Hong Kong Case Law: Decisions & Judgments

Topic

Asset freezing

Legal area

Court

28 Nov 2025

FREMERY RESOURCES LTD AND ANOTHER v. CHAN KAM PING AND ANOTHER

Citation

[2025] HKCFI 5899
Court

Court of First Instance
Case number

HCA1727/2025

The court held that the 1st Plaintiff had a good arguable case that the Husband, by diverting commissions into entities and accounts he controlled, breached fiduciary duties and misappropriated company assets; there was a real risk of dissipation and the balance of justice favoured preservation. Accordingly the court granted a local and worldwide Mareva injunction against the Husband for USD 12,293,822.50, a Chabra injunction against the 2nd Defendant for USD 12,293,822.50, and an interlocutory proprietary injunction in favour of the 1st Plaintiff over USD 7,440,496.50 (being the diverted US$…
30 Sept 2025

AXHT COMPANY LTD v. 李克凡

Citation

[2025] HKCFI 4568
Court

Court of First Instance
Case number

HCMP1258/2024

The plaintiff failed to satisfy the standalone requirement of demonstrating a real risk of dissipation: unexplained delay of months after demand and commencement, account statements showed no substantial realizations or transfers despite opportunities, absence of cogent evidence of dishonesty or fraudulent conduct, and credible evidence supporting the defendants' assertion of a novation/loan swap reduced the inference of dissipation; accordingly the Mareva summonses were dismissed.
4 Jul 2025

CHEN WENCAN AND ANOTHER v. SECRETARY FOR JUSTICE AND ANOTHER

Citation

[2025] HKCA 595
Court

Court of Appeal
Case number

CACV101/2023

The Court held that the RN (Public Interest) Regime (ss 204 and 205 exercised on the basis of s 207(e) of the SFO) satisfies the prescribed by law requirement and is proportionate to legitimate protective aims (preservation of assets, protection of investors, public interest), therefore it does not unlawfully interfere with property rights under BL 6 and BL 105 and the appeal against refusal of leave to apply for judicial review is dismissed.
7 Mar 2025

深圳澳銀天使創業投資企業 (有限合伙) AND ANOTHER v. LIU XIAOLONG AND ANOTHER

Citation

[2025] HKCFI 959
Court

Court of First Instance
Case number

HCMP1801/2023

Court found plaintiffs demonstrated a good arguable case and real risk of dissipation by the 1st and 2nd defendants; continued and granted a Mareva injunction against the 1st defendant up to RMB 11,897,850.91; refused to vary the Mareva injunction to permit maintenance payments absent cogent evidence; granted a Chabra injunction against the 2nd defendant limited to the 1st defendant's half share of the property with specified relaxations (rental income allowed) and procedural steps to agree final wording; dismissed the 2nd defendant's summons and made costs orders on a nisi basis.
5 Dec 2024

COMPANY A AND ANOTHER v. COMPANY C

Citation

[2024] HKCFI 3505
Court

Court of First Instance
Case number

HCCT60/2024

The Court found the Tribunal had not finally implemented the escrow arrangements and the Defendant had obstructed and delayed compliance with tribunal directions; because section 45 empowers the Court to grant ancillary interim measures to facilitate the arbitral process, it was appropriate, just and convenient to grant the plaintiffs' injunctions (including a worldwide asset freeze up to USD 55,506,138.62) and to grant leave to enforce PO 36 and PO 41 under section 61 to preserve the status quo pending the Tribunal's further and final orders and award.
12 Nov 2024

梁對陳

Citation

[2024] HKCA 1028
Court

Court of Appeal
Case number

CAMP61/2024

Leave to appeal was refused because the applicant failed to demonstrate a reasonable prospect of success or any other reason in the interests of justice; the lower court's interim injunction preserving HKD800,000 in the husband's MPF was a lawful, proportionate and factually supported exercise of discretion to prevent dissipation of assets pending ancillary relief, and appellate intervention was not warranted.
30 Apr 2024

GREEN ELITE LTD (IN LIQUIDATION) v. FANG ANKONG AND ANOTHER

Citation

[2024] HKCFI 1191
Court

Court of First Instance
Case number

HCA1779/2022

The application was dismissed because Green Elite failed to establish a real risk of dissipation of the Hong Kong assets; the assets relied on are effectively a subset of assets already frozen by the BVI injunction and there is no practical basis to conclude there is a real, unjustified risk of dissipation in Hong Kong.
31 May 2023

LAU LAI SHAN LISA v. ZHANG QI AND OTHERS

Citation

[2023] HKCFI 1465
Court

Court of First Instance
Case number

HCA1992/2019

The summons for fortification was dismissed because the 1st Defendant failed to establish a significant change of circumstances warranting the late application (consolidation did not materially increase delay or costs and the alleged property market downturn did not demonstrate a real reduction in the plaintiff's security) and, on the merits of the ordinary test, the 1st Defendant did not prove or adequately quantify the likelihood of significant loss nor show that the plaintiff would be unable to make good such loss; therefore fortification was not just and proper.
30 Sept 2022

CHUNG PUI TAK AND ANOTHER v. TAM CHI LEUNG NOLAN AND OTHERS

Citation

[2022] HKCFI 3027
Court

Court of First Instance
Case number

HCA1439/2012

The plaintiffs established a good arguable case and sufficient evidence of a real risk of dissipation so that a Mareva injunction would have been justifiable on balance, but because D1 provided binding undertakings and paid specified sums into court, the court accepted those undertakings, adjusted the asset cap to align with the judgment sum, ordered disclosure and authorized permitted expenditures, and therefore made no Mareva injunction order.
7 Jun 2022

SECURITIES AND FUTURES COMMISSION v. MAXIM CAPITAL LTD AND ANOTHER

Citation

[2022] HKCFI 1518
Court

Court of First Instance
Case number

HCA2482/2015

The defendants, by representations on websites, social media, seminars and promotional materials, held themselves out as prepared to carry on Type 9 (asset management) and Type 1 (dealing in securities) regulated activities while unlicensed, in contravention of ss.109(1) and 114(1)(b) of the SFO; Maxim Capital, by maintaining and using the Maxim Capital Account to receive and handle investor funds, was an accessory (aiding/abetting/knowingly involved); accordingly the Court (applying s.213 and established authority) granted declarations, injunctions, a freezing order of the identified account…