Hong Kong Case Law: Decisions & Judgments

Topic

Enforcement of foreign judgment

Legal area

Court

14 Oct 2025

HAYWARD INDUSTRIES, INC. v. NINGBO C.F. ELECTRONIC TECH CO., LTD AND OTHERS

Citation

[2025] HKCFI 5252
Court

Court of First Instance
Case number

HCA2340/2024

The court held that the compensatory part of the US judgment may be enforceable only if it is separable by reference to distinct causes of action, but because the 1st Defendant's complaint of breach of natural justice and an appeal in the US were pending the court adjourned the summary judgment application against the 1st Defendant pending the US appeal and permitted further expert affirmation exchange; the summary judgment application against the 2nd Defendant was dismissed for lack of pleaded basis to hold it liable; security for costs of HK$1,200,000 was ordered for claims against the 2nd…
1 Aug 2025

JACKY ZONG AND OTHERS v. KELLY FULI ZONG AND ANOTHER

Citation

[2025] HKCFI 3355
Court

Court of First Instance
Case number

HCMP2772/2024

The court held that the plaintiffs established serious issues to be tried on both the contractual and trust/fiduciary claims and that, applying the two-stage s21M test, it was just and convenient to grant a preservation order in aid of the PRC proceedings; accordingly a preservation order prohibiting withdrawal or encumbrance of the HSBC Account Assets and an ancillary disclosure order were granted, limited to preserving assets for determination by the PRC Court and without adjudicating merits of the foreign claim.
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.
24 Jan 2024

THE JOINT AND SEVERAL LIQUIDATORS OF GREEN ELITE LTD (IN OFFICIAL LIQUIDATION IN THE BRITISH VIRGIN ISLANDS) v. STANDARD CHARTERED BANK (HONG KONG) LTD

Citation

[2024] HKCFI 259
Court

Court of First Instance
Case number

HCMP2187/2022

The court granted discovery against SCB limited to documents necessary to trace the Director's Debt (not the sale proceeds distribution already traced to the three directors by the BVI court): account opening documents, bank statements and communications for accounts 8522350750, 5100023 and any other SCB accounts in the name of Fang Ankong from April 2010 to date; wider discovery in relation to the sale proceeds and immediate further transaction-specific disclosure were refused; disclosed material may be used for enforcement proceedings and, if evidence justifies, for criminal reporting or pr…
14 Jun 2018

NAGRAVISION SA v. ZHUHAI GOTECH INTELLIGENT TECHNOLOGY CO LD AND OTHERS

Citation

[2018] HKCFI 1330
Court

Court of First Instance
Case number

HCA2297/2016

On interlocutory evidence the plaintiff established a good arguable case on multiple causes of action, the Texas default judgment met the standards for enforcement in Hong Kong (final, for a definite sum, and by a court of competent jurisdiction), there was sufficient evidence of presence/substantial US-based operations to support US jurisdiction, there was a real risk of dissipation and it was just and convenient to continue interlocutory relief; accordingly the Mareva injunction and delivery up order were continued, bankers records order granted, and the defendants jurisdictional challeng…
9 Feb 2018

BARCLAY PHARMACEUTICALS LTD v. ANTOINE MEKNI AND OTHERS

Citation

[2018] HKCFI 436
Court

Court of First Instance
Case number

HCMP2094/2017

Given the existence of final English judgment, clear evidence that the 6th defendant holds assets in Hong Kong, strong prima facie evidence of breaches of Hong Kong freezing injunctions and a real risk of dissipation, together with the absence of any substantial defence and the plaintiff's undertaking as to damages, the balance of convenience required appointment of receivers over the 6th defendant to protect the assets and ensure effectiveness of the freezing orders.
5 Jun 2015

CHINACAST EDUCATION CORPORATION AND OTHERS v. CHAN TZE NGON AND OTHERS

Citation

CHINACAST EDUCATION CORPORATION AND OTHERS v. CHAN TZE NGON AND OTHERS
Court

Court of First Instance
Case number

HCA1062/2012

Entitlement to security for costs was established; plaintiffs failed to demonstrate that an order would stifle the action because they were able but unwilling to fund further litigation; a Delaware judgment in favour of the plaintiff did not negate the power to order security because judgment debtor status does not equate to the defendant holding the plaintiff's money and enforcement in Hong Kong was not assured; taking into account deficiencies in the skeleton bill and excessive time charging, security for costs up to 29 May 2015 was fixed at HK$300,000 and the application for further securi…
19 Jan 2015

HO MIU HA formerly t/a GREAT ENTERPRISE INTERNATIONAL CO v. LI YEE HUNG

Citation

HO MIU HA formerly t/a GREAT ENTERPRISE INTERNATIONAL CO v. LI YEE HUNG
Court

District Court
Case number

DCCJ4193/2012

The application for leave to appeal was refused because the defendant did not show a reasonable prospect of success; the judge acted within judicial discretion and applied correct principles for lis alibi pendens, properly considered affidavit evidence (including acts not pleaded for the purposes of the stay application), correctly concluded the PRC and Hong Kong proceedings involved different subject matters (Agreement breach v employee duty), accepted the plaintiff had a legitimate purpose and juridical advantage in suing in Hong Kong and that enforcement issues could arise in the PRC, and…
13 May 2011

佛山市順德區金鳳製衣有限公司 v. FIRST DRAGON FASHION (HONG KONG) LTD

Citation

佛山市順德區金鳳製衣有限公司 v. FIRST DRAGON FASHION (HONG KONG) LTD
Court

Court of Appeal
Case number

CACV38/2011

Given the company's cessation of operations, disposal of assets, director outside the jurisdiction, undisputed petitioning debt and conduct amounting to abuse of process, the court ordered indemnity security of HK$175,000 to be paid into court by the named individual or by any director or shareholder within 28 days; until compliance the appeal is stayed and will be dismissed if security is not provided, with costs to be taxed and paid by the company. This follows the settled principle that companies appealing alone must provide security and that such security should be adequate and indemnity…
14 Jun 2010

PENG YU YAN also known as REGINA PENG v. STAVROS P. PAPADOPOULOS also known as STEVE PAPPS AND ANOTHER

Citation

PENG YU YAN also known as REGINA PENG v. STAVROS P. PAPADOPOULOS also known as STEVE PAPPS AND ANOTHER
Court

Court of First Instance
Case number

HCCL26/2007

The court refused to exercise its discretion to stay the Hong Kong proceedings because the applicant failed to prove that Brazil was clearly or distinctly the more appropriate forum; jurisdiction in Hong Kong was properly established as of right, the agreement relied on was signed in Hong Kong, the 1st defendant was resident and served in Hong Kong, payments were routed through a Hong Kong company and the dispute is a simple contractual claim limited to unpaid instalments, so the matter should be tried in Hong Kong.