Hong Kong Case Law: Decisions & Judgments

Topic

Interest on costs

Legal area

Court

25 Feb 2026

LEE KA MAN v. NG TSZ MAN AND OTHERS

Citation

[2026] HKDC 323
Court

District Court
Case number

DCCJ2840/2023

The Court held the sanctioned offer was valid and defendants failed to beat it; defendants' conduct (fraudulent misrepresentations and a groundless counterclaim) constituted special and unusual features justifying indemnity costs; costs ordered on High Court scale from issuance of writ to 20 June 2023 and on District Court scale thereafter, both on indemnity basis; enhanced interest awarded at 8% above judgment rate on HK$733,000.91 from 31 December 2024 to date of judgment; interest on indemnity costs awarded at 4% above judgment rate from 31 December 2024; judgment for plaintiff for HK$1,46…
17 Oct 2025

CHAN MAN SAU v. 風采中學（教育評議會主辦）法團校董會

Citation

[2025] HKDC 1749
Court

District Court
Case number

DCEC2172/2020

Sanctioned payments were valid and Applicant failed to obtain judgments better than those payments; accordingly, under Rules of District Court O.22 r.23 the court must impose the prescribed costs consequences; the Applicant's requests to vary the Costs Order Nisi were refused; costs in the four proceedings where sanctioned payments were made are to be taxed on party and party up to the specified cut-off dates and on indemnity basis thereafter with certificate for counsel, interest ordered on costs at the specified aggregate rate periods, sanction sums to be paid out to respondent's solicitors…
17 Oct 2025

CHAN MAN SAU v. 風采中學（教育評議會主辦）法團校董會

Citation

[2025] HKDC 1749
Court

District Court
Case number

DCEC962/2022

O.22 r.23 mandates the imposition of specified costs consequences where a plaintiff fails to obtain a judgment better than sanctioned payments unless it would be unjust; the Applicant failed to beat valid sanctioned payments, his explanations did not show it would be unjust to apply r.23, and therefore the Costs Order Nisi was varied to impose indemnity taxation and interest for costs after the specified cut-off dates, direct sanctioned payments to be paid out as ordered, and direct that the Respondent's costs be taxed together before the same Master.
16 Oct 2025

HUNG PUI MAN v. INTERCONTINENTAL LIMOUSINE COMPANY LTD

Citation

[2025] HKDC 1721
Court

District Court
Case number

DCPI4214/2022

The court held that indemnity costs for the entire action are warranted because the plaintiff proceeded with a claim despite having earlier access to defendant documents that exposed clear inconsistencies and rendered the pleaded case highly unreasonable; awarded defendant indemnity costs with certificate for counsel to be taxed if not agreed; ordered enhanced interest at judgment rate plus 5% from 22 June 2023 to 19 March 2025 and thereafter until full payment; sanctioned payments totalling HK$50,000 (plus any accrued interest) to be paid out to the defendant; refused to make a wasted costs…
6 Jun 2025

周宴鋌對 DOULTSONS LTD

Citation

[2025] HKDC 847
Court

District Court
Case number

DCEC1429/2021

Because the applicant failed to obtain a better judgment than the Part 22 payments and did not establish that making the Rule 23 orders would be unjust, the court varied the interim costs order: costs to and including 10 Oct 2022 to be assessed on party-and-party basis with interest at HSBC prime rate +1%; costs from 11 Oct 2022 to 20 Nov 2024 to be assessed on indemnity basis; interest at judgment rate +3% awarded on specified disbursements proven to have been paid by the insurer; items unsupported by documentary proof or lacking requisite counsel certificate were disallowed.
6 Jun 2025

周宴鋌對 DOULTSONS LTD

Citation

[2025] HKDC 847
Court

District Court
Case number

DCEC2290/2021

[2025] HKDC 847
17 Apr 2025

HE YU FEI v. XIONG XINXI t/a TAILOR-MADE FURNITURE AND ANOTHER

Citation

[2025] HKDC 570
Court

District Court
Case number

DCEC1181/2022

The Sanctioned Offer complied with Order 22 Rule 5; the 1st Respondent failed to achieve a better outcome than the offer and identified no factors making it unjust to apply Order 22 Rule 24; accordingly the Court ordered indemnity costs from 9 May 2024 with enhanced interest of 0.5% above judgment rate and granted a Sanderson order obliging the 1st Respondent to pay the 2nd Respondent's costs because the 1st Respondent's conduct caused the reasonable joinder of the 2nd Respondent.
3 Jan 2025

ZHANG XINGLI v. ZHANG LI

Citation

[2024] HKDC 2204
Court

District Court
Case number

DCCJ1883/2020

The court found it was not unjust to apply RDC O22 r23 because the Plaintiff was in an informed position to evaluate the sanctioned payment, there was no evidence the payment was tactical or non-genuine, and acceptance could have produced meaningful cost savings; accordingly the Costs Order Nisi was varied to award indemnity costs after 8 December 2023 and enhanced interest was awarded at 4.9375% from 9 December 2023 to 17 June 2024.
10 Dec 2024

CHEUNG KI LAM 對 CHOI TAK TAI 及另一人

Citation

[2024] HKDC 2078
Court

District Court
Case number

DCPI2504/2019

The court found the Order 22 payments (HK$1 on 29/10/2020 and HK$49,999 on 11/2/2022) were validly filed and served; the plaintiff did not accept them within the prescribed periods and failed to obtain a better result against the second defendant. It was not unjust to apply Rule 23, therefore the interim costs order was varied: plaintiff to pay second defendant party-and-party costs to 25 November 2020 and indemnity costs from 26 November 2020 (including wasted trial dates), and to pay interest on the indemnity costs at a rate 2% above the judgment rate; the court refused to order indemnity c…
28 Oct 2024

HUANG YUNLIAN 對 XUN YAO CONSTRUCTION LTD及另一人

Citation

[2024] HKCFI 3031
Court

Court of First Instance
Case number

HCPI51/2021

Order 22 r23 applies and, having found it would not be unjust to do so, the court varied the earlier costs order: defendants are entitled to plaintiffs' costs incurred after 31 January 2022 to be paid by the plaintiff on an indemnity basis, interest on those costs is fixed at judgment rate plus 6%, the plaintiff is denied interest on the award from 1 February 2022, and the court will retain HKD47,483.39 of the sanctioned payment pending assessment and set‑off; the remainder of the sanctioned payment is released to defendants.