Hong Kong Case Law: Decisions & Judgments

Topic

Committal proceedings

Legal area

Court

16 Mar 2026

WSW v. CSLPC

Citation

[2026] HKCA 430
Court

Court of Appeal
Case number

CAMP29/2025

The application for extension of time to appeal was dismissed because the intended appeal had no real prospect of success: there was no evidence a copy of the ancillary relief order served on the Wife was endorsed with a penal notice and no justification to dispense with service; the alleged contempt was resolved by payment and alternatives to committal had already been pursued, rendering committal unnecessary and inappropriate.
2 Mar 2026

YAO GUOLIANG AND ANOTHER v. FOREVER WINNER INTERNTIONAL LTD AND OTHERS

Citation

[2026] HKCFI 1146
Court

Court of First Instance
Case number

HCMP2442/2024

On an objective construction of the Undertaking and its context, "assets" did not include mere physical share certificates; the mere movement of those certificates from the UBS account without more did not constitute dealing with Forever Winner's assets and therefore did not breach the Undertaking or render Wang's affirmation false; accordingly the ex parte Order 52 leave was set aside and the committal (contempt) proceedings dismissed.
10 Dec 2025

LI WAI CHUN TRANSPORTATION COMPANY LTD v. CHANG MAN SHAN YVETTE AND OTHERS

Citation

[2025] HKCFI 6303
Court

Court of First Instance
Case number

HCA198/2023

The court granted a limited variation of the domestic and worldwide Mareva injunctions permitting HK$762,830 of the HK$1,669,985.78 net proceeds to be paid to the 1st Defendant for legal costs because the Plaintiff's pleaded proprietary claim could at most cover 12% of the proceeds (c. HK$200,398), leaving sufficient unencumbered funds; the 1st Defendant had, on the evidence, sufficiently shown lack of other available assets and that the purpose was to fund her defence rather than dissipate assets; the balance of justice therefore favored allowing the payment subject to compliance with the En…
19 Sept 2025

LEONG MA LI v. HIGH FASHION NEW MEDIA CORPORATION LIMITED (suing on behalf of itself and also in its capacity as the sole shareholder of LONGFORD INFORMATION AND TECHNOLOGY CO., LIMITED) (上海梁富信息科技有限公司)

Citation

[2025] HKCFA 16
Court

Court of Final Appeal
Case number

FAMV42/2025

Under Rule 7 the Court dismissed as not reasonably arguable Questions 3–14 and the applicant's 'or otherwise' ground, but directed an oral hearing limited to Questions 1 and 2. The Court concluded only questions raising whether a principal can be held in contempt for an agent's prohibited acts (authorisation or foreseeability/failure to prevent under Hone v Page) were sufficiently arguable to merit oral hearing, and required focused assistance on whether leave should also be entertained on two narrow 'or otherwise' grounds concerning s732 Companies Ordinance and non-prosecution of the Action.
5 Sept 2025

CARTIER INTERNATIONAL AG AND OTHERS v. DYNASTY JEWELRY (HONG KONG) LTD AND OTHERS

Citation

[2025] HKCA 818
Court

Court of Appeal
Case number

CACV232/2021

Where an applicant in civil committal proceedings proves contempt beyond reasonable doubt on available evidence, a respondent who advances an affirmative explanation (eg that incriminating statements were mere 'sales talk') must lay some evidential basis for that explanation; the respondent's right to silence does not relieve him of the evidential burden to support such a defence and the court may convict in the absence of contrary evidence, accordingly the proposed questions were unarguable and leave to appeal was refused.
23 May 2025

CARMON REESTRUTURA-ENGENHARIA E SERVICOS TÉCNICOS ESPECIAIS(SU) LIMITADA v. CARMON RESTRUTURA LTD AND ANOTHER

Citation

[2025] HKCFI 2163
Court

Court of First Instance
Case number

HCA1812/2022

Security for costs application dismissed because plaintiff demonstrated a high degree of probability of success at trial based on the Consortium Agreement and prior findings; setting aside application dismissed because the alleged non-disclosures were either not material (DIFC matters, deadline misstatement) or had been brought to the court's attention prior to granting leave (D2's 7th affidavit) and remedial steps were insufficient to vitiate the ex parte leave; costs ordered to plaintiff to be summarily assessed on paper.
6 Nov 2024

ZURICH INSURANCE COMPANY LTD 對 CHAN MAN FU

Citation

[2024] HKDC 1615
Court

District Court
Case number

DCMP1351/2024

The court convicted the respondent of contempt because contemporaneous signed documents (bankruptcy returns and social welfare applications) showing zero income directly contradicted the verified Statement of Damages claiming HK$45,000 monthly income; the respondent failed to adduce credible evidence or call his lawyer to support his explanation, and the court was satisfied beyond reasonable doubt that the statement was false and made knowingly or recklessly.
23 Sept 2024

TKLK v. WKJ

Citation

[2024] HKFC 181
Court

Family Court
Case number

FCMP38/2007

Respondent committed contempt by failing to provide his residential address as required by the 2021 Order; a custodial sentence of 14 days was appropriate to reflect the seriousness and to enforce compliance, but it was suspended for 7 days conditional on filing and serving an affirmation of current residential address within 7 days; appropriate costs awarded to Applicant on a half basis taxed party and party if not agreed, with Applicant's own costs taxed per Legal Aid Regulations.
26 Aug 2024

SECRETARY FOR JUSTICE v. LI KWOK WING AND ANOTHER

Citation

[2024] HKCFI 2107
Court

Court of First Instance
Case number

HCMP2254/2020

The deliberate harassment, abusive shouting and obscene gestures by the defendants at witnesses exiting the Inquest, captured on video and corroborated by witness testimony, constituted criminal contempt because the acts were inherently likely to interfere with the administration of justice; for this form of contempt basic intent to do the acts was sufficient and the prosecution proved guilt beyond reasonable doubt.
25 Aug 2023

RAMANJIT SINGH v. COMMISSIONER OF CORRECTIONAL SERVICES AND ANOTHER

Citation

[2023] HKCFI 1983
Court

Court of First Instance
Case number

HCAL1064/2023

The magistrate erred in wholly excluding the New Evidence from consideration of the section 5 application because section 12(4)/10(2)(b) permit receiving evidence for section 5 and section 23(4) does not preclude such consideration; however, after receiving and weighing that evidence afresh the court concluded the applicant did not meet the requisite burdens under section 5(1)(c) or (d). The New Evidence did not render the prosecution case worthless nor defeat prima facie sufficiency for committal, and amendments to particulars on remittal were permissible to align charges with the evidence.…