Hong Kong Case Law: Decisions & Judgments

Topic

Expert valuation evidence

Legal area

Court

4 Feb 2026

XU YING v. CHINA GAS HOLDINGS LTD

Citation

[2026] HKCFI 1436
Court

Court of First Instance
Case number

HCA1083/2017

The court admitted expert evidence narrowly confined to whether the shareholding could reasonably have been sold as a single bloc on or about 1 March 2017 and, if not, the reasonable method and timeframe for disposal and the likely net proceeds; the plaintiff's application to instruct experts to value sale proceeds over 18- and 24-month windows was dismissed because those later assessment dates amount to claims for special damages that are not pleaded and therefore neither relevant nor necessary; dividends need not be calculated by experts.
13 Sept 2024

LI CHUN BON AND ANOTHER v. CHINA MOBILE HONG KONG COMPANY LTD

Citation

[2024] HKCA 865
Court

Court of Appeal
Case number

CAMP344/2023

Leave to appeal granted on the construction point (ground 1) because the issue whether the term "Main Roof" includes the Disputed Parts is reasonably arguable and merits appellate consideration; leave refused on the valuation point (ground 2) because the judge's valuation reasoning was adequate, the plaintiffs' criticisms were not reasonably arguable and his valuation remarks were obiter.
2 Aug 2019

PKJ v. WMLA

Citation

[2019] HKFC 196
Court

Family Court
Case number

FCMC8604/2016

Application dismissed because applicant failed to satisfy the Currey criteria: the court was not persuaded that he could not reasonably procure legal services by other means and significant unexplained accounting entries (dividend entries leading to an approximate HKD2.5 million negative directors' current account and other transfers) undermined his claim of no available resources; given available family funds and unresolved discrepancies in disclosure the application for litigation funding was not justified.
11 Jul 2014

WISDOM GAINING LTD v. WISDOM LIGHT INDUSTRIAL LTD AND OTHERS

Citation

WISDOM GAINING LTD v. WISDOM LIGHT INDUSTRIAL LTD AND OTHERS
Court

Lands Tribunal
Case number

LDCS23000/2012

The tribunal exercised its discretion under s12(1) Lands Tribunal Ordinance and Order 62 guidance, refused indemnity and High Court scale, concluded respondents did not adopt a neutral stance and unjustifiably increased applicant's costs; ordered the 1st and 3rd respondents each to pay 30% of the applicant's overall costs (60% collectively), taxed on a party-and-party basis at the District Court scale with a certificate for counsel, and allocated additional costs relating to the variation applications and the 1st respondent's summons as set out in the orders.
28 Aug 2013

KWAN SO LING v. WOO HARRY KEE YIU AND OTHERS

Citation

KWAN SO LING v. WOO HARRY KEE YIU AND OTHERS
Court

Court of First Instance
Case number

HCA1311/2011

Leave was granted to adduce property valuation expert evidence on two issues (open market value as at 22 November 2008 and current open market value) limited to a single jointly instructed expert; the Masters refusal to allow the amendments and expert evidence was set aside. The Assignment valuation evidence would have been allowable as relevant and necessary but became unnecessary after defendants admission at hearing; the current valuation remained necessary for molding equitable relief. Costs allocated: defendants to pay plaintiff costs of the appeal; various costs below to be in the cau…
20 Feb 2013

YES PROFIT INVESTMENT LTD v. MAINLY TONE CO LTD

Citation

YES PROFIT INVESTMENT LTD v. MAINLY TONE CO LTD
Court

Court of First Instance
Case number

HCA2656/2008

Leave granted because the valuation evidence was relevant and necessary to determine quantum, the lateness did not amount to conscious abuse of process, and any prejudice to the defendant could be cured by firm directions and timetable (service deadlines and pre-trial review adjustment); costs of the application ordered in the cause.
14 Feb 2012

厦門新景地集團有限公司 v. ETON PROPERTIES LTD AND OTHERS

Citation

厦門新景地集團有限公司 v. ETON PROPERTIES LTD AND OTHERS
Court

Court of First Instance
Case number

HCMP18/2012

The commercial judge's overall grant of permission to amend and to give expert valuation directions was within the ambit of legitimate case management discretion, but permitting paragraph 35(5) to be forced into imminent trial dates without hiving it off was unfair to defendants; accordingly the appeal is allowed in part by adjourning the trial of paragraph 35(5) for further directions after the upcoming trial outcome, and defendants are awarded costs with certificate for two counsel.
14 Feb 2012

厦門新景地集團有限公司 v. ETON PROPERTIES LTD AND OTHERS

Citation

厦門新景地集團有限公司 v. ETON PROPERTIES LTD AND OTHERS
Court

Court of First Instance
Case number

HCMP21/2012

The commercial judge's allowance of the amendments was not so plainly wrong as to warrant overturning in full, but the late and surprising new claim in paragraph 35(5) caused potential injustice by depriving defendants adequate time to prepare; the appropriate remedy was to allow the appeal in part by adjourning/hiving off paragraph 35(5) for further directions after the outcome of the imminent March trial, while otherwise upholding the judge's exercise of discretion; costs awarded to defendants with certificate for two counsel.
21 Nov 2011

DAIMLER AG (FORMERLY MERCEDES-BENZ AQ) v. LEIDUCK, HERBERT HEINZ HORST AND ANOTHER

Citation

DAIMLER AG (FORMERLY MERCEDES-BENZ AQ) v. LEIDUCK, HERBERT HEINZ HORST AND ANOTHER
Court

Court of First Instance
Case number

HCA4089/1994

The Court refused the Plaintiff's application to overturn the existing directions because there was no material change in circumstances, the Plaintiff delayed in bringing the application and had taken advantage of the directions to inspect the new affidavits; pleadings and general discovery are not required at this stage; expert directions and cross-examination directions are premature and should await the Plaintiff's affidavit in opposition; the original directions stand subject to limited variations; costs ordered to Defendants in amount specified.
13 Jul 2006

THE INCORPORATED OWNERS OF YAN ON MANSION v. LEUNG YUN AND ANOTHER

Citation

THE INCORPORATED OWNERS OF YAN ON MANSION v. LEUNG YUN AND ANOTHER
Court

District Court
Case number

DCCJ2223/2004

The court accepted the expert was qualified but reduced the expert's overall mesne profit figure by 20% because the valuer failed sufficiently to account for the significantly lower actual rent previously agreed between the parties, resulting in an assessed mesne profit of HK$1,701,152; the District Court had jurisdiction to make the award by virtue of consent transfer under section 44 of the District Court Ordinance.