26 Sept 2025
JACKY ZONG AND OTHERS v. KELLY FULI ZONG AND ANOTHER
- Citation
- [2025] HKCFI 4525
- Court
- Court of First Instance
- Case number
- HCMP2772/2024
The court refused leave to appeal and held that in section 21M applications in aid of foreign proceedings Stage 1 requires only a serious issue to be tried (a low threshold) and Stage 2 permits the court to exercise its discretion regarding foreign elements, need for security and policing measures; preservation orders may be granted without a prerequisite real risk of dissipation where necessary to preserve the subject-matter; on the facts there were serious issues to be tried on trust and proprietary claims and the disclosure order was justified to police the preservation order.