HARSEN INDUSTRIES LTD V. WONG YEE CHUK (and 3 others)

[2024] HKCFI 1563 Court of First Instance 11 June 2024 • HCA193/2018; HCMP3363/2016; HCMP3365/2016; HCMP3366/2016 • 83 min read

9 cases cited (0 HK, 9 foreign) Cited by 3 cases

Outcome

Application refused

The application was refused primarily on the grounds that (1) the value of NHEL’s assets far exceeded the 2021 Judgment Debt, (2) Yibao could have continued with the enforcement proceedings, and (3) there was no necessity for putting NHEL into liquidation.

Source: [2024] HKCFI 1563, Court of First Instance, decided 11 June 2024. Read directly from the judgment.

Judges (1)

Linda Chan Coram

Counsel (8)

Chan Wong & Yip Firm Fung Wong Ng & Lam LLP Solicitors Firm Lau, Chan & Ko Firm Albert Yau Counsel Unknown Bernard Lam Counsel Respondent Joseph Wong Counsel Respondent Kaiser Leung Counsel Respondent Man Yin Ting Counsel Unknown

Case Significance

Harsen Industries Ltd v. Wong Yee Chuk (and 3 others) [2024] HKCFI 1563 was decided by the Court of First Instance on 11 June 2024, on an application concerning the liquidation of a company connected to a 2021 judgment debt owed to Yibao. The court held: "The application was refused primarily on the grounds that (1) the value of NHEL's assets far exceeded the 2021 Judgment Debt, (2) Yibao could have continued with the enforcement proceedings, and (3) there was no necessity for putting NHEL into liquidation." The decision has since been referenced in Chiu Wing Keung Mikey v. Interasia Corporation Ltd and Others [2025] HKCFI 386, Re Wong Yee Chuk [2026] HKCFI 1741, and Cobo Asia Ltd v. Liang Tianxiang (and 4 others) [2026] HKCFI 2696.

Why was the liquidation application refused in Harsen Industries Ltd v. Wong Yee Chuk ([2024] HKCFI 1563)?

In Harsen Industries Ltd v. Wong Yee Chuk (and 3 others) [2024] HKCFI 1563, the Court of First Instance refused the application because NHEL's assets exceeded the 2021 judgment debt, Yibao could still pursue enforcement, and liquidation was found unnecessary.

Which later cases cite Harsen Industries Ltd v. Wong Yee Chuk ([2024] HKCFI 1563)?

Harsen Industries Ltd v. Wong Yee Chuk (and 3 others) [2024] HKCFI 1563 was cited in Chiu Wing Keung Mikey v. Interasia Corporation Ltd and Others [2025] HKCFI 386 and Re Wong Yee Chuk [2026] HKCFI 1741.

Statutes Cited

Companies Ordinance (Cap 622)

s 724(1)

Trustee Ordinance (Cap 29)

s 60

Cases Cited (9)

UK (4)

[1973] AC 360 [1981] 3 All ER 797 [1986] Ch 211 [1999] 1 WLR 1092

HK (5)

(2013) 16 HKCFAR 681 (2015) 18 HKCFAR 501 [2000] 2 HKLRD 218 [2021] HKCFI 3572 [2022] HKCFI 3806

Cited By (3)

[2026] HKCFI 2696

COBO ASIA LTD V. LIANG TIANXIANG (and 4 others)

[2026] HKCFI 1741

RE WONG YEE CHUK

[2025] HKCFI 386

CHIU WING KEUNG MIKEY V. INTERASIA CORPORATION LTD AND OTHERS

Citation influence

HKLII records this judgment as cited by 3 later judgments. This counts every later Hong Kong judgment that references this case, which is broader than the resolved citations listed above.

[2026] HKCFI 2696 Court of First Instance

12 May 2026

[2026] HKCFI 1741 Court of First Instance

23 March 2026

[2025] HKCFI 386 Court of First Instance

21 January 2025