Hong Kong Case Law: Decisions & Judgments

Topic

Jurisdiction and domicile

Legal area

Court

10 Feb 2026

ZHAN XIANMING v. GRACEWOOD INTERNATIONAL LTD

Citation

[2026] HKCA 87
Court

Court of Appeal
Case number

CACV473/2024

Security for costs ordered (HK$750,000) because material before the Court established Zhan's impecuniosity, residence outside the jurisdiction, and history of non‑payment of costs making enforcement likely difficult and expensive; the asserted merits of the appeals do not constitute sufficient countervailing factors to outweigh the special circumstances justifying security; quantum reduced from draft estimate to exclude potential VCF application costs.
23 Oct 2024

RE ZHAN XIANMING

Citation

[2024] HKCFI 2890
Court

Court of First Instance
Case number

HCB3433/2005

VCF application dismissed because the applicant failed to establish a sound reason to depart from in‑court testimony: medical evidence was unsubstantiated and inconsistent, core issues in the annulment were contested and raised serious credibility questions requiring in‑person assessment, the application was belated causing prejudice and logistical impediments, and any travel‑cost objections could and should have been addressed by other means; accordingly allowing VCF would unfairly prejudice the interested party and risk undermining the court's ability to assess credibility.
23 Dec 2016

WU YANG v. DAYUAN INTERNATIONAL DEVELOPMENT LTD AND OTHERS

Citation

WU YANG v. DAYUAN INTERNATIONAL DEVELOPMENT LTD AND OTHERS
Court

Court of First Instance
Case number

HCCW103/2015

The petitioner is ordinarily resident outside the jurisdiction and his asserted Hong Kong asset (30% share in a private company) is insufficiently readily realisable to negate the need for security; the petition is complex so merits do not outweigh the need for security; overlapping cross‑claims justify reducing the quantum. Therefore security for costs is ordered in reduced sums: HK$1,500,000 for the New Bright Parties and HK$750,000 for the 4th Respondent, payable up to completion of discovery; costs nisi orders are granted against the petitioner for half the New Bright Parties' costs of th…
8 Jul 1997

TRANSAMERICA LEASING INC. v. CHINA FOREIGN TRADE DEVELOPMENT COMPANIES INC.

Citation

TRANSAMERICA LEASING INC. v. CHINA FOREIGN TRADE DEVELOPMENT COMPANIES INC.
Court

Court of Appeal
Case number

CACV81/1997

The Court allowed the appeal and exercised its discretion to continue the Mareva injunction because the trial judge materially misdirected himself by downplaying the significance of the defendant's foreign domicile (by reference to presumed backing of a foreign state) and thereby failed to consider an important factor; given the default US judgment, the defendant's inaction to set it aside, and the presence of readily transferable local assets, a real risk of dissipation was established.

Hong Kong Case Law

ZHAN XIANMING v. GRACEWOOD INTERNATIONAL LTD

RE ZHAN XIANMING

WU YANG v. DAYUAN INTERNATIONAL DEVELOPMENT LTD AND OTHERS

TRANSAMERICA LEASING INC. v. CHINA FOREIGN TRADE DEVELOPMENT COMPANIES INC.