Hong Kong Case Law: Decisions & Judgments

Topic

Liquidator powers

Legal area

Court

10 Mar 2026

RE KEVIN BRIAN LAWRENCE, THE LIQUIDATOR OF LUXHOLDCO GARDIEN S.C.A. (IN LIQUIDATION IN LUXEMBOURG)

Citation

[2026] HKCFI 1472
Court

Court of First Instance
Case number

HCMP276/2026

The court recognized the liquidator's appointment and granted the requested ancillary powers because the Company's voluntary liquidation in Luxembourg is a collective insolvency proceeding, the Company's COMI is in Luxembourg, the assistance sought was necessary to administer the Company's Hong Kong assets, and the powers sought were consistent with Hong Kong substantive law and public policy and aligned with the standard-form order.
11 Dec 2025

RE DOINGCOM INTERNATIONAL LTD (in liquidation)

Citation

[2025] HKCFI 6221
Court

Court of First Instance
Case number

HCMP2076/2025

The court concluded that all Cooperation Mechanism criteria were satisfied (applicants are Hong Kong liquidators; Xiamen is a pilot area; Doingcom’s COMI is Hong Kong; substantial assets and records are in Xiamen; assistance is necessary) and therefore it was appropriate to issue a letter of request to the Xiamen Bankruptcy Court to recognise the liquidators and to seek assistance to exercise the stated statutory powers under Hong Kong law in the Mainland to enable performance of their duties.
26 Jul 2024

RE HONG KONG LEE YUAN INTERNATIONAL GROUP LTD

Citation

[2024] HKCFI 1971
Court

Court of First Instance
Case number

HCMP952/2024

The court concluded that all Cooperation Mechanism requirements were satisfied — the applicants are Hong Kong liquidators, recognition was sought from a pilot area court (Xiamen), COMI was Hong Kong for over six months, the Company’s principal Mainland asset is located in Xiamen, and the assistance sought is necessary to enable the liquidators to perform their duties — and accordingly granted the letter of request authorising the Xiamen Intermediate People’s Court to recognise the liquidation and the liquidators and to afford the powers sought (mirroring CWUMPO), with costs of the application…
15 Jul 2024

RE PPLIVE SPORTS INTERNATIONAL LTD (in liq)

Citation

[2024] HKCFI 1850
Court

Court of First Instance
Case number

HCMP612/2024

The court granted the letter of request because the liquidators met the Cooperation Mechanism criteria: they are Hong Kong liquidators seeking assistance from a Mainland pilot court; the Company’s COMI is Hong Kong for more than six months; the Company holds principal assets and potential claims in Shanghai; and recognition and assistance are necessary to obtain information, secure assets and pursue recoveries in the Mainland where banks and parties will not cooperate without a Mainland court order.
30 Apr 2024

JOINT AND SEVERAL LIQUIDATORS OF YES! E-SPORTS ASIA HOLDINGS LTD (IN LIQUIDATION) v. HOLMAN FENWICK WILLAN (A FIRM)

Citation

[2024] HKCFI 1197
Court

Court of First Instance
Case number

HCCW208/2021

The court held that JSL were entitled to issue the section 286B summons because the Respondent had no legitimate basis to impose payment on account or require the former directors' consent before returning the Company's files; the Respondent's application for security for costs lacked a proper jurisdictional basis and was dismissed; accordingly costs of the summonses were awarded to JSL on an indemnity basis with directions for summary assessment.
8 Sept 2021

THE JOINT AND SEVERAL LIQUIDATORS OF DING HE MINING HOLDINGS LTD v.HONG KONG MEDIA ENTERPRISES HOLDINGS LTD

Citation

[2021] HKCFI 2737
Court

Court of First Instance
Case number

HCCW172/2018

The summons was properly brought; the court exercised its discretion to allow joinder of HKME for costs and to approve the sale of 36,000,000 CVM shares and the entire indebtedness owed by CVM to the Company to HKME for HK$12,000,000, authorising the liquidators to take all steps to effect the sale, without requiring further inquiry into the commercial rationale given the support of the majority of the Committee of Inspection.
8 Jun 2021

RE FOUNDER INFORMATION (HONG KONG) LTD

Citation

[2021] HKCFI 1749
Court

Court of First Instance
Case number

HCCW350/2020

The court directed that, on the evidence before it, the liquidators' proposed sale by private tender of the Company's 3,850,134,407 shares in PKU Resources would be a proper exercise of their powers under section 199(3) and falls within the range of decisions a reasonable liquidator could properly take; accordingly the court gave a direction under section 200(3) and ordered costs to be paid from the Company's assets.
24 May 2021

RE FOUNDER INFORMATION (HONG KONG) LTD

Citation

[2021] HKCFI 1508
Court

Court of First Instance
Case number

HCCW350/2020

Leave was granted because the application was properly brought by the Liquidators, was in good faith and did not involve a perverse commercial decision; the court will supervise the subsequent High Court Action and requires any Beijing administrators defending PUFG to prove authority either by recognition or by evidence of agency.
27 May 2020

RE PATRICK COWLEY AND LUI YEE MAN, JOINT AND SEVERAL LIQUIDATORS OF THE COMPANY

Citation

[2020] HKCFI 922
Court

Court of First Instance
Case number

HCMP373/2020

A liquidator does not require the court's prior sanction to enter a funding agreement which either effects an assignment of a chose in action or funds litigation, because such actions fall within the statutory powers conferred by Parts 2 and 3 of Schedule 25 (notably para 9) read with s251(1)(b) for voluntary liquidations and s199(3) for winding-ups by the court; court directions should be sought only to resolve discrete legal questions or genuine legal uncertainty, not to approve ordinary commercial judgments of the liquidator.
16 Jan 2019

CHINA GUANGZHOU INTERNATIONAL ECONOMIC & TECHNICAL COOPERATION CO LTD formerly known as CHINA GUANGZHOU INTERNATIONAL ECONOMIC & TECHNICAL COOPERATION CO v. OFFICIAL RECEIVER

Citation

[2019] HKCFI 152
Court

Court of First Instance
Case number

HCCW339/2008

The court declared the dissolution void and restored the company because there was a substantial pre-existing civil claim (settled for RMB 4,000,000), directors had failed in their disclosure duties and could not rely on ignorance, and restoration was necessary to enable proper recovery and administration of the company's assets by the liquidators.