Hong Kong Case Law: Decisions & Judgments

Topic

Summary assessment of costs

Legal area

Court

20 May 2026

YAN MEI and YAN DONG, the Joint and Several Administrators of the Estate of FONG LAP CHUNG GEORGE, Deceased AND ANOTHER v. FONG LAP SHAN

Citation

[2026] HKCFI 2963
Court

Court of First Instance
Case number

HCA104/2023

The defendant's summons was an abuse of process and misconceived; the costs order nisi was made absolute; a summary assessment is appropriate and the defendant must pay assessed costs of HK$70,000, apportioned HK$35,000 to each of P1 and P2, with the P1 portion to be set off against amounts payable by P1 under the Unless Order and the P2 portion payable forthwith by the defendant.
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.
4 May 2026

WONG TO YICK WOOD LOCK OINTMENT LTD v. BENNY KONG & TSAI LLP formerly known as BENNY KONG & TSAI (A FIRM)

Citation

[2026] HKCFI 2519
Court

Court of First Instance
Case number

HCMP362/2022

The Court granted the Applicant leave to use the three affirmations for the purpose of lodging a complaint with the Law Society because, given the Respondent’s prior correspondence and the ambiguity in authority about whether consent alone removes the risk of contempt, the Applicant was entitled to a court order to remove doubt; the Respondent’s consent arrived late and after threatening action, so the Respondent was ordered to pay the Applicant’s costs of the application, summarily assessed at HK$300,000 (HK$150,000 counsel equivalent and HK$150,000 solicitors' fees).
22 Apr 2026

GLOBAL ENTERPRISES CORPORATION LTD v. TOMY INDUSTRIAL CO LTD AND ANOTHER

Citation

[2026] HKCFI 2280
Court

Court of First Instance
Case number

HCA2076/2023

The appeal is dismissed because the Master did not err in law or act unreasonably: the Master reasonably concluded a binding settlement was reached on the evidence and, alternatively, properly assessed the merits of the setting aside application; the Ladd v Marshall material was admitted but did not materially affect the outcome; accordingly the Master's Costs Order is upheld and the plaintiff must pay the defendants' costs of this re‑hearing in the sum awarded.
17 Apr 2026

PACIFIC ACE FINANCE LTD v. DELAY, GILDA H. AND ANOTHER

Citation

[2026] HKDC 669
Court

District Court
Case number

DCCJ3298/2018

Leave to appeal was refused because the applicant failed to demonstrate a reasonable prospect of success under s63A DCO: the court's recalculation of default interest was an assessment of damages rather than an impermissible amendment of pleadings; Delay's challenges were largely re‑arguements of factual findings unsupported by law or evidence and did not meet the threshold of 'plainly wrong'; default interest is excluded from effective interest rate under the cited authority; accordingly the original judgment was affirmed and costs awarded against the defendants including summary assessment…
14 Apr 2026

SERES PROPERTIES B.V. v. LEE HOCK PUN AND ANOTHER

Citation

[2026] HKCFI 2102
Court

Court of First Instance
Case number

HCA1287/2022

The Consent Order did not exclusively prevent D1 from seeking to set aside the Default Judgment by other routes; the Default Judgment was irregular and therefore properly set aside ex debito justitiae; there was no abuse of process or such delay as to justify a different result; variation to order immediate summary assessment was refused because procedural preconditions were not met; both the Leave Summons and Variation Summons were dismissed and Plaintiff ordered to pay HK$42,000 to the 1st Defendant as summarily assessed costs of the summonses.
10 Apr 2026

SHAHZAD FAISAL v. SECRETARY FOR JUSTICE

Citation

[2026] HKDC 635
Court

District Court
Case number

DCCJ3746/2022

The Master erred in law by effectively awarding solicitor and counsel fees contrary to s24 of the Small Claims Tribunal Ordinance and binding authorities; the Master's Assessment is set aside and costs are to be assessed on the SCT scale in a broad‑brush manner, resulting in an award of HK$500 to the Plaintiff; the appeal is allowed and a nisi order for the Defendant's costs of the appeal is made.
1 Apr 2026

LEE CHICK CHOI v. THE HONG KONG GOLF CLUB

Citation

[2026] HKDC 460
Court

District Court
Case number

DCEO11/2019

The applications were dismissed because the leave application was procedurally defective and failed the substantive merit threshold for an arguable appeal, the Claimant did not adduce adequate evidence of serious deleterious effect to justify a stay or variation of the costs order, the Respondent's submissions were not out of time and any prejudice was minimal, and costs were properly summarily assessed and ordered against the Claimant on a nisi basis.
31 Mar 2026

THE BANK OF EAST ASIA, LTD v. TARJOTO HERU HIDAJAT AND ANOTHER

Citation

[2026] HKCA 527
Court

Court of Appeal
Case number

CACV267/2025

The Defendants failed to address the only relevant questions (why they should not be liable for their failed stay application and the quantum of costs) and instead raised irrelevant alleged wrongs; accordingly the Summons is dismissed and costs follow the event, with the Plaintiff's costs of the Summons assessed on an indemnity basis at HK$28,346.
18 Mar 2026

BAO YUAN FINANCE LTD v. LAU YEE TING AND OTHERS

Citation

[2026] HKCFI 1702
Court

Court of First Instance
Case number

HCMP2470/2024

The appeal was allowed and leave to file and serve the 3rd Defendant's second affirmation was granted because the substantive hearing had been adjourned so prejudice to the Plaintiff could be minimized, the applicant provided an explanation for delay that was not inexplicable, and the interests of justice required the new defence to be ventilated; the Plaintiff was given 28 days to file an affirmation in reply and costs were allocated accordingly.