Hong Kong Case Law: Decisions & Judgments

Topic

Specific discovery

Legal area

Court

19 May 2026

GERMAN POOL GROUP CO LTD AND OTHERS v. DYSON TECHNOLOGY LTD AND ANOTHER

Citation

[2026] HKCFI 2297
Court

Court of First Instance
Case number

HCIP53/2019

Plaintiffs caused unnecessary costs by pursuing a broad set of requests and making late concessions; there was inadequate evidence to compute a fair set-off; ordering costs in the cause would be unfair in a damages assessment action; therefore, the fair disposal is that each party bears its own costs of and occasioned by the Discovery Summons, including all costs reserved.
15 May 2026

CHINA MEDICAL TECHNOLOGIES, INC (IN LIQUIDATION) AND OTHERS v. BANK OF CHINA (HONG KONG) LTD

Citation

[2026] HKCFI 2817
Court

Court of First Instance
Case number

HCA1742/2018

Interim confidentiality conditions were imposed on disclosure of the KPMG documents because plaintiffs claimed confidentiality and defendant took a neutral position; defendant was held to be the substantive winner of the specific discovery application and awarded summary-assessed costs of HK$300,000, because the application was necessary to obtain the disclosure and plaintiffs did not demonstrate the application was avoidable.
16 Mar 2026

ANGELA CHEN v. WAI WAI CHEN AND OTHERS

Citation

[2026] HKCFI 1584
Court

Court of First Instance
Case number

HCAP10/2020

Vivien's specific discovery application was dismissed because she failed to establish requisite relevance and necessity under Order 24 (no prima facie showing that the documents would advance or damage the pleaded cases beyond speculative fishing); alternatively, even if relevance were established, the drafts and correspondence were protected by legal advice privilege in the factual context where solicitors were engaged to prepare the documents (a Balabel scenario), and Angela could assert privilege on her own behalf and on behalf of the deceased's estate, thus defeating the discovery claim.
18 Dec 2025

TOP EMINENT HEALTHCARE GROUP LIMITED (formerly known as CLSA PREMIUM LTD and KVB KUNLUN FINANCIAL GROUP LTD) AND OTHERS v. BANCLOGIX SYSTEM CO LTD

Citation

[2026] HKCFI 568
Court

Court of First Instance
Case number

HCA1416/2019

The application for specific discovery was dismissed solely on the ground of inordinate delay because it was issued unacceptably late before the discovery deadline and trial, no satisfactory explanation for the delay was given, and requiring further discovery at that stage would be unfair and disruptive to the plaintiffs' trial preparation; the court declined to rule on relevance to avoid prejudging the trial.
18 Dec 2025

BANCLOGIX SYSTEM CO LTD v. TOP EMINENT HEALTHCARE GROUP LTD (formerly known as CLSA PREMIUM LTD and KVB KUNLUN FINANCIAL GROUP LTD)

Citation

[2026] HKCFI 568
Court

Court of First Instance
Case number

HCA452/2020

The summons for specific discovery is dismissed on the ground of inordinate delay by the defendant; there was no satisfactory explanation for the late issuance of the summons and granting the application at this late stage would unfairly prejudice the plaintiffs and disrupt trial preparation, therefore dismissal is warranted without determining relevance.
11 Dec 2025

LAM SIU SUN DENNIS AND ANOTHER v. TAM MAN CHUN AND ANOTHER

Citation

[2025] HKCFI 6197
Court

Court of First Instance
Case number

HCMP1092/2024

The originating summons was dismissed because (1) the ex parte leave to commence committal related only to breaches existing at the time of the leave and the specific discovery order as first made did not bear a penal notice, so the procedural prerequisites for enforcement were not met and the committal proceedings were misconceived; and (2) independently, the alleged non‑compliance and affirmational inaccuracies were trivial, not shown to be dishonest or to cause serious prejudice, and committal would be oppressive and disproportionate; costs were awarded to defendants on indemnity basis.
26 Nov 2025

LEUNG, KINGSLEY v. LIANG, VIVIEN JOYCE HUI YAN

Citation

[2025] HKCFI 6120
Court

Court of First Instance
Case number

HCA1350/2024

The appeal was dismissed because the requested documents were not shown to be relevant or necessary to the narrow issues for setting aside the Consent Order, the Defendant failed to demonstrate that the documents were in the Plaintiff's possession custody or power, many requests were imprecise or overly wide, and the proposed new evidence did not satisfy Ladd v Marshall and was late.
22 Oct 2025

SARAS GOPI also known as SARASWATHI GOPALAKRISHNAN v. BINA DEEGAN also known as BINA CUNNINGHAM also known as BINA GOPI

Citation

[2025] HKCFI 5441
Court

Court of First Instance
Case number

HCA3075/2015

Bina established a prima facie case of existence, possession/control and relevance for narrowed categories of documents concerning ownership/title, the 2021 sale and receipt of sale proceeds of the Taipei property; Subi failed to rebut that case or to show disclosure was unnecessary, so discovery as narrowed was ordered; Subi's cross-application was dismissed because he failed to establish prima facie existence for the broad requests, many items were previously refused or already disclosed and remaining items were irrelevant to the sole live issue of quantum; costs were awarded to Bina on an…
26 Sept 2025

KISHIN SAMTANI, THE ADMINISTRATOR OF THE ESTATE OF NARIAN SAMTANI, DECEASED v. CHANDERSEN TIKAMDAS SAMTANI

Citation

[2025] HKCFI 4526
Court

Court of First Instance
Case number

HCA496/2011

The court refused the plaintiff's proposed variations: the plaintiff failed to show that the credit notes produced late were of the bank-issued category previously sought and the plaintiff had nonetheless pursued the misappropriation claim after the CESCO Arrangement was pleaded; there were insufficient special features to award indemnity costs; the administrator (Kishin) is prima facie personally liable and therefore the Estate of Narian Samtani and Kishin are ordered jointly and severally to pay defendant's costs on party-and-party basis with certificate for two counsel; the plaintiff's var…
4 Sept 2025

SOCAM DEVELOPMENT LTD (formerly known as SHUI ON CONSTRUCTION AND MATERIALS LTD) v. NEW PI (HONG KONG) INVESTMENT CO., LTD AND ANOTHER

Citation

[2025] HKCFI 4017
Court

Court of First Instance
Case number

HCA1974/2017

The judge allowed the plaintiff's appeal and set aside the Master’s order for discovery of the Class III Documents because defendants failed to establish a prima facie case of existence and relevance in respect of the whole class (all three document types); the request was too wide and not sufficiently particularized, the disclosed email did not establish relevance in the Peruvian Guano sense to the pleaded interference, and the blue pencil could not save the application; accordingly specific discovery for Class III was dismissed and costs awarded to plaintiff.