Hong Kong Case Law: Decisions & Judgments

Topic

Section 25a high court ordinance

Legal area

Court

21 Nov 2025

VIOLET PASSION HOLDINGS LTD v. LIAN YI

Citation

[2025] HKCFI 5596
Court

Court of First Instance
Case number

HCA1981/2020

Because the sealed order and judgment were validly served by email pursuant to paragraph 21 and the defendant failed to respond and neglected or refused to comply as evidenced by the Fung-36th affidavit, the court properly exercised its discretion under s.25A High Court Ordinance to nominate the plaintiff’s solicitor to execute documents on the defendant’s behalf and awarded costs to the plaintiff.
16 Sept 2025

POON LAI TAK AND ANOTHER v. KFH INVESTMENT CONSULTANCY LTD AND ANOTHER

Citation

[2025] HKCFI 4360
Court

Court of First Instance
Case number

HCA248/2024

Given the earlier declaration and order that the 2nd defendant holds the property on resulting trust for the plaintiffs and must assign the legal title, and given the 2nd defendant's failure to comply or to respond after service, the court properly exercised its power under s.25A High Court Ordinance to direct the plaintiffs' solicitor to execute all necessary documents to transfer the legal title and awarded costs to the plaintiffs.
24 Mar 2023

JOHN JOSEPH DORAN v. LB SHOE CO., LTD AND OTHERS

Citation

[2023] HKCFI 847
Court

Court of First Instance
Case number

HCA886/2022

On the pleadings the plaintiff established deceit, fraudulent misrepresentation and conspiracy by the primary defendants and unjust enrichment by second‑layer recipients sufficient to merit default judgment; equitable relief including declaration of constructive trust, delivery up/transfer and tracing orders are necessary to vindicate the plaintiff's rights; compound interest was not awarded absent pleaded fiduciary duty; post-judgment freezing injunctions were extended for eight months; the Court declined to make a s25A substituted execution order at this stage.
27 Feb 2023

ANTHONY WONG v. JIAN XIAOFEI

Citation

[2023] HKCFI 606
Court

Court of First Instance
Case number

HCA1140/2019

The Defendant was properly notified, failed to comply with the transfer order and did not appear or respond; under s25A and RHC O 32 r 5(1) the Court may authorise a partner of the Plaintiff's solicitors to execute the transfer note to effectuate the transfer order and it is appropriate to do so given established practice and absence of special circumstances to the contrary.
21 Apr 2021

CHEN YUNG NGAI KENNETH AND ANOTHER v. HO YUK WAH DAVID (A BANKRUPT) AND OTHERS

Citation

[2021] HKCFI 1113
Court

Court of First Instance
Case number

HCA971/2012

The court was satisfied that Ng J's earlier order constituted a judgment directing the 5th Defendant to execute transfer documents, that the 5th Defendant neglected or refused to comply within the prescribed period and could not be found acting through solicitors, that the company remained a legal entity despite being struck off, and that service of the summons was valid; accordingly s.25A empowered the court to nominate a person (Dennis Lam) to execute the necessary documents and to award costs to the Plaintiffs.
7 Sept 2020

PANG MAN MING v. PANG WAN LI YAN

Citation

[2020] HKCFI 2353
Court

Court of First Instance
Case number

HCA1859/2019

The ex parte s.25A Order was set aside because it effected final relief without urgency or secrecy, bypassed inter partes safeguards, was obtained before the writ and without proper service or opportunity to be heard, and there was potential material non-disclosure by the applicant; accordingly the s.25A Order was improperly procured and must be revoked with costs payable by the applicant.
3 Jul 2019

KWONG MUK HING, one of the executors named in the Will of LUK HEUNG deceased v. CHENG PUI NIN WILLIAM AND ANOTHER

Citation

[2019] HKCFI 1726
Court

Court of First Instance
Case number

HCMP202/2018

The Court declared that the 2008 assignment contained substantial discrepancies from the authorised terms required by the Housing Ordinance and, subject to the Housing Authority's consent to rectification, ordered the respondents to execute a confirmatory assignment in favour of the executors. Further, pursuant to s25A High Court Ordinance, if the respondents fail to execute or cannot be found after reasonable inquiry, the Registrar of the High Court is appointed to execute the confirmatory assignment on their behalf; the draft must be lodged for the Registrar's approval. Costs of execution a…
11 Oct 2018

YARON BROWN AND OTHERS v. LEXINTA LTD AND OTHERS

Citation

[2018] HKCFI 2302
Court

Court of First Instance
Case number

HCA2610/2017

Grant limited section 21 disclosure orders only as to identified banks where there is evidence and nexus to the alleged misappropriation; dismiss application for blanket orders against all banks in Hong Kong as impermissible fishing expedition; grant release from the implied undertaking permitting plaintiffs to provide discovered material and affirmations to the Zurich Public Prosecutor; dismiss section 25A applications seeking Registrar execution and circulation of blanket authorisation letters; grant the section 21L order against DBS Vickers where it consented.
15 May 2018

LAU YUN LIN v. REGISTRAR OF COMPANIES

Citation

[2018] HKCFI 1073
Court

Court of First Instance
Case number

HCMP1111/2017

The court was satisfied on the evidence that the plan annexed to the 28 August 2012 assignment contained an error as to the area conveyed; no other interested parties were shown; accordingly s25A of the High Court Ordinance entitled the court to order a nominated person (the Registrar of the High Court) to execute a confirmatory assignment to rectify the error, and the orders sought were made including costs of HK$1,500.
22 Mar 2017

LAU YUN LIN v. KWAN TSEUNG CO LTD

Citation

LAU YUN LIN v. KWAN TSEUNG CO LTD
Court

Court of First Instance
Case number

HCMP29/2017

The originating summons was dismissed because the defendant company had been dissolved and therefore was a non-existent legal person against whom no order could be made under s25A HCO; consequently s25A could not be invoked to nominate a person to execute the confirmatory assignment and the proper defendant would be the Government/Registrar or the company must be restored under the Companies Ordinance if relief is sought.