Hong Kong Case Law: Decisions & Judgments

Topic

Civil contempt

Legal area

Court

14 Feb 2025

CHAN HIN CHEUNG v. KWAN YAT HUNG

Citation

[2025] HKCFI 703
Court

Court of First Instance
Case number

HCMP106/2024

Contempt was proven for willful and cynical non-compliance with the Order of Lisa Wong J; the defendant was absent, uncooperative and had not purged contempt; although aggravating factors warranted custody, there was insufficient basis to find obstruction of administration of justice requiring an indeterminate sentence or to conclude assets were dissipated; appropriate sentence is 3 months' imprisonment plus payment of plaintiff's costs on an indemnity basis, to be taxed if not agreed.
14 May 2010

YUEN MINGHWA FRANCOIS, the administrator of the estate of YUEN KIU KWAN, deceased v. LO MEI KIN STELLA

Citation

YUEN MINGHWA FRANCOIS, the administrator of the estate of YUEN KIU KWAN, deceased v. LO MEI KIN STELLA
Court

Court of First Instance
Case number

HCA2682/2008

Defendant was in contempt by failing to comply with orders and by making unauthorised payments from companies under her control; because admission and repayment were delayed and prejudice and additional costs resulted, the appropriate sanction is a fine of $100,000 payable within 28 days plus payment of the plaintiff's committal costs on an indemnity basis rather than immediate imprisonment.
24 Nov 2009

SECRETARY FOR JUSTICE v. OCEAN TECHNOLOGY LTD t/a CITIZENS\' RADIO AND OTHERS

Citation

SECRETARY FOR JUSTICE v. OCEAN TECHNOLOGY LTD t/a CITIZENS\' RADIO AND OTHERS
Court

Court of First Instance
Case number

HCMP71/2008

The respondents knowingly breached a valid court injunction and thereby committed civil contempt; malice is not a necessary element of contempt, but mitigation (good faith, apology and public interest context) can affect penalty; given the exceptional factual context and that the respondents had purged their contempt, imprisonment was inappropriate and the appropriate sanctions are a fine of HKD 10,000 and a contribution of HKD 50,000 towards the Secretary for Justice's legal costs for each respondent, with the court declining to order full indemnity costs due to proportionality and public in…
5 May 2000

PFIZER INC. v. ULTRASOUND HOLDINGS LTD.

Citation

PFIZER INC. v. ULTRASOUND HOLDINGS LTD.
Court

Court of First Instance
Case number

HCA2712/1999

Evidence of personal service was insufficient to prove service beyond reasonable doubt, but Li Man knowingly aided and abetted publication that continued the defendant's magazine and thus committed a civil contempt; the conduct did not amount to criminal contempt because it did not impede or interfere with the administration of justice as required for criminal contempt.

Hong Kong Case Law

CHAN HIN CHEUNG v. KWAN YAT HUNG

YUEN MINGHWA FRANCOIS, the administrator of the estate of YUEN KIU KWAN, deceased v. LO MEI KIN STELLA

SECRETARY FOR JUSTICE v. OCEAN TECHNOLOGY LTD t/a CITIZENS\' RADIO AND OTHERS

PFIZER INC. v. ULTRASOUND HOLDINGS LTD.