought for them; the Plaintiff may amend but must re-draft particulars to remove speculative material…

Hong Kong Case Law

陳戈理 (又名陳為) 對 柯伍陳律師事務所及另一人

陳戈理（又名陳為）對 思謀集團有限公司及另一人

AGRITRADE RESOURCES LIMITED THROUGH THE JOINT PROVISIONAL LIQUIDATORS NG KIAN KIAT, OON SU SUN AND E. ALEXANDER WHITTAKER AND ANOTHER v. ASHOK KUMAR SAHOO

WAH NAM GROUP LTD v. RODERICK JOHN SUTTON AND ANOTHER

WADDINGTON LTD v. CHAN CHUN HOO THOMAS AND OTHERS

陳戈理 (又名陳為) 對柯伍陳律師事務所及另一人

陳戈理（又名陳為）對思謀集團有限公司及另一人