Hong Kong Case Law: Decisions & Judgments

Topic

Quantum meruit

Legal area

Court

28 Nov 2025

WING LOK CONSTRUCTION & ENGINEERING CO LTD v. TECHOY CONSTRUCTION CO LTD

Citation

[2025] HKCFI 5546
Court

Court of First Instance
Case number

HCCT2/2023

Wing Lok failed to discharge the burden of proof on the quantum meruit claim for WI74 because it produced no expert evidence to justify applying the subcontract rate; the penalties/fines were enforceable as proportionate protections of Techoyʹs legitimate interests; rectification costs were necessary and recoverable contra‑charges; netting of claims and counterclaims resulted in Wing Lok owing Techoy HK$377,005.58 with interest and costs.
21 Mar 2025

CHINACHEM FINANCIAL SERVICES LTD v. CENTURY VENTURE HOLDINGS LTD

Citation

[2025] HKCA 265
Court

Court of Appeal
Case number

CACV98/2023

The appeal is dismissed because the trial judge's factual findings that the Agreement expired on 25 February 2011, that no new contract was formed by the parties' conduct, and that the defendant's performance involved serious illegality interfering with the PRC judicial process were open on the evidence; consequently the Agreement was unenforceable and the defendant's counterclaim for payment failed, so the trial judgment is affirmed and costs follow the event.
9 Jan 2025

IDEAS DESIGN ENGINEERING COMPANY LTD v. M.O.P. DEVELOPMENT LTD

Citation

[2025] HKDC 15
Court

District Court
Case number

DCCJ1044/2021

Plaintiff proved, by production of FS251 certificates and witness evidence, that required works and testing were completed for Contracts 3–6 (except certain minor items) thereby accruing the Defendant's obligation to pay 90% of those contract prices less deposits; Plaintiff failed to prove completion or certification for Contracts 1 and 2 so no further sums were recoverable on those contracts; quantum meruit was inapplicable; interest ordered from 27 March 2019 and costs awarded to Plaintiff.
6 Dec 2024

TUNG PO DECORATION ENGINEERING LTD v. GREAT BRIGHT ENGINEERING LTD

Citation

[2024] HKDC 2081
Court

District Court
Case number

DCCJ4853/2020

The Costs Order Nisi was varied to no order as to costs because both parties only succeeded on small fractions of their respective claims with no significant disparity; the Plaintiff's primary case failed and its alternative success depended on the Defendant's concessions and an opposing schedule; both parties contributed to the extended trial by introducing late evidence and neither took steps to mitigate its impact; therefore denying costs to both parties proportionately reflects the outcome and conduct.
27 Nov 2023

CHINA HEALTH GROUP LTD v. CHIU & PARTNERS (A firm)

Citation

[2023] HKCFI 2995
Court

Court of First Instance
Case number

HCA891/2022

The appeal was dismissed because the indorsement of claim and the statement of claim were properly struck out: the SOC pleadings advanced causes of action beyond the scope of the IOC contrary to O.18 r.15(2) (Purview Ground) and the identical pleadings filed in two actions constituted an impermissible multiplicity of proceedings (Duplicity Ground). Other grounds (quantum meruit, limitation, abuse of process) were not plain and obvious and therefore did not justify strike out.
24 Nov 2023

CHAN CHUNG SING v. QUPITAL LTD

Citation

[2023] HKCFI 3042
Court

Court of First Instance
Case number

HCA40/2023

The appeal is dismissed because the plaintiff cannot avoid the consequences of the earlier dismissal for non-compliance by blaming his solicitor; established authorities attribute solicitors\' default to their clients, and a second action based on the same cause after dismissal for non-compliance is an abuse of process absent special reasons, which the plaintiff failed to establish. Further, pursuing this appeal while relief from sanctions in the earlier action remains available constitutes an abuse and would permit impermissible re-litigation and circumvention of sanctions.
10 Nov 2023

REDLAND PRECAST CONCRETE PRODUCTS (CHINA) LTD v. PERMASTEELISA HONG KONG LTD

Citation

[2023] HKCA 1278
Court

Court of Appeal
Case number

CACV422/2020

No binding pre-bid agreement or sub-subcontract was established because the documentary and conduct evidence was equivocal and consistent with defendant's tender analysis and due diligence, the Confidentiality Agreement expressly disclaimed any obligation to contract and plaintiff knew defendant denied any commitment; accordingly plaintiff's quantum meruit claim fails because the work was preparatory in a tendering process and not performed in the confident expectation of a binding contract that materialised.
9 Jun 2023

DAI TIM KEUNG v. HO WING KEUNG

Citation

[2023] HKDC 577
Court

District Court
Case number

DCCJ5016/2018

The court found the plaintiff committed the repudiatory breach by issuing an unreasonable ultimatum demanding itemised quotations without finalised designs and thereby terminated the contract; plaintiff's loss of rental claim was dismissed; the defendant was entitled to quantum meruit for completed work valued at HK$480,300 less payments of HK$400,000, yielding a counterclaim of HK$80,300, with interest from 16 March 2018 and costs to defendant to be taxed. The court applied a broad‑brush, common‑sense valuation using expert joint reports and midpoint assessments where appropriate.
9 Jun 2023

POWERTECHNIC LTD v. THE INCORPORATED OWNERS OF MONTE VISTA

Citation

[2023] HKDC 750
Court

District Court
Case number

DCCJ874/2019

The written Contracts unambiguously named Powertechnic Limited as contractor; the defendant did not prove a mistake of identity or lack of consensus ad idem; PL was entitled to enforce the Contract and recover HK$2,068,088.70 with contractual interest; the defendant's counterclaim for repayment of HK$413,617.74 failed.
9 Jun 2023

POWERTECHNIC LTD v. THE INCORPORATED OWNERS OF MONTE VISTA

Citation

[2023] HKDC 750
Court

District Court
Case number

DCCJ878/2019

The written contracts unequivocally named PL as contractor and the contemporaneous conduct and documents (including payments, demand letters and a 19 Feb 2016 letter acknowledging PL's operation of the project) preclude a finding of mistake of identity; accordingly PL was the contracting party and entitled to enforce the contract for the outstanding instalments and contractual interest (alternative quantum meruit available); the defendant's counterclaim for repayment is dismissed.