Hong Kong Case Law: Decisions & Judgments | LexChat

Topic

Next friend requirement for minors

Legal area

Court

23 Dec 2025

SUGIANAH AND ANOTHER v. TORTURE CLAIMS APPEAL BOARD / NON-REFOULEMENT CLAIMS PETITION OFFICE [Decision on Leave Application]

Citation

[2025] HKCFI 6263
Court

Court of First Instance
Case number

HCAL119/2023

The leave application is dismissed because the applicants failed to identify arguable grounds in Form 86 and to show any error of law, procedural unfairness or irrationality in the Board's fact-based findings; the withdrawal by the applicants was confirmed and the court amended the Form 86 title on its own motion while treating procedural non-compliance regarding next friend as an irregularity not fatal to disposition.
22 Aug 2024

RE UBONGEN LEANNE PALMA AND ANOTHER

Citation

[2024] HKCA 791
Court

Court of Appeal
Case number

CAMP376/2023

Short delay notwithstanding, extension of time was refused because the intended appeal had no realistic prospect of success: the Board lawfully and rationally assessed evidence and COI, made fact findings open to it and there was no demonstrable legal error, procedural unfairness or irrationality to justify judicial review; minors' non-compliance with next friend representation treated as mere irregularity and did not alter outcome.