Hong Kong Case Law: Decisions & Judgments

Topic

Contempt

Legal area

Court

17 Dec 2025

BEIJING SONGXIANGHU ARCHITECTURAL DECORATION ENGINEERING CO LTD v. KITTY KAM ALSO KNOWN AS WANG YUZHI

Citation

[2025] HKCA 1134
Court

Court of Appeal
Case number

CAMP247/2024

The Court of Appeal held that the judge did not err in principle or law in making the unless order and entering judgment on default: the unless order was a permissible, proportionate last resort to enforce the Repatriation Order in light of the defendant's flagrant, contumelious non‑compliance and abusive litigation conduct; the defendant could appeal as of right because the judgment was entered pursuant to the unless order; the appeal was dismissed and the costs award was affirmed.
17 Dec 2025

BEIJING SONGXIANGHU ARCHITECTURAL DECORATION ENGINEERING CO LTD v. KITTY KAM ALSO KNOWN AS WANG YUZHI

Citation

[2025] HKCA 1134
Court

Court of Appeal
Case number

CACV495/2024

The Court held the Unless Order was lawful and discretionary to enforce the Repatriation Order as a last-resort measure; because the defendant defaulted the sanction (strike out of defence and entry of judgment) took effect automatically and gave rise to an appeal as of right; the primary judge was entitled to disbelieve the defendant's late unsigned draft affirmation, to find flagrant and contumelious non-compliance, and to conclude the sanction was proportionate in all the circumstances; accordingly the appeal was dismissed and the judgment entered below was upheld; costs awarded on indemni…
9 Oct 2025

SOREMI INVESTMENTS LTD v. CHINA NATIONAL GOLD GROUP HONG KONG LTD AND ANOTHER

Citation

[2025] HKCFI 4768
Court

Court of First Instance
Case number

HCA797/2025

The court granted the Mareva injunction because SIL demonstrated a good arguable case on conversion, dishonest assistance and conspiracies; CNG has assets in Hong Kong (notably CGI shares); and there is a solid basis for concluding a real risk of unjustified dissipation given the alleged wrongful transfers, the circumstantial evidence of control and instruction, delay tactics, non-compliance with orders and a BVI contempt finding. On balance of convenience a domestic freezing order is necessary and appropriate; narrowly tailored ancillary disclosure about the manner of holding of CGI shares w…
23 Jul 2025

YU QUAN LI AND ANOTHER v. SUEN KIN WING

Citation

[2025] HKCFI 3204
Court

Court of First Instance
Case number

HCA1671/2018

The defendant's admissions in the criminal Summary of Facts together with extensive documentary and WeChat evidence established deceit and unjust enrichment; the defendant was debarred from giving evidence for failing to file a court‑ordered supplemental witness statement; the illegality defence was not established on the evidence and therefore did not bar recovery; accordingly plaintiffs entitled to judgment for HK$119,000,000 plus specified interest; costs reserved.
8 Jul 2025

SIN CHAN KAM 對 THE INCORPORATED OWNERS OF WAI SUN BUILDING

Citation

[2025] HKCA 637
Court

Court of Appeal
Case number

CAMP24/2025

The Court held that the Land Tribunal has power to punish contempt under s10(1A) and that appeals concerning contempt are governed by HCO s50(1); notwithstanding that s50(1) may render leave unnecessary, the Court granted leave because the respondent demonstrated arguable errors of law: the trial judge either failed to consider the respondent's ability to comply with the mandatory injunction or failed to state clearly that finding, thereby giving the appeal a real prospect of success; costs reserved to the appeal hearing.
27 May 2025

ANZ COMMODITY TRADING PTY LTD v. EXCELLENCE RAISE OVERSEAS LTD AND OTHERS

Citation

[2025] HKCFI 2292
Court

Court of First Instance
Case number

HCCL4/2017

The defendant was found to have willfully and deliberately evaded service and disobeyed disclosure orders; however, having regard to her minor clerical role, family and financial circumstances and the four days custody already served, a custodial sentence was not warranted; instead the court imposed a financial sanction by ordering the defendant to pay HK$50,000 towards the plaintiff's costs into court within 21 days, with default imprisonment for 2 days, and discharged the bail conditions.
22 Apr 2025

CHINA EVERGRANDE GROUP (IN LIQUIDATION) v. HUI KA YAN AND OTHERS

Citation

[2025] HKCFI 1644
Court

Court of First Instance
Case number

HCMP1080/2024

The court refused leave to appeal both the Discharge Decision and the Unless Ruling for lack of reasonable prospects; found Xia repeatedly and deliberately non‑compliant with asset disclosure orders and that the Defence filed on 27 March 2025 without a Statement of Truth (and effectively filed to frustrate an imminent unless sanction) was an abuse of process and struck it out; granted a final extension to comply with the Asset Disclosure Order to 12 noon on 25 April 2025, failing which Xia will be debarred from defending the action; and ordered costs for the applications in favour of CEG (inc…
28 Mar 2025

BEIJING RENJI REAL ESTATE DEVELOPMENT GROUP CO., LTD v. ZHU MIN

Citation

[2025] HKCFI 1295
Court

Court of First Instance
Case number

HCA189/2025

The application for interim-interim receivership was dismissed because the applicant failed to demonstrate a serious or urgent risk of dissipation: the September 2024 transfer was transparent and publicly disclosed, the assets remained caught by an existing Mareva injunction, less-draconian remedies (including contempt proceedings and supervisory measures) were available, and the balance of fairness did not justify the appointment of receivers with draconian powers on the expedited footing sought.
20 Jun 2024

CHAN YUK PING v. LIEW SHUK FUI

Citation

[2024] HKDC 999
Court

District Court
Case number

DCCJ1811/2022

Liability having been established by interlocutory judgment, the court awarded compensatory general/aggravated damages of HK$600,000 and special damages for medical expenses of HK$2,000 (total HK$602,000), refused exemplary damages because compensatory award and prior contempt punishment were sufficient and the case did not fall within Rookes categories or justify additional punishment, rejected all other special damages for lack of evidence, and awarded pre-judgment interest at 1% above HSBC prime from date of writ with post-judgment interest at judgment rate; costs nisi to plaintiff.
11 Jun 2024

WONG YEE CHUK AND ANOTHER v. LO PO WAI, HARRY AND OTHERS

Citation

[2024] HKCFI 1563
Court

Court of First Instance
Case number

HCMP3363/2016

Petitions dismissed because petitioners failed to prove the alleged breaches of the Common Understanding/Agreed Mode by Lo/Pan; court found companies had operated as a group and that shareholders reposed mutual trust, but rejected existence of any broad Consent Requirement; critical mainland court findings and evidential record justified Pan/Lo actions (including withholding supply to non‑paying Yibao); concurrently, Wong breached fiduciary duties by causing trademark transfers, registering competing trademarks and by acts that harmed NHEL (withholding payments, failing to assist with regulat…