Hong Kong Case Law: Decisions & Judgments

Topic

Asset tracing

Legal area

Court

9 Feb 2026

EVERCARE HEALTH LTD v. SO LAI KAN also known as GOBBY SO AND OTHERS

Citation

[2026] HKDC 230
Court

District Court
Case number

DCCJ3316/2025

At the interlocutory stage the plaintiff established good arguable cases on unjust enrichment, proprietary claim, dishonest assistance and unlawful means conspiracy based on HK$255,470 paid by fraud into the 2nd defendant's MOX account; there are assets in Hong Kong and objective circumstantial evidence supports a real risk of dissipation; the balance of convenience favours continuation of the proprietary‑cum‑Mareva injunction until trial; accordingly paragraphs 1 and 2 of the summons are allowed and the injunction is continued, with costs ordered nisi.
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.
29 Aug 2025

BAI YANG v. THE HONGKONG AND SHANGHAI BANKING CORPORATION LTD AND OTHERS

Citation

[2025] HKCFI 3965
Court

Court of First Instance
Case number

HCMP42/2025

Court granted a limited Norwich Pharmacal Order against the 6th Respondent (China Construction Bank (Asia) Corporation Limited) for disclosure of bank statements and, on identification of specific transactions, corresponding transaction records for the period 12 May 2015 to 12 May 2017 because there was cogent evidence of concealment, necessity was established, other routes were exhausted, comity with the Mainland court was not offended, service on HK Morgold was valid via the Registrar, and the order must be narrowly tailored and court-controlled.
28 Jan 2025

RE LEE SIU FUNG SIEGFRIED

Citation

[2025] HKCFI 462
Court

Court of First Instance
Case number

HCB345/2001

The trustees satisfied the two primary s29 tests — the information and documents sought were reasonably required for them to perform their functions and there was a prima facie case that the respondent, by reason of her directorships and shareholdings in relevant companies, could provide the information; balancing proportionality and delay factors did not outweigh the trustees' need for investigation, so a s29 order for production and examination was justified with limited scope and timing amendments.
28 Aug 2024

MEIDI INVESTMENT HOLDING LTD v. BSC CAPITAL LTD AND OTHERS

Citation

[2024] HKCFI 2207
Court

Court of First Instance
Case number

HCA1445/2021

The court held that, applying established authorities, the Plaintiff demonstrated strong reasons to justify continuation of Hong Kong proceedings despite the exclusive jurisdiction clause in the CMA: centralisation was necessary to adjudicate alleged fraud and conspiracy involving multiple parties and Hong Kong‑based securities and transfers, and the interests of justice in avoiding fragmentation outweighed enforcement of the EJC; accordingly the 2nd Defendant’s application to discharge the injunction and oust Hong Kong jurisdiction was dismissed.
9 Feb 2024

POWER-PACK NETWORK INTERNATIONAL PTE LTD v. STANDARD CHARTERED BANK (HONG KONG) LTD

Citation

[2024] HKDC 291
Court

District Court
Case number

DCMP5999/2023

Given cogent and compelling evidence of fraud, a clear prospect that the specified disclosure will materially assist tracing and preserving assets, and that the scope of documents sought is specific and not unduly wide, the court grants Norwich Pharmacal relief ordering the bank to disclose the specified account information and transactional records for the stated period.
3 Nov 2022

ZHAO ZHI QIANG v. ZHAO ZHIGUANG AND ANOTHER

Citation

[2022] HKCFI 3356
Court

Court of First Instance
Case number

HCA1614/2019

The court held the Unless Order required qualitative compliance (not merely a time filing) given the Judge’s prior finding of non‑compliance and the context; however, after reviewing the course of disclosure (4th–7th affirmations) and construing the Disclosure and Unless Orders narrowly where ambiguous, the court found D1 had provided 'literally complete compliance' in good faith and granted retrospective relief from sanction, refusing to strike out the defence or enter judgment against D1 and adjourning the application against D2 sine die.
27 Sept 2022

A v. R1 AND ANOTHER

Citation

[2022] HKCFI 3012
Court

Court of First Instance
Case number

HCMP1062/2022

On the facts there was a real possibility that R1 and R2 had been mixed up in B's scheme to frustrate enforcement because transfers through their Hong Kong accounts temporally coincided with account openings and closures abroad and the misappropriation established in the Country X judgment; disclosure would likely yield substantial and worthwhile information enabling enforcement of the foreign judgment and any detriment to the banks was minimal, therefore a Norwich Pharmacal order should be granted in the terms of the draft order with modifications.
13 May 2022

TARGET INSURANCE CO LTD v. NG YU AND OTHERS

Citation

[2022] HKCFI 1362
Court

Court of First Instance
Case number

HCA305/2022

Court granted a conditional interim stay of paragraphs 7 and 8 of the Order but varied paragraph 7 to increase the individual disclosure threshold to HK$200,000 because D1 had already disclosed assets with an estimated value exceeding the Sum and admitted beneficial ownership; the stay was justified on balance provided conditions (periodic sealed affirmations, updates and liberty to apply to lift) to protect plaintiff's ability to police the injunction and to avoid irremediable prejudice to the defendant.
11 Apr 2022

CYCT v. FHJAL

Citation

[2022] HKFC 76
Court

Family Court
Case number

FCMC16235/2012

The court accepted there was a material, unforeseen deterioration in the husband’s financial position (sale of TMHK and termination of employment), accepted that the wife’s asset position had substantially improved, accepted evidence of a reduction or tacit agreement reducing maintenance to US$5,500 from early 2016/2017 and exercised its s11 discretion to vary the periodic payment to US$5,500 from 4 April 2019 until 10 April 2022 and thereafter to a nominal HK$1 per annum from 11 April 2022, with no further CPI adjustments.