14 Apr 2026
Recusal refused because the apparent bias test was not met: prior involvement was remote in time, limited to a single interlocutory application, the judge had no recollection or ongoing connection to the matter and there were no cogent reasons indicating a real possibility of bias, so the judge was impartial and entitled to continue presiding.
2 Apr 2026
The injunctions against the 2nd Defendant were discharged because the plaintiff failed to adduce reasonable evidence that the specific funds remained under the 2nd Defendant's control (defeating the proprietary claim), there was no solid evidence of a real risk of dissipation (defeating the Mareva claim), and the ex parte application involved material non-disclosure and an unfortified undertaking which, together with the disproportionate disruption to the trustee's legitimate business, militated against continuing the freezing relief.
4 Mar 2026
The ex parte application was dismissed because the applicant failed to establish urgency or necessity for secrecy, the relief sought was wide and would interfere with ongoing Family Court proceedings which are the proper forum for many of the contested issues, and any challenge to prior injunctions or undertakings should be pursued in the Family Court or by remedies available under those undertakings.
26 Jan 2026
Material non-disclosures regarding the erroneous legal foundation for the ex parte application, when the correct legal position was clearly established by authority and repeatedly pointed out to the Plaintiff, amounted to egregious conduct warranting indemnity costs; the matter was self-contained and did not raise assessment legal issues, so summary assessment was appropriate, resulting in dismissal of the Plaintiff’s Costs Summons and confirmation of the indemnity costs order with a summarily assessed amount of HK$59,630; the Plaintiff must give an undertaking as to damages within a short ti…
22 May 2025
The summons to convert the originating summons to a writ (or to permit oral evidence and cross-examination) is refused because the principal contentions are matters of law or do not disclose genuine, substantial disputes of fact central to the OS that require conversion; the Plaintiffs have not met the high threshold to impugn the liquidators' conduct; and allowing conversion would cause disproportionate and prejudicial delay given the age and multiplicity of related proceedings.
14 Feb 2025
The Mainland Judgments satisfied the requirements of s5 MJREO and/or were otherwise enforceable at common law, the Plaintiff established a good arguable case, there was evidence of assets and conduct giving rise to a real risk of dissipation in Hong Kong, and the balance of convenience favoured continuation of the post‑judgment Mareva injunction; accordingly the interlocutory freezing order was continued for D3 and D4 (with a clerical variation) and continued as to D1 and D2 pending proper service out with leave to serve out granted and ancillary procedural orders made.
27 Nov 2024
Court found a serious issue to be tried over ownership of the HK$173,000, accepted that termination of the police investigation created sufficient urgency and that the funds were identifiable (proprietary claim); despite unsatisfactory delay explanations, the shortness of delay from alleged termination of investigation and applicant's undertakings and promise to file affidavits justified granting a conditional interim freezing order.
10 Oct 2024
Because an appeal is pending and release of the larger sum could render the appeal nugatory and unfairly prejudice the appellees, and because fairness requires preserving the funds until the appeal is determined, both sums are to remain in court pending the appeal with liberty to apply on changed circumstances.
14 Feb 2024
The injunction was continued because there is a serious question to be tried on adverse possession; the defendant had been served and had opportunity to be heard so the duty of full and frank disclosure did not apply to discharge the injunction; the plaintiff demonstrated financial capacity to give an undertaking as to damages, making damages an adequate remedy for the defendant, and accordingly there was no reason to refuse continuation of the interim-interim injunction until trial.
30 Aug 2022
There is a serious question to be tried that defendants (or their agents) perpetrated harassing and intimidating acts; plaintiffs offered an adequate cross-undertaking and no convincing evidence was shown that fortification was required; the balance of convenience favoured granting an interlocutory injunction in the terms of the defendants' prior undertaking to prevent further harassment pending trial.