William Thomson v. Roland John Jeans and Another

Read the full judgment text of DCCJ 3388/2005 on BabelCite. This District Court judgment was delivered on 18 July 2013.

1. In these actions, the plaintiffs, Mr Thomson in DCCJ 3388/2005 (“P1”) and Mr Boewe in DCCJ 3389/2005 (“P2”), had agreed with the 1 st defendant (“D1”) to invest in a company called Wanchai Bierkeller Ltd (the “Company”).  P1 had agreed to invest $500,000 (the “P1 Investment”) and P2 had agreed to invest $250,000 (the “P2 Investment”).

Cites 7 cases

Case No.DCCJ 3388/2005
Court
District Court
Date18 Jul 2013
Judge
Case Document
100%Judiciary

DCCJ 3388/2005

IN THE DISTRICT COURT OF THE

HONG KONG SPECIAL ADMINISTRATIVE REGION

CIVIL ACTION NO. 3388 OF 2005

________________________

BETWEEN

  WILLIAM THOMSON Plaintiff

and

  ROLAND JOHN JEANS 1st Defendant
  TANNER DE WITT (a firm) 2nd Defendant

________________________

DCCJ 3389/2005

IN THE DISTRICT COURT OF THE

HONG KONG SPECIAL ADMINISTRATIVE REGION

CIVIL ACTION NO. 3389 OF 2005

________________________

BETWEEN

  HANS-JUERGEN BOEWE Plaintiff

and

  ROLAND JOHN JEANS 1st Defendant
  TANNER DE WITT (a firm) 2nd Defendant

________________________

Before: Deputy District Judge R Lai
Date of Hearing: 10 July 2013
Date of Decision: 18 July 2013

________________________

DECISION

________________________

Background

1.In these actions, the plaintiffs, Mr Thomson in DCCJ 3388/2005 (“P1”) and Mr Boewe in DCCJ 3389/2005 (“P2”), had agreed with the 1st defendant (“D1”) to invest in a company called Wanchai Bierkeller Ltd (the “Company”).  P1 had agreed to invest $500,000 (the “P1 Investment”) and P2 had agreed to invest $250,000 (the “P2 Investment”).

2.The 2nd defendant (“D2”) was and is a firm of solicitors acted for D1 and the Company at the material times.

3.At the request of D1, P1 and P2 paid their investments, ie the P1 Investment and the P2 Investment, to D2 on about 24 January 2004 and 8 December 2003 respectively.  There is no dispute that D2 had received the payments.

4.There is also no dispute that D2 had released the P1 Investment and the P2 Investment to D1 or the Company.

5.No shares in the Company had been issued to the plaintiffs.  The Company was put into liquidation by a resolution passed in an extraordinary general meeting of the Company held on 4 January 2005.

6.The plaintiffs claim against the defendants for return of their investments on the grounds of total failure of consideration, money had and received, conversion and breach of trust.  The central issues in dispute between the plaintiffs and D2 are the purposes for the payments to D2 and the terms upon which the payments were paid to D2. 

7.Trials of both actions have been scheduled to commence on 5 August 2013 with 4 days reserved.

8.D2 took out two applications in each action on 7 May 2013 and 5 June 2013.  The first set of applications is to seek leave to amend its defences filed in both actions (the “Amendment Applications”).  The second set of applications is to seek leave to file and serve further or supplemental witness statements (the “Witness Statement Applications”).  The summonses for these applications were all returned before me on 10 July 2013.  I dealt with them all together.  The plaintiffs opposed to all these applications.

Development of the proceedings

9.Before I deal with the aforesaid applications, it will be helpful to briefly set out the development of these actions to put the applications in context.

10.The writs in both actions were issued on 16 July 2005.  Both plaintiffs served their statements of claim on 29 July 2005.  P1 amended his statement of claim on 13 October 2005 and re-amended the same on 9 July 2012.  P2 also amended his statement of claim on 9 July 2012.

11.D2 filed its defences in both actions on 20 September 2005 and provided particulars on its defences on 26 January 2006.  On 17 May 2006, the court struck out part of D2’s defences in both actions (the “Striking Out Orders”).

12.The plaintiffs filed their replies to D2’s defences in both actions on 4 October 2005. P2 amended his reply on 5 October 2005.

13.D1 filed his defences in both actions on 10 October 2005.

14.On 12 March 2012, D2 applied to strike out the plaintiffs’ statements of claim in both actions.  The applications were dismissed on 28 November 2012.

15.The plaintiffs filed their witness statements on 21 March 2012.  D2 filed statements of its witnesses on 26 March 2012.

16.On 26 February 2013, the court set down both actions for trial to commence on 5 August 2013 with pre-trial reviews to be held on 10 June 2013.

17.On 7 May 2013, D2 took out the Amendment Applications.

18.On 16 May 2013, D2 took out summonses in both actions to adjourn the pre-trial reviews and to vacate the scheduled trial dates.  D2 also took out summonses in both actions on the same day for specific discovery.  On 29 May 2013, the court re-fixed the pre-trial reviews to 18 July 2013 and adjourned D2’s aforesaid summonses to a date to be fixed for argument.

19.On 5 June 2013, D2 took out the Witness Statement Applications.

The Amendment Applications

20.The summonses for the Amendment Applications were taken out more than two months after the actions had been set down for trial.  By the summonses, D2 sought leave to file and serve its amended defences in both actions.

21.The plaintiffs did not oppose to all proposed amendments.  The plaintiffs only opposed to the following proposed amendments:

(1)  insertions of para 2(g) in DCCJ 3388/2005 and para 4A in DCCJ 3389/2005;

(2)  insertions of paras 3A and 3B in both actions;

(3)  reference to paras 3A and 3B in para 4 of DCCJ 3388/2005 and para 6 of DCCJ 3389/2005;

(4)  insertions of para 4A in DCCJ 3388/2005 and para 6A in DCCJ 3389/2005);

(5)  amendments to the last sentence of para 5 in DCCJ 3388/2005 and para 7 in DCCJ 3389/2005;

(6)  insertions of paras 12A, 12B and 12C in DCCJ 3388/2005 and paras 14A, 14B and 14C in DCCJ 3389/2005;

(7)  reference to para 4A in para 15(b) of DCCJ 3389/2005;

(8)  reference to paras 3A and 4A in para 14 of DCCJ 3388/2005 and paras 3A and 6A in para 16 of DCCJ 3389/2005;

(9)  insertions of paras 14A, 14B, 14C and 14D in DCCJ 3388/2005 and paras 16A, 16B, 16C and 16D in DCCJ 3389/2005. 

22.I shall refer to the above proposed amendments as Amendments (1) to (9) as numbered above in this decision.  Amendments (3), (7) and (8) are only consequential amendments to Amendments (2) and (4).

23.Amendment (1) propose to plead that the plaintiffs had acquired beneficial interest in the shareholdings of the Company.

24.Amendment (2) propose to plead that there was an understanding that the Company would have immediate use of the plaintiffs’ investments (the “Investment Money Arrangement”) and that D2 received the plaintiffs’ investments as agent of the Company.

25.Amendment (4) are part of the proposed plea of the Investment Money Arrangement.

26.Amendment (5) are to elaborate D2’s defences relying on the Law Society Rules of Professional Conduct.

27.Amendment (6) are to plead further to the plaintiffs’ restitution claims.

28.Amendment (9) propose to plead to the plaintiffs’ breach of trust claim.  Mr Yu, representing D2, confirmed at the hearing that D2 would not pursue the proposed insertions of para 14D(a) in DCCJ 3388/2005 and para 16D(a) in DCCJ 3389/2005.  I shall hereafter refer to the latest proposed Amendment (9) as Revised Amendment (9).

29.The plaintiffs opposed to the Amendment Applications on three grounds:

(1)  the allegations of the Investment Money Arrangement (Amendments (2) and (4) and Revised Amendment (9)), beneficial ownership in shares of the Company (Amendment (1) and part of Amendment (6)) and matters relating to defences relying on the Law Society Rules of Professional Conduct (Amendment (5)) had already been struck out by the Striking Out Orders;

(2)  any pleading of new defences to restitution (the remaining part of Amendment (6)) had been barred by the orders dated 13 February 2012 made in both actions (the “Waiver Orders”);

(3)  the Amendment Applications were inexcusably late and should be disallowed.

The Striking Out Orders

30.Before I go into the parties’ submissions on the effects of the Striking Out Orders on the proposed amendments, I shall set out the procedural history leading to the Striking Out Orders.

31.After D2 served its defences to both actions on 20 September 2005, the plaintiffs took out applications in both actions on 28 October 2005 requiring D2 to provide further and better particulars of its defences.

32.On 4 November 2005, the court ordered D2 to answer the plaintiffs’ requests within 21 days.  The time was subsequently extended.  However, D2 did not answer the plaintiffs’ requests within the specified time.

33.On 6 January 2006, the court ordered that unless D2 answered the plaintiffs’ requests by 26 January 2006, certain parts of D2’s defences in both actions be struck out (the “Unless Orders”).  On 26 January 2006, D2 filed and served its answers to the plaintiffs’ requests (the “Answers”).  The plaintiffs took the view that the Answers failed to answer their requests.  They took out summonses on 27 January 2006 to strike out various parts of D2’s defences in both actions. Deputy District Judge A Kot found that D2 was in breach of the Unless Orders by furnishing illusory answers to the plaintiffs’ requests.  She made the Striking Out Orders on 17 May 2006.

34.After the Striking Out Orders, P1 re-amended his statement of claim and P2 amended his statement of claim on 9 July 2012 to add a claim for breach of Quistclose trust.

35.Mr Chan, representing the plaintiffs, submitted that the proposed amendments of D2 to plead the Investment Money Arrangement and the plaintiffs’ alleged beneficial ownership in shares of the Company as well as the matters relating to the Law Society Rules of Professional Conduct were direct repetition / resurrection of those averments which had already been struck out by the Striking Out Orders and D2 was barred by the Striking Out Orders from relying on the same factual allegations in the present proceedings.

36.Mr Chan submitted that if D2 was dissatisfied with the Striking Out Orders, it should have appealed against the orders.  However, D2 had taken no actions for seven years after the Striking Out Orders to challenge the said decisions.  To allow the proposed amendments was to allow D2 to resurrect the struck out parts in circumvention of the Striking Out Orders.  It would be a back-door appeal against the Striking Out Orders seven years after the orders were made and was an abuse of court process.  

37.Mr Yu relied on Total Lubricants Hong Kong Limited v Christophe De La Cropte de Chanterac (unrep., CACV 37/2012, 15 March 2013) to submit that the Striking Out Orders struck out part of D2’s defences on pleading point and did not give rise to either cause of action estoppel or issue estoppel.  The principles of res judicata or abuse of process did not apply.  In Total Lubricants, the plaintiffs’ original plea of conspiracy against the 5th and 6th defendants was struck out by Poon J for failure to disclose any reasonable cause of action and being an abuse of process.  The plaintiffs did not appeal against the said decision of Poon J but applied to amend their statement of claim to advance a properly pleaded claim of unlawful means conspiracy against all defendants including the 5th and 6th defendants.  The amendments if allowed would bring the 5th and 6th defendants back into that action.  Poon J allowed the amendment application.  He explained in para 17 of his decision as follows (unrep., HCA 1694/2008, 7 February 2012):

“Plainly, what the plaintiffs have done here is not an abuse of process. I previously struck out and dismissed their claim against the 5th and 6th defendants purely on a pleading point. That is to say, their cause of action as then pleaded was deficient. What they do now is to formulate their claim properly. They are not trying to resurrect the exact plea, which had been struck out, without improvement. If that is what they are doing, then the principle of res judicata or abuse of process would apply.”

38.The defendants appealed against the said decision of Poon J in allowing the amendments.  The Court of Appeal dismissed the appeal and affirmed the aforesaid reasoning of Poon J. (See para 21 of the Court of Appeal judgment)

39.Mr Chan submitted that this case was different from Total Lubricants as the Striking Out Orders were made because of non-compliance of the Unless Orders. The court was exercising its case management power and it was not opened for D2 to say after seven years that it had now complied with the Unless Orders to resurrect the struck out parts.

40.Mr Yu submitted that the plea of res judicata did not apply to the Striking Out Orders which were interlocutory orders.  He referred to the discussion on the principle of re-litigation and res judicata in 18/19/11 of the Hong Kong Civil Procedure 2013 vol 1 at pp 423 to 422 which stated as follows:

“The basic rule assumes that the court has made a final determination on an issue in litigation. But where there is simply an exercise of discretion in an interlocutory proceeding, there may be no final determination of an issue giving rise to a res judicata (see Mullen v. Conoco Ltd [1998] Q.B. 382, at 390G-391B, 396F-G). The circumstances in which renewal of an interlocutory application (such as an application to discharge an ex parte injunction)can give rise to an abuse of process may therefore be problematical.

In Chu Hung Ching v. Chan Kam Ming, Chu Oi Ling and Wong Chi Wai (t/a Ming Lee (International Trading Co.), [2001] H.K.C. 396, at 400-1, the Court of Appeal referred with approval to the decision of the Alberta Court of Appeal in Pocklington Foods Inc. v. Alberta Provincial Treasurer (1995) 123 D.L.R. (4th) 141, where at 144-145 the following guidelines were put forward:

McDonald J. relied on the decision of this court in Talbot v. Pan Ocean Oil Corp. (1977) 4 CPC 107, 3 Alta LR (2d) 354, 5 AR 361 (SCAD), in concluding that the principles of res judicata and issue estoppel do not apply to procedural interlocutory motions. … While in the judgment of Clement J.A. in Talbot, there is considerable discussion of the position where a decision is made on the adequacy of the material rather than on the merits of the application, when read as a whole the decision support the position taken by McDonald J. in this case.

However, the court is not powerless to deal with attempts to re-litigate issues already decided by it. In Talbot, after refusing to apply res judicata to interlocutory procedural application, Clement J.A. stated at 112:

“… I am of the opinion that the principle does not apply to an interlocutory application of the nature now before us; rather, the second application is subject to control by the exercise of judicial discretion in determining whether it is frivolous or vexation in all the circumstances then appearing.”

McDonald J. went on to consider the reasoning which should apply in controlling abuse of process. He cited from the decision of Lord Maugham LC in New Brunswick Ry. Co. v. British & French Trust Corp. Ltd. [1939] AC 1 (HL) at 20 (cited with approval in Talbot) as follows [at 282]:

“If an issue has been distinctly raised and decided in an action, in which both parties are represented, it is unjust and unreasonable to permit the same issue to be litigated afresh between the same parties or persons claiming under them.”

He continued:

“Thus the raison d’etre of the principle of res judicata or issue estoppel lies in what is just and reasonable. Applying that notion to an assertion that a ruling or an interlocutory application is res judicata when the same issue is raised in a subsequent interlocutory application in the same action, it will not be unjust or unreasonable to allow the second application to be heard, for what is involved is not re-litigation of an identical issue of law or fact:

(a) if the ruling on the first application was not based on the merits of the issue but on a technical objection …

(b) if upon the first application the applicant had failed to prove essential facts from mistake or inadvertence …

(c) if there is new evidence that seriously justifies reconsideration of the issue …

(d)  if there is a material change of circumstances of a non-evidentiary nature.”

We accept this statement of principles governing the discretion of the chambers judge to entertain a second application on a procedural matter.  However, we emphasize that the object of the exercise is to avoid re-argument and re-litigation of issues already dealt with by the court and in respect of which an order has been taken out.  Such re-litigation is unfair to the other party and wastes the valuable and scarce resources of the court.”

41.Mr Yu submitted that the Striking Out Orders were not based on the merits of the issues but on technical objections and the plaintiffs’ new pleas of Quistclose trust were material changes of circumstances of non-evidentiary nature.  He submitted that after the Civil Justice Reform (“the CJR”), bare denials were insufficient to defend the new pleas of the plaintiffs.  D2 had to plead its positive cases.  The Investment Money Arrangement was D2’s positive cases to defend the plaintiffs’ Quistclose trust claims.  Mr Yu submitted that D2 did not seek to re-litigate on the same issues upon which the Striking Out Orders were made by the proposed amendments and there was no abuse of court process.

42.Mr Chan submitted that the pleas of Quistclose trust were based on the same factual allegations in support of the original claims of restitution.  It did not give rise to new factual issues.  The plaintiffs were merely claiming that based on the same set of facts as pleaded in support of the restitution claims, trust relationship also arose between the plaintiffs and D2.  He submitted that there were no material changes of circumstances which would allow D2 to ignore the Striking Out Orders and resurrect the struck out parts.

43.I shall set out below the parts of D2’s defences which had been struck out but are relevant to the plaintiffs’ objection to the Amendment Applications together with the requests for particulars raised by the plaintiffs and the answers of D2.  I shall also set out the proposed amendments which are objected by the plaintiffs.

Effects of the Striking Out Orders on the plea of Investment Money Arrangement

44.The following are matters related to the alleged Investment Money Arrangement:

(1)  The struck out parts of D2’s defences pleaded as follows:

“The 2nd Defendant was informed by the 1st Defendant that several proposed investors would purchase an interest in the Company and its business, and would do so by paying their investment money into the bank account of the 2nd Defendant for use, without restriction, by the Company for the purpose of its business, as the Company did not have its own bank account at that time.” (Part of para 3 of D2’s defences in both actions)

(2)  The requests raised in DCCJ 3388/2005 were as follows:

“State the date when such information was given by the 1st Defendant to the 2nd Defendant and whether it was oral or in writing, if oral, identify the person in the 2nd Defendant to whom the information was given; if in writing, identify the date and description of the document.” (Request 3)

(3)  The following answers were provided by D2 in DCCJ 3388/2005:

“The matter has already been properly and adequately pleaded. This is not a particular of pleading as the nature of the case is already known by the pleadings, rather this is a matter of evidence to be given on discovery and/or to be dealt with at the trial of the matter.”

(4)  The requests raised in DCCJ 3389/2005 were as follows:

“1. State the date of the information to the 2nd Defendant and whether it was oral or in writing; if oral, identify the person in the 2nd Defendant receiving the information; if in writing, identify the date and description of the document.

2. Specify what interest in the Company and its business would be purchased by and identify the several proposed investors,

3. State whether the Company had its own bank account at your account at any material time between December 2003 and November 2004; and if so, whether the investment money was paid into the Company’s bank account at any such material time;

4. State whether the investment money was used by the Company for the purpose of its business and how it was used.” (Request 2)

(5)  The answers provided by D2 in DCCJ 3389/2005 were as follows:

“1. The matter has already been properly and adequately pleaded. This is not a particular of pleading as the nature of the case is already known by the pleadings, rather this is a matter of evidence to be given on discovery and/or to be dealt with at the trial of the matter.

2. This matter has already been properly and adequately pleaded.

3. This matter has already been properly and adequately pleaded.

4.  This matter has already been properly and adequately pleaded.”

(6)  The proposed insertions objected by the plaintiffs are as follows:

1.  “The 2nd Defendant avers that it received the Plaintiff’s payment of the said sum of [“HK$500,000” in DCCJ 3388/2005 and “HK$250,000” in DCCJ 3389/2005] upon the understanding that the 2nd Defendant would hold the investment money paid by the Plaintiff (and by other investors who invested in the Company after its incorporation) on terms that the Company would be free to put such investment money to immediate use by the Company for its business (the “Investment Money Arrangement”)

PARTICULARS

(a)  On the 1st Defendant’s instructions, the 2nd Defendant arranged for the Company’s incorporation on 16 July 2003.

(b)  Subsequently, the 2nd Defendant assigned a new reference number “03/299/IDW” to the client matters of the Company and the 1st Defendant.

(c)  Since the incorporation of the Company, funds in the 2nd Defendant’s bank account that stood to the credit of the Company were assigned the reference number 03/299/IDW on the 2nd Defendant’s records (the “Company Funds”).  The Company Funds were at all material times held on account of the Company as part of its general assets.  The 1st Defendant’s payment of HK$20,000 to the 2nd Defendant’s bank account on 13 August 2003 constituted the first moneys held as the Company Funds.

(d)  Since around 16 August 2003, expenses for the establishment of the Company and the operation of its business were regularly defrayed by payments out of the Company Funds.  Each payment was made with the express authorisation of the Company acting through the 1st Defendant.

(e)  Since around 18 November 2003, various investors, including the Plaintiff, paid their investment money into the 2nd Defendant’s bank account (the “Investment Moneys”) as part of the Company Funds.  At all material times, the 2nd Defendant’s instructions from the 1st Defendant were that the Investment Moneys were to be put to immediate use by the Company.

(f)  Specifically, the 1st Defendant by his emails on or around 18 December 2003 informed the 2nd Defendant that the Company needed the funds paid by [“a gentleman named Mr. Hans-Juergen Boewe” in DCCJ 3388/2005 and “the Plaintiff” in DCCJ 3389/2005] as soon as possible.

(g)  It was clear to the 2nd Defendant that, in the circumstances, the Investment Moneys were to be freely used by the Company in the Company’s business in accordance with the Investment Money Arrangement,” (Para 3A in both actions)

2.  “Further, the 2nd Defendant avers that the said sum of [“HK$500,000” in DCCJ 3388/2005 and “HK$250,000” in DCCJ 3389/2005] was received by the 2nd Defendant in its capacity as agent of and solicitors acting for the Company.” (Para 3B in both actions)

3.  “It is specifically denied that the Plaintiff’s investment money was held by the 2nd Defendant “only and not otherwise” for the purposes alleged in paragraph [“3(b)” in DCCJ 3388/2005 and “3(a)” in DCCJ 3389/2005] of the Statement of Claim.  Under the Investment Money Arrangement, which the 2nd Defendant honestly and reasonably believed constituted the terms on which it received the Investment Money (including the Plaintiff’s payment of [“HK$500,000” in DCCJ 3388/2005 and “HK$250,000” in DCCJ 3389/2005] as aforesaid), the Company was free to put the said investment money to immediate use by the Company.  In this regard, paragraphs 3, 3A and [“4” in DCCJ 3388/2005 and “6” in DCCJ 3389/2005] of the Defence above are repeated.” (Para 4A in DCCJ 3388/2005 and para 6A in DCCJ 3389/2005)

4.  “Specifically, it is denied that the 2nd Defendant was a express, resulting or constructive trustee in respect of the said sum of [“HK$500,000” in DCCJ 3388/2005 and “HK$250,000” in DCCJ 3389/2005].  Paragraph [“14” in DCCJ 3388/2005 and “16” in DCCJ 3389/2005] of the Defence above is repeated.  Alternatively, if the said sum of [“HK$500,000” in DCCJ 3388/2005 and “HK$250,000” in DCCJ 3389/2005] is trust money belonging to the Plaintiff, which is denied, the 2nd Defendant is not accountable to the Plaintiff therefor.  The 2nd Defendant avers that:

(a)  It has at all material times no knowledge that the payment of the said sum of [“HK$500,000” in DCCJ 3388/2005 and “HK$250,000” in DCCJ 3389/2005] was only for the purposes alleged in paragraph [“3(b)” in DCCJ 3388/2005 and “3(a)” in DCCJ 3389/2005] of the Statement of Claim,

(b)  Further, it has at all material times reasonably and honestly believed that the Company was free to put the said sum to immediate use for the business of the Company in accordance with the Investment Money Arrangement, and it was instructed by the 1st Defendant to do so.

Paragraphs 3, 3A and [“4A” in DDCJ 3388/2005 and “6A” in DCCJ 3389/2005] of the Defence above are repeated.” (Para 14A in DCCJ 3388/2005 and para 16A in DCCJ 3389/2005)

5.  “Save it is admitted that the 2nd Defendant had made payments of the said sum of [“HK$500,000” in DCCJ 3388/2005 and “HK$250,000” in DCCJ 3389/2005] to the 1st Defendant as disclosed in the ledger account of the 2nd Defendant discovered by the 2nd Defendant during discovery in this Action, it is denied that any payments were made on the 1st Defendant’s behalf.  It is averred that all payments from the Company Funds in the 2nd Defendant’s bank account were made on the Company’s behalf in accordance with the Investment Money Arrangement.  Paragraph [“12B” in DCCJ 3388/2005 and “14B” in DCCJ 3389/2005] of the Defence above is repeated.” (Para 14B in DCCJ 3388/2005 and para 16B in DCCJ 3389/2005)

6.  “By reason of the aforesaid, it is denied that the said payments constituted the 2nd Defendant’s acting or participation in the misapplication of the said sum of [“HK$500,000” in DCCJ 3388/2005 and “HK$250,000” in DCCJ 3389/2005] or any breach of trust.  The 2nd Defendant avers that:-

(a)  The Plaintiff ceased to have any beneficial interest in the said sum of [“HK$500,000” in DCCJ 3388/2005 and “HK$250,000” in DCCJ 3389/2005] upon payment of the same out of the Company Funds in the 2nd Defendant’s bank account for the purposes of the Company’s business and/or in accordance with the Investment Money Arrangement, upon which the purpose or basis of the Plaintiff’s payment of the said sum was fulfilled.

(b)  Further and/or in the alternative, by reason of the matters pleaded in paragraphs 3, 3A, [“4A and 14A” in DCCJ 3388/2005 and “6A and 16A” in DCCJ 3389/2005] of the Defence above, the 2nd Defendant did not have at any material time any knowledge sufficient to render it liable as a constructive trustee or at all.

(c)  Further and/or in the alternative, by reason of the matters pleaded in paragraph 3B and [“12C” in DCCJ 3388/2005 and “14C” in DCCJ 3389/2005] of the Defence above, the 2nd Defendant did not receive the said sum of [“HK$500,000” in DCCJ 3388/2005 and “HK$250,000” in DCCJ 3389/2005] beneficially but only as agent of the Company.” (Para 14C in DCCJ 3388/2005 and para 16C in DCCJ 3389/2005)

7.  “Alternatively, if it is found that the 2nd Defendant was in breach of trust, which is denied:-

(b)  Further, by reason of the matters pleaded in, inter alia, paragraphs 3, 3A, [“4A and 14A” in DCCJ 3388/2005 and “6A and 16A” in DCCJ 3389/2005] of the Defence above, the 2nd Defendant has acted honestly and reasonably and ought fairly to be excused for any alleged breach of trust, pursuant to section 60 of the Trustee Ordinance (Cap. 29).” (Para 14D(b) in DCCJ 3388/2005 and para 16D(b) in DCCJ 3389/2005)

45.Mr Yu submitted that the struck out parts of para 3 of D2’s defences in both actions pleaded that D2 was informed by D1 about the payment of the investment moneys and how the investment moneys were to be used.  They were struck out because D2 failed to properly answer requests on particulars on the alleged information provided to D2.  The proposed amendments pleaded D2’s understanding on the usage of the investment moneys derived from objective circumstances and were D2’s positive cases to the plaintiffs’ Quistclose trust claims.  They were not resurrection of the exact pleas which had been struck out.  The factual basis was different.  He submitted that if D2 was not allowed to put forward its positive cases, D2 would not be able to defend the plaintiffs’ newly added Quistclose trust claims.  This would be grossly unfair to D2.

46.Mr Chan submitted that the court should look into the substance of the struck out parts of para 3 of D2’s defences.  They pleaded that the investment moneys would be used without restriction by the Company for the purpose of its business.  The Investment Money Arrangement pleaded in the proposed amendments raised the same plea in substance.

47.I agree with Mr Yu that part of para 3 of D2’s defences was struck out because D2 failed to provide particulars to substantiate its plea of D2 being informed by D1 on usage of the investment moneys.  The proposed amendments pleaded D2’s understanding on the usage of the investment moneys derived from objective circumstances are pleas based on different factual basis.  The Striking Out Orders were not made on merits of the pleas but on failure to provide particulars which is a pleading point and on non-compliance of the Unless Orders which is a procedural point.  In such circumstances, D2 is not barred by the Striking Out Orders from raising the plea of the Investment Money Arrangement. However, the Striking Out Orders will bar D2 from raising a plea on the use of the investment moneys relying on information from D1.  D2 is barred from resurrecting such plea through inserting the last sentence of the proposed para 3A(e) in both actions which pleaded that: “At all material times, the 2nd Defendant’s instructions from the 1st Defendant were that the Investment Moneys were to be put to immediate use by the Company.”

Effects of the Striking Out Orders on the plea of alleging the plaintiffs having beneficial interest in the shareholdings of the Company

48.The following are matters related to the alleged beneficial interest of the plaintiffs in the shareholdings of the Company:

(1)  The following parts of D2’s defences being part of para 3 in DCCJ 3388/2005 and part of para 4 in DCCJ 3389/2005 had been struck out:

“The 2nd Defendant was instructed by the 1st Defendant that, in due course and once all potential shareholders had been ascertained and had paid their investment money, shares in the Company would be allotted in accordance with their investment, including to the Plaintiff, and that in the meantime to all intents and purposes the Plaintiff (and others) were to be treated as shareholders, their interest being held on trust by the 1st Defendant until such time as the shareholding was allotted and share [“certificate” in DCCJ 3388/2005 and “certificates” in DCCJ 3389/2005] issued. At all material times, the 2nd Defendant was instructed by the Company through the 1st Defendant that the beneficial ownership interest of the Plaintiff in the Company was [“14.285%” in DCCJ 3388/2005 and “7.142%” in DCCJ 3389/2005] and that in due course shares in this proportion would be allotted to him.”

(2)  The requests raised in both actions were as follows:

“1. State the date of the instruction given to the 2nd Defendant and whether it was oral or in writing; if oral, identify the person in the 2nd Defendant receiving the said instruction; if in writing, identify the date of the document.

2. Identify “the potential shareholders” by their names (DCCJ 3388/2005); or

Identify “the potential shareholders” and state whether they had in fact paid their investment moneys; and if so, when (DCCJ 3389/2005).

3. Specify what was the registered share capital and structure of the Company, and all allotment(s) of shares therein made by the Company, as at the date of the instruction;

4. Specify in what manner and by what means would shares in the Company be allotted to the potential shareholders including to the Plaintiff in accordance with the instruction;

5. [“Specify” in DCCJ 3388/2005 and “Clarify” in DCCJ 3389/2005] how to all intents and purposes the Plaintiff was to be treated as a shareholder (of the Company);

6. Identify the nature of the interest of the Plaintiff being held on trust by the 1st Defendant until such time as the shareholding was allotted and share certificates issued.

7. Specify how the trust of the said interest held by the 1st Defendant until such time as the shareholding was allotted and share certificates issued, arose or came into existence.” (Request 4 in DCCJ 3388/2005 and request 5 in DCCJ 3389/2005)

(3)  D2 answered all the above requests by either (a) or (b) set out below:

(a)  “The matter has already been properly and adequately pleaded.  This is not a particular of pleading as the nature of the case is already known by the pleadings, rather this is a matter of evidence to be given on discovery and/or to be dealt with at the trial of the matter.”

(b)  “This matter has already been properly and adequately pleaded.”

(4)  The following parts of D2’s defences being part of para 8 in DCCJ 3388/2005 and part of para 10 in DCCJ 3389/2005 had also been struck out:

“In the premises, it is averred that the Plaintiff, having a beneficial interest in the Company, together with others with similar beneficial interests, was served with notice of an extraordinary general meeting of the Company and at the first meeting of contributories that was held on 4 January 2005, which the Plaintiff chose not to attend, a majority of the Company’s shareholders voted and passed a resolution placing the Company into creditors’ voluntary liquidation.”

(5)  The requests raised in DCCJ 3388/2005 were as follows:

“1. State the nature of the beneficial interest in the Company which the Plaintiff had, when the notice was served;

2. State when, where, in what manner and by whom the Plaintiff was served with notice of an extraordinary general meeting of the Company and by whom;

3. State the place where the first meeting of contributories of the Company was held on 4 January 2005 and the name(s) of the chairman and the contributories who attended the meeting and their share-holdings in the Company;

4. State, by reference to the total registered shareholders in the Company what was the majority of the Company’s shareholders who voted and passed a resolution placing the company into creditors’ voluntary liquidation.” (Request 10)

(6)  The answers of D2to the above requests were as follows:

“1. This matter has already been properly and adequately pleaded. Again, the nature of the case is already known by the pleadings.

2. Aside from the fact that this is an enquiry that should be properly made of the Liquidators of the Company, not the 2nd Defendant, the matter has already been properly and adequately pleaded. Again, the nature of the case is already known by pleadings. As far as the 2nd Defendant is aware, notice was given by letter and by advertisement.

3. Aside from the fact that this is an enquiry that should be made of the Liquidators of the Company, not the 2nd Defendant, the matter has already been properly and adequately pleaded. Again, the nature of the case is already known by pleadings.

4.  Aside from the fact that this is an enquiry that should be made of the Liquidators of the Company, the matter has already been properly and adequately pleaded.  This is not a particular of pleading as the nature of the case is already known by the pleadings, rather this is a matter of evidence to be given on discovery and/or to be dealt with at the trial of the matter.”

(7)  The requests raised in DCCJ 3389/2005 were as follows:

“1. State the nature of the beneficial interest in the Company which the Plaintiff had, when the notice was served;

2. State when, where, in what manner and by whom the Plaintiff was served with notice of an extraordinary general meeting of the Company and identify who issued the notice;

3. State the place where the first meeting of contributories of the Company was held, and the contributories who voted, and their registered share-holdings in the Company;

4. State, by reference to the total registered shareholders in the Company what constituted the majority of the Company’s shareholders who voted and passed a resolution placing the company into creditors’ voluntary liquidation.” (Request 10)

(8) D2 answered all the above requests by either (a) or (b) set out below:

(a)  “The matter has already been properly and adequately pleaded.  This is not a particular of pleading as the nature of the case is already known by the pleadings, rather this is a matter of evidence to be given on discovery and/or to be dealt with at the trial of the matter.”

(b)  “This matter has already been properly and adequately pleaded.”

(9)  The following parts of D2’s defences being part of para 13(b) in DCCJ 3388/2005 and part of para 15(b) in DCCJ 3389/2005 had also been struck out:

“The Plaintiff did make the said payment of [“HK$500,000” in DCCJ 3388/2005 and “HK$250,000” in DCCJ 3389/2005], which the 2nd Defendant was instructed represented his beneficial interest of [“14.285%” in DCCJ 3388/2005 and “7.142%” in DCCJ 3389/2005] in the Company. At all material times, the 2nd Defendant was instructed by the Company that the Plaintiff had a beneficial interest and was a shareholder of the Company.”

(10)  Requests raised in DCCJ 3388/2005 were as follows:

“1.  Indentify who instructed the 2nd Defendant that a payment of $500,000.00 represented his beneficial interest of 14.285% in the Company and what constituted “beneficial interest”.

2.  Specify the date of such instruction of the 1st Defendant to the 2nd Defendant and whether it was oral or in writing; if oral, identify the person in the 2nd Defendant and the Company to whom and by whom the same was given and received; if in writing, identify the date of the document.

3.  Identify who in the Company instructed the 2nd Defendant that the Plaintiff had a beneficial interest in and was a shareholder of the Company; and

4.  Specify the date of such instruction by the 1st Defendant to the 2nd Defendant and whether it was oral or in writing; if oral, identify the persons in the 2nd Defendant and the Company to whom and by whom the same was given and received; if in writing, identify the date of the document.” (Request 12)

(11) The following requests were raised in DCCJ 3389/2005:

“1. Specify the date of instruction by the 1st Defendant to the 2nd Defendant that a payment of $250,000.00 represented the Plaintiff’s 7.142% beneficial interest in the Company and whether it was oral or in writing; if oral, identify the person in the 2nd Defendant and the Company to whom and by whom the instruction was given and received; if in writing, identify the date of the document;

2. Specify how the said payment of $250,000.00 represented the Plaintiff’s beneficial interest of 7.142% in the Company.

3. Specify, in terms of date(s), what were “at all material times”; and whether the 2nd Defendant’s instruction(s) by the Company was oral or in writing; if oral, identify the person(s) in the 2nd Defendant and the Company to whom and by whom the same was given and received; if in writing, identify the date(s) of the document(s).” (Request 12)

(12)  D2 answered all the above requests in both actions by either (a) or (b) set out below:

(a)  “The matter has already been properly and adequately pleaded.  This is not a particular of pleading as the nature of the case is already known by the pleadings, rather this is a matter of evidence to be given on discovery and/or to be dealt with at the trial of the matter.”

(b)  “This matter has already been properly and adequately pleaded.”

(13)  The following first sentence of para 15(c) in DCCJ 3389/2005 had also been struck out:

“Furthermore, the Plaintiff acquiesced to his position as a shareholder of the Company, and was treated, and acted, as such at all material times.”

(14)  The following requests were raised on the aforesaid paragraph:

“1. State all facts including all overt acts on the Plaintiff’s part, relied on by the 2nd Defendant to show how and at what material times the Plaintiff acquiesced to his position as a shareholder of the Company and was treated as such.” (Request 13)

(15) The answers of D2 were as follows:

“The matter has already been properly and adequately pleaded. This is not a particular of pleading as the nature of the case is already known by the pleadings, rather this is a matter of evidence to be given on discovery and/or to be dealt with at the trial of the matter.”

(16) The proposed amendments by way of insertions objected by the plaintiffs are as follows:

“It is further averred that, in all the circumstances, the Plaintiff acquired a beneficial interest in the shares in the Company which were held by the 1st Defendant on trust for the Plaintiff pending the allotment of shares in the said proportion to the Plaintiff by the Company. At all material times, the Company treated the Plaintiff as a shareholder [“and the Plaintiff had participated in the Company’s affairs in that capacity” in DCCJ 3389/2005].” (Para 3(g) in DCCJ 3388/2005 and para 4A in DCCJ 3389/2005)

“Specifically, it is denied that consideration for the payment of the said sum of [“HK$500,000” in DCCJ 3388/2005 and “HK$250,000” in DCCJ 3389/2005] had wholly failed. The 2nd Defendant avers:-

(b) Further, the Plaintiff obtained a beneficial interest in the shares of the Company. Paragraph [“3” in DCCJ 3388/2005 and “4A” in DCCJ 3389/2005] of the Defence above is repeated.” (Para 12A(b) in DCCJ 3388/2005 and para 14A(b) in DCCJ 3389/2005)

49.The aforesaid parts of D2’s defences relating to the alleged beneficial interest of the plaintiffs in the Company were struck out for, inter alia, the following reasons:

(1) D2 failed to provide particulars to substantiate its plea of D2 being instructed by D1 on the plaintiffs having beneficial interest in the shareholdings of the Company;

(2) D2 failed to provide particulars to substantiate how to all intents and purposes the plaintiffs were to be treated as shareholders of the Company;

(3) D2 failed to identify the nature of the interest of the plaintiffs being held on trust by D1;

(4) D2 failed to specify how the trust of the said interest held by D1 arose or came into existence;

(5) D2 failed to provide particulars on what constituted “beneficial interest” of P1;

(6) D2 failed to provide particulars on how P2’s payment represent P2’s beneficial interest of 7.142% in the Company; and

(7) D2 failed to provide proper particulars to show how and when P2 acquiesced to his position as a shareholder of the Company and was treated by the Company as such.

50.The proposed amendments pleaded that the plaintiffs acquired beneficial interest in the shares in the Company which were held by D1 on trust for the plaintiffs and the Company treated the plaintiffs as shareholders.  These were pleas struck out by the Striking Out Orders.  The proposed amendments also resurrect the plea that P2 had participated in the Company’s affairs in the capacity of a shareholder.

51.The proposed amendments to allege the plaintiffs having beneficial interest in the shareholdings of the Company held on trust by D1 are attempts to resurrect the exact pleas which had been struck out by the Striking Out Orders.  D2 is barred by the Striking Out Orders to raise such pleas.

Effects of the Striking Out Orders on the plea relying on The Law Society Rules

52.The following are matters related to the plea relying on The Law Society Rules of Professional Conduct:

(1)  The following parts of D2’s defences being part of para 5 in DCCJ 3388/2005 and part of para 7 in DCCJ 3389/2005 had been struck out:

“The 2nd Defendant avers that on several occasions the 2nd Defendant sought instructions on the preparation and finalising of shareholder agreements for the investors in the Company and allotment of shares, but at no time were such instructions forthcoming.”

(2)  The following requests were raised in both actions:

“1. State the dates of the several occasions when the 2nd Defendant sought the instructions;

2. State whether the 2nd Defendant sought instructions orally or in writing; if oral, the person(s) by whom and from whom instructions were sought; and if in writing, the date and description of the document(s); and

3. State what instructions were sought for the preparation and finalising of the shareholder agreements for the investors in the Company and allotment of shares and identify the investors and parties to the shareholder agreements.” (Request 7 in DCCJ 3388/2005 and request 9 in DCCJ 3389/2005)

(3)  D2 answered all the above requests by either (a) or (b) set out below:

(a)  “The matter has already been properly and adequately pleaded.  This is not a particular of pleading as the nature of the case is already known by the pleadings, rather this is a matter of evidence to be given on discovery and/or to be dealt with at the trial of the matter.”

(b)  “This matter has already been properly and adequately pleaded.”

(4)  D2 proposed to make the following amendments to the aforesaid paragraphs of its defences:

“The Law Society Rules of Professional Conduct prevented the 2nd Defendant from finalising the shareholder agreements or allotting shares to the Plaintiff without the express instructions of its client, which the 2nd Defendant never received.” (Proposed amendments in italic)

53.The parts of D2’s defences being struck out were D2’s claims that it had sought instructions to finalise the shareholder agreements.  They were struck out because D2 failed to provide proper particulars on its alleged seeking of instructions.  The proposed amendments are to elaborate the pleas relying on the Law Society Rules which were part of D2’s original defences and which have not been struck out.  I do not agree that these amendments are resurrection of the pleas previously struck out by the Striking Out Orders or that such amendments are barred by the Striking Out Orders.

Proposed amendments to defences to restitution claims

54.D2 proposed to insert the following paragraphs to its defences to plead further to the plaintiffs’ restitution claims:

(1)  “Specifically, it is denied that consideration for the payment of the said sum of [“HK$500,000” in DCCJ 3388/2005 and “HK$250,000” in DCCJ 3389/2005] had wholly failed.  The 2nd Defendant avers:-

(a)  The said sum of [“HK$500,000” in DCCJ 3388/2005 and “HK$250,000 in DCCJ 3389/2005] was paid in accordance with the Investment Money Arrangement.  Further, with the authorisation of the Company, the said sum of [“HK$500,000” in DCCJ 3388/2005 and “HK$250,000” in DCCJ 3389/2005] was put to use for the business of the Company.  Paragraphs 3, 3A and [“4A” in DCCJ 3388/2005 and “6A” in DCCJ 3389/2005] of the Defence above are repeated.

(b)  Further, the Plaintiff obtained a beneficial interest in the shares of the Company.  Paragraph [“3” in DCCJ 3388/2005 and “4A” in DCCJ 3389/2005] of the Defence above is repeated.

(c)  Further and/or in the alternative, since a contract between the Plaintiff and the 1st Defendant for the purchase and/or allotment of shares in the Company worth [“HK$500,000” in DCCJ 3388/2005 and “HK$250,000” in DCCJ 3389/2005] is subsisting, no claim for money had and received or restitution can be maintained.” (Para 12A in DCCJ 3388/2005 and para 14A in DCCJ 3389/2005)

(2)  “Further and/or in the alternative, as a result of the Plaintiff’s payment of the said sum of [“HK$500,000” in DCCJ 3388/2005 and “HK$250,000” in DCCJ 3389/2005], the 2nd Defendant in good faith paid out of the Company Funds in its bank account on the Company’s behalf sums amounting to or exceeding [“HK$500,000” in DCCJ 3388/2005 and “HK$250,000” in DCCJ 3389/2005],  The said payments by the 2nd Defendant were made:-

(a)  on the lawful instructions of the Company;

(b)  for the purposes of settling liabilities and expenses of the Company or its business; and

(c)  as the 2nd Defendant reasonably and honestly believed, in accordance with the Investment Money Arrangement.” (Para 12B in DCCJ 3388/2005 and para 14B in DCCJ 3389/2005)

(3)  “Further and/or in the alternative, by reason of the matters pleaded in paragraph 2 and 3B of the Defence above, the 2rd Defendant received the sum of [“HK$500,000” in DCCJ 3388/2005 and “HK$250,000” in DCCJ 3389/2005] from the Plaintiff on behalf of the Company.  It did not receive the said sum to its own benefit and it has never been enriched by the same.  It has, in any event, paid over the said sum to the instructions of the Company, as pleaded in paragraph [“12B” in DCCJ 3388/2005 and “14B” in DCCJ 3389/2005] of the Defence above, in good faith and before receiving notice of the Plaintiff’s claim.” (Para 12C in DCCJ 3388/2005 and para 14C in DCCJ 3389/2005)

55.Mr Chan submitted that the aforesaid proposed amendments were unrelated to the latest amendments made by the plaintiffs on 7 July 2012 to their claims.  They were amendments in relation to the plaintiffs’ restitution claims pleaded before the latest amendments.  He referred to an order made by the court in both actions on 13 February 2012 to submit that “those amendments which seek to address the original cause of action of restitution should be deemed to be waived by D2 by the effect of the order of Master I Wong dated 13 February 2012”. (para 21 of the skeleton submissions for the plaintiffs)

56.To deal with this contention of the plaintiffs, it is necessary to set out the procedural history of this case after the making of the Striking Out Orders.

57.After the Striking Out Orders were made on 17 May 2006, not much had happened in these proceedings until late 2011.  Case management summonses were taken out in both actions on 2 September 2011.  Various case management directions were given by the court on 3 October 2011 for both actions.  Case management conferences (“CMCs”) for both actions were fixed for 10 January 2012 which were later re-fixed for 13 February 2012.  At the CMCs hearing on 13 February 2012, the learned Master made further case management directionsin both actions including the Waiver Ordersin the following terms:

“The 2nd Defendant do apply for leave to amend the Defence on or before 27 February 2012, failing which the 2nd Defendant will be treated to have waived the application.”

58.D2 did not make any amendment application within the specified time.  Instead, it took out striking out applications on 12 March 2012 to strike out the plaintiffs’ statements of claim in both actions (“D2’s Striking Out Applications”).  On 30 March 2012, the court ordered that the Waiver Orders be stayed pending determination of D2’s Striking Out Applications.

59.On 9 July 2012, the court granted leave for the plaintiffs to amend their claims in both actions to include claims under Quistclose trust.  The court also granted leave for D2 to amend its defences within 14 days thereafter.

60.On 13 July 2012, D2 amended D2’s Striking Out Applications to include an application to postpone the time for D2 to amend its defences pending determination of D2’s Striking Out Applications (the “Postponement Applications”).

61.On 28 November 2012, the court dismissed D2’s Striking Out Applications.  However, no directions were given by the court in respect of the Waiver Ordersor the Postponement Applications.

62.Mr Yu submitted that the Waiver Orders had been stayed pending determination of D2’s Striking Out Applications.  When the court dealt with D2’s Striking Out Applications, the court made no further directions in respect of the Waiver Orders.  Subsequent to the Waiver Orders, the plaintiffs had amended their claims and the court had on 9 July 2012 granted leave for D2 to amend its defences.  D2 subsequently made the Postponement Applications which again were not dealt with by the court.  Mr Yu submitted that as D2 had to amend its defences to deal with the plaintiffs’ Quistclose trust claims, D2 wished to deal with all amendments together.  D2 had informed the court in the CMCs hearing held on 26 February 2013 that it would apply to amend its defences.  Mr Yu submitted that although the court would take into consideration the Waiver Orders in considering the Amendment Applications, the Waiver Orders did not bar D2 from seeking leave to amend its defences.

63.The Waiver Orders directed D2 to apply for leave to amend its defences by 27 February 2012. The consequence of failure to do so was that D2 would be “treated to have waived the application”.  The court did not make unless orders barring D2 from making amendment applications after 27 February 2012.  In fact, the court had, after 27 February 2012, on 30 March 2012 ordered that the Waiver Orders be stayed.  It seems that the learned Master, when making the orders to stay the Waiver Orders, took the view that the time for D2 to apply to amend its defences under the Waiver Orders had not expired as at 30 March 2012 which was more than one month after the specified deadline.  If the time for D2 to make amendment applications did not expire on 27 February 2012, the Waiver Orders had not specified any other deadlines.  It such case, the effect of the Wavier Orders became uncertain.  The parties should have sought clarification from the court at the disposal of D2’s Striking Out Applications or by separate applications thereafter.  However, no actions were taken by either party.  In such circumstances, I do not consider that it is fair to hold that D2 had been barred by the Waiver Orders to apply for leave to amend its defences.  However, when I consider theAmendment Applications, I shall bear in mind that the court had previously made the Waiver Orders and D2 had not made its applications within the specified time.

Delay

64.The restitution claims were pleaded when the statements of claim were filed on 29 July 2005.  D2 filed its defences on 20 September 2005.  Applications to amend defences to further deal with the restitution claims were made on 7 May 2013, ie more than seven years after the filing of the defences and less than three months before the trials.

65.The Quistclose trust claims were added in July 2012.  The court had on 9 July 2012 granted leave for D2 to amend its defences to deal with the Quistclose trust claims within 14 days, ie by 23 July 2012.  D2’s proposed amendments were not ready until early May 2013, ie more than nine months after the time specified by the court for D2 to amend its defences had expired.

66.Mr Chan submitted that these were “last minute” applications before trial in the post-CJR era.  He referred to Liu Chen v Chan Poon Wing & Anor (unrep., HCPI 779/2006, Master Marlene Ng, 7 October 2009) when the learned Master stated that:

“36. Let me say as a general observation that the court is generally unhappy with last minute applications at the commencement of assessment hearing for further evidence to be filed or for further discovery to be made. After the CJR, the court is even more jealous to ensure that the assessment of damages will proceed as scheduled, and that the hearing will not be burdened with last-minute applications that take up valuable time thereby prolonging the assessment hearing, causing an adjournment and/or increasing costs for the party(ies). To say the least, last minute applications fly in the face of the underlying objectives of reasonable expedition, procedural economy, costs-effectiveness and fairness between parties enshrined in Order 1A of the RHC.

37.  In the circumstances, after the implementation of the CJR, if there is any last minute application (which necessarily be a rare occurrence), the court will not expect anything less than what was required even prior to the CJR, namely, a full account for the lateness of the application.  In addition, it is further expected that the applicant will place before the court full justification as to why the application should be entertained at all at such late stage notwithstanding the underlying objectives.  Failure to do so may result in the court rejecting the application without further ado, especially if there is a history of breach of court timetables or if there is something in the conduct of the application of the applicant that gives rise to suspicion of conscious manoeuvring.”

67.Mr Chan in his skeleton submitted that to allow substantial amendments of the pleading would result in the introduction of substantial amendments and would certainly derail the trial dates.  An adjournment of trial per se was a serious prejudice caused to the plaintiffs.  As Mr Yu confirmed at the hearing that D2 did not pursue the amendments to insert paragraph 14D(a) in DCCJ 3388/2005 and paragraph 16D(a) in DCCJ 3389/2005 (which alleged waiver, acquiescence or concurrence), Mr Chan confirmed that the only further evidence which the plaintiffs might need to adduce was the evidence from Mr Jurgen Thorwithwho was also present when the plaintiffs’ discussed their investments with D1.  He said that Mr Thorwith’s evidence would support the plaintiffs’ versions of the agreed arrangements between the plaintiffs and D1.  Mr Chan confirmed that the plaintiffs would not seek adjournment of the trials to obtain evidence from Mr Thorwith.

68.Ms Tai Ho Tung in her 4th affidavits filed on 31 May 2013 in both actions supporting the Amendment Applications explained that after D2’s Striking Out Applications failed in late November 2012, D2 started to consider amending its defences.  At first, D2 attempted to amend its defences by itself but later realised that defence to Quistclose trust raised complex legal issues.  D2 decided to instruct counsel to amend its defences.  D2 only managed to obtain fee quote from counsel in mid-February 2013 because of the intervening holidays.  She said that D2 did not expect that the trial dates would be fixed at the CMCs hearing of 26 February 2013.  After the said CMCs hearing, D2 took immediate actions to engage counsel to settle the amendments to its defences.  However, the counsel used to represent D2 in these proceedings was not free to appear at the scheduled trial dates and suggested D2 to instruct another counsel to represent it at the trials and to attend to the amendments of D2’s defences.  D2 then took actions to find another suitable counsel and to obtain fee quotes.  D2 eventually found another counsel in mid-March 2013.  As counsel was not previously involved in these proceedings, he needed times to review papers related to these proceedings.  Due to the legal complexity of the cases, counsel took time to consider the amendments required and managed to finalise the proposed amendments at the end of April 2013.  Draft amended defences were sent to the plaintiffs’ solicitors on 30 April 2013 and the Amendment Applications were subsequently taken out.

69.Mr Yu submitted that the proposed amendments were either defence in law which did not require further factual evidence or covered by evidence already disclosed. They would not call for further factual evidence and the trial dates would not be affected.

70.Mr Chan said that D2 was a firm of solicitors.  Its alleged difficulties in instructing counsel were far from professional and acceptable.  He submitted that the casual attitude adopted by D2 in instructing counsel was far below the acceptable standard and akin to bad faith.

71.D2’s Amendment Applications are no doubt late applications.

72.In Ketteman v Hansel Properties Ltd [1987] 1 AC 189 at 212Lord Brandon summarised the principles on which discretion to allow or refuse applications to amend should be exercised as follows:

“First, all such amendments should be made as are necessary to enable the real questions in controversy between the parties to be decided. Secondly, amendments should not be refused solely because they have been made necessary by the honest fault or mistake of the party applying for leave to make them: it is not the function of the court to punish parties for mistakes which they have made in the conduct of their cases by deciding otherwise than in accordance with their rights. Thirdly, however blameworthy (short of bad faith) may have been a party’s failure to plead the subject matter of a proposed amendment earlier, and however late the application for leave to make such amendment may have been, the application should, in general, be allowed, provided that allowing it will not prejudice the other party. Fourthly, there is no injustice to the other party if he can be compensated by appropriate orders as to costs.”

73.The above principles remain good law after the CJR. (See Topwell Corporate Ltd v 關錦泉 & Anor (unrep., CACV 88/2013, 21 May 2013).  Of course, in the post-CJR era, the court must have regard to the underlying objectives stated in Order 1A of the Rules of the District Court (the “Rules”).  The court would need to balance all relevant factors to decide how its discretion should be exercised if the application is made in circumstances offending one or more of the underlying objectives.

74.As stated by Lam J (as he then was) in para 14 of his judgment in Guangzhou Green-Enhan Bio-Engineering Co Ltd & anr v Green Power Health Products International Co Limited & Ors (unrep., HCA 4651/2002, 22 July 2004):

“Whilst generally the court could allow an amendment to enable the real issue in dispute to be canvassed no matter how late it is applied for, the modern approach is that lateness and explanation for the delay in making the application are relevant factors to be taken into account in the exercise of discretion by the court. Other factors include the important of the amendments to the party applying for leave and the prejudice the amendments would cause to the other side and whether that could be remedied by costs or adjournment. There could be other relevant factors depending on facts of the case. It is a balancing exercise and the ultimate consideration is fairness (procedural as well as substantive) to the parties in all the circumstances.”

75.The plaintiffs had added claims for Quistclose trust by their latest amendments to their statements of claim.  If D2 is not allowed to amend its defences, D2 will have no positive cases in answering the plaintiffs’ Quistclose trust claims.  Order 18 rule 13(4) of the Rules provides that:

“(4) Where an allegation made in a statement of claim or counterclaim is traversed by a denial, the party who denies the allegation shall in his defence or defence to counterclaim ─

(a) state his reasons for doing so; and

(b)  if he intends to put forward a different version of events from that given by the claimant, state his own version.”

76.The underlying objectives of the CJR as set out in Order 1A rule 1 of the Rules include, inter alia, to ensure fairness between the parties. (Order 1A rule 1(d))

77.I agree that D2’s explanation for delay in making the Amendment Applications is not most satisfactory.  However, I do not agree that the Amendment Applications were made in bad faith.  The cases pleaded in the proposed amendments to D2’s defences are not distinct defences raised for the first time on the other.  The relevant facts had already been disclosed and the trial dates would not be affected by the proposed amendments.  No prejudice will be caused to the plaintiffs as there would not be any delay in the proceedings because of the amendments.

78.I note that D2’s Striking Out Applications were not determined until 28 November 2012 which was about eight months before the scheduled trials. The Amendment Applications were not made at trial as in the case of Liu Chen but at about five months after disposal of D2’s Striking Out Applications and about three months before the scheduled trials.  Although there was delay, I accept that it was not substantial after taking into account the intervening holidays and the problems encountered by D2 in engaging counsel to settle the amendments.

79.As Bowen LJ stated in Cropper v Smith [1884] 26 Ch. D. 700 at 710-711 that:

“Now, I think it is a well established principle that the object of Courts is to decide the rights of the parties, and not to punish them for mistakes they make in the conduct of their cases by deciding otherwise than in accordance with their rights. … Courts do not exist for the sake of discipline, but for the sake of deciding matters in controversy, and I do not regard such amendment as a matter of favour or grace. … It seems to me that as soon as it appears that the way in which a party has framed his case will not lead to a decision of the real matter in controversy, it is as much a matter of right on his part to have it corrected, if it can be done without injustice, as anything else in the case is a matter of right.”

80.Order 1A rule 2(2) of the Rules provides that:

“(2) In giving effect to the underlying objectives of these Rules, the Court shall always recognize that the primary aim in exercising the powers of the Court is to secure the just resolution of disputes in accordance with the substantive rights of the parties.”

81.If a defendant denies part of a plaintiff’s claim, he is not entitled thereby to call evidence of fact contrary to the plaintiff’s contention without first setting out his positive case in his defence.  To disallow D2 to plead its positive cases to the Quistclose trust claims is to shut out D2’s defences to such claims.

82.Other proposed amendments are to plead legal defence.  Order 18 rule 11 of the Rules provides that: “A party may by his pleading raise any point of law.”  The learned editors of the Hong Kong Civil Procedure 2013 vol 1 stated in para 18/11/1 at p 392 that:

“If a party intends to raise a point of law on the facts as pleaded, it is a convenient course to do so in pleading. See, too, O.14A. But nevertheless he may, at the trial, raise a point of law open to him even though not pleaded (Independent Automatic Sales Ltd v. Knowles & Foster [1962] 3 All E.R. 27). In a proper case, the court will allow a party to amend his pleading so as to raise a point of law for argument before the trial, as in Lever v. Land Security Co (1894) 70 L.T. 323; …”

83.Although Mr Chan said that the plaintiffs might seek to adduce evidence from Mr Jurgen Thorwith on discussions between the plaintiffs and D1 to deal with the Investment Money Arrangement plea, I do not see that this is necessitated by D2’s proposed amendments.  As the plaintiffs were present on all occasions when they discussed their investments with D1, the plaintiffs could give direct evidence on what had happened in those meetings.  Mr Thorwith’s evidence on those meetings between the plaintiffs and D1 attended also by Mr Thorwith will only serve to boost the credibility of the plaintiffs.  Whether the proposed amendments to D2’s defences are allowed, the credibility of the plaintiffs is in issue. Furthermore, Mr Chan confirmed that the plaintiff did not require postponement of the trials for obtaining evidence from Mr Thorwith, if required.

84.After balancing all the factors, I am of the view that it is unfair to shut out D2’s defences pleaded in the proposed amendments.  For the reasons stated above, I do not see any prejudice causing injustice to the plaintiffs in granting the Amendment Applications.  I allow the Amendment Applications save and except those proposed amendments seeking to resurrect the same pleas struck out by the Striking Out Orders as stated in paragraphs 47 and 51 above.  As D2 did not pursue the proposed insertions of paragraph 14D(a) in DCCJ 3388/2005 and paragraph 16D(a) in DCCJ 3389/2005, these paragraphs shall not be included in the allowed amendments.  I direct D2 to file and serve its amended defences in both actions within 7 days from the date of this decision.

85.I grant leave for P1 to amend his reply and P2 to re-amend his reply within 14 days from the date of this decision.

The Witness Statement Applications

86.D2 sought to file and serve witness statements made by D1 and Mr Bruno Arboit (“BA”), one the Liquidators to the Company as well as a supplemental statement of Mr Ian De Witt (“IDW”).

87.The supplemental witness statement of IDW deals with a retainer letter issued by D2 on 17 December 2001 (the “Retainer Letter”).  When dealing with D2’s Striking Out Applications, Deputy District Judge Norman Hui found that the Retainer Letter required D2 to provide security to the investors while awaiting the total investment from investors to reach HK$2,000,000 before the investment funds could be used by the Company and D2 had departed from the obligations stated in the Retainer Letter.  The supplemental witness statement of IDW seeks to explain that such requirement of security only applied to the fundraising of the Company in 2001 which was failed and funds were returned to the investors.  There was no similar security requirement for the fundraising in late 2003 and early 2004 to which the plaintiffs participated.

88.Mr Yu said that IDW’s supplemental witness statement explained some of the documents already disclosed which showed that there were two rounds of fundraising.  He submitted that the supplemental witness statement of IDW would fill the lacuna in evidence which caused concern to Deputy Judge Norman Hui when he was asked to determine whether the plaintiffs had reasonable causes of action.

89.Mr Yu submitted that D1 was the one who established the Company and coordinated with the investors.  He was the key person in these proceedings.  D1 had filed his defences in both actions but had not been participated actively in these proceedings.  He did not file any witness statement.  IDW contacted D1 after the CMCs hearing on 26 February 2013 which fixed the trial dates and eventually managed to get D1 prepared and signed his witness statement in mid-May 2013.  In his witness statement D1 confirmed his pleaded case that it had been made clear to the plaintiffs that the moneys which they would invest by paying to D2’s account would be used straight away.  D1 also denied that he had made the misrepresentation claimed by the plaintiffs.  Mr Yu submitted that D1’s witness statement also explained the first round fundraising based on disclosed documents.

90.Mr Yu submitted that D1 as a defendant to both actions had the right to be heard at the trials as the court’s judgment would bind him qua defendant in the actions.

91.Mr Yu said that in the decision on D2’s Striking Out Applications, Deputy District Judge Norman Hui referred to a letter from BA to D2 dated 18 October 2011 which stated that the plaintiffs were shareholders of the Company according to the Liquidators’ records.  The learned Deputy Judge queried what were the “records” referred to by the Liquidators. BA in his witness statement explained that the “records” were information provided by D1 and D2 in late December 2004 to early January 2005.  BA referred to documents already disclosed.

92.Mr Yu submitted that these further and supplemental witness statements were necessary for the fair resolution of the disputes.  They were necessitated by the failure of D2’s Striking Out Applications which was not disposed of until 28 November 2012.  Mr Yu submitted that there was no intentional delay on the part of D2 and these further and supplemental witness statements had no surprise to the plaintiffs.  He submitted that drafts of these further and supplemental witness statements had been provided to the plaintiff for over a month and the plaintiffs had not identified any specific and real prejudice.

93.Mr Yu submitted that although there were two additional witnesses, this would not necessarily derail the trial dates.

94.Mr Chan informed the court that judgment against D1 in both actions had just been sealed and the court needed not concern with the claims against D1 at the trials.

95.Mr Chan submitted in his skeleton submissions that the further and supplemental witness statements dealt with the alleged Investment Money Arrangement and the alleged beneficial interest in the shareholding of the Company which had been struck out by the Striking Out Orders.  He further submitted that one could not lead evidence on matters not pleaded and the Witness Statement Applications should not be disallowed.

96.Mr Chan agreed that if the Amendment Applications were allowed, the contents of the further and supplemental witness statements would then become related to D2’s pleaded case.

97.Mr Chan further submitted that there was a delay of about seven months from the decision on D2’s Striking Out Applications to the Witness Statement Applications.  The further and supplemental witness statements raised substantive factual matters which would complicate and lengthen the trial.  Mr Chan submitted that it was grossly unfair to compel the plaintiffs to respond to the further and supplemental witness statements before the trials.

98.Mr Chan rightly pointed out that the further and supplemental witness statements were related to matters which had been struck out by the Striking Out Orders.  The Witness Statement Applications would likely be refused if made before the Amendment Applications.  If not because of the imminent trials, the applications would better be made after disposal of the Amendment Applications.  I do not consider that there was substantial delay on the part of D2 in making the Witness Statement Applications.

99.D2’s case after the amendments allowed would be that according to D2’s understanding there was the Investment Money Arrangement.  D2 reasonably and honestly believed that the investment moneys paid by the plaintiffs to D2 were governed by the Investment Money Arrangement and D2 had been acting in accordance with the Investment Money Arrangement.  D2 relied on objective circumstances to justify its said understanding and belief.  In such case, evidence from D1 and BA are irrelevant to the issues in dispute between D2 and the plaintiffs.  It should also be noted that D2 had been barred by the Striking Out Orders from relying on instructions from D1 to substantiate its pleas of Investment Money Arrangement.  The trials are not occasions to clarify queries raised in the decision of Deputy Judge Norman Hui on D2’s Striking Out Applications.  I refuse leave for D2 to file and serve witness statements of D1 and BA.

100.The supplemental witness statements of IDW are relevant to the background for D2’s understanding of and belief in the Investment Money Arrangement.  Draft of IDW’s supplemental witness statements had been sent to the plaintiffs’ solicitors in early June 2013, ie two months before the trials.  In view of the nature of the matters raised, I am of the view that the plaintiffs’ solicitors should have sufficient time to take instructions from the plaintiffs on the matters raised therein.  Mr Chan did not specify which matters raised in IDW’s supplemental witness statementswould have to be replied to by the plaintiffs.  It seems that IDW’s supplemental witness statements covered matters which the plaintiffs would not have personal knowledge.  There is not much that the plaintiffs would have to reply to, if any.

101.IDW’s supplemental witness statements are not lengthy and they are on specific subject.  I do not see that such evidence will substantially prolong the trials.  As I have allowed the Amendment Applications for D2 to plead the Investment Money Arrangement and IDW’s supplemental witness statements are relevant to this subject, it will not do justice if I do not allow D2 to rely on them at the trials.

102.I grant leave for D2 to file and serve IDW’s supplementalwitness statements.

103.To be fair to the plaintiffs, I grant leave for the plaintiffs to file and serve, within 14 days from the date of this decision, supplemental witness statements to reply to the matters raised in IDW’s supplemental witness statements.  I note that the plaintiffs may not be in Hong Kong before the trials, I direct that fax copies of such supplemental witness statements of the plaintiffs will be acceptable for filing and serving provided that the plaintiffs’ solicitors shall undertake to file the original signed copies of the same before commencement of the trials.

Other matters

104.Mr Yu had the following to say in his skeleton submission on adducing witness statements dated 8 July 2013:

“38. Second, it does not lie in the mouths of the Plaintiffs to complain about delay. It is incumbent for the Plaintiffs to actively prosecute the actions, but they have failed to do so and have at least contributed to 5 years of delay.

39.  Tanner De Witt’s delay in taking out the present applications (in terms of months since the striking out application) pales in significance.  If Tanner De Witt is blamed for the delay, the Plaintiffs are at least in pari delicto if not in greater fault.”

105.After the CJR, all parties to the court proceedings have the duties to proceed with the proceedings in an expeditious way.  If a plaintiff fails to prosecute the action actively, the defendant should have taken out appropriate applications to proceed with the proceedings.  The old days’approach of “let sleeping dogs lie” is no longer acceptable.  Delay by the other side is not excuse, less to say as reason, for one’s own delay.  The aforesaid submissions of Mr Yu have no merits.

106.In his skeleton submission for the Amendment Applications dated 5 July 2013, Mr Yu stated that:

“30. On 26 February 2013, the parties attended the 2nd CMC before Master D. Ho.

(1) Ms. Tai of Tanner De Witt submitted that it would apply to amend its Defences and apply for further security for costs: … This was also clearly stated in Tanner De Witt’s Listing Questionnaires: …

(2) On this basis, Tanner De Witt indicated that the case was not ready to set down for trial: …

31. Since there was no application to amend the Defences (at the time counsel’s quotes have just been obtained), Master D. Ho proceeded to set down the actions for trial on 5 August 2013 … without consulting counsels’ diaries: …

32. The fixing of the trial dates took Tanner De Witt by surprise, particularly given the Plaintiffs’ dilatoriness in prosecuting the actions.  It did not expect the trial dates to be fixed so soon and Ms. Tai deposes that Tanner De Witt would have proceeded with the amendment of the Defence more expediently had it been aware of the proximity of trial: …”

107.In his skeleton submissions on adducing witness statements, Mr Yu stated that:

“36. The present applications are made close to trial because of the abrupt fixing of the trial dates at the 2nd CMC in February 2013, when Tanner De Witt clearly maintained that the case was far from ready for trial: see skeleton submissions dated 5 July 2013 … Tanner De Witt made clear to Master D. Ho at the 2nd CMC that there were loose ends to be tied.”

108.nbsp;  .   One of the underlying objectives of the CJR is “to ensure that a case is dealt with as expeditiously as is reasonably practicable.” (Order 1A, rule 1(b) of the Rules)

109.Order 1A, rule 2(1) of the Rules provides that:

“(1) The Court shall seek to give effect to the underlying objectives of these Rules when it ─

(a) exercises any of its powers (whether under its inherent jurisdiction or given to it by these Rules or otherwise); or

(b)  interprets any of these Rules or a practice direction.”

110.After the CJR, the court is engaged in pro-active case management. Order 1A, rule 4 of the Rules provides that:

“(1) The Court shall further the underlying objectives of these Rules by actively managing cases.

(2) Active case management includes ─

(a) …;

(g) fixing timetables or otherwise controlling the progress of the case;

(h) …;

(l)  giving directions to ensure that the trial of a case proceed quickly and efficiently.”

111.Parties to legal proceedings are required to proceed expeditiously with the proceedings. Order 1A, rule 3 of the Rules provides that:

“The parties to any proceedings and their legal representatives shall assist the Court to further the underlying objectives of these Rules.”

112.Legal proceedings are not to proceed at the leisure of the parties.  The parties should have obtained all necessary directions at the case management summons stage before the CMC. In these actions, the case management summonses were taken out on 2 September 2011, ie more than one years and five months before the setting down of the trials.  The parties should have already complied with all case management directions before the CMCs hearing and should be ready to proceed to trial by the time of the CMCs hearing.  It is exception, not usual, to have more than one CMC.  The CJR does not expect many CMCs before the trial or else the purposes of the CJR will be frustrated.

113.D2 filed its defencesin these actions on 20 September 2005.  If D2 wished to amend its defences, it had plenty of times to do that before the 1stCMCs held on 13 February 2012.  The claims for Quistclose trust were added in July 2012.  The court had allowed plenty of times for D2 to amend its defences to defend the new claims.  D2’s Striking Out Applications had been disposed of three months before the 2nd CMCs held on 26 February 2013.  D2 had ample times to make applications to amend its defences and to adduce further witness statements before the 2nd CMCs.  No applications were placed before the court at the 2nd CMCs hearing.  The court would not be doing justice to the plaintiffs and the learned Master wouldnot be discharging his active case management duties if he accepted a bare claim from D2 that it had further interlocutory applications to make and did not fix the trial dates at the second (not the first) CMCs when there were no pending interlocutory applications.

114.The learned Master in fixing the trial dates for these actions to more than five months after the CMCs had allowed further times for D2 to take out all necessary interlocutory applications.  Knowing that the trial dates had been fixed for early August 2013, D2 still did not take out these applications until May 2013.  To take out interlocutory applications close to trial, D2 took the risk that its applications might be refused on the ground that they might disturb the trial dates, being milestone dates.  Order 25, rule 3(3) of the Rules provides that the court shall not vary a milestone date unless there are exceptional circumstances justifying the variation.  If its applications are not allowed for disturbing the trials, D2 only has itself to blame.  It was D2’s poor case management which led to applications being made closed to trial.  Trying to shift the blame to the court is totally unacceptable.

115.I shall also point out that if a party wishes the trial date to be fixed in consultation with counsel’s diary, the party shall bring counsel’s diary to attend the CMC hearing.  It is neither a practice nor a rule in the District Court that trial date will be fixed in consultation with counsel’s diary.  Parties can make request to the Listing Master.  However, it is at the discretion of the Listing Master after considering all the circumstances including the underlying objectives whether to accede to such request.  The comment of Mr Yu on the learned Master fixing trials without consulting counsel’s diary is totally unwarranted.

Costs

116.D2 was seeking indulgence from the court to amend its defences and to file further and supplemental witness statements.  These are very late applications.  Although in the very special circumstances of these cases, I allow part of D2’s applications, I see no reasons why D2 should not bear the costs.  I make orders nisi thatD2 to pay the plaintiffs’ costs of and occasioned by these applications with counsel certificate.  Such costs orders nisi shall become absolute after 14 days from the date of this decision unless application is received within the said 14 day period from any party to vary the same.

Conclusion

117.I grant leave for D2 to file and serve within 7 days from the date of this decision its amended defence in DCCJ 3388/2005 per draft annexed to D2’s summons taken out on 7 May 2013 save and except that paragraphs 3(g), 12A(b), 14D(a) and the last sentence of paragraph 3A(e) are excluded.

118.I grant leave for P1 to amend his reply consequential to D2’s amendments to its defence within 14 days from the date of this decision.

119.I grant leave for D2 to file and serve within 7 days from the date of this decision supplemental witness statement of IDW in DCCJ 3388/2005 as per draft annexed to D2’s summons taken out on 5 June 2013.

120.I grant leave for P1 to file and serve further and/or supplemental witness statements within 14 days from the date of this decision to reply to matters raised in the aforesaid supplemental witness statement of IDW and/or in D2’s amended defence.

121.I make an order nisi that D2 shall pay the costs of and occasioned by P1 for the aforesaid applications of D2 (including all costs previously reserved in relation to these applications) with counsel certificate, to be taxed if not agreed. Such costs order nisi shall become absolute after 14 days from the date of this decision unless application is received within the said 14 day period from any party to vary the same.

122.I grant leave for D2 to file and serve within 7 days from the date of this decision its amended defence in DCCJ 3389/2005 per draft annexed to D2’s summons taken out on 7 May 2013 save and except that paragraphs 4A, 14A(b), 16D(a) and the last sentence of paragraph 3A(e) are excluded.

123.I grant leave for P2 to re-amend his reply consequential to D2’s amendments to its defence within 14 days from the date of this decision.

124.I grant leave for D2 to file and serve within 7 days from the date of this decision supplemental witness statement of IDW in DCCJ 3389/2005 as per draft annexed to D2’s summons taken out on 5 June 2013.

125.I grant leave for P2 to file and serve further and/or supplemental witness statements within 14 days from the date of this decision to reply to matters raised in the aforesaid supplemental witness statement of IDW and/or in D2’s amended defence.

126.I make an order nisi that D2 shall pay the costs of and occasioned by P2 for the aforesaid applications of D2 (including all costs previously reserved in relation to these applications) with counsel certificate, to be taxed if not agreed. Such costs order nisi shall become absolute after 14 days from the date of this decision unless application is received within the said 14 day period from any party to vary the same.

127.The time for the hearings for these applications shall be apportioned equally between the two actions.

  (R Lai)
  Deputy District Judge

Mr Isaac Chan, instructed by John Ip & Co, for the plaintiffs

Mr Jason Yu, instructed by the 2nd Defendant acting in person