Hong Kong Case Law: Decisions & Judgments

Topic

Single joint expert

Legal area

Court

27 Mar 2026

WONG YAN KWOK HENRY v. LOK CHI TO also known as GEORGE LOK

Citation

[2026] HKCFI 1524
Court

Court of First Instance
Case number

HCPI64/2025

The court held psychiatric expert evidence on quantum is necessary and that it is appropriate in the interests of justice for such evidence to be adduced by a single joint expert; parties were granted leave to adduce psychiatric expert evidence by SJE and directed to comply with specified nomination and timetable requirements within 21 days, with costs in the cause.
24 Mar 2026

CHOW CHI YI v. POON TAK LUN (also known as 潘德鄰)

Citation

[2026] HKDC 502
Court

District Court
Case number

DCCJ3293/2023

Leave to adduce a second expert was granted because, on balance and in the interests of justice, the single joint expert had not adequately addressed a central technical issue—the timing and significance of moisture content readings relating to the external wall source—which could not be satisfactorily resolved by clarification or cross-examination alone; accordingly the appeal against the Master's order was dismissed and the defendant permitted to adduce his own expert report.
4 Mar 2026

MEDFORD GARDEN LTD v. THE INCORPORATED OWNERS OF SHUI KI INDUSTRIAL BUILDING

Citation

[2026] HKCFI 1389
Court

Court of First Instance
Case number

HCA1666/2022

The judge refused the Plaintiff's applications because the remedial works had been completed, the Plaintiff had knowledge of the works' scope and delayed taking steps, there was no evidence of continuing seepage so further expert investigation would be speculative and impose unjustified costs, and therefore the January 2025 Summons was spent, amendment was refused and costs were awarded to the Defendant (summarily assessed at HK$80,000).
5 Feb 2026

LAM WOON CHEONG STEVEN v. LOOI CHI YIU SUNNY

Citation

[2026] HKDC 222
Court

District Court
Case number

DCCJ871/2025

The court exercised case management discretion to refuse leave for a second quantum expert because the alleged defects in the single joint expert's report were not so fundamental as to require a separate expert: clarifications and a supplemental report from the existing single joint expert, and cross-examination at trial, were adequate; a structural engineer is capable of addressing quantum and may engage specialist contractor input under the joint appointment; balancing the relevant Daimler factors did not support permitting a second expert.
22 Dec 2025

HUANG WEIHONG v. TAO KEE ENGINEERING COMPANY LTD AND ANOTHER

Citation

[2025] HKCFI 6157
Court

Court of First Instance
Case number

HCPI206/2024

The master did not err in directing that orthopaedic expert evidence on quantum be obtained from a single joint expert. Given the circumstances — the medical issues being usual rather than unusually complex, proportionality and cost considerations, the parties' prior conduct and nominations, and the limits on admitting new evidence on appeal — it was in the interests of justice to order a SJE and to leave the master's choice of SJE undisturbed; appeal dismissed.
30 Sept 2025

LAI CHUN WAI v. SWIRE COCA-COLA LTD trading as SWIRE COCA-COLA HK

Citation

[2025] HKDC 1590
Court

District Court
Case number

DCPI3699/2022

Master held that Dr Lam omitted to give opinion on whether the P's condition was worsened by the Subsequent Incident and on the reasonableness of the post-Subsequent Incident sick leave, and that Dr Lam was not provided with the 11 April 2024 surveillance footage; fairness and utility require a limited supplemental joint expert report addressing specified questions, but oral evidence from the single joint expert is unnecessary and was refused.
6 Aug 2025

張小嫺對九龍巴士（一九三三）有限公司

Citation

[2025] HKCFI 3354
Court

Court of First Instance
Case number

HCPI43/2022

Court accepted the single joint expert opinions that the plaintiff's ocular injury caused a limited permanent impairment (1% whole person) and that her psychiatric condition was pre-existing and not caused or materially worsened by the accident; plaintiff failed to prove pre-accident employment or loss of earnings and many special damages lacked receipts or evidential foundation; accordingly PSLA was assessed at HKD150,000 and special damages at HKD15,000, total HKD165,000, with interest and costs orders as specified.
27 Jun 2025

TAMANG DHIRENDRA v. TOKO CONSTRUCTION & MACHINERY LTD AND ANOTHER

Citation

[2025] HKCFI 2037
Court

Court of First Instance
Case number

HCPI285/2024

The court granted leave for a single joint orthopaedic expert (Dr Terence Chan) because the plaintiff failed to demonstrate specific complexity or likely controversy that would justify separate experts; O38 r4A and PD 18.1 factors taken together favoured appointment of a single joint expert in the interests of justice and the parties were able to agree on an appropriate candidate.
25 Feb 2025

HUANG XING v. PAN ASIA CONSTRUCTION MACHINERY COMPANY LTD AND ANOTHER

Citation

[2025] HKDC 373
Court

District Court
Case number

DCEC2427/2018

Leave granted to the Applicant to adduce a supplemental SJE report limited to Issues 1 and 2 because the contested medical causation questions (effect of strenuous manual task and altered factual premises regarding PTB and smoking) require medical opinion and the SJE did not address the specific heavier weight; Issue 3 refused because SJE has already considered impairment, loss of earning capacity and sick leave; costs reserved to the trial judge.
21 Jan 2025

ALI MUHAMMAD RAZZAQ v. HUNG TAI ENGINEER COMPANY LTD AND OTHERS

Citation

[2025] HKDC 125
Court

District Court
Case number

DCPI2093/2022

Extension of time to appeal was granted in the exercise of the court’s discretion; clarification from the SJE was permitted only on Issue 2 (impact of specific MRI findings of nerve root impingement at L4/5 and S1 compression on symptoms and fitness for rigger work) because that issue lacked sufficient medical explanation in the SJE report; clarification was refused for Issues 1, 3, 4 and 5 as they were adequately reasoned or were matters for trial fact-finding; costs awarded to defendants as specified.