Saturday, 4 April 2026

Freestanding Norwich Pharmacal Applications in the District Court: Seven Procedural Warnings and an Unsettled Jurisdictional Question

(A) Introduction
 
X v. Y Company (DCMP 5633/2025, date of reasons for decision: 2 April 2026) [1] arose from an alleged internet fraud. The Plaintiff commenced the action by originating summons issued by on 13 October 2025 (“OS”) seeking various heads of relief, including a Norwich Pharmacal order, a gagging order and an order that no inspection of the court file be allowed except with leave of the Court. [2]
 
Although this appeared to be a routine proceeding, the Court identified seven procedural irregularities that warrant practitioners’ attention: [3]

(1) Listing the hearing in Chambers (not open to the public) without proper justification and without following Practice Direction 25.1.

(2) Failing to obtain interim anonymity orders and interim no‑inspection orders before filing the OS, leaving the court file open to public inspection for nearly three months.

(3) Seeking broader relief in the notice of appointment (Private Hearing Order and Anonymity Order) than in the OS, without amending the OS or filing evidence of the defendant’s stance.

(4) Improper approach to the interim gagging order: requesting the bank to withhold information from account holders before any court order was made, instead of following the correct three‑step ex parte procedure.

(5) Engaging in extensive pre‑action correspondence with the bank, which negated urgency or secrecy required for ex parte procedure.

(6) Exhibiting nearly 300 pages of WhatsApp screenshots in an inefficient, costly and court‑unfriendly manner, instead of using exported chat files and electronic exhibits.

(7) Failing to exhibit draft documents exchanged with the defendant, leaving the Court unable to understand the parties’ comments and consensus without seeking clarification.
 
Most importantly, this is the third case in which the District Court has substantively considered whether it has jurisdiction to grant a Norwich Pharmacal order. 
After a detailed analysis of the statutory provisions, historical context and relevant authorities, and in the absence of submissions, the Court left the question open. Therefore, whether the District Court has jurisdiction to grant “freestanding” Norwich Pharmacal relief remains unsettled.
 
(B)  Facts
 
The Fraud

In mid-2024, an unknown person the Plaintiff to a WhatsApp group. A group member induced the Plaintiff to download a purported mobile “investment application” and register an “investment account” for investing in Mainland stocks. [4] She was required to transfer funds into the “investment account” before she could trade through the “investment application”. [5]
 
In September 2024, acting on instructions from customer service officers, she transferred funds from her local bank account to four accounts with the Defendant in the names of four different persons (the “1st Tier Recipients”). A small withdrawal from the “investment account” was initially permitted, but a subsequent larger request was refused. Therefore, the Plaintiff lost all her savings (the “Defrauded Sum”). [6]
 
Pre-action Stage

(1) 22 April 2025: The Plaintiff’s solicitors requested the Defendant to disclose correspondence addresses, HKID card numbers, and current balance figures of the four account holders. [7]
 
(2) 24 April 2025: The Defendant declined on grounds of customer confidentiality and indicated that a court order would be required. [8]
 
(3) 28 July 2025: The Plaintiff’s solicitors notified the Defendant of intention to seek a Norwich Pharmacal order and requested the Defendant to withhold informing the account holders, reserving the right to seek a gagging order. [9]
 
(4) 29 September 2025: The Defendant maintained a neutral stance and indicated that it would not contest the action. [10]

The Proceedings

(1) 13 October 2025: The Plaintiff filed an OS seeking: (a) Norwich Pharmacal order for personal particulars, account documents and transaction records; (b) leave to use information for investigation and/or commencing proceedings; (c) gagging order; (d) no inspection of court file order; (e) costs on indemnity basis. [11] On the same day, she took out an ex parte summons for an interim gagging order, but later abandoned it. [12]
 
(2) 17 October 2025: The Defendant acknowledged service, stating no intention to contest. [13]
 
(3) 24 October 2025: The Plaintiff filed the Notice of appointment, seeking additional relief not in the OS: (i) Private Hearing Order (chambers not open to public); (ii) Anonymity Order. [14]
 
(C) The Procedural Features Warranting Attention
 
The Court identified the following unusual procedural features:
 
(1)  Listing of hearing in Chambers (not open to the public) without justification
 
Under Order 28, rule 3A, an originating summons must be heard in open court unless the Court otherwise directs. Paragraph 2(a) of Practice Direction 5.8 provides that the first hearing is to be heard “in chambers”. [15] Paragraph 2 of Practice Direction 25.1 provides that chambers hearings shall be held in public except in specified instances. [16]
 
An action for a Norwich Pharmacal order and ancillary gagging order falls within none of the exceptions. As such, the default position is that the first hearing of such action shall be listed for hearing in Chambers (open to the public). [17]
 
In this case, the Plaintiff listed the hearing as “Chambers (not open to public)” without following the required procedure under paragraph 7 of Practice Direction 25.1 (applying in writing at least 2 clear days before hearing with grounds). As such, the hearing was converted to open court and the Private Hearing Order was abandoned. [18]
 
(2) Failure to Obtain Interim Anonymity and No-Inspection Orders

In this case, the Plaintiff has never sought any interim order to protect the anonymity of the parties. The OS was filed on 13 October 2025 and was open to public inspection for nearly three months. The Daily Cause List published before the hearing would have disclosed the parties’ names to the public. [19]

On the day before the hearing, the Court exercised the implied jurisdiction to make an interim anonymity order so that the parties’ names would not be shown in the Daily Cause List pending the first hearing of the notice of appointment. [20]
 
(3) Notice of Appointment Sought Relief Beyond the Originating Summons

Under Order 28, rule 3(3), a notice of appointment must specify the orders or directions the party serving the notice intends to seek at the hearing. [21] Where a plaintiff seeks orders beyond the scope of the originating summons, the proper procedure is to amend under O 20, rules 5 and 7 and to file evidence of the defendant’s stance on the proposed amendments. [22]
 
In the present case, the Notice of Appointment sought a Private Hearing Order and Anonymity Order which were not in the OS. No amendment application was made and no evidence was filed as to the Defendant’s position. [23] The Court accepted, based on the letter dated 26 September 2025, that the Defendant remained neutral, so amendment was not required on this occasion. [24]

(4)   Failure to Exhibit Draft Correspondence
 
Parties should exhibit draft documents exchanged in correspondence so that the Court can properly understand the parties’ comments and any consensus reached, in accordance with Practice Direction 10.1. A party cannot give factual evidence through bundle descriptions or the way a bundle is prepared. [25]
 
In this case, the draft documents enclosed with letters dated 28 July, 5, 19, 26 September 2025 were omitted from exhibited copies. As such, the Court could not understand the Defendant’s comments on the drafts. [26] The Plaintiff’s solicitors later explained the Draft Order was the final draft sent on 26 September 2025 and the OS had wrongly used a previous draft. [27]
 
(5)   Improper Approach to Interim Gagging Order
 
In Asiya Asset Management (Cayman) Ltd v Dipper Trading Co Ltd [2019] 3 HKC 145, the Court set out the correct three-step procedure for gagging orders: [28]

(a) The plaintiff seeks on an ex parte without notice basis a gagging order against the bank pending the hearing of the Norwich Pharmacal discovery against the bank either on an inter partes basis or at the very least on an ex parte basis but with notice. The notice period to be given should normally be sufficiently long so that the bank can meaningfully make submissions, if it thinks appropriate to do so.

(b) At the hearing of the Norwich Pharmacal discovery application against the bank, the Court will then have the benefit of the submissions of the bank, if any, while the plaintiff on the other hand will be protected by the gagging order until the conclusion of such proceedings.

(c) The Court
can in an appropriate case grant a further brief period for the gagging order to continue, to allow the plaintiff to make such applications as it sees fit to protect its interests.
 
In this case, the Plaintiff requested the Defendant to withhold information from the account holders before any order was made, placing the Defendant in a difficult position vis‑à‑vis its customer duties. [29]
 
(6)   Pre-action Correspondence Negated Urgency/Secrecy for ex parte procedure
 
In A1 v R1 [2021] HKCFI 650, the applicants sought ex parte relief on grounds of urgency and secrecy, but provided draft documents to the banks five days before filing. The Court held that this conduct showed the application was not urgent and secrecy had been given up. [30] A party who engages in pre‑action correspondence with the banks cannot properly seek ex parte relief, as such conduct lnegates the usual foundations of urgency and secrecy. [31]
 
Similarly, in this case, the Plaintiff engaged in extensive pre‑action correspondence over several months, which negated any basis for ex parte relief.
 
(7)   Improper Use of WhatsApp Screenshots as Evidence
 
In this case, nearly 300 pages of colour-printed WhatsApp screenshots were exhibited, creating multiple difficulties: [32]

(a) The messages bear no specific dates, are selectively captured from a rolling screen in a manner suggesting continuity, and often compel legal representatives to make impermissible factual assertions as to how they should be read. The Court must infer the dates of each message from context.

(b) The top and bottom of each page inevitably repeat content from adjoining pages, while large portions are occupied by blank spaces or non‑textual graphics that rarely bear relevance to the issues before the Court.

(c) Pictures attached to WhatsApp messages cannot be shown clearly in screenshots, as they are invariably reduced in size. In the present case, the screenshots were printed in colour and enlarged, seemingly only to render the attached pictures legible.

(d) Screenshots cannot convey the content of documents attached to WhatsApp messages, save perhaps an incomplete file name appearing in the text.

(e) The manual production of screenshots consumes excessive time, unnecessarily expands the volume of papers the Court must review, and increases the legal costs of the proceedings.
 
Recommended practice 
for adducing WhatsApp messages (subject to technological developments) should be as follows: [33]

(a) Parties are expected to prepare exported chats and insofar as necessary and relevant together with media. Where only the textual messages are relevant, the chat .txt file (or an equivalent electronic format) should be exhibited both in printed form and electronically, the latter enabling keyword search.

(b) For relevant attachments, a party should exhibit both the electronic files (with the original file names shown in the chat .txt file) and also its printed version (with clear indication of the aforesaid file name).

(c) The requirement to exhibit printed copies is always subject to the circumstances of individual cases.

(d) Unless compliance is impossible, for example, due to technical reasons, the above practice should be followed. Any departure must be justified. It is difficult to conceive that screenshots themselves could convey more relevant information than an exhibit prepared in accordance with the above, save in the rarest and most exceptional circumstances.
 
(D) Decision
 
Relief

The Court granted the following relief:
 
(a) Norwich Pharmacal Order
 
The Court held that the first two requirements set out in A1 v R1 [2021] HKCFI 650 were clearly satisfied: (1) there was cogent and compelling evidence of internet fraud; (2) the order sought would likely reap benefit for P and enable P to at least assert her interests in one of the four accounts. [34] The third requirement (that the discovery sought must not be unduly wide) was satisfied after the Plaintiff agreed to replace “including” with “namely” to specify the relevant particulars. [35]
 
(b) Gagging Order
 
The Court granted the gagging order on two grounds: (1) the Defendant maintained its neutrality in this action and there is no evidence that the 1st Tier Recipients ever gave any instructions regarding the operation of their accounts; (2) given the nature of the fraud practised upon the Plaintiff, real prejudice would be suffered by the Plaintiff if an order was refused. [36] The Court added that, if a party seeks the bank’s view on a proposed gagging order, the proposed date of expiry should be stated clearly. [37]
 
(c) Anonymity Order
 
The Court held that having regard to all the circumstances and for the purpose of maintaining consistency with other orders granted, the Court held that the Anonymity Order was justified. [38]
 
(d) No Inspection of Court File Order
 
The Court granted this order to maintain consistency with other orders made. [39]

Jurisdictional question left open
 
The District Court has substantively considered this jurisdictional question on two prior occasions: (1) Kwong Sin Yee Florence v Cathay Pacific Airways Ltd [2025] HKDC 1251; and (2) Chan Chun Hei Ryan v Hang Seng Bank Ltd [2026] HKDC 91. [40]

In this case, the Court addressed whether the District Court has jurisdiction to grant “freestanding” Norwich Pharmacal relief where there is no existing action, but only an asserted intention to commence proceedings against the wrongdoers. 

In the absence of submissions, the Court left the above question open, subject to the following observations:

(1) Section 48 of the District Court Ordinance (Cap. 336) (“DCO”) confers power to grant relief “ancillary to” or “in aid of” an existing action, and does not obviously authorize freestanding pre‑action relief. . [41]

(2) Section 52 of the DCO is an unlikely source of jurisdiction. Describing a Norwich Pharmacal order as an “injunction” would stretch the term too far, and an originating summons for disclosure is not a matter “affecting” property. [42]

(3) The District Court does not possess inherent jurisdiction for granting freestanding relief in the strict sense. Its powers are statutory. The proper question is whether the power exists by statutory implication, namely, whether it is “reasonably required” for the effective exercise of expressly conferred jurisdiction. [43]
 
Historically, the District Court’s predecessor never had equitable jurisdiction and the bill of discovery belonged exclusively to the Court of Chancery. [44] Even after equity jurisdiction was conferred on English County Courts in 1865, it was settled that there was no jurisdiction to commence an action for discovery only. [45] Although the Court of Final Appeal in Sir Elly Kadoorie & Sons Ltd v Bradley [2026] HKCFA 2 confirmed that an intention to bring legal proceedings is not a pre‑condition for Norwich Pharmacal relief, that does not automatically answer the jurisdictional question for the District Court. [46]
 
The Court noted an apparent incongruity: although an intention to bring proceedings is not necessary for Norwich Pharmacal relief, it would nevertheless be treated as sufficient to confer jurisdiction on the District Court, even though its realization depends entirely on whether the disclosed information proves useful. [47]

(E)  Key Takeaways

This case provides valuable guidance on the proper procedures for obtaining a Norwich Pharmacal order, an anonymity order, a no‑inspection order and a gagging order, as well as the recommended practice for adducing WhatsApp messages.
 
Notably, whether the District Court has jurisdiction to grant freestanding Norwich Pharmacal relief remain unsettled. To play safe, the applicant can commence in the Court of First Instance, which clearly has jurisdiction. If proceedings must be commenced in the District Court, the applicant can seek a ruling on the jurisdictional question at the earliest opportunity, or frame the application as ancillary to an existing or imminent action within the District Court’s express statutory jurisdiction, rather than as a truly “freestanding” application.



[1] https://legalref.judiciary.hk/doc/judg/word/vetted/other/en/2025/DCMP005633_2025.docx
[2]X v. Y Company (DCMP 5633/2025, date of reasons for decision: 2 April 2026)§1
[3] Ibid§4
[4] Ibid§6
[5] Ibid§7
[6] Ibid§8
[7] Ibid§9
[8] Ibid
[9] X v. Y Company (DCMP 5633/2025, date of reasons for decision: 2 April 2026)§11
[10] Ibid§15
[11] Ibid§17
[12] Ibid§20-§21
[13] Ibid
[14] X v. Y Company (DCMP 5633/2025, date of reasons for decision: 2 April 2026)§22
[15] Ibid§29
[16] Ibid§30
[17] Ibid§32
[18] Ibid§37
[19] Ibid§42
[20] Ibid§43
[21] Ibid§45
[22] Ibid§47
[23] Ibid§48
[24] Ibid§49
[25] Ibid§50
[26] Ibid§16
[27] Ibid§28
[28] Ibid§51
[29] Ibid§53
[30] Ibid§54
[31] Ibid§55
[32] Ibid§57
[33] Ibid§58
[34] Ibid§64
[35] Ibid§65
[36] Ibid§67
[37] Ibid§68
[38] Ibid§70
[39] Ibid§74
[40] Ibid§75-§76
[41] Ibid§77
[42] Ibid§81
[43] Ibid§82
[44] Ibid§83
[45] Ibid§90
[46] Ibid§92
[47] Ibid§94

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