First Laser Ltd v. Fujian Enterprises (Holdings) Co Ltd and Another

Read the full judgment text of CACV 126/2008 on BabelCite. This Court of Appeal judgment was delivered on 4 January 2011.

1. The plaintiff succeeded in its action against the defendants before Deputy High Court Judge To (as he then was).

Cites 5 cases

(I) Please refer to FAMV25/2011 for the relevant appeal(s) to the Court of Final Appeal. (II) Please refer to FACV6/2011 for the relevant appeal(s) to the Court of Final Appeal.
Case No.CACV 126/2008[2011] 2 HKLRD 45
Court
Court of Appeal
Date04 Jan 2011
Judge
Case Document
100%Judiciary

CACV 126/2008

IN THE HIGH COURT OF THE

HONG KONG SPECIAL ADMINISTRATIVE REGION

COURT OF APPEAL

CIVIL APPEAL NO. 126 OF 2008

(ON APPEAL FROM HCA 4414 OF 2001)

________________________

BETWEEN

FIRST LASER LIMITED
(第一激光有限公司)
Plaintiff
and
FUJIAN ENTERPRISES (HOLDINGS) COMPANY LIMITED
(華閩(集團)有限公司)
1st Defendant
JIAN AN INVESTMENT LIMTIED 2nd Defendant

________________________

Before : Hon Cheung, Yeung and Yuen JJA in Court

Date of Hearing : 21-25 June, 30-31 August and 1 September 2010

Date of Further submission by the defendants : 15 September 2010

Date of Judgment : 4 January 2011

________________________

J U D G M E N T

________________________

Hon Cheung JA :

The appeal

1.The plaintiff succeeded in its action against the defendants before Deputy High Court Judge To (as he then was). 

2.The Judge found that 51% of the shares of and in Fujian Casix Laser Inc. (福建華科光電有限公司) (‘FCL’) (formerly known as Fuzhou Castech-Phoenix Inc. (福州科鳯激光有限公司) (‘Castech-Phoenix’) belonged beneficially to the plaintiff.  The Judge found that the 1st defendant was in breach of an agreement to sell the shares to the plaintiff and also in breach of the trust in favour of the plaintiff in respect of the shares when they were wrongfully disposed of by the 1st defendant.  The 2nd defendant was a nominee or conduit of the 1st defendant for the receipt and transfer of the proceeds of sale of the shares in FCL.  Based on the plaintiff’s election to proceed with proprietary remedy, the Judge ordered, amongst other things, an account and tracing inquiry in respect of the shares and their proceeds of sale.

3.The defendants now appeal against the judgment.

Facts

4.The plaintiff is a company incorporated in Macau and is under the control of Mr. Ngan In Leng (顏延齡) (‘Mr. Ngan’).

5.The defendants are companies incorporated in Hong Kong.  They are ‘window companies’ of the Fujian Provincial People’s Government of China.  This means in practical terms the Fujian Government controls the defendants.  The directors of the defendants are employees of the Fujian Government and the shares of the defendants are held on trust for the Fujian Government.

6.In 1991, the 1st defendant set up Castech-Phoenix as a joint venture with the Fujian Research Institute of Material Structures of the Academy of Science (‘FRIMS’) for the production of non-linear crystals.  Castech-Phoenix was a Mainland company.

7.Following disputes with FRIMS, the 1st defendant bought out FRIMS’s shares in Castech-Phoenix and terminated the joint venture agreement in January 1996.

8.Subsequent to this, Castech-Phoenix changed its name to FCL.  The part of FCL’s business which involved intellectual property rights of the products was transferred to a new company called Fuzhou Casix Optronics Inc (福州科騰光電技術有限公司) (‘FCO’), another Mainland company which is also controlled by the defendants.

9.The 1stdefendant then looked for a new partner.  Mr. Ngan who had close contacts with the Fujian government was approached in 1996.  Mr. Ngan had business dealings with the 1st defendant since 1990.  He was regarded by the Fujian government as a ‘patriotic Chinese’.  He was a member of the National Committee of the Chinese People’s Political Consultative Conference (中國人民政治協商會議全國委員會委員) and a member of the Standing Committee of the Fujian Provincial Committee of the Chinese People’s Political Consultative Conference (福建省人民政治協商會議常務委員會委員).

The agreements

10.Eventually the parties entered into four agreements, namely,

1) The Hang Wo Agreement

2) The COM Agreement

3) The First Laser Agreement

4) The COM/Casix/Kexin Agreement (the ‘FCO’) Agreement.

11.This is what the Judge found in respect of the four agreements :

The Hang Wo Agreement

25. The first agreement between the two camps was entered into between the 1stDefendant and Hang Wo [Hang Wo Properties Investment and Management Company Limited, a company controlled by Mr. Ngan] (“Hang Wo Agreement”) dated 12 December 1996.  In the preamble, it was stated that the parties would make use of the 1st Defendant’s optronic technology (高科技光電子產業) and to jointly invest US$20 million in a Macanese company to be incorporated and called COM [Casix Optronic Manufacturing Limited (宇星光電企業製造有限公司] for the purpose of producing crystals.  The parties agreed as follows :

(1) the 1st Defendant would transfer 100% shareholding in FCL and FCO to COM and the shares of COM would be held by the 1st Defendant and Hang Wo in the ratio of 49:51 (clause 1);

(2) Hang Wo would purchase 51% of the 1st Defendant’s shareholding in FCL and FCO by cash (clause 2);

(3) Hang Wo would be solely responsible for contributing to the initial capital of COM in the amount of US$10 million (clause 3); and

(4) the parties understood that certain legal formalities were required for the transfer of the shares in FCL and FCO to COM, hence, in the meantime, the 1st Defendant’s shares in COM would be held by Jenwing, a British Virgin Islands incorporation, on behalf of the 1st Defendant and would be transferred to the 1st Defendant when its shares in FCL and FCO were transferred to COM (clause 4).

The COM Agreement

26. The two camps also entered into a second agreement of the same date (“COM Agreement”).  The parties to the agreement were the 1st Defendant and COM.   The preamble stated that COM was to acquire the 1st Defendant’s shareholding in FCL and FCO.  The parties agreed, inter alia, that :

(1) the 1st Defendant would sell all its shares in FCL and FCO to COM at the valuation of US$6.25 million (clause 1);

(2) COM would pay the 1st Defendant US$3.125 million within one month of execution of the agreement and the balance within three months (clause 5); and

(3) the parties would immediately set up a working party to deal with the necessary procedures and instruct lawyers to handle the share transfer in the PRC (clause 6).

The agreement expressly stated that it was executed on 12 December 1996 in Hong Kong.

The First Laser Agreement

27. Then the two camps entered into yet a third agreement dated 28 December 1996 (“First Laser Agreement”).  The parties to this agreement were the 1st Defendant and the Plaintiff [a company controlled by Mr. Ngan].  This is the latest agreement in the series and the one relied on by the Plaintiff as the basis of this action.  The agreement was vague as to the subject matter.  As a result, the 1st Defendant raises a defence of uncertainty of the subject matter.  The preamble of the agreement states that the 1st Defendant agreed to sell to the Plaintiff 51% its investment in the optronic project in Fuzhou (福州所投資的光電子項目中的51%的股權).  The parties agreed, inter alia, that :

(1)    upon completion of the share transfer, the ratio of the shareholding of the 1st Defendant and the Plaintiff would be 49:51 (clause 1);

(2)    the net asset value of the project to be sold was agreed to be US$6.25 million, hence, the 1st Defendant would sell 51% of its shareholding to the Plaintiff for US$3.1875 million (equivalent to HK$24.64 million) (clause 2);

(3)    upon admission of the Plaintiff into the business, the boards of directors of FCO and FCL would be reorganized, the composition of the new boards would be subject to consultation (clause 3);

(4)    the Plaintiff would pay the 1st Defendant HK$10 million within ten days of execution of the agreement and the balance by two instalments within three months (clause 7); and

(5)    both parties would form a working party as soon as possible for the purpose of liaison and handling the related matters and would instruct lawyers in the PRC to handle matters relating to the change in ownership of the relevant companies (clause 8).

The agreement stated that it was executed on 28 December 1996 in Hong Kong.

……

The COM/Casix/Kexin Agreement

30. In addition to the three agreements, COM and the 1st Defendant’s subsidiaries, namely Casix Limited and Fujian Kexin, also executed another agreement, i.e. the COM/Casix/Kexin Agreement dated 12 December 1996 solely in relation to the transfer or the sale and purchase of the shares in FCO.  There are three different versions of this agreement, one produced by the Plaintiff and two produced by the 1st Defendant…… In the Plaintiff’s version, Fujian Kexin and Casix Limited agreed to transfer their capital investment respectively in the sum of US$63,000 and US$1,447,000 in FCO to COM and COM agreed to accept the transfer of the investment in the total amount of US$1,510,000 and thereafter to assume all the rights and liabilities of Fujian Kexin and Casix Limited in respect of FCO.’ 

12.The Judge found that the First Laser Agreement superseded the two earlier agreements.  He further accepted the plaintiff’s version of the COM/Casix/Kexin Agreement and found that the COM/Casix/Kexin Agreement did not represent the whole of the parties’ agreement under the joint venture but was a document generated solely for producing to the PRC authorities for the purpose of obtaining approval for the transfer of the FCO shares to COM pursuant to the First Laser Agreement.  He held that the COM/Casix/Kexin Agreement was not a genuine agreement supported by any underlying transaction.  It did not have the effect of replacing or superseding any of the three agreements, particularly the First Laser Agreement which was executed subsequent to it.

13.The Judge specifically rejected the defendants’ case that there was no sale of FCL and the only agreement between the parties was for the 1st defendant’s subsidiary to sell FCO.

Payment of purchase price

14.The Judge found that pursuant to the First Laser Agreement the plaintiff paid HK$20 million to the 1stdefendant on 31 December 1996 and 30 April 1997.

15.The Judge further found that according to a Memorandum dated 13 March 1998 (‘1998 Memorandum’) the plaintiff had pursuant to the First Laser Agreement further paid another sum of HK$4.64 million by treating a capital investment in the sum of HK$4.64 million made by the plaintiff in COM as investment by the 1st defendant.

16.The Judge further found that the consideration for the full purchase price for 51% of the shares in FCL and FCO were fully paid by the plaintiff in accordance with the terms of the First Laser Agreement.

The shareholders of COM

17.Hang Wo and Jenwing Holdings Limited (‘Jenwing’) are the sole registered shareholders of COM.  Jenwing is a BVI company, the shares in Jenwing were held on trust by Mr. Ngan’s camp for the 1st defendant.

Transfer of the shares in FCO

18.On 30 December 1996, i.e. one day prior to the payment of the first sum of HK$10 million to the 1st defendant due under the First Laser Agreement, the board of directors of FCO passed a resolution consenting to the transfer of all the shares in FCO to COM in accordance with the wishes of its shareholders, Casix Limited and Fujian Kenxin.  The shares in FCO were duly transferred to COM in March 1997 instead of to the plaintiff pursuant to the First Laser Agreement.

Non-transfer of the shares in FCL

19.On the other hand, the shares in FCL were never transferred to Mr. Ngan’s camp.  Apart from the absence of a board of directors meeting approving the transfer, it appears that the transfer was not carried out because governmental approval for the transfer would not be granted as the share capital of FCL had not been fully paid up.

The 1998 Memorandum

20.The Judge referred to the 1998 Memorandum which explained why the shares in FCL were not transferred to COM.  The documents acknowledged :

‘ (1) that for some historical reasons, such as the fact that US$2.5 million of the registered capital of US$7 million had not yet been injected into FCL and that there were some outstanding legal disputes relating to FCO, the 1st Defendant was still temporarily wholly holding FCL while COM was still temporarily wholly holding FCO; when the above problems were resolved, the Plaintiff’s and the 1st Defendant’s shareholding in COM and FCL would be regularised (理順股權關係) in the ratio of 51:49 (paragraph 1);

(2) that prior to the said regularisation, COM’s and FCL’s investments and rights in respect of FCL, COM and FCO shall be governed by the agreements of 1996 (paragraph 2); and

(3) that as the Plaintiff incurred significant costs in setting up COM and as the 1st Defendant would hold 49% of the shares in COM upon the said regularisation, the outstanding payment in the amount of HK$4.64 million due from the Plaintiff to the 1st Defendant under the First Laser Agreement was treated as having been paid by the plaintiff and representing the 1st Defendant’s capital contribution to COM (paragraph 3).’

Management of FCO and FCL

21.On 10 May 1997, the Mainland State Administration of Industry and Commerce issued a business licence to FCO with Mr. Ngan as the chairman of its board of directors and Wang Hongrui (王洪瑞) as its general manager.  On 30 May 1997, COM issued a letter to FCO appointing Chen Tianbin (陳天彬) as director of FCO in place of Wang Hongrui.

22.According to the Judge’s finding, on 30 December 1996 Mr. Ngan conducted a board of directors meeting of COM in which a resolution was passed appointing himself as the managing director and Wang Hongrui as general manager of FCL.  This meeting was stated to be the first board of directors meeting of COM and not of FCL. On 20 January 1997, COM issued a notice appointing Mr. Ngan, Miss Ngan and Wang Hongrui as directors of FCL.  The appointments were invalid.  However, the meeting was attended by Mr. Kong Fanli (孔凡立) and Wang Hongrui on behalf of the 1st defendant and Mr. Ngan, Miss Ngan and Mr. Huang Xiaodong (黃曉東) on behalf of Mr. Ngan’s camp.  It, nevertheless, shows recognition by those who had control of FCL that Mr. Ngan’s camp had beneficial interest in the shares in FCL. 

23.The Judge found that since 31 December 1996 when the first sum of HK$10 million was paid, the 1st defendant, FCL and FCO treated Mr. Ngan’s camp as a shareholder of FCL and FCO and Mr. Ngan and Miss Ngan participated in the management of FCL and FCO as de facto directors.  Decisions regarding the operation of FCL and FCO were referred to Mr. Ngan and Mr. Kong for approval.  Financial statements of FCL and FCO, requests for increase in staff remuneration of FCL and FCO requests for purchase of staff quarters for FCO and FCL, reports on construction of a building complex for FCL, requests for payment of construction costs of the complex, requests for funds for setting up a branch office of FCL and recommendation of a bonus share scheme for the staff of FCL were referred to both Mr. Kong and Mr. Ngan for consideration and approval.  There was participation by Mr. Ngan in the management and important decision making of FCL and FCO.  In a report to the Fujian Provincial People’s Government dated 5 June 1997, the 1st defendant acknowledged that Mr. Ngan had 51% interest in the joint venture.

Investment of Mr. Ngan

24.FCL has a subsidiary called Casix Inc in the USA which required funds to produce a special optical fiber instrument (‘the project’).  The Judge found that Mr. Ngan remitted RMB 1 million to FCL on 1 August 1997, US$500,000 to Casix Inc on 12 August 1997 and US$100,000 to Casix Inc on 17 April 1998 for the purpose of the project. 

Deterioration of relationship of the parties

25.In May 1998, there were changes within the internal management of the 1st defendant.  Mr. Xu Meixing (許美星) became the deputy chairman of the 1st defendant.  The persons who held the shares in the 1st defendant were also replaced.

26.After the change in the personnel, the relationship between the parties became strained.  In August 1998, Mr. Xu attempted to renegotiate the terms of the joint venture with Mr. Ngan : the 1st defendant wished to be the majority shareholder of 51% in COM instead of the plaintiff.  Mr. Ngan refused and sought help from high officials of Fujian government but to no avail.

27.Mr. Xu later also appointed himself as Chairman of the board of directors of FCL and installed other personnel in FCL.

28.By then Mr. Ngan wished to have his investment in the project returned but was ignored.

Sale of shares to JDS

29.On 29 February 2000, the 1st defendant sold all its FCL shares including the benefit of the project to JDS Uniphase China Holdings Company (‘JDS’) for US$60 million. 

The actions

30.On 9 October 2001, the plaintiff commenced the present action against the defendants in Hong Kong.  Attempts by the defendants to stay the present action was unsuccessful.

31.The defendants also commenced an action in the Fujian Higher People’s Court (‘the Fujian action’) seeking a declaration against Hang Wo, COM and the plaintiffthat the Hang Wo Agreement, the COM Agreement, the First Laser Agreement and the 1998 Memorandum were of no effect (無效).

32.Attempts by Mr. Ngan to challenge the jurisdiction of the Fujian Court in the Fujian action and an application by Mr. Ngan for an anti-suit injunction in Hong Kong against the Fujian action were also unsuccessful. 

The Mainland judgments

33.Eventually on 18 July 2003, the Fujian Higher People’s Court gave judgment that the Hang Wo Agreement, the COM Agreement and the First Laser Agreement were of no effect but it dismissed the 1st defendant’s claim that the 1998 Memorandum was of no effect.

34.On appeal to the Supreme People’s Court by Mr. Ngan’s camp, the Supreme People’s Court in its judgment of 3 December 2004held that at the time of the signing of the first three agreements FCL was a foreign investment enterprise and FCO was a Chinese foreign joint enterprise and any division or important changes of these enterprises would requireapproval from the relevant authority but such approval had not been obtained and on that basisthe Court held that

1) in respect of the Hang Wo Agreement, the part concerning the transfer of the FCO and FCL shares were invalid;

2) the COM agreement was invalid;

3) the First Laser Agreement was invalid;

4) since the first three agreements were invalid, the 1998 Memorandum was also invalid.

The issues

35.The following are the issues in this appeal :

I)     Does the judgment of the Supreme People’s Court give rise to an issue estoppel in the present action?

II)    If it does not, what is the applicable law governing the dispute between the parties in the present case?

III)   If Mainland law is the applicable law what is the consequence on the parties’ rights and obligation?

(IV)   Is estoppel by convention applicable even if the applicable law is Mainland law?

(V)   If, on the other hand, Hong Kong law is the applicable law, what is the consequence?

(I)  Issue Estoppel

36.The question of issue estoppel is closely related to the second issue in this appeal, namely, what is the applicable law to resolve the parties’ dispute.  The second issue arises because of the foreign elements in this case and the Hong Kong Court needs to find out what is the applicable law to resolve the dispute.  This is by way of application of the rules in private international law or what is commonly known as conflict of laws rules.

37.The Supreme People’s Court relied on Article 145Sections 1 and 2 of 《中華人民共和國民法通則》(‘People’s Republic of China Minfatongze’), which is a statute on the general principles of civil law.  The sections provide that the parties to a contract involving foreign interests can choose the law applicable to the contract disputes, unless prescribed by the law; if the parties have not chosen the applicable law, then the applicable law is that of the country which has the closest connection to the contract.  The Supreme People’s Court also referred to the principle of closest connection in private international law.  It held that Mainland law was the applicable law to resolve the contractual dispute.  It held that the three relevant contracts were invalid by reason of the absence of approval being given by the relevant authority. 

38.The defendants argued that the Supreme People’s Court had decided on the following two issues and based on the principle of issue estoppel, the decision of these two issues are binding on the Hong Kong Court : first, the applicable law governing the dispute of the parties was Mainland law, and, second, the contracts were invalid.

39.The Judge rejected the defendants’ argument.

Binding effect of a foreign judgment

40.The binding effect of a foreign judgment is stated by Dicey, Morris & Collins, The Conflict of Laws(‘Dicey’) (14th Ed) at Rule 41 as follows :

‘A foreign judgment which is final and conclusive on the merits and not impeachable under any of rules 42 to 45 is conclusive as to any matter thereby adjudicated upon, and cannot be impeached for any error either of fact or of law.’

41.Dicey, (14th Ed) at page 618 further stated

‘Closely parallel to this rule is the rule that the party must take all available defences in the foreign court, and that if he does not do so, he cannot be allowed to rely on them subsequently in the domestic court.’

Rationale of the rule

42.The rationale of the rule is two-fold, first, public policy : it is in the interest of the public that there should be an end of litigation and second, hardship on the individual in that he should not be vexed twice for the same cause (Lockyer v. Ferrymen (1877) 2 App Case 519 at 530 per Lord Blackburn). 

Caution in respect of foreign judgment

43.It has been said that the domestic court should be cautious in applying issue estoppel based on foreign judgment.  In Carl Zeiss Stiftung v Rayner & Keeler Ltd (No. 2) [1967] 1 AC 853, at 909, per Lord Reid, held that there are three reasons for this caution :

1)   The domestic court is not familiar with modes of procedure in many foreign countries, and it may not be easy to be sure that a particular issue has been decided or that its decision was a basis of the foreign judgment and not merely collateral or obiter.

2)   The practical difficulties of a defendant in deciding whether, even in this country, he should incur the trouble and expense of deploying his full case in a trivial case : it might be most unjust to hold that a litigant here should be estopped from putting forward his case because it was impracticable for him to do so in an earlier case of a trivial character abroad, with the result that the decision in that case went against him.

3)   The foreign judgment must be final and conclusive on the merits.

Three points

44.Three points should be noted :

44.1)        The first two reasons of the Lord Reid do not apply in the present case.  The judgment of the Supreme People’s Court was clear as to the two issues that it had decided and clearly the action before the Supreme People’s Court was not a trivial case.  The judgment addressed the core issues between the parties, namely, the validity of the agreements and the applicable law.

44.2)        Notwithstanding the majority decision of this Court (Cheung, Yuen JJA and Chung J) in李祐榮與李瑞群(Lee Yau Wing v. Lee Shui Kwan) [2007] 2 HKLRD 749 that because of the ‘trial supervision system’ under Mainland law (which entitles the Supreme People’s Procuratorate to apply to the Mainland Courts for a re-trial of an action), the judgment of the Mainland Courts may not be ‘final and conclusive’, the plaintiff in the present case did not challenge the final and conclusive nature of the judgment of the Supreme People’s Court.

44.3)        Before the Supreme People’s Court, the plaintiff accepted that the applicable law was Mainland law.

The Judge’s reasons

45.The Judge held that the Supreme People’s Court’s judgment did not result in issue estoppel being applied in the present case because the issues decided in the two sets of actions were different.  He agreed with the plaintiff’s argument that the issues before the Supreme People’s Court were the transfer of shares in a legal person in the Mainland, the validity of the three agreements and the 1998 Memorandum under the laws of the Mainland and the remedy that was sought was a declaration that the three agreements and the 1998 Memorandum were of no effect; whereas the issues in the present case are the validity of the three agreements, breach of contract and breach of trust under Hong Kong law.

46.In this Court, the plaintiff further argued that issue estoppel is not engaged because the Mainland judgment on the applicable law was a decision on procedure and not substance.  This argument proceeded on the decision by the Judge that ascertaining the applicable law (lex causae) is a matter of procedure for the Court which tries the case and is to be ascertained according to the domestic law of the forum (lex fori).

My view on issue estoppel

47.In my view the Judge was incorrect in holding that issue estoppel does not apply.

48.1) I accept that on the contract issue, the Supreme People’s Court was concerned solely with the question of invalidity of the agreements and not with the consequence of them being invalid.  However, the issue of invalidity of the agreements must clearly be a common issue in both proceedings.  The issue of applicable law is a common issue as well. 

48.2) Further it is not permissible to avoid the consequence of issue estoppel by re-characterizing the issue as one which is sought to be litigated in accordance with the law of a different jurisdiction : see The Sennar (No. 2)(Court of Appeal) [1984] 2 Lloyd’s Rep 142 at 149 per Kerr LJ :

‘ I do not think that it is open to GfG to say simply, in effect: “What we seek to litigate here are issues under English law, and it does not matter that we litigated precisely the same issues under other systems of law in Holland.’

48.3) See also Armacel Property Limited v. Smurfit Stone Container Corporation[2008] FCA 592, 2 May 2008 (Federal Court of Australia) (Lexis Copy) at paragraph 67 per Jaccobson J.

48.4) The Judge’s reasoning taken to the extreme would mean that no foreign judgment can ever be used as the subject matter of issue estoppel in Hong Kong because such judgment may be based on that Court’s application of its own law which may not be exactly the same as Hong Kong law, notwithstanding that the foreign Court may have decided on the very same issue that the Hong Kong Court will have to decide.

48.5) Further, in my view, the plaintiff’s new argument falls exactly into the misconception identified by Lord Brandon of Oakbrook in The Sennar (No. 2) (House of Lords)[1985] 1 WLR 490 at 499 when he said :

‘ In my opinion, this argument is based on a misconception with regard to the meaning of the expression “on the merits” as used in the context of the doctrine of issue estoppel. Looking at the matter negatively a decision on procedure alone is not a decision on the merits. Looking at the matter positively a decision on the merits is a decision which establishes certain facts as proved or not in dispute; states what are the relevant principles of law applicable to such facts; and expresses a conclusion with regard to the effect of applying those principles to the factual situation concerned.’

48.6) The Supreme People’s Court’s decision that Mainland law was the applicable law was a decision on the merits which clearly affected the substantive rights of the parties.

48.7) In any event even according to the case of Desert Sun Loan Corp v Hill [1996] 2 All ER 847 cited by counsel for the plaintiff, Mr. Chan Chi Hung SC and Mr. Jeremy Chan, where the Court recognized the issue estoppel rule (which is defined in terms of a final judgment on the merits) cannot apply when there is no more than ‘an interlocutory decision on a procedural and non substantive issue’, it had also at the same time decided that issue estoppel applies to an interlocutory judgment on procedure when there is an express submission to the procedural or jurisdictional issue to the foreign court.  Evans LJ at 858 stated that :

‘          On balance, and regarding the question entirely as one of principle, I would be prepared to hold that an issue estoppel could arise from an interlocutory judgment of a foreign court on a procedural, ie non-substantive, issue, where the following conditions were fulfilled: (1) there was express submission of the procedural or jurisdictional issue to the foreign court; (2) the specific issue of fact was raised before and decided by the court; and (3) the need for ‘caution’ recognised by Lord Reid in Carl-Zeiss is carefully borne in mind.’  (emphasis added)

48.8) In the present case, as pointed out earlier, the plaintiff had also expressly accepted before the Supreme People’s Court that the applicable law was Mainland law.  In other words there was an express submission by the plaintiff of the procedural or jurisdictional issue to the Supreme People’s Court.  Issue etoppel is therefore engaged.

48.9) The case of Baker and others v. Ian McCall International Limited (Toulson J 22/9/99) which followed Desert Sun does not advance the matter further. Likewise for the case of Charles M Willie & Company (Shipping) Ltd v Ocean Laser Shipping Ltd; G Roussos Sons SA and another v Charles M Willie & Company (Shipping) Ltd (The ‘Smaro’) 29 October 1998.

(II)  If there is no issue estoppel, what is the applicable law?

49.This action involves foreign elements and it is necessary to decide what system of law is to be applied.  The Judge having rejected the defence of issue estoppel, went on to hold that the applicable law is Hong Kong law.  It is common ground that the applicable principles are the three stage approach stated by Staughton LJ in Macmillan Inc v. Bishopgate Trust (No. 3) [1996] 1 WLR 387 at 391 :

‘ First, it is necessary to characterise the issue that is before the court. Is it for example about the formal validity of a marriage? Or intestate succession to moveable property? Or interpretation of a contract?

The second stage is to select the rule of conflict of laws which lays down a connecting factor for the issue in question.  Thus the formal validity of a marriage is to be determined, for the most part, by the law of the place where it is celebrated; intestate succession to moveables, by the law of the place where the deceased was domiciled when he died; and the interpretation of a contract, by what is described as its proper law.

Thirdly, it is necessary to identify the system of law which is tied by the connecting factor found in stage two to the issue characterised in stage one.  Sometimes this will present little difficulty, though I suppose that even a marriage may now be celebrated on an international video link.  The choice of the proper law of a contract, on the other hand, may be controversial.’

Characterization before the Judge

50.In the Court below there was dispute between the parties on the characterization of issues and the nature of the applicable law.  The plaintiff characterized the issue as whether the 1st defendant was under a contractual obligation to transfer the shares in FCL to the plaintiff.  The applicable conflict of laws rule to determine this issue is the proper law of the contract. 

51.The defendants, on the other hand, emphasised the proprietary nature of the plaintiff’s claim and characterised the issue as whether the plaintiff acquired any title/ownership to 51% of the FCL shares, as a result of which the plaintiff would be entitled to the proceeds of the FCL shares.  On that basis the applicable rule is the law where the shares are situated (lex situs) : Macmillian Inc at 399F, 404G-H, Re Harvard Securities (Inliquidation) [1997] 2 BCLC 369 and Tripole Trading Ltd & Others v. Prosperfield Ventures Ltd & Another [2006] 1 HKLRD 200 at [86].

The Judge’s view

52.The Judge accepted the plaintiff’s characterization and proceeded to find that the relevant rule was the proper law of the contract and the relevant system of law was Hong Kong law.

Characterization in this Court

53.In this appeal, the defendants argued that there are two characterization issues rather than one in this case, namely, 

1)   the validity of the agreement,

2)   whether the plaintiff has acquired a beneficial interest in the FCL shares by reason of the transaction.

54.The defendants submitted that the reason why there are two issues is because even if the first issue is resolved in favour of the plaintiff in that the contract is valid, it still needs to show that it is entitled to a beneficial interest in the shares.

55.In my view, it is important to bear in mind,

1)   that the issue of validity of contract is generally classified into questions of formal validity and essential validity.  The present dispute is not on the form of the contract or formal validity but on its material validity which is to be governed by the proper law of the contract.  

2)   In considering the issue of the proper law of the contract, European countries have adopted a uniform conflict rules known as the EEC Convention on the Law Applicable to Contractual Obligations (‘the Rome Convention’).  The Rome Convention contained presumptions in ascertaining the proper law of the contract such as the presumption of characteristic performance and the presumption that the contract is most closely connected with the principal place of business of the party who is to effect the characteristic performance.  These presumptions are not available under common law.  In considering the English textbooks on this topic, one must bear in mind that England has incorporated the Rome Convention as part of its domestic law (subject to two reservations) in 1990.  The new law applies to contracts made after 1 April 1991 (see Dicey, (14th Ed) (537)).  To understand the common law position it is necessary to refer to Chapter 32 of the 11th Edition of Dicey

Intention of the parties/closest and most real connection

56.Rule 180 of Dicey, (11th Ed) page 1161, stated that

‘ The term “proper law of a contract” means the system of law by which the parties intended the contract to be governed, or, where their intention is neither expressed nor to be inferred from the circumstances, the system of law with which the transaction has its closest and most real connection.’

57.The Judge referred to In re United Railways of the Havana and Regla Warehouses Ltd [1960] 1 Ch. D. 52 per Jenkins LJ at 91 in ascertaining the relevant factors

‘ In an inquiry as to what is the proper law of a contract in which the parties have not expressed their own selection of the law to be applied, many matters have to be taken into consideration. Of these, the principal are the place of contracting, the place of performance, the places of residence or business of the parties respectively, and the nature and subject-matter of the contract (Dicey, pp 719, 720, citing Falconbridge, Selected Essays on The Conflict of Laws, 2nd ed, p 378). But, as the editor points out, the most satisfactory formulation is that the proper law is the one with which the transaction has its closest and most real connection: (per Viscount Simonds in Bonython v Commonwealth of Australia [1951] AC 201, 219. “The country in which [the contract’s] elements are most densely grouped will represent its natural seat and the law to which in consequence it belongs. It may have factual links with several countries, each of which has some claim to be considered. ... In most cases, however, an examination of these connecting ties will disclose without undue difficulty the country with which the contract is in fact most closely connected and in which it has its natural seat and centre of gravity.” (Cheshire’s Private International Law, 5th ed, p 207.)’ (emphasis added)

My view on applicable law

58.1) I tend to agree with the defendant’s analysis of the issues.  However, even if the characterization of issue is based on contract only as found by the Judge, I do not agree with the Judge’s decision that the applicable law of the contract is Hong Kong law.

Ascertaining proper law of the contract : the approach

58.2) Although the relevant factors to be considered in this exercise include :

(1) The place where the contract was made,

(2) The places of business of the parties,

(3) The contractual place or places of performance,

(4) The nature and subject matter of the contract,

as pointed out earlier in the Havana Railway case, the issue is to identify the place where the transaction has its closest and most real connection.

58.3) The test is that the judge, putting himself in the place of the ‘reasonable man’, determines the proper law for the parties.  He attempts to ascertain not the (non-existent) ‘intention’ of the parties themselves, but ‘how a just and reasonable person would have regarded the problem’, what intention ‘ordinary, reasonable and sensible businessmen would have been likely to have had if their minds had been directed to the question’, and to the contingencies of which the judge is, but the parties may not have been, aware : Dicey, (11th Ed) page 1191-1192.

58.4) The line between the search for the inferred intention and the search for the system of law with which the contract has its closest and most real connection is a fine one which is frequently blurred.  In theory, in the absence of an express choice as the first test, the court should consider as a second test whether there are any other indications of the parties’ intention, and only if there is no such indication to go on to consider the third stage, namely with what system of law the contract has its closest and most real connection.  But in practice the same result can be reached by the application of the second or third tests, and frequently the courts move straight from the first stage to the third stage.  This is largely because the tests of inferred intention and close connection merged into each other, and because before the objective close connection test became fully established the test of inferred intention was in truth an objective test designed not to elicit actual intention but to impute an intention which had not been formed : Dicey, (11th Ed) page 1162-1163.

58.5) In ascertaining the proper law of contract, the Court does not exercise a discretion but makes a finding of fact from the relevant circumstances about the intention of the parties or the system where the contract has it closest and most real connection.  As in any appeal involving any finding of fact, the appellant court will observe the established principle of restraint and will interfere only where there are, for example, misdirections.

58.6) In ascertaining the intention of the parties, their subsequent conduct after the contract was made are not relevant : James Miller & Partners Ltd v. Whitworth Street Estate Ltd [1970] AC 583 at 603 per Lord Reid.

The Judge's reasons

58.7) The Judge referred to the following circumstances in deciding that the applicable law is Hong Kong law :

‘ 76. Ngan is a Macanese. The Plaintiff, COM and Hang Wo are companies incorporated in Macau. The 1st Defendant is a window company of the PRC. It was incorporated in Hong Kong and has its principal place of business and central administration in Hong Kong. Against this background, the fact that the three agreements, in particular the First Laser Agreement, were all entered into in Hong Kong points to a Hong Kong connection.

77. The Plaintiff’s obligation was to pay for the shares and the 1st Defendant’s obligation was to transfer 51% of the shares in FCL and FCO to Ngan’s camp.  Payment of money is not the characteristic performance of the agreement and not indicative of any connection to any jurisdiction.  However, the price was stated in US dollars but paid in Hong Kong currency.  Two significant sums of HK$10 million were received and acknowledged by the 1st Defendant in Hong Kong.  The balance of the purchase price of HK$4.64 million was acknowledged as having been received by the 1st Defendant under the 1998 Memorandum issued from its Hong Kong office.  Those facts are mildly indicative of a Hong Kong connection and are more consistent with a Hong Kong connection than with a PRC connection.

78. The 1st Defendant’s obligation was to transfer the shares in FCO and FCL to Ngan’s camp.  This was the consideration moving from the 1st Defendant to the Plaintiff under the three agreements and for which the Plaintiffs payment of HK$24.64 million was due.  This was the essence of the transaction if not the characteristic performance of the transaction.  This performance was to be effected in the PRC.  Under the three agreements, the parties agreed that they would instruct PRC lawyers to handle the share transfer in the PRC.  Under common law, this points strongly to a PRC connection.

79. However, on the other hand, this essence of the transaction was to be performed by the 1st Defendant, which is a company incorporated in Hong Kong and having its registered office and central administration in Hong Kong.  The directors and shareholders of the 1st Defendant are in Hong Kong and had Hong Kong addresses.  Not only that, the 1st Defendant conducts its business from its office in Shun Tak Centre in Hong Kong.  All the correspondences in relation to this joint venture or the three agreements were emanated from its office in Hong Kong.  Though the Plaintiff may not rely on the presumptions under the Rome Convention, these are facts on which an inference of Hong Kong connection can be drawn.  This inference offsets, if not outweighs, the inference to be drawn from the fact that performance of the First Laser Agreement was to be effected in the PRC.’

Misdirections

58.8) In my view there are misdirections in the decisions.

58.9) The Judge had correctly identified that the Mainland being the place of performance of the 1st defendant’s obligation to transfer the shares in FCO and FCL to Mr. Ngan’s camp pointed strongly to a Mainland connection.  This view is clearly supported by authorities such as Benaim & Co v. L. S. Debono [1924] AC 514, 520; The Assunzione [1954] P 150 and Bank of India v. Gobindram N Sadhwani [1988] 2 HKLR 262, 268.  Benjamin’s Sale of Goods 7th Ed, paragraph 25—009 summarised the position :

‘ Thus, where the parties to the contract of sale had their place of business in the same country, that country’s law had a strong claim to be the proper law of the contract by way of implied choice of the parties. If there was no single country where the parties both carried on business or if there was some good reason for thinking that the law of such a country was not impliedly intended to be the proper law, the law of any country where all, or a significant portion, of the obligations imposed by the contract, were to be performed had a claim to be the proper law.’ (emphasis added)

58.10) As explained by Lord Esher MR in Chatenay v. Brazilian Submarine Telegraph Company (1890) 1 QB 79 at 83, the rationale of this factor is that if a contract is made in one country to be carried out between the parties in another country, either in whole or in part, unless there appears something to the contrary, it is to be concluded that the parties must have intended that it should be carried out according to the law of that other country.  Otherwise a very strange state of things would arise, for it is hardly conceivable that persons should enter into a contract to be carried out in a country contrary to the laws of that country.  Goode on Commercial Law,page 925 thus stated :

‘ Nevertheless, certain factors do tend to be given particular weight relative to others. The place of intended performance of the contract (lex loci solutionis) is obviously of major importance, for the ability to perform a contract within a given State largely depends on the willingness of the law of that State to accommodate such performance, so that the lex loci solutionis prima facie has a close connection with the contract.’ (emphasis added)

58.11) The Judge, however, then lessened or diluted the importance of this factor by saying that the 1st defendant who was to perform this essential part of the obligation in the Mainland was a resident of Hong Kong.  This is wrong for two reasons :

(1) First, the Judge had already at the beginning of the analysis taken into account the fact that the 1st defendant was incorporated in Hong Kong and has its principal place of business and central administration in Hong Kong.  By referring to the residence of the 1st defendant again, it gives the impression that he was considering this factor twice.

(2) Second, not only was he considering this factor twice, he had attached undue weight to this factor.  The Judge held that although the plaintiff may not rely on the presumptions under the Rome Convention, he further said that these are facts on which an inference of Hong Kong connection can be drawn.  He said at paragraph 75 of the judgment :

‘…it should be noted that under the Rome Convention there are certain presumptions, such as presumption of characteristic performance and presumption that the contract is most closely connected with the principal place of business of the party who is to effect the characteristic performance. While those presumptions are not available under the common law, inferences as to connection may nevertheless be drawn from those factors. It is just a question of weight.’ (emphasis added)

58.12) The relevant presumption is Article 4 of the Rome Convention which Dicey (14th Ed) dealt with in Rule 204(3) :

‘ (3) It will be presumed that the contract is most closely connected with the country where the party who is to effect the performance which is characteristic of the contract has, at the time of conclusion of the contract, his habitual residence, or, in the case of a body corporate or unincorporate, its central administration. If the contract is entered into in the course of the trade or profession of the party who is to effect the performance which is characteristic of the contract, the country with which the contract will be presumed to be most closely connected will be the country in which the principal place of business of that party is situated, or where, under the terms of the contract the performance is to be effected through a place of business other than the principal place of business, the country in which that other place of business is situated.’

58.13) Dicey, (14th Ed) observed at paragraph 32—113 that

‘ The innovative aspect of Art.4 is the use of a presumption based on the place of residence or business of the person effecting the performance which is characteristic of the contract. It is important to note that the presumption leads not to the place of characteristic performance, but to the residence, or central administration, or principal place of business, or other place of business (as the case may be) of the party who is to effect the characteristic performance.’ (emphasis added)

58.14) This presumption, however, proceeds on the basis that the place of performance of the obligation is also the same as the place of residence of the performer.  As explained by Dicey (14th Ed) at paragraph 32—118 :

In practice the place of performance and the place of residence or business will often (but not necessarily) be the same, because most contracts are performed in the country of the party’s place of business. The contract is presumed to be most closely connected with the country of the residence of the individual, or (in the case of a company or partnership) the country of its central administration.’ (emphasis added)

58.15) However, Article 4(5) also provides that, among other things, this presumption can be disregarded if it appears from the circumstances as a whole that the contract is more closely connected with another country.  This is stated in Rule 204(4) of Dicey (14th Ed) which provides that,

‘ (4) the presumptions in clause (3) will not apply if the characteristic performance cannot be determined, and will be disregarded if it appears from the circumstances as a whole that the contract is more closely connected with another country.’

58.16) It is clear that one situation where this presumption is to be discarded is where the place of performance differs from the place of business or place of residence of the party whose performance is characteristic of the contract.  Hence Dicey, (14th Ed) at paragraph 32—127 stated that,

‘ Inevitably the solution of individual cases will depend on the facts, but in principle it is submitted that the presumption may most easily be rebutted in those cases where the place of performance differs from the place of business of the party whose performance is characteristic of the contract. It has already been seen that the presumption is designed to lead to the country of the residence or place of business of the party whose performance is characteristic, and that usually that country will coincide with the place of performance, because normally contracts are performed in the country of that party’s place of business. The situations in which they are performed elsewhere may (but by no means inevitably) provide material to rebut the presumption.’ (emphasis added)

58.17) Footnote 23 to the first passage of paragraph 32—127, stated that :-

‘ This passage was approved in Bank of Baroda v Vysya Bank Ltd [1994] 2 Lloyd’s Rep. 87, 93. See also Samcrete Egypt Engineers and Contracrtors SAE v Land Rover Exports Ltd [2002] EWCA Civ. 2019, [2002] C.L.C. 533, [43]; Marconi Communications International Ltd v PT Pan Indonesia Bank Ltd [2005] EWCA Civ. 422, [2005] 2 All E.R. (Comm.) 325.’

58.18) When the Judge said that instead of relying on the presumption, he could draw inference from the facts which underlines the presumption, he must have attached importance to such facts.  In my view, before he was able to do so the Judge also ought to have recognized the situation where the presumption is to be disregarded.  Such a recognition is particularly important in this case because the place of business or residence of the 1st defendant which was Hong Kong, was different from the place of performance of the characteristic obligation i.e. the transfer of the FCL shares which was to be performed in the Mainland.  This difference will cause the presumption to be replaced.  What the Judge had done was to draw inference from facts, which, in the absence of the presumption, do not lay claim to the proper law of the contract.  In so doing he must have attached wrong or undue weight to the place of residence of the 1st defendant i.e. Hong Kong.  This is because, as said earlier, where the parties to the contract had their place of business in the same country this can be regarded as a strong factor, the same cannot be said when they reside in different places.  In such a situation, under common law,the law of a country, where all, or a significant portion, of the obligations imposed by the contract, are to be performed has a claim to be the proper law.  In the present case such law is the Mainland law.  The strength of this connection is not answered by the plaintiff’s contention that there are also authorities which attached importance to the place of residence of the parties.

58.19) The Judge’s reference to the correspondence being issued from Hong Kong infringes the rule that conduct subsequent to the entering of the contract cannot be taken into account. 

58.20) The place of performance of the agreement was the transfer of shares of a Mainland company; the shares were ‘state assets’ belonging to the window company of a Mainland provincial government; the transfer of which would require approval of the Mainland authority; Mr. Ngan was aware of such circumstances; and the parties expressly agreed to engage Mainland lawyers to handle the transfer.  They all pointed towards Mainland law to be the proper law of the contract which should not be lessened by the other factors referred to by the Judge.

58.21) The signing of the contract in Hong Kong, while being a factor to be taken into account, does not support the finding that Hong Kong law is the proper law. It is indeed fortuitous that the agreements were signed in Hong Kongas submitted by Mr. Benjamin Yu S.C. (who appeared with Mr. Paul Shieh S.C. and Mr. Law Man Chung as counsel for the defendants).

58.22) The Judge also referred to the background of the case where internal correspondence of the 1st defendant to the Fujian government (Report dated 5 June 1997) showed that the 1st defendant desired to relocate part of the operation of FCL in the Mainland to Macau in order to avoid problems over intellectual property rights with FRIMS.  The report stated that :-

‘ According to the Sino British Joint Declaration, the Sino Portuguese Joint Declaration, the Hong Kong Basic Law and Macau Basic Law, after the return of their sovereignty to the PRC, Hong Kong and Macau have independent judicial status.’

58.23) The Judge held that :-

‘ The 1st Defendant’s intention to rely on the separate judicial and legal system in Macau and Hong Kong was clear. So too was its intention that the three agreements shall operate outside the PRC. The parties were clearly distancing themselves from the PRC. This also points very strongly to a Hong Kong connection than a PRC connection.’

58.24) In my view the Judge had not properly recognized that the subject matter of the contract was the sale of the shares and not the operation of FCL.  The 1st defendant’s desire to resort to judicial systems outside the Mainland was to address the dispute with FRIMS and not an indication of its or the parties’ wish to distance themselves from the Mainland in respect of the present transaction.

Title to the shares

58.25) Further the plaintiff is not merely seeking damages under contract but is also asserting a proprietary claim to the shares as well.  This is reflected in the order made by the Judge where he held 51% of the shares in FCL belonged beneficially to the plaintiff.  It has not been seriously disputed that the issue of beneficial interest in shares is determined by the law where the shares are situated (lex situs).  This is reaffirmed by the Court of Final Appeal in Tripole Trading Ltd & Ohters v. Prosperfield Ventures Ltd & Another [2006] 1 HKLRD 200 at paragraph 86.  The FCL shares are situated in the Mainland.  In the circumstances under this limb the applicable law is also Mainland law.

Mainland law applies

58.26) To conclude on this part, the proper law under both characterization is Mainland law rather than Hong Kong law.

(III) Consequence if proper law is Mainland law

59.Because of the Judge’s decision that the proper law of the contract was Hong Kong law, he dealt with the consequence arising therefrom only in the context of Hong Kong law.  As a result this Court is handicapped in addressing fully the consequence in the context of Mainland law because of the absence of findings on this issue.

Contract invalidand the result

60.If Mainland law was the proper law of the contract, then the expert evidence clearly showed that the contract was invalid.  The contract was invalid by reason of FCL not having obtained approval to dispose of its shares.  Under Mainland law, the innocent party is entitled to two remedies :

(1) Restitution : the parties will be restored (返還) to their pre-contract position.

(2) Compensation : the party at fault (過錯) is liable to pay compensation to the other party

Restitution

61.In respect of restitution the defendants have indicated both in the Court below and in this Court that they are prepared to make restitution.  In this Court, the defendants openly stated that it will return HK$20 million being the amount paid by the plaintiff to the 1st defendant with interest and will forego the return of FCO shares and dividends declared or paid by FCO.  The plaintiff has not responded to the open offer.  If this offer is accepted, then there will be a judgment on such terms for the plaintiff.  If not, the issue of restitution must be remitted to the Court of First Instance for determination under Mainland Law.

Compensation

62.The Judge, on the basis that the proper law was Hong Kong law, found that under the Mainland statutory provisions the obligation to procure the necessary approval for transfer of the FCL shares was on FCL and not the 1st defendant.  However, he went on to hold that the 1st defendant was at fault (again on the basis of Hong Kong law) in not causing FCL to obtain approval.  He decided this issuein the plaintiff’s favour and held that the 1st defendant was liable to pay compensation to the plaintiff in the amount of US$30 million. 

Basis of decision

63.The Judge found the 1st defendant was at fault because there was an implied term of the contract that since ‘the 1st defendant is the sole shareholder who had control and management of FCL, it goes without saying that the 1st defendant will procure the approval’.  The Judge further held that :

‘There is no evidence from the 1st Defendant that it has discharged or attempted to discharge or otherwise frustrated from discharging the burden of procuring the approval such that it may be excused from transferring the shares in FCL.’

64.Proceeding on that basis the Judge held that, under Hong Kong law, the 1st defendant was in breach of the contract.  He went on to hold that :-

‘ 111. ….when the 1st Defendant entered into agreement to sell its shares in FCL to JDS, it evinced an intention no longer to be bound by the First Laser Agreement. The Plaintiff is entitled to accept that breach and to treat the date of sale to JDS under that agreement as the date of the 1st Defendant’s breach of the First Laser Agreement….. The Plaintiff’s loss and damage was to be assessed as at that date. ……that the price of sale is the best evidence of the market price of the share at the time of breach. The purchase price having been fully paid by the Plaintiff, the Plaintiff is entitled to 51% of the total consideration of the sale to JDS, i.e. US$30.6 million.’

65.It should be noted that the parties in the Court below had not argued the case of implied term at all.  The Judge took up this issue himself.  Since the Judge made this award under Hong Kong law which I find to be wrong, this award would have to be set aside.  In any event the plaintiff in the Court below elected to proceed by way of proprietary remedies instead of damages.

Is the plaintiff entitled to compensation under Mainland law?

66.In this Court, the plaintiff, by way of an amendment to the respondent’s notice, argued that the Judge ought to have held also that the plaintiff is entitled to compensation under Mainland law as well. Specifically the plaintiff argued that the fault of the 1st defendant lay in disposing of the FCL shares to JDS thereby preventing approval for the transfer of the FCL shares to the plaintiff.

67.This Court allowed this issue to be argued because as pointed out in the Ruling of this Court dated 8 July 2010 both parties had argued this issue before the Judge on the basis that under Mainland law, the plaintiff was entitled to compensation although the Judge made no decision on this issue specifically under Mainland law.

Absence of finding of fault

68.In my view, this Court is not in a position to make a determination on this topic.  First, because the Judge had not made a finding on this issue under Mainland law.  Second, to deal with this issue will require the Court to examine not only the reports of the Mainland law experts but also their oral evidence concerning the responsibility of the 1st defendant which controlled FCL. Third, there are fundamental factual issues to be resolved first, for example, who were actually in control of the 1st defendant; did the parties form a committee to deal with the transfer; would the authority approve of the transfer since it had already approved the FCO transfer?  This Court is not in a position at this stage to address this issue properly.

Should compensation be remitted?

69.However, even if, for the purpose of argument, under Mainland law the 1st defendant was at fault, I still do not see the need to remit the issue of compensation to the Court below for determination.  The only compensation which the plaintiff has sought to recover is based on constructive trust, namely, the disgorgement of profit received by the 1st defendant on the disposal of FCK shares.  As will appear in the following discussion I have found that the plaintiff is not entitled to such profit.  This being the case, it is futile to remit the issue of compensation to the court below.

Constructive trust

70.As pointed out at the beginning of the judgment, the Judge granted equitable relief to the plaintiff.  This was done on the basis that Hong Kong law is the applicable law. The plaintiff had accepted that it is not its case that if the Mainland law was the applicable law and the agreement was invalid under such law, a constructive trust can still arise.  But it also contends in this Court that it is entitled in any event to equitable remedies such as taking of account and tracing by reason of the 1st defendant being a constructive trustee.  Although the applicable law is Mainland law, the trust arises not under Mainland law but by virtue of the remedies available under Hong Kong law by reference to the principles stated in the line of cases represented by Kuwait Oil Tanker Co SAK and another v. Al Bader and others(‘KOT’) [2000] 2 All ER (Comm) 271.

Defendants to disgorge benefit?

71.1) The starting point of this discussion is Dicey’s (14th Ed) Rule 230

‘ Rule 230 — (1) The obligation to restore the benefit of an enrichment obtained at another person’s expense is governed by the proper law of the obligation.

(2) The proper law of the obligation is (semble) determined as follows:

(a) If the obligation arises in connection with a contract, its proper law is the law applicable to the contract;

……’

71.2) At paragraph 34—049 Dicey, (14th Ed)further stated that :-

‘ Similarly, if it is argued that a defendant, who in a domestic case would be required to hold property on constructive trust, is nevertheless not liable, on the ground that the law of the place of the enrichment, or other lex causae, does not recognise the principles of constructive trusteeship, the argument is misconceived. The appropriate analysis is to ask whether, under the lex causae, the defendant owes obligations which would impose on him under that law a liability to disgorge a benefit. If so, an English court may hold him liable as constructive trustee when giving remedial effect to the substantive right arising under the lex causae.’ (emphasis added)

KOT and Arab Monetary Fund

71.3) Nourse LJ in KOT referred to the judgment of Chadwick J in Arab Monetary Fund v. Hashim (No. 9) (15 June 1994, unreported)

‘ In the context of a claim to invoke its equitable jurisdiction it is for the English court to decide whether the necessary fiduciary relationship exists. Where the duties to which a relationship gives rise are determined by foreign law, the question for the foreign law is what is the nature of those duties. It is for the English court to decide whether duties of that nature are to be regarded as fiduciary.

I find nothing in the rule which is inconsistent with the view that, in cases involving a foreign element in which an English court is asked to treat a defendant as a constructive trustee of assets which he has acquired through; misuse of his powers, the relevant questions are: (i) what is the proper law which governs the relationship between the defendant and the person for whose benefit those powers have been conferred; (ii) what, under that law, are the duties to which the defendant is subject in relation to those powers, (iii) is the nature of those duties such that they would be regarded by an English court as fiduciary duties and (iv), if so, is it unconscionable for the defendant to retain those assets.’

71.4) Nourse LJ then held that,

‘ In the present case the answers to Chadwick J’s four questions are the following: (i) the proper law which governed the relationship between the defendants and the claimants was the law of Kuwait; (ii) the duties imposed on the defendants by arts 264 and 267 of the 1980 Civil Code were to make restitution in respect of the sums misapplied by them respectively; (iii) the nature of those duties was such that they would be regarded by an English court as fiduciary duties; and (iv) it would be unconscionable for the defendants to retain the funds. We accordingly hold that the claimants’ alternative case is made out.’

71.5) In order to properly understand the decision in KOT that the nature of duties of restitution imposed by Kuwaiti law is to be regarded as fiduciary duties by English court, one must refer to the evidence that was adduced in that case.  This can be found at paragraph 191 of the judgment

‘191. Although the concept of a trust is unknown to Kuwaiti law, both Dr. Hoyle and Professor Ballantyne agreed that arts 264 and 267 of the 1980 Civil Code (see above) imposed on each of the defendants an obligation to make restitution to the claimants in respect of the funds misapplied by him. On that footing the judge followed the decision of Chadwick J in Arab Monetary Fund v Hashim (15 June 1994, unreported), which has since itself been followed by Mance J in Grupo Torras SA v Sheikh Fahad Mohammed Al Sabah, Fouad Khaled Jaffar v Grupo Torras SA (24 June 1999, unreported), and held that the restitutionary obligation under Kuwaiti law could be characterised as fiduciary in character by English law and thus capable of supporting the equitable remedies in personam which would be available to the claimants in an English court.’

Applying KOT to the present case

71.6) In the present case, the plaintiff, in order to succeed on this topic, must demonstrate that the Mainland law (which is the proper law of the contract or the proper law of the obligation) requires the defendants to disgorge the benefit it received from the disposal of the FCL shares. 

71.7) Although Mr. Bai (the defendant’s expert) in his report of 7 July 2005 stated that under Mainland law the plaintiff and the 1st defendant did not have any trust legal relationship, Professor Wang (the plaintiff’s expert) in his report dated 12 January 2006 stated that Mr. Bai’s statement could easily have caused confusion in Hong Kong which applied the common law; the legal term ‘trust’ has a great difference in the different context of Mainland law and common law; although under Mainland law, the act of infringing the property given by another person is not directly labeled as breach of the duty of trust, the carrying out of such an act is nonetheless required to assume civil liability, for example, to assume the responsibility of compensation. 

71.8) There is no finding by the Judge on this issue raised in the expert evidence.  However, there are further hurdles for the  plaintiff to overcome.

Institutional and Remedial Constructive Trust

71.9) Snell’s Equity, 31st Ed, paragraph 24—09 discussed the difference between institutional constructive trust and remedial constructive trust :

‘ In England, the constructive trust has in general been regarded as a substantive institution rather than a remedy. The distinction between these two explanations of the trust is uncertain, owing to a lack of clear definition of the terms used. The commonly accepted distinction is that an institutional constructive trust arises independently of any court order, once the facts on which the creation of the trust depends have occurred. The function of the court is merely to declare its prior existence. A constructive trust would be remedial if it depended on an order of the court for its creation. It might lie in the discretion of the court to determine its existence and the extent to which the equitable interest of the claimant under the trust should take priority over the interests of third parties.

At one time it was thought that a constructive trust might be used as a remedy and be “imposed by law whenever justice and good conscience require it”. ….. More recent authorities, however, make it unlikely that this approach will be followed.  The courts have affirmed that general formulae such as inequitability and the prevention of unconscionable conduct may not be used as tests for the imposition of a trust.  For the present at least, this appears to preclude the recognition of the remedial constructive trust in English law.’

71.10) The defendants argued that the trusteeship arising from existence of a specifically enforceable contract is an institutional trust as distinguished from a remedial constructive trust.  The existence of such a trust must be founded on a valid and enforceable contract – which is absent here.  They argued that as a result, remedial constructive trust is not available to the plaintiff as a matter of law.

71.11) While I tend to accept the defendant’s submission on this point, in my view, in the absence of argument of how the difference of these two concepts may impact on KOT, I am not prepared to hold on this ground alone that the plaintiff’s claim for equitable remedy is precluded.

Requirement of specific performance

71.12) However, a more fundamental problem on the availability of equitable remedy under the KOT approach is the absence of a specifically enforceable contract.  These two topics must be viewed together since they are an integral part of the equitable remedy.

72.In this Court it is submitted by the defendants that if the applicable law on the plaintiff’s proprietary claim could only subsist if it were Hong Kong law, the Judge erred in holding that the plaintiff had acquired a beneficial interest in the FCL shares.  It did not acquire such an interest because specific performance of the First Laser Agreement (insofar as the transfer of the FCL shares are concerned) could not have been decreed due to the lack of required approval under the statutory provisions of the Mainland.  The defendants relied on Howard v. Miller [1915] AC 318 and Okachi (Hong Kong) Co. Ltd. v. Nominee (Holding) Ltd [2007] 1 HKLRD 55.

73.The requirement of specific performance to constitute the trust is well established.  In Okachithe position is summarised as follows :

‘ 95. What is more important is that the principle of equity is based on the requirement of specific performance. The often cited passage of Sir George Jessel MR in Lysaght v Edwards (1875-76) LR 2 Ch D 499 is that:

... the moment you have a valid contract for sale the vendor becomes in equity a trustee for the purchaser of the estate sold, and the beneficial ownership passes to the purchaser.

But as Lord Parker of Waddington said in Howard v Miller & Another [1915] AC 318 at p.326:

It is sometimes said that under a contract for the sale of an interest in land the vendor becomes a trustee for the purchaser of the interest contracted to be sold ... but however useful such a statement may be as illustrating a general principle of equity, it is only true if and so far as a Court of Equity would under all the circumstances of the case grant specific performance of the contract.

Degeling and Edelman in Equity in Commercial Law at ch.18, p.465 stated that:

If, for whatever reason, specific performance will not issue, no trust will arise.  So, for example, if I agree to sell you a parcel of shares in a public company, you will not have the benefit of a trust, for shares in a public company are not unique, an award of expectation damages generally being an adequate response to any breach on my part of the contract of sale.  But if I contract to sell you shares in a private company, for which there is no market, such a contract is specifically enforceable and you will have the benefit of a trust in your favour.

Finally, it should be noted that the trust in no way depends on the purchase money having been paid.  However, if it has not, the vendor has an equitable lien for the purchase price over the right contracted to be sold.

96. The short point I wish to make is that the Agreement is not capable of specific performance because the Agreement requires the defendant to fulfill its obligations of application to the SFC and the HKFE in the first place and the Scheme expressly provided for the deadline for the transfer to be approved.  The deadline had long gone.  This case illustrates most vividly the operation of the qualification to the Lysaght v Edwards principle in terms of the requirement for specific performance.’

The plaintiff’s position : equity in personam

74.The plaintiff’s case on constructive trust is by reason of the 1st defendant being the vendor of the FCL shares.  The plaintiff’s beneficial interest arose from the agreement.  The plaintiff took the points that,

(1) assuming that transfer of legal title requires application and approval, once there is application and approval for transfer of legal title, then the 51% FCL shares can be transferred to the plaintiff.  In the present case impossibility to carry out the transfer happened when the shares were transferred to JDS.  But the defendants have not pleaded nor proved any impossibility to obtain approval before the transfer to JDS.  The only case run by the defendants below was that the agreement was invalid.

(2) even if the defendants are allowed to plead the matter, there is no evidence of impossibility.  The defendants had never relied on impossibility of obtaining approval in their negotiations.  On the contrary, since the change of management of the 1st defendant, they wished to re-negotiate the percentage holding instead of honouring the agreement and thus never tried to obtain approval for the transfer.

(3) even if approval is impossible so that no legal title can be transferred, that does not mean the contract is impossible to be performed by the 1st defendant.  As equity acts in personam, Hong Kong will compel recognition by the defendants of the plaintiff’s beneficial interest.

75.The plaintiff relied on the following cases :

(1.1) Lightning and Another v. Lightning Electrical Contractors Ltd and Others [1998] EWHC Admin 431.  A company controlled by L bought property in Scotland.  L provided the purchase price. The company charged the property to a bank.  In Scotland there was no presumption of resulting trust.  L commenced action in England seeking a declaration that the property or the proceeds of sale were held on a resulting, alternatively constructive trust for L.

(1.2) Peter Gibson LJ held that :

‘ 18. The fact that a dispute relates to foreign land or involves interests in foreign land, which a court of equity in this country recognises, but the courts of the foreign land would not, has never been a bar to the English court exercising jurisdiction over a person amenable to the jurisdiction, for example by being present in England. As was stated by the Earl of Selborne L.C in Ewing v Orr Ewing (1883) L.R. 9 H.L. 34 at page 40:

“The Courts of Equity in England are, and have always been, courts of conscience, operating in personam and not in rem; and in the exercise of this personal jurisdiction they have always been accustomed to compel the performance of contracts and trusts as to subjects which were not either locally or ratione domicili within their jurisdiction. They have done so as to land, in Scotland, in Ireland, in the Colonies, in foreign countries: Penn –v– Baltimore 1 Ves Sen 444.”

19. In Deschamps –v– Miller [1908] 1 Ch 856 at page 863, Parker J described the obligation which the Court will enforce as depending:

“…on the existence between the parties to the suit of some personal obligation arising out of contract or implied contract, fiduciary relationship or fraud, or other conduct which, in a view of the Court of Equity in this country, would be unconscionable, and do not depend for their existence on the law of the locus of the immovable property.” ’

(1.3) Millett LJ held that :

‘ 34……. If A provides money to B, both being resident in England, to purchase landed property in his own name but for and on A’s behalf, and B does so, the consequences of that transaction are governed by English law. It would be absurd if they were governed by the law of the place where the property in question happened to be located.’

(2) Chattey and another v. Farndale Holdings Inc and others [1997] 1 EGLR 153.  A purchaser signed a contract with a company to take up a subunderlease of a flat.  The contract was conditional upon planning permission being given.  Permission was later given.  The chargee of the superior lessor later sold the flat.  The purchaser sought the return of deposits paid under the contract on the ground that he had a lien on the property to protect the deposit, alternatively there was a constructive trust.  It was held that the circumstances in which a purchaser’s lien will arise are not limited to those in which the contract is or has been specifically enforceable, but include those in which there is or has been a right to call for the legal estate whether presently, in the future or conditionally so as to give rise to an equitable interest or estate.

(3.1) In Michaels v. Harley House Ltd [2000] Ch. 104, the facts are rather complex.  Robert Walker LJ (as he then was) at 113 stated the following principle :

‘ ……a contract for the sale of shares (at any rate in a company whose shares are not quoted and readily obtainable on the market) is, like a contract for the sale of land, at first sight enforceable by specific performance; and that the effect of specific performance being available is to make the vendor under an uncompleted contract of sale a trustee of some sort for the purchaser.’

(3.2) The conditionality of a contract may prevent a trusteeship from arising.  Robert Walker LJ at 116 accepted that there is a difference

‘ between a true condition precedent which it is not within a contracting party’s power to bring about, even though he may undertake to use his best endeavours to bring it about, and a promissory condition which the party does have power to fulfil or to cause to be fulfilled.’

(4) In Whitbread & Co., Limited v. Watt [1902] 1 Ch. 835, it was held that the purchaser of real estate has a lien on the property for his deposit when the contract for purchase is determined without any default on his part, not only when it is determined by reason of the default of the vendor.

(5) In re Smith Lawrence v. Kitson [1916] 2 Ch 206, a testator in consideration of money owing by him to his sisters, charged all his shares and interest in an estate in Dominica, West Indies to secure the repayment of the money.  Eve J at 209 adopted the approach of Cozens-Hardy MR in British South Africa Co. v. De Beers Consolidated Mines [1910] 2 Ch. 502 that,

‘ In my opinion an English contract to give a mortgage on foreign land, although the mortgage has to be perfected according to the lex situs, is a contract to give a mortgage which —inter partes—is to be treated as an English mortgage and subject to such rights of redemption and such equities as the law of England regards as necessarily incident to a mortgage.’

(6.1) In re The Anchor Line (Henderson Brothers) Limited [1937] 1 Ch 483, an English company granted a debenture over its assets situated in, among other places, Scotland.  The argument was that the instrument was unenforceable in Scotland because it was unenforceable under Scottish law since no step was taken for the purpose of reducing into possession before winding up any of the property realized.

(6.2) Luxmoore J at 487 and 488 held that

‘ … It was given by an English company and although it was executed in Scotland it must I think be construed according to English law.

When an English company possesses land abroad and purports to charge it by way of floating charge, the charge, putting it at its lowest, amounts to an agreement to charge that land, and is a valid equitable security according to English law. ….

…  The law on this point is correctly stated by Sir Francis Palmer in the 5th edition of Company Law at p. 236 :

“Even without complying with the formalities required by the local law in relation to transfers or mortgages, it is competent to a company to create an effective charge on property belonging to it in a foreign country, for the Court, in virtue of its Chancery jurisdiction in personam, enforces equities in regard to foreign land where the mortgagor company is within the jurisdiction…… and in determining whether there is an equity the Court regards English, not foreign law, and if according to English law there is an equity, e.g., if for valuable consideration a company agrees to give a charge on foreign property, the court will enforce it, although the equity may be one not recognized by the lex loci rei sitae.” ’ (emphasis added)

(7) In Webb v. Webb [1991] 1 WLR 1410, the defendant purchased a property in France which his father (the plaintiff) claimed was acquired by the defendant by funds provided by him.  The father sought a declaration that the defendant held the property on trust for him.  Judge Baker Q.C., at 1418 after referring to the Report by Professor Schlosser on the European Convention on Jurisdiction and the Enforcement of Judgments in Civil and Commercial Matters 1968 held that,

‘ Indeed it reflects the ancient equitable jurisdiction expressed by the maxim that equity acts in personam. One of the principal applications of that maxim is in relation to the court’s jurisdiction over property abroad as exemplified in Penn v. Lord Baltimore (1750) 1 Ves. 444, and in many subsequent cases. Where there is a defendant within the court’s jurisdiction, and there exists some relationship between him and the plaintiff arising out of contract, trust or fraud or other fiduciary bond, the court may make an order directed to the defendant to perform his contract, carry out his fiduciary duties or undo the effects of his fraud. Through the relationship, the defendant’s conscience is affected and bound. The sanctions for failure to carry out the order are commitment for contempt and sequestration of any assets of his to be found within the jurisdiction. It is no objection that the order relates to land abroad, save only this, that the order will not be made if the carrying of it out is illegal or impossible according to the lex situs. In Penn v. Lord Baltimore the parties had entered into articles of agreement as to the settlement of the boundaries between the two American states of Pennsylvania and Maryland. A decree of specific performance of the articles of agreement was made.’ (emphasis added)

(8) In Martin v. Secretary of State for Works and Pensions [2009] EWCA Civ 1289, the claimant acquired property in his name in France with funds provided by V.  The claimant did not disclose this to the relevant department which paid income support supplement to the claimant.  The department sought the return of overpayment.  Dispute arose on what was the proper law to determine the existence of the putative implied trust.  Mummery LJ held that :

‘ 29. First, the common law principles. The Commissioner rightly rejected Mr Croally’s [counsel for the claimant] reliance on Webb and Lightning as determining the applicable law issue. Those cases are clear authority binding on this court for the proposition that, at common law, even if the subject matter is foreign immovable property, English law may be the law applicable to the question whether there is an implied trust of that property. However, on the particular facts of those cases, it was plain that English law was the law applicable to the relationship between the people concerned and their property arrangements. Thus in Lightning, in which English law and the law of implied trusts were held to apply to the purchase of land in Scotland, the facts were that, apart from the provision of money for the purchase of property in Scotland, there was nothing to connect Scottish law with the parties concerned, their relationship or their arrangements. English law was obviously the law with which the putative trust was most closely connected. Similarly in Webb the only connecting factor with French law was the situs of the property purchased.’

My view

76.1) It is inevitable that one must pay regard to the important requirement that the validity or enforceability (to use a neutral term) of the contract depends on a fulfilment of a condition, namely, approval being given by the relevant authority.  The non fulfilment of this condition will render the contract “of no effect”, invalid or unenforceable and specific performance will not be decreed.

76.2) As apparent from the cases, even when Courts exercised the equity jurisdiction in personam, it does not mean they would ignore the fact where the equitable relationship no longer existed.  The statements by Luxmoore J in In re The Anchor Line that ‘a valid equitable security according to English law’ and Judge Baker that ‘the order will not be made if the carrying out of it is illegal or impossible according to the lex situs’ in Webb underlined the requirement of a relationship which gives rise to equity.

76.3) Where the equity has been destroyed, the claimant is no longer able to invoke the personam jurisdiction which is based on that equity.  Peter Gibson LJ observed in Lightning,

‘ 23. … it seems to me implicit that the English court not unnaturally regarded English law as applicable to the relationship between the parties before it in the absence of any event governed by the lex situs destructive of the equitable interest being asserted.

24. As is pointed by Millett LJ when sitting at first instance at Macmillan Inc v Bishopsgate Trust (No 3) [1995] 1 WLR 978 at page 989 (commenting on Norris v Chambres(1891) 29 Beavan, 246, affirmed 3 De Gex Fisher and Jones 583), where a plaintiff invokes the in personam jurisdiction of the English court against a defendant amenable to the jurisdiction and there is an equity between the parties which the court can enforce, the English court will accept jurisdiction and apply English law as the applicable law, even though the suit relates to foreign land.  In contrast if the equity which is asserted does not exist between the parties to the English litigation, for example where there has been a transfer of the property to a third party with notice of an equity but by the lex situs governing the transfer, the transfer extinguished the plaintiff’s equity, the English court could not then give relief against the third party even though he is within the jurisdiction.’ (emphasis added)

76.4) In the present case, since the contract was “of no effect”, invalid or unenforceable because the condition has not been fulfilled, this means that the equity has been destroyed or does not exist between the parties and as a result Hong Kong Court could not give relief to it.

76.5) Insofar as the plaintiff relied on cases based on a trusteeship or lien arising from payment of the purchase price (In Whitbread and Chattey) it is important to distinguish them from a trusteeship which arises from the existence of a specifically enforceable contract between vendor and purchaser.  Megarry and Wade on The Law of Real Property 7th Ed at 15—054 stated that :-

‘ 3. Nature of trusteeship. It is necessary to distinguish the trusteeship that arises from the existence of a specifically enforceable contract between vendor and purchaser and the trust or lien that arises from a payment of some or all of the purchase price by the purchaser: “A purchaser who enters into a specifically enforceable contract for the sale of land acquires an equitable interest in the land and retains that interest for as long as the contract remains enforceable……” ’ (emphasis added)

76.6) In respect of the trust from a specifically enforceable contract, the authorities clearly established that it must be unconditional. As Nourse LJ observed in J Sainsbury Plc. v. O’Connor (Inspector of Taxes) [1991] 1 WLR 963 at 979

‘ Then take the previous example, but suppose that the contract is subject to a condition precedent. Until the condition is satisfied the equitable interest in the shares will not pass to company C. It will remain in company A. What ground is there for thinking that the beneficial ownership of the shares will not also remain in company A? In order to answer that question we must look to Wood Preservation Ltd. v. Prior [1969] 1 W.L.R. 1077. That is a difficult decision. Goff J. at first instance did not distinguish between the beneficial ownership of the shares and the equitable interest in them. In my view he was right not to make that distinction. However, he thought that, because the purchaser could obtain specific performance of the contract by waiving the condition precedent at any time, “the beneficial interest had sufficiently passed to the purchaser.” I respectfully think that that was an error on the part of the judge. Unless and until the condition was either waived or satisfied there could be no right to specific performance and no passing of the equitable interest.’ (emphasis added)

76.7) In fact the principle that the conditionality of a contract precludes specific performance is expressly recognized after J Sainbury plc in cases such as Michaels and Chattey.  Lewin on Trust 18th Ed at paragraph 10—05 accepted this principle :

‘The trusteeship depends on the availability of specific performance, a remedy to which the buyer will ordinarily be entitled to enforce a contract for the sale of land. If, however, the contract is conditional and the condition has not yet been fulfilled, specific performance is not available and the beneficial ownership has not passed to the purchaser. (But a contract is not conditional in the relevant sense if fulfilment of the supposed condition is within the control of a contracting party.)’

76.8) Michaels recognized (as in Lewin) that there is a distinction between a true condition precedent which it is not within a contracting party’s power to bring about, even though he may undertake to use his best endeavours to bring it about, and a promissory condition which the party does have power to fulfil or to cause to be fulfilled.  However this will not assist the plaintiff in the present case because even if, for the purpose of argument, the 1st defendant controlled FCL and could have applied for approval on its behalf, the ultimate decision whether to grant approval or not did not rest with the 1st defendant but with the relevant approving authority.  The argument that the 1st defendant controls FCL will not assist the plaintiff.

76.9) The difficulty is not answered by the contention that the 1st defendant had by reason of the disposal of the FCL shares to JDS prevented the condition being fulfilled because the fact remains that at the time of the disposal upon which the plaintiff’s right was crystallised, there was no approval given by the relevant authority : the plaintiff did not have a specifically enforceable contract then. This would preclude the plaintiff from seeking the equitable relief.

76.10) In my view, the defendants have sufficiently established the problem of specific performance even without relying on the argument that Mr. Bai (the defendants’ expert) had further said that approval would not be given for the agreement because it was inconsistent with the FCO agreement for which it had given approval.

76.11) In the course of arguments Mr. Yu, SC, had referred to academic work on the topic that title to land is not governed by the lex situs : Dicey (14th Ed) Paragraph 29—064; The Common Law Choice of Law Rules for Resulting and Constructive Trust by Chong (2005) 54 ICLQ 855; Yeo, Choice of Law for Equitable Doctrines; Birks and Rose, Restitution and Equity (Chapter 8 on Resulting Trusts in the Conflicts of Law by Stevens).  No opinion is expressed on these works.

76.12) The compensation sought by the plaintiff is based on the availability of equitable remedy to the plaintiff.  Mr. Chan, apart from a reference to the expert’s view on interest arising from a subject matter, was unable to advance any other alternative basis of compensation if the disgorgement of profit is not available to the plaintiff.  Certainly if there is another basis it has not been properly formulated at the conclusion of the appeal.  This being the case it is not necessary to remit the issue of disgorgement of profit to the court below.

(IV)  Estoppel by Convention

77.This Court also allowed the plaintiff to amend its respondent’s notice to address the issue of estoppel by convention even if Mainland law is the proper law of the contract.  This issue was specifically raised below.  The Judge did not make a specific decision on whether estoppel by convention was available to the plaintiff, although he did address one specific defence, namely, public policy, to the issue of estoppel by convention.  This specific defence was also relied upon by the defendant as a defence to the plaintiff’s claim on breach of contract. 

78.Whether the evidence supports a case of estoppel by convention is not something that can be fully dealt with by this Court.  I will discuss this topic on the assumption that there is sufficient evidence to raise estoppel by convention.

Procedural or substantial?

79.The plaintiff argued that even if the proper law of the contract is Mainland law, nonetheless, because it is also relying on estoppel by convention in support of its claim, Hong Kong law which is the applicable law for this issue applies.  The plaintiff relied on two bases to advance this argument.  First, estoppel by convention is to be classified as ‘procedural’ in nature, so that the law of the forum (lex fori) i.e. Hong Kong law, rather than law of the cause (lex causae) i.e. Mainland law, is the applicable law.  Second, even if estoppel by convention is a substantive issue, by applying the approach of Staughton LJ in The Amazonia [1990] 1 Lloyd’s Rep 236, the proper law of ‘estoppel by convention’ is Hong Kong law.

80.The starting point of the inquiry is Rule 17 of Dicey which states that all matters of procedure are governed by the domestic law of the country to which the court wherein any legal proceedings are taken belongs (lex fori).

81.The plaintiff then relied on the statement in cases that estoppel by convention is a matter of evidence in order to bring this topic into the ‘procedural’ fold.  In National Westminster Bank v. Somer International Ltd [2002] QB 1286, Potter LJ having referred to cases such as Low v. Bouverie [1891] 3 Ch 82 and London Joint Stock Bank Ltd v. Macmillan [1918] AC 777 was of the view that in the light of the state of the authorities, it was not open to the English Court at least to depart from the traditional classification of estoppel by representation as a rule of evidence.

82.The debate of whether estoppel by convention is a matter of evidence or substance in these cases was not considered in the context of conflict of laws.  But even under the traditional classification, it is clear that the Court is not constrained by the view that this concept is simply a matter of evidence only.  This is made abundantly clear by the Court of Final Appeal in Unruh v. Seeberger (2007) 10 HKCFAR 31 where Ribeiro PJ at paragraph 154 stated that,

‘ It has been said that estoppel in pais is merely a rule of evidence and not a cause of action (Seton, Liang & Co v Lafone (1887) LR 19 QBD 68; Low v Bouverie [1891] 3 Ch 82; Re Ottos Kopje Diamond Mines, Ltd [1893] 1 Ch 618) but that proposition needs some explanation. If the estoppel relates to the existence of a contract between the parties, the legal relationship between the parties is ascertained by reference to the terms of the contract which has been assumed to exist. If, in the assumed state of affairs, the contract confers a cause of action on the party raising the estoppel, the cause of action may be enforced. The source of legal obligation in that event is the assumed contract; the estoppel is not a source of legal obligation except in the sense that the estoppel compels the party bound to adhere to the assumption that the contract exists.’

83.My understanding of this analysis is that this concept is not merely a matter of evidence but rather a matter of substance which is in line with the view of Lord Wright in Canada and Dominion Sugar Co Ltd v. Canadian National (West Indies) Steamships Ltd [1947] AC 46 at 56 that,

‘ Estoppel is often described as a rule of evidence, as, indeed, it may be so described. But the whole concept is more correctly viewed as a substantive rule of law.’

and that of Lord Denning MR in Moorgate Mercantile Co Ltd v. Twitchings [1976] QB 225 at 241 that,

‘ Estoppel (by representation) is not a rule of evidence. It is not a cause of action. It is a principle of justice and of equity.’

84.In the context of conflict of laws, I would adopt the majority view of the Australian High Court in John Pfeiffer Pty Ltd v. Rogerson (2000) 203 CLR 503 at 543 that,

‘ matters that affect the existence, extent or enforceability of the rights or duties of the parties to an action are matters that, on their face, appear to be concerned with issues of substance, not with issues of procedure. Or to adopt the formulation put forward by Mason CJ in McKain (207), “rules which are directed to governing or regulating the mode or conduct of court proceedings” are procedural and all other provisions or rules are to be classified as substantive (208).’

85.The Australian approach also finds favour in England in Harding v. Wealands [2005] 1 WLR 1539 in the majority judgments of Arden LJ and Sir William Aldous.  Although Waller LJ in his minority judgment stated that Pfeiffer was considered in the ‘federal’ context of Australia and not in the international context and the High Court of Australia in Regie National des Usines Renault SA v Zhang (2002) 210 CLR 491, at paragraph 76 stated that ‘We would reserve for further consideration, as the occasion arises, whether that that position should be applied in cases of foreign tort’, this does not lessen in any way the force of the Pfeiffer approach.

86.Based on the analysis in Unruh, I am of the firm view that estoppel by convention is a matter of substance.  Further it clearly affects the existence, extent or enforceability of the rights or duties of the parties and it is not simply directed to governing or regulating the mode or conduct of court proceedings.

87.Professor T M Yeo of Singapore in ‘Choice of Law for Equitable Doctrines’ at paragraph 4.104 was also of the view that estoppel by convention is also substantive in nature.

‘4.104 In domestic law, estoppel may be procedural or substantive depending on the context. Its choice of law characterization also depends on the context in which it arises. Estoppel by record raises an issue of procedure or public policy. An important equitable contribution closely related to estoppel, that it is an abuse of process to raise issues which should have been but were not raised in earlier foreign proceedings, is no doubt procedural. In many cases, estoppel principles represent substantive policies of domestic law that shape the liabilities of the parties. Civil law systems may use the doctrine of good faith in situations where estoppel would be invoked in the common law. These issues should be seen as substantive for choice of law purposes. The following types of estoppel have been assumed (correctly, it is suggested) to be substantive for choice of law purposes: estoppel by convention, estoppel on the issue of title; and estoppel in the context of ostensible authority of an agent to bind a principal. Estoppel arising in the context of a claim in contract is arguably substantive. Waiver operates like estoppel, and may be substantive for the same reasons. For this purpose, there should be no difference between common law and equitable estoppel.’ (emphasis added)

88.Dicey in addressing specifically the classification of estoppel in conflict of laws (paragraph 7—031) stated that this is an undecided issue :

Estoppel. For the purposes of English domestic law, estoppel is sometimes said to be a rule of evidence. Whether, for the purpose of this Rule, it should be regarded as a rule of substance or as a rule of procedure is an entirely open question, the answer to which may well vary with the type of estoppel under consideration. Thus the question whether a principal is estopped from denying his agent’s authority to deal with a third party probably depends on the lex causae. On the other hand, the question precisely when an estoppel by record arises probably depends on the lex fori, although, of course that law may distinguish for this purpose between the effect of foreign and domestic judgments.’

89.On the other hand, Johnston in ‘The Conflict of Laws in Hong Kong’ at paragraph 2.010 was of the view that estoppel by convention is a matter of substance :

‘ Issue estoppels based on foreign judgments are matters principally for the lex fori discussed in Chapter 9. The other species of estoppel most commonly encountered – promissory estoppel, estoppel by convention, proprietary estoppel – are, it is suggested, clearly matters of substance; their evidential clothing is essentially a legal fiction.’

Proper law for estoppel by convention?

90.If estoppel by convention is a substantive issue, the difficult question that arises is whether the proper law for this issue is to be governed by the proper law of the contract from which the estoppel by convention arises or whether it is to be governed by another set of law.  In The Amazonia, the proper law of the contract was Australian law.  Questions arose as to whether there was, first, an ad hoc contract between the parties and, second, an estoppel by convention on the appointment of an arbitrator both of which would be governed by English law. In respect of the issue of estoppel, Staughton LJ at 247 stated that,

‘ The convention was that there was a valid arbitration agreement between the parties. In a case of estoppel by convention where a foreign element is involved, one has in my judgment to look for something which can conveniently be called the proper law of the estoppel. If the communings of the parties in this case had taken place in Australia, between their Australian lawyers, one might perhaps have concluded that the proper law of the estoppel was Australian law, just as one might have concluded that a contract made in that way was governed by Australian law. As it is, I have no doubt that the estoppel is governed by English law.’

91.Mr. Yu, SC referred to Johnston at paragraph 2.010 that the applicable law of estoppel of convention ought to be governed by the law of the main issue to which it relates :

‘ The law applicable to an estoppel issue will therefore have to be determined: it is suggested in this regard that estoppels ought to be governed by law of the main issue to which they relate: for example, a promissory estoppel or estoppel by convention pleaded in connection with a contractual issue should be assessed according to the law governing the contract; and a proprietary estoppel raised in respect of property should be governed by the lex situs. The matter is essentially one of characterisation: whether the estoppel in question is, in effect, part of the law of contract, property or something else.’

92.Briggs in The Conflict of Laws (2nd Ed, Page 167) (not cited by the parties) seemed to suggest that different proper laws may apply to different parts of the contract but at the same time he recognized that the original contract would be and remain a source of obligations governed by its original proper law unless and until this proper law recognized the validity and effectiveness of a change.

‘ Although it allowed for freedom to choose the proper law of a contract, the common law was reluctant to permit two laws to govern different parts of the contract, no doubt to avoid the risk of contradiction which might well arise from allowing it.  And it denied the validity of an agreement to defer making the actual choice of law to a date in the future: it was not open to the parties to specify that no choice of law was to be made until, atsome point after the formation of the contract, one party nominated it.  Such a ‘floating’ choice of law was axiomatically precluded, on the footing that a contract must be a source of obligation from its inception, and in the absence of a governing law it would contain no mechanism to impose any obligations.  But there appeared to be no obstacle to prevent the parties changing the proper law: if it was open to them to vary the contract, it must also have been open to vary this provision as well.  As a matter of logic, if not clear authority, however, the alteration to the proper law would need to comply with, or be licensed by, the original proper law as well as being permitted by English law: the contract would be and remain a source of obligations governed by its original proper law unless and until this proper law recognized the validity and effectiveness of a change.’ (emphasis added)

93.The case cited by Briggs in support of the common law position is The Amar [1981] 1 All ER 498 where Megaw LJ at 505 stated that,

‘The governing law cannot fall to be decided, retrospectively, by reference to an event which was an uncertain event in the future at the time when obligations under the contract had already been undertaken, had fallen to be performed and had been performed. Nor is it, I think, an attractive, or a possible, concept of English private international law that the governing law, initially being, say, the law of Algeria, should thereafter change into the law of England.’

94.It is not possible for me to give a detailed analysis of this topic in view of the paucity of authorities.  Assuming Staughton LJ did put forward the idea of the proper law of estoppel by convention, I would not adopt his approach which is not binding on this Court as his approach had not been fully analyzed.

(1)   The Amar was not cited in The Amazonia.  Even if subsequent conduct may be relevant to the issue of estoppels (James Miller & Partners Ltd at 614), the estoppel by convention that arises is still, as discussed in Unruh, based on the contract between the parties of which the proper law is Mainland law.  Although subsequent events may give rise to the estoppel, it does not mean that somehow the proper law of the contract can also be changed to Hong Kong law.  Estoppel by convention is an issue that arises out of the contract, just like other issues such as waiver or variation of contractual terms which are plainly governed by the proper law of the contract.  I see no reason why it should be otherwise for estoppel by convention.

(2)   Further it has been recognized that ascertaining the proper law of the contract is also a matter of ascertaining the intention of the parties.  Having ascertained their intention that the proper law of the contract is to be one set of law i.e. Mainland law as I have so found, in order to put forward another set of proper law i.e. Hong Kong law, that applies to estoppel by convention, it is necessary, as a matter of logic and principle, that the Court must first find that the parties had also intended that the proper law they had agreed upon may change by subsequent events.  Likewise there must also be evidence showing that Mainland law allows a subsequent change of the proper law.  In other words the ascertainment of the proper law of the estoppel by convention cannot be done in isolation solely by reference to the ‘communings’ of the parties in relation to their subsequent conduct.  There must also be evidence on the parties’ intention and also on the proper law of the contract that permit a subsequent change of the contractual proper law before a foray into a different regime of proper law can be made.

95.This is precisely the difficulties that the plaintiff faces in this case : the parties having agreed Mainland law to be the proper law of the contract (as I have so found), the plaintiff is required to adduce evidence that nonetheless they also intended and Mainland law also permits such proper law may be changed by subsequent events.  This evidence must be specifically put forward at the trial and it is not permissible for the plaintiff to say that the issue of communings should be remitted to the Court below without first identifying the necessary evidence on the preconditions.  For the reasons I have given, I rule that the plaintiff is not entitled to avail itself of the Hong Kong law concept of estoppel by convention.

(V)  Consequence if proper law is Hong Kong law

96.As my decision is that Mainland law and not Hong Kong law is the proper law of the contract and the plaintiff is not entitled to avail itself of the Hong Kong law concept of estoppel by convention, I will refrain from expressing any view on the question of loss and damages if the proper law is Hong Kong law (other than the non-availability of equitable remedy which, although discussed under the KOT approach under Mainland law, applies equally to the situation where Hong Kong law is the applicable law).

Conclusion

97.The appeal is accordingly allowed.  The judgment below is set aside.  The issue of restitution under Mainland law as discussed above will be remitted to To J for determination.  The plaintiff’s respondent notice (as amended) is dismissed.

Costs

98.The plaintiff is entitled to costs of the appeal and those occasioned by the respondent’s notice (as amended) and also the costs below on a provisional basis.

Hon Yeung JA :

99.I agree.

Hon Yuen JA :

100.I agree with the judgment of Cheung JA.

(Peter Cheung)
Justice of Appeal
(Wally Yeung)
Justice of Appeal
(Maria Yuen)
Justice of Appeal

Mr. Chan Chi Hung, SC & Mr. Jeremy Chan, instructed by Messrs Mayer Brown JSM, for the Plaintiff

Mr. Benjamin Yu, SC, Mr. Paul Shieh, SC & Mr. Law Man Chung, instructed by Messrs Paul, Hastings, Janofsky & Walker, for the 1st and 2nd Defendants

(I) Please refer to FAMV25/2011 for the relevant appeal(s) to the Court of Final Appeal. (II) Please refer to FACV6/2011 for the relevant appeal(s) to the Court of Final Appeal.