Hong Kong Case Law: Decisions & Judgments

Topic

Multiplier for future loss

Legal area

Court

10 Feb 2026

IP SIU CHI v. KWAN WING HANG trading as FAI HUNG CONSTRUCTION COMPANY AND OTHERS

Citation

[2026] HKCA 204
Court

Court of Appeal
Case number

CACV217/2024

Appeal allowed: the 30% reduction for pre-existing psychiatric conditions was wrongly applied to pre-trial and post-trial loss of earnings because those losses flowed from orthopaedic injuries alone and the Judge had already factored pre-existing condition into the reduced multiplier for future loss; costs ordered on High Court scale because the action was properly commenced in the High Court when jurisdictional limit was $1,000,000 and the subsequent increase to District Court jurisdiction is not retrospective.
11 Dec 2013

CHAN CHI MING v. SZE HING SANG AND ANOTHER

Citation

CHAN CHI MING v. SZE HING SANG AND ANOTHER
Court

Court of First Instance
Case number

HCPI531/2011

On the evidence and medical report, plaintiff reached maximum medical improvement, could not resume pre-accident heavy manual work but could perform lighter duties; court adopted plaintiff's earning figures for purposes of common law claim (HK$800/day median for sick leave, HK$900/day pre-injury potential), allowed specified past and future losses with reductions for likely security-guard earnings, applied multiplier of 10 for future loss, deducted prior Employees' Compensation award and ordered interest and costs to plaintiff.
9 Feb 2007

ASHOK G. C. v. KAM KEE CONSTRUCTION WORKS LTD AND ANOTHER

Citation

ASHOK G. C. v. KAM KEE CONSTRUCTION WORKS LTD AND ANOTHER
Court

Court of Appeal
Case number

CACV244/2006

Appeal allowed in part: the master erred by applying a global 40% reduction across pre-trial and post-trial losses for the pre-existing L4/5 degeneration. Absent evidence of pre-trial effect, pre-trial loss should not be reduced; future loss should be addressed by an appropriate reduced multiplier (six years) rather than a blanket percentage reduction. Court recalculated the components and entered judgment for the plaintiff for a net sum of $849,094.68.
7 Aug 2006

NGAI LUNG HING v. GOWIN ENGINEERING CO LTD AND ANOTHER

Citation

NGAI LUNG HING v. GOWIN ENGINEERING CO LTD AND ANOTHER
Court

Court of First Instance
Case number

HCPI211/2005

The court found the claimant more likely to have worked 23 days/month pre-accident, his injury warranted PSLA of HK$300,000 (higher than fracture cases but below claimant's ask), no separate award for loss of earning capacity was appropriate to avoid double recovery, multiplier of 14 applies to future loss using his current earnings, future driving employment is unsuitable given pain risk, ECC of HK$195,480 is deductible and the award is reduced by the claimant's 30% contributory share.
20 Sept 2000

Chung Sze Mui v. Dragages et Travaux Publics and Penta-Ocean Construction Co. Ltd.

Citation

Chung Sze Mui v. Dragages et Travaux Publics and Penta-Ocean Construction Co. Ltd.
Court

Court of First Instance
Case number

HCPI590/1999

Court accepted plaintiff's income basis (average Jan–May 1996 producing monthly HKD 12,704, with notional assessment income HKD 15,562 and median HKD 14,133), held grandson was a dependant, applied dependency percentages (wife 26.3%, grandson 33%, mother 12%), adopted a multiplier of 5 for all dependants, allowed funeral expenses and bereavement, deducted employees' compensation of HKD 504,531.58, and awarded interest as specified.
25 Jun 1997

CAROLYN DALL v. CHOY YING WAI

Citation

CAROLYN DALL v. CHOY YING WAI
Court

Court of First Instance
Case number

HCPI176/1995

Application to adduce actuarial evidence refused because, in light of Chan Pui Ki, conventional multipliers and conventional discounts govern assessment of future loss and actuarial evidence cannot displace those conventions; valuation of provident fund, national insurance and other employer benefits can be made by employer or pension fund manager and actuarial evidence is not necessary; property interests form part of the estate and actuarial evidence is not required for claimed loss of accumulation of wealth.
17 Feb 1997

CHAN KUI v. LEE FAI t/a FAI KEE TIMBER

Citation

CHAN KUI v. LEE FAI t/a FAI KEE TIMBER
Court

Court of First Instance
Case number

HCPI126/1995

Master found the plaintiff's injuries fell just below the 'serious injury' category and, after evaluating medical and occupational evidence, adopted a pain and suffering award of HK$350,000; adopted a 10% annual payroll inflation rate and a reasonable post-injury wage of HK$4,500 in May 1994; accepted proposed past loss figures through April 1994 and calculated past loss to date at HK$307,608 and future loss at HK$201,312 using a multiplier of 4 for remaining working life; awarded HK$60,000 for loss of earning capacity and made agreed special damages awards; deducted employees' compensation o…
11 Apr 1986

WAN FUNG CHUN AND ANOTHER v. LEE KWOK HUNG

Citation

WAN FUNG CHUN AND ANOTHER v. LEE KWOK HUNG
Court

Court of First Instance
Case number

HCA4006/1984

On the unchallenged evidence the Senior Master accepted the plaintiffs' factual case, made quantified findings of loss using housekeeping evidence for dependency and bank statements for business savings, adopted a multiplier of 12 based on recent awards and practice, and awarded specified sums for business loss, pre-trial and post-trial employment loss, funeral expenses and loss of expectation of life; he apportioned HK$100,000 for the child to be held by the Registrar, fixed interest rates for special and general damages, and ordered costs to the plaintiffs with a certificate for counsel and…
21 Nov 1984

KONG MIU LIN AND OTHERS v. TONG WING TAT AND ANOTHER

Citation

KONG MIU LIN AND OTHERS v. TONG WING TAT AND ANOTHER
Court

Court of First Instance
Case number

HCA3660/1984

Master accepted employer evidence that deceased would be earning $2,600/month today, added $50/month for annual bonus to start post‑trial income at $2,650, deducted one‑third of income for personal expenses (given proven frugality) yielding a multiplicand of $1,770/month, applied a 10‑year multiplier for future loss (less 39 months pre‑trial already elapsed) and treated LARCO/FAO as merged into the lost years claim, producing the damages awards as set out.