20 Mar 2023
CHAN PAK YUEN v. LAM MAN KIT
- Citation
- [2023] HKCFI 818
- Court
- Court of First Instance
- Case number
- HCPI199/2021
The court affirmed the master's decision: treating-doctor reports may include admissible facts (history, diagnosis, treatment) but any portions that express opinion serving as expert evidence require prior leave; the reports before the master contained opinion material amounting to expert evidence and were properly expunged; legal representatives must exercise judgment to redact or obtain leave for opinion material.