CHIANG SHAM LAM ANTHONY AND ANOTHER V. ACCOUNTING AND FINANCIAL REPORTING COUNCIL

[2026] HKCA 391 Court of Appeal 12 March 2026 • CAMP124/2025 • 25 min read

14 cases cited (0 HK, 14 foreign)

Outcome

Application dismissed

We dismiss the application for leave to appeal.

Source: [2026] HKCA 391, Court of Appeal, decided 12 March 2026. Read directly from the judgment.

Judges (2)

Barma Coram Harris Coram

Counsel (7)

MinterEllison LLP Firm Munros Firm John Leung Counsel Applicant Jonathan Fung Counsel Respondent Nicholas Pirie Counsel Applicant Raymond Leung Counsel Applicant Sara Tong Counsel Respondent

Parties (3)

ANTHONY S L CHIANG & CO (a firm) Applicant Accounting and Financial Reporting Council Respondent Chiang Sham Lam Anthony Applicant

Case Significance

Chiang Sham Lam Anthony and Another v. Accounting and Financial Reporting Council [2026] HKCA 391 is a Court of Appeal decision on an application for leave to appeal arising from disciplinary proceedings before the Accounting and Financial Reporting Council. The court held: 'We dismiss the application for leave to appeal.'

In reaching this result, the Court of Appeal considered its earlier approach to leave to appeal from disciplinary bodies in Li Sang Edward v. Disciplinary Board under the Land Survey Ordinance [2024] HKCA 197, alongside a broader set of authorities cited in the judgment.

What did the Court of Appeal decide in Chiang Sham Lam Anthony and Another v. Accounting and Financial Reporting Council [2026] HKCA 391?

The Court of Appeal held, 'We dismiss the application for leave to appeal,' rejecting the applicants' bid to pursue further appeal from disciplinary findings of the Accounting and Financial Reporting Council.

What earlier case did the court reference on leave to appeal from disciplinary bodies ([2026] HKCA 391)?

The judgment referenced Li Sang Edward v. Disciplinary Board under the Land Survey Ordinance [2024] HKCA 197 as part of its consideration of applications for leave to appeal from professional disciplinary determinations in Hong Kong.

Statutes Cited

Accounting and Financial Reporting Council Ordinance

s 37Q

Companies Ordinance (Cap 622)

s 140(2)

Rules of the High Court (Cap 4A)

Cases Cited (14)

UK (3)

[2003] EWHC 2271 [2012] EWHC 1440 [2013] EWHC 2130

HK (11)

(2009) 12 HKCFAR 237 [2001] 1 HKLRD 687 [2008] 3 HKLRD 372 [2009] 4 HKLRD 125 [2009] 5 HKC 515 [2018] HKCA 463 [2019] 4 HKLRD 294 [2022] HKCA 805 [2022] HKCA 935 [2023] HKCA 645 [2024] HKCA 197