Friday, 18 July 2025

Hong Kong Court's Reminder: Condemnation of Tactical Delays and Unilateral Hearing Hijacking

(A) Introduction
 
In L v R, HCCT 87/2023, date of judgment: 18 July 2025, the Honourable Madam Justice Mimmie Chan issued a reminder to parties and practitioners regarding the essential conduct governing applications and hearings on the Arbitration List. This decision underscores the imperative of efficiency in arbitration-related court proceedings, reinforcing Hong Kong’s commitment to the core arbitral principles of speedy dispute resolution.[1]
 
(B) Facts
 
The Plaintiff commenced proceedings under sections 66 and 81 of the Arbitration Ordinance (the “Ordinance”) seeking to set aside (1) a Settlement Agreement made in relation to arbitral proceedings in Hong Kong and (2) a procedural order made by the tribunal.[2]
 
The Originating Summons was issued on 13 November 2023, and amended on 14 February 2024 with leave of the Court.[3] The Amended Originating Summons was set down for hearing on 29 September and 30 September 2025.[4]
 
On 20 June 2025, the Defendant issued a summons seeking to expunge various parts of the affirmations filed by the Plaintiff (the “Expunge Summons”). This was set down for a hearing on 18 July 2025.[5]
 
On 3 July 2025 (i.e. around 2 weeks before the above hearing), the Defendant issued another summons to seek security for costs pursuant to Order 23 rule 1 RHC and section 905 of the Companies Ordinance (the “Security Summons”). The Defendant applied for the Security Summons to be heard concurrently on 18 July 2025.[6]
 
(C) Decisions
 
Court's Disposition of the Summonses
 
At the hearing, the Defendant withdrew the Security Summons. The Court made no orders on either the Expunge Summons or the Security Summons.[7]   
 
Court’s criticisms
The Court  directed the parties' and practitioners' attention to the following:
 
1.     Condemnation of Procedural Tactics: The Court criticized the practice of unilaterally setting a new summons for hearing on a day reserved for an earlier summons on a different subject matter.[8] Such tactics “derail the hearing and the preparations made for a summons issued and set down for disposal at the time indicated by the parties”.[9]
 
2.     Reaffirmation of Speed as Overriding Objective: The Court reaffirmed the overriding objective under Section 3 of the Ordinance, namely, to facilitate “the speedy resolution of disputes”.[10] Interlocutory skirmishes should be avoided, as they (1) distract parties and the Court from focusing on substantive issues requiring expeditious resolution, for example, setting aside arbitral awards, enforcing awards, or challenges to the jurisdiction of the tribunal; and (2) derail proceedings before the Court, the preparations for the substantive hearing and its determination.[11]
 
3.     Unjustifiable Delay in Seeking Security: The Court criticized the unjustifiable delay in issuing the Security Summons. Despite the proceedings commencing in November 2023, the Court found that the grounds for seeking security “should have become apparent upon commencement” of the proceedings.[12] The Court also viewed that there was no purpose for ordering security for the Defendant’s costs 2 months before the substantive hearing of the Amended Originating Summons, especially when the Defendant contented with the status since November 2023. Applications for security can be dismissed on the ground of delay alone, in the absence of exceptional circumstance which can explain the party’s inaction.[13]
 
4.     Adverse Costs Order: The Court reiterated that unwarranted applications would be penalized by costs orders, including orders against the legal representatives in appropriate cases.[14]
 
(D) Key Takeaways
 
In conclusion, this decision sends a clear message that the Hong Kong Courts actively manage the Arbitration List to prevent procedural maneuvering from undermining arbitration's fundamental objective of speedy resolution under Section 3 of the Ordinance.
 
Parties and their advisors must not hijack hearings scheduled for one purpose to argue unrelated late-filed applications. Further, applications for security for costs must be made promptly at the commencement of proceedings. Significant delay without justifications is likely to lead to refusal. 


[1] https://legalref.judiciary.hk/doc/judg/word/vetted/other/en/2023/HCCT000087A_2023.doc
[2] L v R, HCCT 87/2023, date of judgment: 18 July 2025, §1
[3] Ibid, §2
[4] Ibid, §3
[5] Ibid, §4
[6] Ibid, §5
[7] Ibid, §6
[8] Ibid, §8
[9] Ibid
[10] Ibid, §9
[11] Ibid
[12] Ibid, §11
[13] Ibid
[14] Ibid, §12

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