Hong Kong Case Law: Decisions & Judgments

Topic

Self-dealing/conflict of interest

Legal area

Court

4 Nov 2025

CHAN SUN JUDY v. QIN XIAOJIAN, the sole administrator of the estate of CHAN WAI HING ALEXANDER, deceased

Citation

[2025] HKCFI 5225
Court

Court of First Instance
Case number

HCMP2396/2024

The administratrix was removed because she participated in transactions which involved sale of estate assets to herself and close relatives through the company that held estate assets, creating a clear conflict of interest and amounting to self‑dealing that endangered the proper administration of the estate; the Court was satisfied removal was necessary to investigate and protect beneficiaries and appointed an independent solicitor (Mr Wong Tak Shing) as administrator, revoking the existing grant and issuing directions for inventory, delivery of documents and assets, and specified costs order…
31 Dec 2024

NG, ROSE KAI CHING AND OTHERS v. LIANG LOK HO LING, the person appointed to represent the estate of LIANG YUM SHING HOWARD (in his personal capacity and as the executor and trustee of the estate of LIANG TING SEN THOMAS, deceased) AND ANOTHER

Citation

[2024] HKCFI 3692
Court

Court of First Instance
Case number

HCMP2013/2018

Having found that the proceedings were within the 3rd category of Re Buckton but that there was no finding of dishonesty or underhand motive by Howard, the Court ordered that D1 (the estate) pay 85% of the Plaintiffs' remaining costs of the action up to and including trial (certificate for two counsel) to be taxed on a party and party basis if not agreed; Howard/D1's own costs are to be borne personally by him/D1 and any amounts paid by the Estate on his behalf must be reimbursed by D1; indemnity costs were not appropriate; disclosure order as sought was unnecessary because inventory and acco…

Hong Kong Case Law

CHAN SUN JUDY v. QIN XIAOJIAN, the sole administrator of the estate of CHAN WAI HING ALEXANDER, deceased

NG, ROSE KAI CHING AND OTHERS v. LIANG LOK HO LING, the person appointed to represent the estate of LIANG YUM SHING HOWARD (in his personal capacity and as the executor and trustee of the estate of LIANG TING SEN THOMAS, deceased) AND ANOTHER