Hong Kong Case Law: Decisions & Judgments

Topic

Post-judgment enforcement

Legal area

Court

17 Oct 2025

HMM (HONG KONG) LTD (FORMERLY KNOWN AS HYUNDAI MERCHANT MARINE (HONG KONG) LTD) v. MA CHUN KIT

Citation

[2025] HKCFI 5084
Court

Court of First Instance
Case number

HCA619/2016

An extension of a post-judgment Mareva injunction requires demonstrable diligence in enforcement and evidence that the extension will assist recovery or be in the interests of justice; absent adequate particularised evidence of enforcement activity and utility, a full 24-month extension was unjustified and a limited 15-month extension was appropriate.
10 Oct 2022

LCC v. LTLA

Citation

[2022] HKCFI 3127
Court

Court of First Instance
Case number

HCMC4/2019

The Husband failed to demonstrate reasonable prospects of success on any pleaded ground of appeal and did not show the appeal would be rendered nugatory if no stay were granted; on balance the discretion to deprive the successful party of the judgment's fruits was not engaged, therefore the application for stay was dismissed and costs awarded to the Wife.
2 Sept 2022

ALLTOGETHER LAND CO LTD v. CHINA CREATE CAPITAL LTD AND ANOTHER

Citation

[2022] HKCFI 2726
Court

Court of First Instance
Case number

HCA883/2020

D1 failed to discharge the burden to show variation was just: it produced no reliable evidence of which securities were subject to the injunction, their holdings, liquidity, current market values, or that any surplus would remain after prior encumbrances and judgments; given the credible risk of insolvency, prior charges and the potential for undervalue or related‑party sales, permitting the sale would prejudice the judgment creditor; therefore the summons to vary the injunction was dismissed with costs.
28 Dec 2018

LI PING CHUN AND ANOTHER v. LIANG TONGHUA

Citation

[2018] HKCFI 2757
Court

Court of First Instance
Case number

HCA745/2011

The court found the plaintiffs have a good arguable proprietary claim that the assignments were suspect and potentially voidable under s.60 CPO, the Mareva and asset preservation criteria are satisfied as to TH and extendable to HW and KW on the facts, and therefore the interim Mareva injunction and asset preservation order should continue; HW and KW's restraint is limited to dealing with the two properties and an asset disclosure order is granted only against TH.
19 Oct 2018

ERWIANA SULISTYANINGSIH v. LAW WAN TUNG

Citation

[2018] HKDC 1267
Court

District Court
Case number

DCPI569/2015

Given the prior court finding that the defendant and her husband intended to defraud creditors by assigning the defendant's interest in the residential property and the subsequent appearance of a default judgment, charging order and an unaccounted HK$3,000,000 legal charge, there was a real risk that the defendant would dissipate assets; accordingly the post-judgment Mareva injunction and associated disclosure order were necessary and should be continued until full payment of the judgment or further order.
14 Dec 2015

GOLDDECADE INTERNATIONAL LTD v. HUANG ZIQIANG

Citation

GOLDDECADE INTERNATIONAL LTD v. HUANG ZIQIANG
Court

Court of First Instance
Case number

HCA1521/2015

The court has jurisdiction under section 42 HCO to grant third-party disclosure post-judgment to assist enforcement where the applicant demonstrates necessity and practicable inability to obtain the information from the judgment debtor; on the facts the plaintiff satisfied the threshold and the order for HSBC to disclose account numbers and current balances was justified.
27 Nov 2000

KWAKU ATUAHENE-GIMA v. DAMON DRUMMOND

Citation

KWAKU ATUAHENE-GIMA v. DAMON DRUMMOND
Court

Court of First Instance
Case number

HCA13924/1997

The stay of execution was lifted because the respondent's financial position had materially improved as shown by payments into court and provision of security for costs, removing the original basis (poverty) for the stay and permitting enforcement pending appeal.

Hong Kong Case Law

HMM (HONG KONG) LTD (FORMERLY KNOWN AS HYUNDAI MERCHANT MARINE (HONG KONG) LTD) v. MA CHUN KIT

LCC v. LTLA

ALLTOGETHER LAND CO LTD v. CHINA CREATE CAPITAL LTD AND ANOTHER

LI PING CHUN AND ANOTHER v. LIANG TONGHUA

ERWIANA SULISTYANINGSIH v. LAW WAN TUNG

GOLDDECADE INTERNATIONAL LTD v. HUANG ZIQIANG

KWAKU ATUAHENE-GIMA v. DAMON DRUMMOND