Hong Kong Case Law: Decisions & Judgments

Topic

Causation and damages

Legal area

Court

7 Nov 2025

HANSOM FINANCE LTD (IN CREDITORS\' VOLUNTARY LIQUIDATION) v. YANG HAOYING

Citation

[2025] HKCFI 5278
Court

Court of First Instance
Case number

HCA784/2022

The court found that Mr Yang breached his duties to exercise reasonable care, skill and diligence, to exercise independent judgment and to act bona fide in the best interests of Hansom by approving and signing five large unsecured loans and authorising payments to third-party recipients without adequate due diligence or security and by extending two defaulted loans on uncommercial terms; those breaches caused Hansom's loss of HK$799,000,000 and judgment was entered for that sum with interest and costs.
16 Aug 2022

TREASURE EXPRESS INDUSTRIAL LTD v. DRAGON WORKSHOP LTD AND ANOTHER

Citation

[2022] HKDC 839
Court

District Court
Case number

DCCJ4006/2018

Tenant breached Clause 16 by conditioning execution of transfer forms on full refund; breach date found to be 10 August 2017; but-for the breach the transfers would likely have proceeded and Fresh applications, additional consultancy costs of HK$63,000 and apportioned renovation cost of HK$9,000 were caused by the breach; total loss HK$72,000 deductible from retained deposit of HK$40,144.73 leaving Tenant and Lai liable to pay HK$31,855.27; counterclaim dismissed; costs order nisi that Tenant pay 85% of costs to be taxed on Small Claims Tribunal scale; pre-judgment interest at 1% above prime…
1 Feb 2019

ONC LAWYERS (a firm) v. YIU WING CHING JOHN

Citation

[2019] HKDC 144
Court

District Court
Case number

DCCJ909/2015

Defendant, as a held‑out salaried partner entrusted with independent conduct of clients, owed fiduciary and duty‑of‑care obligations to the plaintiff; he knew or ought to have known the client Au's precarious finances, failed to obtain sufficient costs on account and failed to attempt to exercise a lien over the settlement cheque, and those failures caused the plaintiff's recoverable losses; additionally the defendant knowingly misrepresented his intention re emigration to induce early release; therefore judgment for plaintiff for specified damages and costs.
23 Mar 2016

NG WAI KWAN v. LAI WAI LAM trading under the name of W L LAI & CO, SOLICITORS

Citation

NG WAI KWAN v. LAI WAI LAM trading under the name of W L LAI & CO, SOLICITORS
Court

District Court
Case number

DCCJ2282/2014

The defendant's pre-completion advice was not incorrect in context: no executed sub-DMC was produced before the completion deadline so the vendor had failed to show a good title and the purchaser was not bound to complete; on the negligence standard the defendant's judgment fell within the range of reasonable professional responses and the plaintiff failed to prove negligence or causation. Claim dismissed.
16 May 2012

LOU SIU PING AND ANOTHER v. LAM TSZ MAN AND ANOTHER

Citation

LOU SIU PING AND ANOTHER v. LAM TSZ MAN AND ANOTHER
Court

Court of First Instance
Case number

HCA506/2009

Woo owed the plaintiffs a duty of care as their solicitor in relation to their intended purchase; he breached that duty by failing to explain and warn the plaintiffs about the legal effect and risks of the will/power of attorney arrangement and by failing to take steps to protect or register their interest; that breach caused the foreseeable loss (purchase price, fees and costs) and plaintiffs are entitled to damages.
17 Mar 2010

ORDONA RIZALINDO JACILDONE v. COMPASS TECHNOLOGY CO LTD AND ANOTHER

Citation

ORDONA RIZALINDO JACILDONE v. COMPASS TECHNOLOGY CO LTD AND ANOTHER
Court

Court of Appeal
Case number

CACV212/2009

The Amended Statements of Claim were struck out because the pleaded unlawful‑means conspiracy failed to plead essential elements (particulars of the unlawful means, the requisite intention to injure and a causal link to the claimed loss); the plaintiffs' alternative case advanced at hearing could not be inferred from the pleadings, was inconsistent with their own evidence and Labour Tribunal filings, and there was no realistic prospect of curing the defects by amendment, therefore dismissal was appropriate.
18 Jul 2005

WYCOMBE INVESTMENT LTD v. EDWIN LEONG SIU HUNG

Citation

WYCOMBE INVESTMENT LTD v. EDWIN LEONG SIU HUNG
Court

Court of First Instance
Case number

HCCL66/2004

Court found Wycombe was the correct plaintiff but the oral contract for the fund was with Tai Hung Fai Enterprises Ltd; there was no objective evidence that Leong assumed personal responsibility such as would displace limited liability, so Leong was not personally liable and the action must be dismissed. The court additionally found that, had Leong been held personally liable, his trading in late 1991 amounted to breach of the minimum standard of care for a fund manager (reckless over‑exposure), but the plaintiff's blanket claim for return of US$2,000,000 with compound interest could not be s…
12 Dec 2002

MART TREASURE INVESTMENT LTD. v. DAI SHU SHING AND OTHERS

Citation

MART TREASURE INVESTMENT LTD. v. DAI SHU SHING AND OTHERS
Court

Court of First Instance
Case number

HCA905/2001

The 2nd and 3rd Defendants breached the professional duty of care owed to their client by failing to disclose material knowledge (the inflated purchase price and proposed payments), failing to verify or obtain proper authority for disbursements, and making payments contrary to the shareholders' instructions; those breaches caused the Plaintiff loss of $4,100,000 and justify judgment for that sum with interest and indemnity costs.