Hong Kong Case Law: Decisions & Judgments

Topic

Sanctioned payments

Legal area

Court

23 Jan 2026

MOHAMMAD-RIASAT v. WANTON BUSINESS SERVICES LTD

Citation

[2026] HKCFI 567
Court

Court of First Instance
Case number

HCPI312/2021

Plaintiff failed to obtain a result better than defendant's sanctioned payments and his repeated, informed rejections of settlement offers made the exercise of the court's powers under O.22 r.23 appropriate; accordingly the Nisi Costs Order was varied: enhanced interest awarded on defendant's costs at 3% per annum above judgment rate (traditional approach), the judgment sum (HK$952,477.44 plus HK$20,406.18 interest) to be set off against WBS costs incurred after discharge of legal aid on 6 July 2023, the balance after set-off to be paid to the Director of Legal Aid forthwith, and the remainin…
17 Oct 2025

CHAN MAN SAU v. 風采中學（教育評議會主辦）法團校董會

Citation

[2025] HKDC 1749
Court

District Court
Case number

DCEC2174/2020

O.22 r.23 consequences applied: the court held sanctioned payments in DCEC 2171, 2172, 2174 and 962 were valid, the Applicant failed to obtain better judgments, and nothing made it unjust to impose the mandatory consequences; costs orders were varied to require the Applicant to pay the Respondent's costs on indemnity basis from the specified post‑acceptance dates with certificate for counsel, directed joint taxation before the same Master, ordered sanctioned payments paid out (with HK$300 to Applicant in DCEC 2171), and refused the Applicant's requested variations (no order/50% or change in a…
17 Oct 2025

CHAN MAN SAU v. 風采中學（教育評議會主辦）法團校董會

Citation

[2025] HKDC 1749
Court

District Court
Case number

DCEC2172/2020

Sanctioned payments were valid and Applicant failed to obtain judgments better than those payments; accordingly, under Rules of District Court O.22 r.23 the court must impose the prescribed costs consequences; the Applicant's requests to vary the Costs Order Nisi were refused; costs in the four proceedings where sanctioned payments were made are to be taxed on party and party up to the specified cut-off dates and on indemnity basis thereafter with certificate for counsel, interest ordered on costs at the specified aggregate rate periods, sanction sums to be paid out to respondent's solicitors…
17 Oct 2025

CHAN MAN SAU v. 風采中學（教育評議會主辦）法團校董會

Citation

[2025] HKDC 1749
Court

District Court
Case number

DCEC2171/2020

O.22 r.23 applies mandatorily where applicant failed to obtain judgments better than sanctioned payments; it was not unjust to apply the rule here. The court varied the costs order nisi to (a) award respondent costs on indemnity basis from specified post-cut-off dates and party-and-party before those dates as set out, (b) order payment of interest on such costs, (c) permit sanctioned payments to be paid out to respondent's solicitors except HK$300 to applicant, and (d) direct that all relevant costs be taxed together before the same Master; applicant's variation applications were refused exce…
16 Oct 2025

HUNG PUI MAN v. INTERCONTINENTAL LIMOUSINE COMPANY LTD

Citation

[2025] HKDC 1721
Court

District Court
Case number

DCPI4214/2022

The court held that indemnity costs for the entire action are warranted because the plaintiff proceeded with a claim despite having earlier access to defendant documents that exposed clear inconsistencies and rendered the pleaded case highly unreasonable; awarded defendant indemnity costs with certificate for counsel to be taxed if not agreed; ordered enhanced interest at judgment rate plus 5% from 22 June 2023 to 19 March 2025 and thereafter until full payment; sanctioned payments totalling HK$50,000 (plus any accrued interest) to be paid out to the defendant; refused to make a wasted costs…
1 Apr 2025

CHU CHEUNG CHEUNG AND ANOTHER v. THE INCORPORATED OWNERS OF PROVIDENT CENTRE No 21-53 WHARF ROAD, NORTH POINT, HONG KONG AND OTHERS

Citation

[2025] HKDC 523
Court

District Court
Case number

DCCJ244/2021

Plaintiffs plainly obtained a judgment greater than their sanctioned offer and the defendants' explanations (no breakdown, missing supplemental materials, involvement of 4th defendant) did not render enforcement unjust. Accordingly the court varied the costs order: indemnity costs and enhanced interest at 5% above judgment rate apply after 11 September 2023, with party-and-party costs up to 11 September 2023 and indemnity thereafter; interest on specified sums follows the staged rates ordered.
20 Dec 2024

CHEUNG HON KIN v. CHUBB LIFE INSURANCE COMPANY LTD (formerly known as NEW YORK LIFE INSURANCE WORLDWIDE LTD and ACE LIFE INSURANCE COMPANY LTD respectively)

Citation

[2024] HKCFI 3623
Court

Court of First Instance
Case number

HCA2711/2016

It was not unjust to make the orders under RHC O.22 r.23. The costs order nisi was varied: costs allocated between plaintiff and Director of Legal Aid according to periods of legal aid; indemnity costs ordered for the period 21 June 2023 to date of judgment payable by the plaintiff; enhanced interest awarded at 4% above judgment rate (12.875% p.a.) for the Director/paid period 11 April 2019–20 June 2023 and at 5% above judgment rate (13.875% p.a.) for plaintiff for 21 June 2023–date of judgment; sanctioned payments totalling HK$1,500,000 and accrued interest to be paid out to defendant; costs…
11 Dec 2024

SANDHU JATINDER SINGH v. MA SHIU MING AND ANOTHER

Citation

[2024] HKDC 2092
Court

District Court
Case number

DCPI2647/2022

The Form 23 notices expressly indicated the payments related to part of the claim with explanatory note excluding property damage; read in context with D2's pleaded case and authorities, the three sanctioned payments of $450,000 were properly construed as relating only to the bodily injury claim. The adjudged bodily injury sum plus interest ($442,327.95) was less than $450,000, so P failed to obtain a judgment better than the sanctioned payments and the mandatory costs sanctions under O 22 r 23 apply: D2 must pay P costs up to 28 February 2023; P must pay D2's costs after that date on an inde…
19 Mar 2024

CHAN YIU MAN v. HA CHING MAN MARIA

Citation

[2024] HKDC 461
Court

District Court
Case number

DCPI349/2020

Because the plaintiff had only partial blame for delayed disclosure but the defendant could have discounted a sanctioned payment despite incomplete disclosure and the plaintiff's claim was grossly inflated, the court ordered no costs up to and including 24 November 2021; the plaintiff must pay the defendant's assessment costs after 24 November 2021 on indemnity; enhanced interest on costs set at 3% per annum above prevailing judgment rate from 25 November 2021 to 16 February 2024; specific interest rates on heads of damages until 24 November 2021 were also fixed.
4 Sept 2023

楊艷娥對保良局第一張永慶中學

Citation

[2023] HKDC 1171
Court

District Court
Case number

DCEC101/2012

Order 22 rule 23 applies because the applicant obtained judgments far inferior to the sanctioned payments and there was no injustice in making the rule 23 orders; therefore the applicant must pay respondent's costs on an indemnity basis from 9 August 2014 (DCEC 101) and from 6 December 2017 (DCEC 1528) until the judgment date 27 April 2022, and those costs shall bear interest at the judgment rate plus 2%; sanctioned payments shall be disbursed to the applicant for the awarded compensation and remaining balances returned to the respondent subject to the legal aid first charge and related agree…