Hong Kong Case Law: Decisions & Judgments

Topic

Enforcement of foreign judgments

Legal area

Court

27 Apr 2026

DR SEYED MASOUD SAJJADI ALEHASHEM v. THE HONG KONG POLYTECHNIC UNIVERSITY AND OTHERS

Citation

[2026] HKCFI 2376
Court

Court of First Instance
Case number

HCIP48/2024

The intended appeal was refused because it lacked a reasonable prospect of success and there was no other reason in the interests of justice: the Judge properly considered the plaintiff's present residence (outside Hong Kong) under O.23 r.1(1)(a), the plaintiff failed to identify Mainland assets that would make the reciprocal enforcement Arrangement material, and the plaintiff's substantive claim was assessed as having low prospects; accordingly leave to appeal was refused, the summons dismissed and costs were assessed at HK$40,000 as a costs nisi.
31 Jul 2025

LIU ZUO BIN v. LIU YING TING AND ANOTHER

Citation

[2025] HKCFI 3097
Court

Court of First Instance
Case number

HCA37/2024

Security for costs was ordered because P is ordinarily resident outside Hong Kong, P failed to demonstrate a very high probability of success on the pleaded case, P did not identify substantial fixed assets within Hong Kong or certain readily enforceable assets in Mainland China, and P failed to adduce credible evidence that an order would stifle the claim; exercising broad‑brush discretion the court ordered security of HK$550,000 and stayed proceedings pending payment and allowed costs to defendants of HK$320,000 on a nisi basis.
31 Mar 2025

FOUR TREASURE ZHUHAI LTD v. ZHUHAI GREENERY HOTEL COMPANY LTD

Citation

[2025] HKCFI 1296
Court

Court of First Instance
Case number

HCMP2109/2022

The Hong Kong court has jurisdiction: the dispute is characterised as an in personam contractual claim for specific performance to execute documents and take steps to enable P to perfect title under a Hong Kong governed PTA; it does not require determination of title to the Mainland property and thus does not fall within the Mocambique rule; no exceptional forum non conveniens or comity reasons exist to stay proceedings under the non‑exclusive Hong Kong jurisdiction clause; Jurisdiction Summons §§1 and 2 dismissed and leave to adduce further evidence granted under §3.
7 Mar 2025

深圳澳銀天使創業投資企業 (有限合伙) AND ANOTHER v. LIU XIAOLONG AND ANOTHER

Citation

[2025] HKCFI 959
Court

Court of First Instance
Case number

HCMP1801/2023

Court found plaintiffs demonstrated a good arguable case and real risk of dissipation by the 1st and 2nd defendants; continued and granted a Mareva injunction against the 1st defendant up to RMB 11,897,850.91; refused to vary the Mareva injunction to permit maintenance payments absent cogent evidence; granted a Chabra injunction against the 2nd defendant limited to the 1st defendant's half share of the property with specified relaxations (rental income allowed) and procedural steps to agree final wording; dismissed the 2nd defendant's summons and made costs orders on a nisi basis.
25 Feb 2025

STEPHENSON HARWOOD (A FIRM) v. FANG ANKONG ALSO KNOWN AS FANG AN KONG

Citation

[2025] HKCA 193
Court

Court of Appeal
Case number

CACV19/2024

Application for security for costs dismissed because appellants have Hong Kong assets (notably the Escrow Fund and funds paid into court) and other available assets (Singapore property) that, despite being subject to Mareva injunctions or competing claims, remain their property and are prima facie available to satisfy any costs order; applicant failed to demonstrate such enforcement would involve undue expense or delay amounting to special circumstances to justify security.
2 Aug 2024

CORNELIS PIETER ALEXANDER VAN DE RIET v. KD CONCEPT LTD AND ANOTHER

Citation

[2024] HKDC 1256
Court

District Court
Case number

DCCJ5717/2021

Applying a broad‑brush exercise the court found it just to order security given the plaintiff's foreign residence, absence of Hong Kong assets and difficulty of enforcing a Hong Kong costs order in Thailand, rejected that defendants had unreasonably delayed or that the counterclaim alone barred security, apportioned risk between parties and ordered the plaintiff to pay HK$540,000 into court within 60 days and made an order nisi for costs to be summarily assessed.
21 Jul 2023

ETHIOPIAN AIRLINES v. JIETONG OVERSEAS TRADE CO LTD AND OTHERS

Citation

[2023] HKCFI 1896
Court

Court of First Instance
Case number

HCA837/2022

The appeal is allowed because D1 is a Hong Kong anchor defendant against whom there is a real issue; D2 and D3, having closely connected roles in the same incident and potential joint or several liability, are necessary or proper parties under Order 11(1)(c); Hong Kong is the appropriate forum because claims against all defendants cannot conveniently be pursued together in the Mainland (procedural restrictions), the legal issues under Mainland law are straightforward, documentary and expert evidence is available in English/Chinese, and there is a reasonable expectation of enforceability in th…
21 Apr 2021

PINPOINT MULTI-STRATEGY MASTER FUND (formerly known as PINPOINT MULTI-STRATEGY FUND) v. GANGTAI GROUP CO., LTD

Citation

[2021] HKCFI 1011
Court

Court of First Instance
Case number

HCMP146/2020

The injunction was discharged for material non-disclosure because the ex parte applicant failed to inform the judge of material considerations (the need to confine any Chabra freezing order to identifiable assets in respect of XCJ, failure to address New York court practice on Mareva-type relief, and omission of material information about the plaintiff's assets relevant to fortification). However, the plaintiff's substantive case remained strong (dissipation risk) so the court refused payment out of the USD33,762,475 paid into court, continued the plaintiff's undertaking as to damages and ord…
14 Apr 2021

CHEN LINGXIA v. 中國金谷國際信託有限責任公司 AND OTHERS

Citation

[2021] HKCFI 982
Court

Court of First Instance
Case number

HCA2012/2018

The court held the substantive issues are contractual in nature and governed by Mainland law because the SCA and SCA/S1 (which encompassed the Subject Shares transfer) contain applicable choice of law and exclusive jurisdiction clauses; the Plaintiff had already litigated in the Mainland and submitted to Mainland jurisdiction; the Xicheng Court was a clearly and distinctly more appropriate forum than Hong Kong; accordingly the Hong Kong action was stayed on forum non conveniens grounds.
23 Feb 2021

CHEN HONGQING v. LIU YIU KEUNG STEPHEN AND OTHERS

Citation

[2021] HKCFI 440
Court

Court of First Instance
Case number

HCA1699/2019

The Court held that Jinan Group has a sufficient direct interest in the subject matter (the CSI shares) by virtue of the Jinan Group SPAs and Tianqiao judgments to justify joinder under Order 15 r 6(2)(b). The Employee Interveners should be joined. It was not plain and obvious that joinder would be futile, and there was no basis to adjourn the joinder application pending uncertain SPC guidance; consequential procedural directions and paper determination of the injunction were ordered.