Hong Kong Case Law: Decisions & Judgments

Topic

Valuation methodology

Legal area

Court

17 Oct 2025

CHAN YAM CHUN, ALBERT v. NG SHIU WAI, ANDREW AND OTHERS

Citation

[2025] HKCFI 4949
Court

Court of First Instance
Case number

HCCW198/2025

Winding up relief was struck out because on the pleaded facts the Company is solvent and profitable, the petitioners did not satisfactorily demonstrate why winding up (rather than a s.724 buyout) was necessary or preferable, there was no prima facie case that the respondents could not finance a buyout, valuation disputes and allegations requiring investigation do not alone justify retaining winding up relief, and therefore the strike out was appropriate; joinder and amendment were allowed.
26 Aug 2024

THE DIRECTOR OF LANDS v. ZITTA INVESTMENTS LTD (formerly known as KIND BOSS INVESTMENTS LTD)

Citation

[2024] HKLdT 73
Court

Lands Tribunal
Case number

LDLR6/2023

On the balance of probabilities as at 16 September 2012 the Lot and shop lacked realistic redevelopment potential given its small site area and absence of evidence of developer interest; therefore compensation must be assessed on existing use (open market) value, the Tribunal accepted the expert direct comparison valuation and determined the market value at HK$14,570,000 and ordered payment.
2 Aug 2023

YIELD-THE-BEST LTD v. SECRETARY FOR TRANSPORT AND HOUSING

Citation

[2023] HKLdT 44
Court

Lands Tribunal
Case number

LDMR1/2021

The Tribunal held that s.12(b) and s.12(c) of the Lands Resumption Ordinance apply to resumptions under the Roads Ordinance by virtue of the Schedule and therefore the value of temporary or non-conforming structures must be disregarded for assessment of market value; paragraph 5 of the Schedule to the Roads Ordinance is supplementary and does not override s.12(b) but permits a discretionary reduction (eg for demolition costs) and cannot be construed to require inclusion of unlawful building-value; there was no abandonment or waiver of the restrictive covenants on the facts; the resumed land m…
18 May 2023

RISE TALL DEVELOPMENTS LTD v. YEUK MAN CO LTD

Citation

[2023] HKCFI 1237
Court

Court of First Instance
Case number

HCA1953/2019

Paragraph 1(a) (evidence as to what constitutes 'properly managed and maintained premises') is not admissible expert evidence because no recognised specialised expertise governed by standards exists and it would not assist the court; a split trial separating quantum from liability was not justified because exceptional circumstances were not shown and the anticipated savings did not outweigh the risk of duplication, delay and increased aggregate costs; expert evidence is appropriate for valuation only; fresh expert report on appeal was not admitted because no special grounds shown and the repo…
7 Dec 2022

NEW MERIT LTD v. THE PERSONAL REPRESENTATIVES OF CHAN KUM KWAN, DECEASED

Citation

[2022] HKLdT 66
Court

Lands Tribunal
Case number

LDCS1000/2022

Applicant satisfied statutory ownership threshold (>90%); tribunal accepted expert valuation evidence (EUV total $95,810,000) and residual valuation (RDV $106,000,000) and accepted expert building condition reports establishing redevelopment justified due to age and poor state; applicant had taken reasonable steps to acquire outstanding share; accordingly an order for sale by public auction with reserve price $106,000,000 was granted and trustees were appointed.
2 Sept 2022

LUCK MOST LTD AND OTHERS v. GOOD MOVEMENT LTD

Citation

[2022] HKLdT 43
Court

Lands Tribunal
Case number

LDCS11000/2020

Reports 2-4 were not within the scope of the October Order (leave was for valuation of the Property) and, alternatively, in their current form are irrelevant and unhelpful because they do not provide RDV or an apportionment methodology linking the RDV of larger lots to the subject Property; Report 5 fails to cure those defects; consequently Reports 2-4 are expunged from the court file and inadmissible and Report 5 is not admitted; directions given for further case management and potential strike out application.
7 May 2020

SOUTH CROWN DEVELOPMENT LTD v. CHUNG KI TO (AS ADMINISTRATOR OF THE ESTATE OF CHUNG KOON KOW, DECEASED) AND OTHERS

Citation

[2020] HKCA 188
Court

Court of Appeal
Case number

CAMP288/2019

Leave to appeal refused because the Lands Tribunal's factual findings that the Settlement Prices did not reflect true market values were supported by evidence; the applicant had taken reasonable steps under s4(2)(b); the Tribunal's valuation methodology was proper in the absence of expert evidence supporting the alternative approach; many grounds were academic or lacked reasonable prospects of success, therefore no basis to grant leave.
31 Oct 2019

SOUTH CROWN DEVELOPMENT LTD v. and CHUNG KI TO (AS ADMINISTRATOR OF THE ESTATE OF CHUNG KOON KOW, DECEASED) AND OTHERS

Citation

[2019] HKLdT 61
Court

Lands Tribunal
Case number

LDCS2000/2016

The applicant failed to demonstrate reasonable prospects of success because the tribunal properly concluded the putative comparators did not reflect market value and no expert evidence or workable alternative valuation methodology was produced to support the challenge; accordingly leave to appeal is refused and costs ordered.
23 Jan 2019

LEE CHONG YIP v. DIRECTOR OF LANDS

Citation

[2019] HKLdT 6
Court

Lands Tribunal
Case number

LDLR7/2016

The Tribunal held that the Relevant Covenant in the Block Government Lease operates as a prohibition that falls within s12(c) LRO so that any expectancy of obtaining a building licence or lease modification for NTEH cannot be taken into account; evidence showed no vehicular access to either the Northern or Southern Sites at the resumption date; accordingly the best use was open storage with pedestrian access only and compensation was assessed by reference to open storage comparables with specified adjustments, producing the awards set out in the judgment.
15 Nov 2016

PENNY\'S BAY INVESTMENT CO LTD v. DIRECTOR OF LANDS

Citation

PENNY\'S BAY INVESTMENT CO LTD v. DIRECTOR OF LANDS
Court

Court of Appeal
Case number

CACV13/2015

The Court set aside the Tribunal's award and remitted the case to the Tribunal to determine compensation in accordance with the Court's judgment; the Court held there should be no differentiation in treatment of deferment and risk between Before and After values as a matter of law, refused to make additional declarations sought by the Applicant, refused both parties' applications for leave to appeal to the Court of Final Appeal, and ordered that each party bear their own costs of these appeals.