Hong Kong Case Law: Decisions & Judgments

Topic

Authority to act

Legal area

Court

24 Apr 2026

TONG TIN TAI v. ZHANG MINGLIN AND ANOTHER

Citation

[2026] HKCFI 2502
Court

Court of First Instance
Case number

HCMP508/2026

The court refused interim-interim injunctions in paragraphs 1(a) and 1(b) because the Plaintiff had delayed in bringing the application (undermining urgency), regulatory circumstances (FAMR refusal and the PRC business licence held by the recorded legal representative) made implementation speculative, and paragraph 1(b) sought an impermissibly broad blanket restraint; paragraph 1(c) (restraint on removing the Plaintiff as director of the 2nd Defendant) was continued because the 1st Defendant gave an undertaking and the Recorder had already ordered the same against the 2nd Defendant until dete…
22 Feb 2019

LAU MO CHOI v. LAU MUK FAT (as the Manager of Lau Shau Wo Tso‘劉壽和祖’)

Citation

[2019] HKCFI 380
Court

Court of First Instance
Case number

HCA1263/2012

The court rejected the existence of the alleged 1994 and 2010 agreements on credibility, contemporaneous documentary evidence and legal principle (the sketch was at best an invitation to treat and WSS lacked authority from Ping); Ping was a necessary party and the plaintiff lacked authority to bind Ping, so the plaintiff's claims failed and were dismissed, with judgment entered for the defendant and the plaintiff ordered to pay costs and to share assessed expenses.
16 Jan 2019

CARGO CHANNEL SERVICES LTD (in Liquidation) v. HANJIN SHIPPING CO LTD

Citation

[2019] HKCFI 127
Court

Court of First Instance
Case number

HCA1919/2016

Appeal dismissed: plaintiff failed to prove BCC's authority had lapsed on 1 September 2016; even if authority had been affected by the Seoul bankruptcy on 17 February 2017, the trustee ratified BCC's conduct by providing a statement of truth dated 23 March 2017; accordingly no wasted costs order against BCC and plaintiff must pay the costs of the appeal to BCC to be assessed summarily.
11 Oct 2018

LEELOONG INVESTMENT CO LTD v. LAU KWONG & HUNG (a firm of solicitors)

Citation

[2018] HKCFI 2244
Court

Court of First Instance
Case number

HCMP868/2018

The court found that Lau Kwong & Hung did not have authority from Leeloong to file the Notice to Act and that the DHCJ Seagroatt Order could not be construed as conferring such authority or as enabling LKH to pursue a common law derivative action; accordingly the Notice to Act dated 11 May 2018 was set aside and costs were awarded to the applicant where appropriate.
11 Oct 2018

CHEN HA PING HEPBURN (as executrix of the estate of CHEN TSING KWAN, deceased) AND OTHERS v. CHEN TING SAN DANIEL also known as CHEN TING SAN and DANIEL CHEN AND OTHERS

Citation

[2018] HKCFI 2244
Court

Court of First Instance
Case number

HCA570/2014

The court held that the DHCJ order could not be construed as conferring authority on Lau Kwong & Hung to act for Leeloong; the Notice to Act filed by Lau Kwong & Hung was therefore not supported by authority and was set aside; costs consequences follow the presumption in CPR 38.6 unless the claimant demonstrates a good reason to depart from it.
30 Jul 2010

GRAND FIELD GROUP HOLDINGS LTD v. FRANCIS LIM AND OTHERS

Citation

GRAND FIELD GROUP HOLDINGS LTD v. FRANCIS LIM AND OTHERS
Court

Court of First Instance
Case number

HCA873/2009

The 19/3 and 27/3 resolutions were invalid because the requisite notice was not given to the 7 Directors; the 5 Directors' appointments were void (per Reyes J) so the 16/4 resolution could not ratify the earlier invalid resolutions; therefore Kennedys acted without authority in commencing the 1st and 2nd Actions and breached the implied warranty of authority and must personally pay Lim's costs.
1 Feb 2001

Re Skychain Investment Ltd.

Citation

Re Skychain Investment Ltd.
Court

Court of First Instance
Case number

HCMP6506/2000

Application adjourned sine die because the applicant (the dissolved company) and its deponent failed to establish they are persons aggrieved entitled to apply under s.291AB(2) and the deponent's authority and the company's ability to be applicant post-dissolution were not shown.

Hong Kong Case Law

TONG TIN TAI v. ZHANG MINGLIN AND ANOTHER

LAU MO CHOI v. LAU MUK FAT (as the Manager of Lau Shau Wo Tso‘劉壽和祖’)

CARGO CHANNEL SERVICES LTD (in Liquidation) v. HANJIN SHIPPING CO LTD

LEELOONG INVESTMENT CO LTD v. LAU KWONG & HUNG (a firm of solicitors)

CHEN HA PING HEPBURN (as executrix of the estate of CHEN TSING KWAN, deceased) AND OTHERS v. CHEN TING SAN DANIEL also known as CHEN TING SAN and DANIEL CHEN AND OTHERS

GRAND FIELD GROUP HOLDINGS LTD v. FRANCIS LIM AND OTHERS

Re Skychain Investment Ltd.