Hong Kong Case Law: Decisions & Judgments

Topic

Reciprocal enforcement

Legal area

Court

12 Feb 2026

ZHANG RUI KANG AND ANOTHER v. TUNGHSU GROUP CO LTD

Citation

[2026] HKCFI 954
Court

Court of First Instance
Case number

HCA1391/2021

The appeal was allowed because the plaintiffs, as foreign judgment creditors adjudicated by a competent court, satisfied the bona fide claim test and warranted special treatment such that security for costs should not be ordered; the defendant failed to discharge its burden to show reasons to displace that starting position, so the Master's order granting security was set aside, the defendant's summons dismissed, and the security and assessed costs were ordered returned/paid to the plaintiffs.
29 Mar 2023

LI MING AND OTHERS v. LIU YIU KEUNG also known as STEPHEN LIU AND ANOTHER

Citation

[2023] HKCFI 884
Court

Court of First Instance
Case number

HCA86/2018

The application for security for costs was refused because overlapping proceedings (the Assessment Proceedings assessing former receivers' fees and HCA 548) engaged the same allegations so that ordering security would effectively require plaintiffs to pay for defences they would need to run elsewhere; plaintiffs' holding of 16,783 CSI shares together with an undertaking not to dispose, while not amounts to fixed permanent assets, provided adequate protection; on balance it was not just to order the requested security.
15 Mar 2021

LX v. CWC, the Administratrix of the Estate of WTFP

Citation

[2021] HKFC 58
Court

Family Court
Case number

FCMP171/2019

Because the applicant was resident in the Mainland and failed to adduce credible evidence of impecuniosity or a high probability of success, and because the Inheritance Ordinance claim would not be covered by the Mainland–HKSAR Reciprocal Arrangement making enforcement of costs in the Mainland problematic, it was just to order security for costs; the court fixed security at HK$200,000 and stayed further proceedings until payment.
5 May 2016

CRANE WORLD ASIA PTE LTD v. HONTRADE ENGINEERING LTD

Citation

CRANE WORLD ASIA PTE LTD v. HONTRADE ENGINEERING LTD
Court

Court of First Instance
Case number

HCA109/2014

On balance the court refused security: it found the plaintiff ordinarily resident outside Hong Kong but its Hong Kong assets were not fixed or readily realizable; reciprocal enforcement in Singapore was only a factor; and the defendant's delay and lack of cost-effectiveness in the timing of the application made ordering security unjust. The application for security for costs was therefore dismissed and costs ordered to the plaintiff.
5 May 2016

CRANE WORLD ASIA PTE LTD v. HONTRADE ENGINEERING LTD

Citation

CRANE WORLD ASIA PTE LTD v. HONTRADE ENGINEERING LTD
Court

Court of First Instance
Case number

HCA462/2014

The plaintiff was found ordinarily resident outside Hong Kong (central management in Singapore); although reciprocal enforcement in Singapore exists and the plaintiff has some Hong Kong assets, those assets are not of a fixed or readily realizable nature and the defendant delayed in bringing the application such that ordering security would not be just or cost-effective; therefore the application for security for costs was refused; costs nisi awarded to the plaintiff in sum HK$90,000.
14 Apr 2016

SUZANNE RUTH HENDERSON v. SCOTT HENDERSON

Citation

SUZANNE RUTH HENDERSON v. SCOTT HENDERSON
Court

Court of First Instance
Case number

HCMP1780/2013

There was a good arguable case for registration under the Maintenance Orders (Reciprocal Enforcement) Ordinance but not for enforcement at common law because the 2009 Ontario order was not final and conclusive; the plaintiff committed material non-disclosure, intentional misrepresentation and lies and breached undertakings when obtaining the ex parte Mareva injunction, which justified discharging the Mareva injunction and related orders and dismissing the originating summons; costs ordered to the defendant on a nisi basis.
4 Dec 2015

YPC also known as CL v. SSHL

Citation

YPC also known as CL v. SSHL
Court

Family Court
Case number

FCMP103/2012

The SA Summons was dismissed: the Registrar lawfully has statutory authority under the MOREO and MORER to enforce a reciprocated foreign maintenance order in his office and title without being joined as a party; the Judgment Summons issued complied with applicable family and district court rules (Rule 87 MCR and O.90A RDC) and was not irregular; issues of human rights compatibility and procedural reform should be addressed by legislation rather than by invalidating the existing judgment summons remedy, and the judgment summons process remains available where properly taken and used as a last…
5 Jun 2015

CHINACAST EDUCATION CORPORATION AND OTHERS v. CHAN TZE NGON AND OTHERS

Citation

CHINACAST EDUCATION CORPORATION AND OTHERS v. CHAN TZE NGON AND OTHERS
Court

Court of First Instance
Case number

HCA1062/2012

Entitlement to security for costs was established; plaintiffs failed to demonstrate that an order would stifle the action because they were able but unwilling to fund further litigation; a Delaware judgment in favour of the plaintiff did not negate the power to order security because judgment debtor status does not equate to the defendant holding the plaintiff's money and enforcement in Hong Kong was not assured; taking into account deficiencies in the skeleton bill and excessive time charging, security for costs up to 29 May 2015 was fixed at HK$300,000 and the application for further securi…
31 Mar 2015

SUZANNE RUTH HENDERSON v. THE REGISTRAR, DISTRICT COURT

Citation

SUZANNE RUTH HENDERSON v. THE REGISTRAR, DISTRICT COURT
Court

Court of First Instance
Case number

HCAL82/2014

2009 decision: judicial review application dismissed as being out of time without adequate explanation; 2014 decision: quashed because Registrar failed to direct himself on applicable law of residence and omitted relevant evidence, rendering the decision irrational; mandamus refused because the evidence did not establish that only one legally open result existed; matter remitted to Registrar for fresh consideration; costs: no order against Registrar, Mr Henderson to pay 50% of costs (summary assessment).
20 Jun 2014

TRONIC INTERNATIONAL PTE LTD (“Tronic”) v. TOPCO SCIENTIFIC CO LTD (“Topco”) AND OTHERS

Citation

TRONIC INTERNATIONAL PTE LTD (“Tronic”) v. TOPCO SCIENTIFIC CO LTD (“Topco”) AND OTHERS
Court

Court of Appeal
Case number

CACV235/2013

The application was dismissed because the defendants failed to show the special circumstances required to order security: there was no evidence that enforcement in Singapore would cause undue expense or delay given the reciprocal enforcement regime, and the appellant's non-payment of the Final Award was plausibly explained by an arguable claim to refundable deposits so impecuniosity could not be inferred; accordingly security was not justified and the defendants' application was refused with a costs order nisi in favour of the appellant.