Hong Kong Case Law: Decisions & Judgments | LexChat

Hong Kong Case Law

Order 24 discovery scope
  • 15 Mar 2024

    ELITE CONSORTIUM LTD AND OTHERS v. YIM WAN POR AND OTHERS

    Citation
    [2024] HKCFI 704
    Court
    Court of First Instance
    Case number
    HCA66/2022

    Tracing is not a free-standing basis for broad Order 24 discovery; whether tracing-related discovery is appropriate depends on whether tracing is a live issue at the imminent trial (ie whether the plaintiff can identify specific property or has a proprietary injunction) — in this case tracing was not a live issue so broad tracing discovery was refused, but limited discovery was granted where the defendants' non-admission made bank statements and certain correspondence relevant and necessary to issues in the imminent trial.