29 Sept 2022
TONG CUN MING AND OTHERS v. CHEUNG SUN LING SANNY, the Administratrix of the Estate of KWAN YAU HANG, deceased AND OTHERS
- Citation
- [2022] HKCFI 3002
- Court
- Court of First Instance
- Case number
- HCMP143/2011
Plaintiffs have locus to commence the Better Administration Action because, as members of the Koon (a charity), including some who served on the Executive Committee and contributors of substantial donations, they possess an interest materially greater than that of ordinary members of the public; the court's inherent parens patriae jurisdiction extends to charitable corporations and is not confined to the SJ or to persons falling strictly within s57A Trustee Ordinance; derivative action/company law constraints are not determinative of locus in parens patriae proceedings.