Hong Kong Case Law: Decisions & Judgments | LexChat

Topic

Precision of discovery requests

Legal area

Court

14 Aug 2024

LONG HAI HONG (龍海紅) the administratrix of the estate of LEE SO WINSTON (李甦), deceased v. LIU DAN AND ANOTHER

Citation

[2024] HKCFI 2116
Court

Court of First Instance
Case number

HCA721/2019

The Court held Category 2 did not identify documents that related to any matter in issue but instead sought matters solely relevant to credit; the request was imprecise in scope and therefore there was no jurisdiction under O.24 r.7 to order specific discovery of the Category 2 documents; the appeals were dismissed and costs awarded to the respondent.
14 Aug 2024

LONG HAI HONG (龍海紅) the administratrix of the estate of LEE SO WINSTON (李甦), deceased (suing on behalf of herself and all other shareholders in the 5th defendant other than the 1st to 3rd defendants) v. LIU DAN AND OTHERS

Citation

[2024] HKCFI 2116
Court

Court of First Instance
Case number

HCA175/2018

The appeals were dismissed because the Category 2 requests did not relate to any matter in issue required for specific discovery under O.24 r.7, were confined to matters of credit, and the requests lacked the necessary precision (they did not encompass the corrections in Long 2nd and were overly broad and inconsistent), such that there was no jurisdiction to order specific discovery of the documents sought.