Hong Kong Case Law: Decisions & Judgments

Topic

Default judgment enforcement

Legal area

Court

27 Feb 2026

LAU TIN FAI v. GOLD REGAL INTERNATIONAL LTD

Citation

[2026] HKDC 311
Court

District Court
Case number

DCCJ7008/2024

The defendant had not complied with the Default Judgment Order and water seepage persisted, creating a safety risk; accordingly, under Order 45 r8 RDC the court granted the plaintiff leave to enter the defendant's property to carry out remedial works at the defendant's cost, ordered payment of the plaintiff's costs on demand, endorsed a penal notice and summarily assessed costs at HK$50,000.
24 Mar 2025

日進機械工程有限公司對雍境建築有限公司

Citation

[2025] HKDC 412
Court

District Court
Case number

DCCJ4456/2022

The defendant failed to make a timely application for relief from sanctions within the 14‑day period and provided no sworn evidence to justify relief; the alleged letter was not received and bank statements did not support the claimed inability to pay; the defendant’s payment of HK$15,000 to court demonstrated available assets; therefore the automatic sanction (striking out the amended defence and counterclaim and entering judgment for the plaintiff) was properly applied and the defendant’s appeal is dismissed.
29 May 2024

HIP LIK PACKAGING PRODUCTS FACTORY LTD v. THE HONGKONG AND SHANGHAI BANKING CORPORATION LTD

Citation

[2024] HKDC 856
Court

District Court
Case number

DCMP1555/2024

Norwich Pharmacal relief was granted because the applicant produced cogent and compelling evidence (default judgment and declarations against IPML), the narrowly tailored disclosure sought was likely to yield substantial benefit by revealing subsequent recipients and facilitating preservation or recovery of funds, other reasonable avenues had been exhausted, and the balance of interests favored disclosure; costs ordered to be paid by the applicant to the bank on an indemnity basis.
23 Sept 2021

SECRETARY FOR JUSTICE v. CAI KANG GANG AND ANOTHER

Citation

[2021] HKCFI 2159
Court

Court of First Instance
Case number

HCMP1271/2014

The court held that the Restraint Order was validly made and, on the evidence, including patterns of transactions and the scale of receipts through R2, there remained a real risk that the funds were proceeds of crime; delay alone did not justify varying the Order to enable satisfaction of the Intervener’s judgment and the discretionary relief sought was refused (the Restraint Order was maintained).
24 Jun 2020

WING ON FINANCE CO LTD v. CHINA METAL RECYCLING (HOLDINGS) LTD (In Compulsory Liquidation) AND OTHERS

Citation

[2020] HKCFI 1385
Court

Court of First Instance
Case number

HCA1412/2013

The court permitted variation of the Injunction Order in the form agreed by the parties: the specified judgment sum of HK$3,845,343 together with interest from 28 February 2015 and summary assessed costs of HK$12,000 were excluded from the assets subject to the Mareva injunction because Mareva relief is a personal restraint aimed at preventing dissipation and is not intended to thwart creditors' enforcement rights; adequate notice procedure was addressed.
19 Sept 2018

BANCO DE CHILE v. BORUIDA TRADING CO LTD AND OTHERS

Citation

[2018] HKCFI 2294
Court

Court of First Instance
Case number

HCA1621/2018

The application for disclosure was granted because the plaintiff's abandonment of proprietary remedies against Tech Giant did not preclude ordering SCB to disclose account records necessary to trace the misappropriated DB funds and pursue recovery against third parties; the disclosure is relevant and properly ancillary to the Mareva injunction and to enforcement of the default judgment, and a limited release from the implied undertaking was justified while preserving the bank's privilege against self-incrimination.
26 May 1987

MALAHON CREDIT COMPANY LIMITED v. SIU CHUN WAH, ALICE AND ANOTHER

Citation

MALAHON CREDIT COMPANY LIMITED v. SIU CHUN WAH, ALICE AND ANOTHER
Court

Court of First Instance
Case number

HCMP526/1987

The charging order under Cap.4 gave Malahon a charge against Mr. Ng’s interest only in the proceeds of sale, not an interest in the land; on the evidence (uncontradicted affidavit and deed evidence) Madam Siu held a one‑half beneficial interest which had been exonerated under the doctrine of equity of exoneration, so after repayment of the mortgage and further charge the surplus must be divided one‑half to Madam Siu.
17 Jul 1986

TOPPAN PRINTING CO LTD v. CHAMPION DRAGON DEVELOPMENT LTD

Citation

TOPPAN PRINTING CO LTD v. CHAMPION DRAGON DEVELOPMENT LTD
Court

Court of First Instance
Case number

HCA4985/1985

The judge restored Master O'Donnell's order and allowed the examination because evidence showed Mr. Wai was actively conducting management and directorial functions for the defendant companies (including cheque signatory and contracting), the alleged misstatement before Master Woolley was attributable to Mr. Wai rather than the plaintiff, and therefore the ex parte order should not have been discharged.
17 Jul 1986

TOPPAN PRINTING CO LTD v. CHAMPION DRAGON DEVELOPMENT LTD

Citation

TOPPAN PRINTING CO LTD v. CHAMPION DRAGON DEVELOPMENT LTD
Court

Court of First Instance
Case number

HCA4986/1985

On the evidence the respondent (Mr Wai) was actively conducting management and directorial functions for the defendant companies (signing cheques, contracting and instructing deliveries), and therefore was an 'officer' for the purposes of Order 48 r.1 (including as a past officer); Master Woolley's setting aside of Master O'Donnell's order was incorrect because the plaintiff's affidavit was not deceptive and the misleading assertions originated with the respondent; the original examination order must be restored and the examination must proceed.
17 Jul 1986

TOPPAN PRINTING CO LTD v. CHAMPION DRAGON DEVELOPMENT LTD

Citation

TOPPAN PRINTING CO LTD v. CHAMPION DRAGON DEVELOPMENT LTD
Court

Court of First Instance
Case number

HCA4984/1985

The evidence demonstrated that Mr Wai was actively conducting management functions (contracts, delivery instructions, cheque signatory) for the defendant companies despite assertions of resignation; Master Woolley erred in setting aside Master O'Donnell's order; therefore the appeal is allowed, the original order restored, and Mr Wai must be examined under Order 48 r.1.