Hong Kong Case Law: Decisions & Judgments

Topic

Satisfaction of judgment

Legal area

Court

5 Feb 2026

SECRETARY FOR JUSTICE v. WOO TAK YAN

Citation

[2026] HKDC 154
Court

District Court
Case number

DCMP7075/2024

On the balance of probabilities the appellant did not prove payment of the Subject Award before the proceedings; the bank withdrawal evidence was insufficient to establish payment and DoJ's records and the Small Claims Tribunal showed no payment, therefore the Master's order making the Charging Order Nisi absolute (reduced amount HK$51,566.84) was correct and the Master's costs assessment was not disturbed.
17 Jul 2007

TSE NGAN HEUNG v. THE RITZ-CARLTON LTD AND OTHERS

Citation

TSE NGAN HEUNG v. THE RITZ-CARLTON LTD AND OTHERS
Court

Court of Appeal
Case number

CACV312/2006

The appeal was dismissed because once the plaintiffs' judgments were satisfied the plaintiffs' causes of action were extinguished and therefore Ming An, as assignee, could not pursue an assessment of damages against the Hotel; Ming An should have pursued a restitutionary claim to be made whole and, in any event, the post-judgment interest paid appeared to be self-induced and not recoverable.
28 Nov 1989

J.H. TRACHSLER (HONG KONG) LTD v. BJOERNLOHSE AND OTHERS

Citation

J.H. TRACHSLER (HONG KONG) LTD v. BJOERNLOHSE AND OTHERS
Court

Court of First Instance
Case number

HCA2906/1987

The court held that the $1,550,000 paid by other defendants must be taken into account and credited against the Plaintiff's assessed loss; the payment did not wholly bar enforcement because the judgment exceeded that payment, but the Plaintiff cannot recover more than its loss; specific additional sums (trade debt and rent) and interest were added to the judgment and further detailed calculations (including commission deductions) were to be performed by expert accountants; costs remain to be determined.
2 Sept 1988

HEUN SOOK JONG v. STEPHEN HENRY MILLER

Citation

HEUN SOOK JONG v. STEPHEN HENRY MILLER
Court

Court of First Instance
Case number

HCA3993/1985

The husband failed to establish that the transfers were intended by both parties to satisfy the judgment debt; absent mutual agreement that the transfers discharged the debt, the judgment remained unsatisfied and the declaratory and injunctive relief must be refused.
8 Aug 1988

HEUN SOOK JONG v. STEPHEN HENRY MILLER

Citation

HEUN SOOK JONG v. STEPHEN HENRY MILLER
Court

Court of First Instance
Case number

HCA3993/1985

The applications were dismissed: the stay of execution was refused because the defendant provided no adequate, concrete basis for a stay (the assertion that the debt had been paid required proof and the request for time to inquire was premature and unsupported; matrimonial settlement is not per se relevant; no instalment proposal was properly formulated); the request for further time to appeal was refused because the defendant had withdrawn a formerly lodged notice of appeal thereby effectually abandoning an accrued right and gave no sufficient explanation to justify indulgence. Costs awarded…

Hong Kong Case Law

SECRETARY FOR JUSTICE v. WOO TAK YAN

TSE NGAN HEUNG v. THE RITZ-CARLTON LTD AND OTHERS

J.H. TRACHSLER (HONG KONG) LTD v. BJOERNLOHSE AND OTHERS

HEUN SOOK JONG v. STEPHEN HENRY MILLER

HEUN SOOK JONG v. STEPHEN HENRY MILLER