Hong Kong Case Law: Decisions & Judgments

Topic

Special damages

Legal area

Court

14 May 2026

陳华玲對黃漢邦

Citation

[2026] HKDC 697
Court

District Court
Case number

DCPI3825/2022

Court fixed PSLA at HKD 400,000 because injuries (right tibial plateau fracture, tibial shaft spiral fracture and fibular head fracture requiring ORIF and prolonged inpatient treatment and physiotherapy) were serious but achieved satisfactory healing and functional recovery per joint orthopaedic expert; pre-trial income loss rejected for lack of supporting documentary evidence and claimant's likely retirement/limited labour-market prospects; family care claim rejected for lack of evidence of market value and hours; specific special damages proven and quantified to HKD 359,267 (excluding QEH i…
16 Mar 2026

黃銘源對文城康

Citation

[2026] HKDC 426
Court

District Court
Case number

DCPI2225/2022

Liability having been previously determined, the court assessed quantum on the medical evidence and contemporaneous records: PSLA for the combined knee injuries and resultant mild PTSD is set at $320,000 based on comparison with authorities and facts of the case; proved special damages are $101,899; LEC claim withdrawn; interest and costs awarded to plaintiff.
4 Feb 2026

XU YING v. CHINA GAS HOLDINGS LTD AND OTHERS

Citation

[2026] HKCFI 1436
Court

Court of First Instance
Case number

HCA751/2017

Expert evidence on corporate and securities advisory valuation is admitted only on a narrowly framed issue: whether a holder could reasonably have sold the shares as a single bloc on 1 March 2017 and, if not, the reasonable method and timeframe and the likely net proceeds; P's proposed valuation dates at 18 or 24 months and expert calculation of dividends were refused because those dates constitute claims for special damages not pleaded and dividends require no expert opinion.
24 Oct 2025

HUANG CHANFENG v. LI YAN CHUN

Citation

[2025] HKDC 1767
Court

District Court
Case number

DCPI748/2023

On the evidence the plaintiff suffered non-serious but material injuries with scarring, intermittent pain and psychological sequelae; in absence of medical expert opinion the court relied on contemporaneous hospital records, witness testimony and comparable authorities to fix PSLA at HK$180,000; court accepted proved special damages (medical HK$2,050 and travel HK$803.90), deducted HK$2,500 received, and ordered interest and costs as specified.
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.
14 Jul 2025

LAW KWAI YEE v. LAW MOON KWONG

Citation

[2025] HKDC 1137
Court

District Court
Case number

DCPI3261/2022

Interlocutory judgment on liability coupled with credible contemporaneous evidence (medical reports, video, payroll records and testimony) established the plaintiff's entitlement to damages; on quantified assessment the court awarded PSLA $285,000, pre-trial loss $75,187.88, loss of earning capacity $50,000 and special damages $8,275, with interest and costs as specified, because the plaintiff proved injury, treatment and some economic loss but did not prove a longer unemployment period causally linked to the injury.
6 Jun 2025

CHOI CHUN TAI v. LAM SZE LING

Citation

[2025] HKDC 944
Court

District Court
Case number

DCPI3716/2022

The court awarded damages of $443,000 based on the neurosurgery expert opinion that the plaintiff's CSDH was causally linked to the assault with a 3% whole person impairment, selected PSLA ($375,000) by analogy with comparable authorities, accepted unreceipted special expenses as reasonable on the evidence, rejected the path construction claim for lack of nexus, and adjusted loss of service to 30 months ($60,000).
29 May 2025

BARBARA CAPPELLI v. HUANG, RENQIN

Citation

[2025] HKDC 800
Court

District Court
Case number

DCPI1077/2023

The court awarded PSLA of HK$250,000 based on the nature of an open comminuted fracture requiring surgery and intramedullary nailing, the postoperative recovery timeline and residual ankle symptoms, and allowed special damages of HK$281,263 on the basis of supporting receipts and records; interest and costs were ordered as specified.
27 May 2025

XIAO LONG v. LAM TAK YUEN

Citation

[2025] HKDC 795
Court

District Court
Case number

DCPI1305/2021

Liability having been established by interlocutory judgment and employees' compensation award, Master J. Chow assessed quantum on the evidence: accepted orthopaedic opinion that plaintiff reached MMI with mild residual chest and left hand symptoms and 3% impairment; accepted 139 days sick leave as reasonable; adopted comparators (notably Sunwar Navin Kumar) to fix PSLA at HK$200,000; calculated pre-trial loss of earnings by comparing notional earnings at HK$27,500/month to actual post-sick leave earnings, applied 5% uplift for contingencies, awarded pre-trial loss HK$969,580.50; awarded loss…
11 Apr 2025

YAN KWOK SING v. TSANG YUEN FAI

Citation

[2025] HKCFI 1440
Court

Court of First Instance
Case number

HCPI276/2022

The court found the plaintiff had materially recovered sufficient function and surveillance corroborated activity; the Plaintiff was not working as a taxi driver at the material time, pre-trial loss of earnings is limited to 27 July 2021 to 31 December 2023 with Deliveroo net monthly income assessed at HKD 15,921.86, PSLA assessed at HKD 550,000 as case close to bottom of 'serious' category, other special damages limited to HKD 49,743, no award for future loss or loss of earning capacity, and costs and specified interest orders granted.