Jade’s Realm Ltd v. Director of Lands for and on behalf of the Government of the Hong Kong Special Administrative Region

Read the full judgment text of HCA 1509/2012 on BabelCite. This High Court CFI judgment was delivered on 10 June 2014.

1. This is the Plaintiff’s application by summons dated 13 December 2013 (“ Summons ”) for specific discovery, inspection and taking copies of seven categories of documents pursuant to RHC Order 24 rules 7, 11 and 11A.  The documents sought were set out in the Schedule to the Summons. The application is supported by the Fourth Affidavit of Simon Richard Deane dated 13 December 2013 (“ Deane 4 th ”), the Fifth Affidavit of Simon Richard Deane dated 2 May 2014 (“ Deane 5 th ”) and the Second Affid

Cited by 6 cases · Cites 4 cases

Case No.HCA 1509/2012
Court
High Court CFI
Date10 Jun 2014
Judge
Case Document
100%Judiciary

HCA 1509/2012

IN THE HIGH COURT OF THE

HONG KONG SPECIAL ADMINISTRATIVE REGION

COURT OF FIRST INSTANCE

ACTION NO 1509 OF 2012

____________

BETWEEN

  JADE’S REALM LTD Plaintiff

and

  DIRECTOR OF LANDS for and on behalf of THE GOVERNMENT OF THE HONG KONG SPECIAL ADMINISTRATIVE REGION Defendant
____________
Before: Hon Ng J in Chambers
Date of Hearing: 23 May 2014
Date of Judgment: 10 June 2014

_______________

J U D G M E N T

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Introduction

1.This is the Plaintiff’s application by summons dated 13 December 2013 (“Summons”) for specific discovery, inspection and taking copies of seven categories of documents pursuant to RHC Order 24 rules 7, 11 and 11A.  The documents sought were set out in the Schedule to the Summons. The application is supported by the Fourth Affidavit of Simon Richard Deane dated 13 December 2013 (“Deane 4th”), the Fifth Affidavit of Simon Richard Deane dated 2 May 2014 (“Deane 5th”) and the Second Affidavit of Chong Chew Then (Mr. Deane’s wife) dated 2 May 2014 (“Chong 2nd”).

2.Before I turn to the Schedule itself, it is necessary to give a brief synopsis of the parties’ pleaded cases so that the application can be more easily understood.

The Plaintiff’s pleaded case

3.As pleaded by the Plaintiff, the Hong Kong Government[1] was and is the owner of a piece of land in DD 214 (“Land”) in Nam Wai, Sai Kung, New Territories. For identification purpose, the Land is shaded yellow on a plan annexed to the amended Statement of Claim now replaced by the 8th Schedule (“8th Schedule Plan”).

4.By a Block Crown Lease dated 27 March 1907, Lot Nos. 355 and 356 in DD 214 (“the Lots”) were granted to one Yau Chiu Wa and others who were members of the Yau Clan. Through a chain of assignments, the Plaintiff became the registered owner of the Lots on 7 September 2007 and has remained so ever since. For identification purpose, the Lots are shaded pink on a plan annexed to the amended Statement of Claim now replaced by the 9th Schedule (“9th Schedule Plan”). The Lots adjourn the Land and are completely surrounded by it.

5.The Lots and the Land (collectively as “Enclosed Area”) are delineated by a stone wall traced purple (“Stone Wall”) on a plan annexed to the amended Statement of Claim now replaced by the 10th Schedule (“10th Schedule Plan”). 

6.As pleaded in paragraph 8 of the amended Statement of Claim, between 1907 and 7 September 2007, a number of houses and structures (“Houses and Structures”) had been “constructed, completed and rebuilt” by the Plaintiff’s predecessors-in-title and the Plaintiff on the Enclosed Area. For identification purpose, the Houses and Structures are shaded green on the 10th Schedule Plan.

7.On the Plaintiff’s case, the Stone Wall was built in or about 1937 by the then registered owners of the Lots and members of the Yau Clan. Since not later than 1937, the Enclosed Area has been in the exclusive possession of and enjoyed by the Plaintiff’s predecessors‑in‑title and the Plaintiff as a single tenement.

8.It is further the Plaintiff’s case that, despite changes in ownership, the predecessors-in-title of the Plaintiff continued to possess exclusively the Enclosed Area and incur money and money’s worth in the maintenance, repair and reconstruction of the Stone Wall and the Houses and Structures.  Further, since 7 September 2007, the Plaintiff has continued and still continues to occupy the Enclosed Area and incur money and money’s worth in the maintenance, repair and reconstruction of the Stone Wall and the Houses and Structures.

9.Lastly, the Defendant is said to be estopped from denying the Plaintiff’s title of and in the Land on the ground that the construction, maintenance and repair works on the Land and the Lots were done openly but the Defendant had stood by and acquiesced in the improvements to the Land and the Lots by the predecessors-in-title of the Plaintiff and the Plaintiff itself.

10.In the prayer for relief, the Plaintiff claims inter alia:

(1)  a Declaration that the Defendant’s title of and in the Land has been extinguished by virtue of the Limitation Ordinance;

(2)  a Declaration that the Plaintiff has acquired a squatter’s title to the Land;

(3)  a Declaration that the Lots are as identified in the 9th Schedule Plan;

(4)  a Declaration that the Plaintiff has acquired a proprietary interest in the Land, the Stone Wall and all buildings and structures thereon and that the Defendant is estopped from exercising the Government’s right therein.

11.The Plaintiff has also put forward a number of alternative cases with regard to the locations of the Lots and the Land. For identification purpose, these locations are colour-shaded on the plans annexed to the amended Statement of Claim now replaced by the 11th, 12th and 13th Schedules. In the prayer for relief, the Plaintiff claims similar Declarations with regard to the Land and the Lots so identified.

The amended Defence and Counterclaim

12.The Defendant disputes the Plaintiff’s claims on a number of grounds. For the present purpose, this court needs only mention five.

13.First, the boundaries of the Lots are not as set out in the plans annexed to the amended Statement of Claim. Rather, they are as indicated on a plan annexed to the amended Defence and Counterclaim now replaced by Schedule E (“Schedule E Plan”).

14.Second, there were acknowledgments of the Government’s title to the Land by the Plaintiff’s predecessors-in-title, including Madam Chu Kit Ha (“Madam Chu”), at various times between 1962 and 2006, so that the limitation period should be deemed to commence only on the dates of the acknowledgements pursuant to section 23 of the Limitation Ordinance.

15.Third, the Defendant disputes the time when the Houses and Structures referred to in paragraph 8 of the amended Statement of Claim were erected. The Defendant’s pleaded case, at paragraph 10(A) of the amended Defence and Counterclaim, is that they were first seen on the dates set out below and identified on a plan annexed to the amended Defence and Counterclaim now replaced by Schedule G (“Schedule G Plan”).

  Area Date
 E1a (Structure No. 1[2] in BLUE) 11 June 1972
 E1b (Structure No. 1 in ORANGE)  6 February 2004
 E2a (Structure No. 2) 27 December 1956
 E2b (Structure No. 2) 3 October 1972
 E3 (Structure No. 3) 19 February 1963
 E4 (Structure No. 4)  October 1974
 E5 1959
 E6  3 October 1984
 E7a  27 July 2008
 E7b  22 November 2007

16.Fourth, the occupation of some of the Houses and Structures ie Structures Nos. 2, 3 & 4 was allowed to continue with the Government’s consent or licence consequent upon a territory-wide stock-taking survey on squatting structures in 1982 by the Squatter Control Unit of the Housing Department and, for that reason, was not adverse.

17.Fifth, the Plaintiff has acquired no proprietary interest in the Land. Nor is the Government estopped from exercising its rights over or taking any action in relation to the Land: in particular, the Defendant did not stand by or acquiesce in the investments in or improvements to the Houses and Structures by the Plaintiff’s predecessors-in-title and the Plaintiff.

18.In its amended Counterclaim, the Defendant counterclaims for:

(1) a Declaration that the boundaries of the Lots are as set out in the Schedule E Plan;

(2) an Order for the delivery of vacation possession of the Land to the Government; and

(3) mesne profits for the Plaintiff’s wrongful use and occupation of the Land since September 2007.

The amended Reply and Defence to Counterclaim

19.By its amended Reply and Defence to Counterclaim dated 12 December 2013, the Plaintiff joins issue with the Defendant. 

The issues

20.Mr Chong submits, and this court is content to adopt with slight modification, the following are the principal issues which emerge from the pleadings:

(1)  Whether the Plaintiff has been in adverse possession of the Land for a period of not less than 60 years and, hence, the title of the Government therein has extinguished (“the Adverse Possession Issue”) or whether the Plaintiff’s predecessors-in-title have acknowledged the Government’s title in the Land (“the Acknowledgment Issue”).

(2)  Whether the Land has been encroached upon by the Plaintiff and its predecessors-in-title for the statutory period so that the Plaintiff would be entitled to hold it until the expiry of the existing terms of the Lots (“the Encroachment Issue”).

(3)  Whether, by investing money and money’s worth in the Land by the Plaintiff and its predecessors-in-title, the Plaintiff has acquired a proprietary interest in the Land and the Government is estopped from recovering the same (“the Proprietary Estoppel Issue”).

(4)  Whether, by reason of its dealings with the predecessors-in-title of the Lots and the Land, the Government has abandoned the restrictive building covenant in the Government Lease (“the Abandonment of Covenant Issue”).

(5)  What are the correct boundaries of the Lots (“the Boundary Issue”).

The legal principles

21.I shall first remind myself of the principles which are germane to the present application.

(1)  There is no jurisdiction to make an order for specific discovery under RHC O 24 r 7 unless there is sufficient evidence or prima facie case that: (a) the documents or classes of documents exist which the other party has not disclosed; (b) the documents relate to a matter in issue in the action; and (c) the documents are in the possession, custody or power of the other party. 

(2)  Once it is established that those three prerequisites for jurisdiction do exist, the court has a discretion whether or not to order discovery. 

(3)  The Court will not make an order unless the discovery sought is necessary either for disposing fairly of the cause or matter or for saving costs.

(4)  The order must identify with precision the documents or categories of documents which are required to be disclosed, for otherwise the person giving discovery may find himself in serious trouble for swearing to a false affidavit, even though doing his best to give an honest disclosure.

(5)  Where discovery is sought in relation to a class of documents, it is important that the class should not be defined or described too widely, and should not be defined so as to include documents which are not relevant.

(6)  Despite the Peruvian Guano test for relevance, “fishing” is not allowed, and discovery should not be oppressive. 

(7)  Statements in a party’s affidavit of documents are conclusive e.g. on the question whether he has or has had any documents other than those disclosed, as to their relevancy or as to the grounds stated in support of a claim for privilege from production.

(8)  The respondent may answer an application for specific discovery by an affidavit stating that he does not have the documents, and this will be conclusive at the interlocutory stage.

See: Hong Kong Civil Procedure 2014 Vol. 1 para. 24/7/1; Berkeley Administration Inc v McClelland [1990] FSR 381 at 382-3; Lee Nui Foon v Ocean Park Corp (No 1) [1995] 2 HKC 390 at 391-3; Paul’s Model Art GMBH v UT Ltd [2006] 1 HKC 238 at paragraphs 24 & 32; Tai Fook Futures Ltd v Cheung Moon Hoi Jeff [2006] 4 HKC 81 at paragraphs 33 to 35.

22.On the question of oppression, Mummery J had this to say in Molnlycke AB v. Proctor & Gamble (No 3) [1990] RPC 498, 503:

“An order may be refused on the ground that it is unduly oppressive to the party giving discovery. The court takes account of such considerations as the value of the discovery to the person seeking it and the burden imposed on the party giving it, with a view to restricting the volume of documents and the labour and expense involved to that which is necessary for fairly disposing of the issues in the case.”

23.After the introduction of the CJR, the court must give effect to the underlying objectives of the rules when exercising its powers under RHC Order 24.  In Sunny Tadjudin v Bank of America unrep., HCA 322 of 2008, 22 December 2011, Deputy High Court Judge M Chan (as she then was) observed at paragraph 7:

“In deciding whether any document relates to a matter in question in the action, whether any document is or has been in the possession, custody or power of a party, and whether discovery of a document sought is necessary either for disposing fairly of the cause or matter or for saving costs, the Court should always bear in mind the objectives of cost effectiveness, expeditious disposal of cases, proportionality, procedural economy and ensurance of fairness between the parties.”

24.A similar sentiment was expressed by Deputy High Court Judge Lok in HSBC Private Bank (Suisse) SA v. Mission Bridge Limited unrep. HCA 406 of 2008, 18 June 2012 at paragraph 16:

“Following the CJR, the increasing emphasis is for the court to limit discovery in the context of its duty actively to manage the case.”

The Documents sought

25.I now return to the Schedule.

Paragraph 1 of the Schedule

26.Paragraph 1 of the Schedule seeks:

All correspondence, emails, memoranda, notes, plans, notices, agreements and other documents (to the extent not already disclosed by the Defendant) between the following departments of the Government and the owners of the property now known as 98 Nam Wai Road, Sai Kung (“Property”) between 16 February 1981 and 31 October 2006 in relation to the Government’s dealings with the Property and its owners in connection with the fish farm business operating at the Property, including but not limited to all internal emails, memoranda, notes and other correspondence passing within each Government department and between them including but not limited to the following:

(a) the Hong Kong Housing Authority and its predecessor departments;

(b) the Lands Department;

(c) the Building Authority and its predecessor departments;

(d) the Fire Department and its predecessor departments;

(e) the Food and Environmental Hygiene Department and its predecessor departments;

(f) the Food and Health Bureau and its predecessor departments;

(g) the Planning Department and its predecessor departments.” (emphasis added)

27.In Mr Chong’s skeleton submissions for the Plaintiff, these documents are said to relate to the Government’s dealings with the Plaintiff’s predecessors-in-title viz Mr Chu Poon Shin (“Mr Chu”) and his daughter Madam Chu (collectively “the Chus”) concerning theuse of part of the Land for their fish farm business. The request is for the period from 16 February 1981 to 31 October 2006: 16 February 1981 was the date when Mr Chu became registered owner of the Lots while 31 October 2006 was the date when Madam Chu disposed of the Lots. Although the same is not evident from the Plaintiff’s affidavits in support, Mr Chong told this court the fish farm business was in operation during this period. Apparently, the Plaintiff uses the term “Property” in the Summons to refer to the Lots.

28.The basis of the Plaintiff’s request is set out in Deane 4th at paragraph 7:

“The reason the Plaintiff requests discovery of the paragraph 1 documents is that I am informed by my wife, Chong Chew Then, and verily believe that from her interviews conducted with Madam Chu Kit Ha (“Madam Chu”) (who was involved in operating the fish farm business at the Property during the period from 1981 to 2006) that there were extensive dealings and correspondence between her and the fish farm business and Government Departments in relation to the operation of the business during the period that it was open.  These dealings and correspondence included regular visits and checks by the Fire Department and the Food and Environmental Hygiene Department (and/or its predecessors) to ensure the safety and hygiene of the business and dealings with the Lands Department and Building Authority in relation to extension and improvement works carried out by Madam Chu and her previous owner to the house at the Property (including the addition of a second storey).  None of the documents relating to the safety and hygiene of the fish farm business has been discovered and I believe that only some of the documents have relating to the dealings between the Lands Department and Building Authority in relation to extension and improvement works have been discovered by the Defendant... Hence, it is much more likely that the Defendant has them.  All these documents relate to the issue of liability in relation to the Plaintiff’s claim against the Defendant in this action.” (emphasis added)

29.Mr Chong, relying on the fact that the Defendant has disclosed some documents relating to the Government’s dealings with Madam Chu on the fish farm business, submits that the Defendant has impliedly conceded their relevance. Mr Chong further submits that the documents sought to be disclosed forms part of a chainof correspondence/exchange between the various Government Departments and Madam Chu and/or her solicitors, and should be disclosed.

30.In the view of this court, that is a non-point. The fact that the Defendant has disclosed some documents only means those documents actually disclosed are accepted by the Defendant (or rather its legal advisers) as relevant. It cannot, without more, mean those documents not disclosed are also relevant.

31.Ifthe Plaintiffhad put the documents disclosed by the Defendant before this court and if Mr Chong can demonstrate to this court that what has been disclosed and what the Plaintiff now seeks in paragraph 1 of the Schedule indeed form a chain of correspondence/ exchange between the Government Departments and Madam Chu and/or her solicitors, then perhaps he may have a point.

32.However, the fact is that documents disclosed by the Defendant have not been put before this court - what is exhibited to Deane 4th and hence before the court is simply (i) the 3 lists of documents filed by the Defendant in this action; and (ii) correspondence between the parties’ solicitors on the adequacy or otherwise of the Defendant’s discovery. No efforts, genuine or otherwise, have been made by the Plaintiff or its legal team to demonstrate to this court.

(1) the existence of a chain of correspondence/exchange between the various Government Departments and Madam Chu and/or her solicitors throughout the entire 25-year period from February 1981 to October 2006;

(2) the relevance of the alleged chain of correspondence/exchange between the various Government Departments and Madam Chu and/or her solicitors, as a class of documents, to the issue(s) in the proceedings.

33.As far as existence is concerned, Mr Chong submits at paragraph 17 of his skeleton submission that, given the documents disclosed by the Defendant in its 2nd Supplemental List of Documents coupled with Chong 2nd as to what Madam Chong had been told by Madam Chu, the existence of the documents sought in paragraph 1 of the Schedule has been shown and proved.

34.With respect, that is a non sequitur.

35.To start with, it is unclear to this court how one can just look at a list of documents and infer that more documents are in existence and have not been disclosed.  If the documents themselves have been put before the court, and those documents, on their face, refer to some other documents, then an inference that more has yet to be disclosed might be drawn. But that is not the case here.

36.Further, little weight can be placed on Chong 2nd as to what she has been told by Madam Chu. The reasons are these.

37.In Chong 2nd, Madam Chong said she had 2 telephone conversations with Madam Chu and had been told that (i) the Police, the Food and Environmental Hygiene Department, the Health Department and the Fire Department often paid visits to the fish farm to ensure the “cleanliness and safety/security of the [fish farm] business” because it was an important supplier of food to the local restaurants - their visits were to ensure the operation was not going to cause a health problem; and (ii) Madam Chu had added a storey to the house on the Property and subsequently a demolition order was served in 2003 – she had spent a lot of time visiting government officials to resolve the case. 

38.However, Madam Chu denies she has ever given Madam Chong the above information.  In a letter dated 28 January 2014 from Madam Chu’s solicitors Messrs Liu Chan & Lam (“LCL”) to the Plaintiff’s solicitors, LCL said at page 2:

“In Paragraph 5 of his Affidavit, Mr. Deane said that Madam Chu had ‘indicated’ to his wife Madam Chong Chew Then that she (Madam Chu), Mr. Aaron Chan, EMS. and our firm had had many and regular dealings with several Government departments in relation to the fish farm at the Property from 1981 until 2006 and in relation to building works that she carried out to the Property from 1999 until 2006. Madam Chu categorically denies having made such an indication. Madam Chu does not know Madam Chong and had not told her much about the Property. ” (emphasis added)

39.As far as relevance is concerned, one simple example can illustrate the difficulties of the Plaintiff’s case.  Suppose for the sake of argument there are correspondence between the Fire Department and the Food and Environmental Hygiene Department on the one hand and the Chus on the other.  In all probabilities, these correspondence, if exist, would only be concerned with the safety and hygiene of the fish farm business.  How these correspondence can conceivably relate to the issues in the proceedings which are adverse possession, acknowledgments of the Government’s title, occupation with Government’s consent since 1982 and so on is unclear from Mr Chong’s skeleton submission.

40.But that is not all.

41.If one reads paragraph 1 of the Schedule carefully, one will find that the Plaintiff is in fact seeking three different classes of documents:

(1) all correspondence, emails etc. between all Government Departments (including but not limited to the seven identified) and the Chus (“Class 1”);

(2) internal emails, memoranda etc. within each Government Department (including but not limited to the seven identified) (“Class 2”); and

(3) internal emails, memoranda etc. between each Government Department (including but not limited to the seven identified) (“Class 3”);

from February 1981 to October 2006 in connection with the fish farm business.

42.As far as Classes 2 and 3 are concerned, there was no attempt by the Plaintiff to demonstrate to this court why these internal emails, memoranda etc. within any Government Department or between any two (or more) Government Departments during the 25‑year period, if exist, are relevant to any of the issues in the proceedings.

43.Take another example: emails, memoranda etc. within the Fire Department. Common sense dictates that these internal emails, memoranda etc., if exist, would only be concerned with the Fire Department’s own area of responsibility ie issues of fire safety of the Structures used in connection with the fish farm business.  If the Plaintiff seeks specific discovery of these documents, it has to demonstrate why they are also relevant to questions of adverse possession, acknowledgments of the Government’s title, consent and so on. On this question, Mr Chong’s skeleton submission is silent save for the fact that the Defendant has disclosed some documents relating to the Government’s dealings with Madam Chu on the fish farm business.

44.In the view of this court, if the Plaintiff chooses to cast the net so wide as to encompass documents “which are now or, have at any time been, in the possession, custody, control or power of any department, agency, bureau, division or arm”[3] of the Government for the entire 25‑year period in question and which are not demonstrably relevant to the issues in this case, it runs the risk of its request being considered a fishing exercise, oppressive, not necessary for disposing of the case fairly or for saving costs and inimical to the objectives of cost effectiveness, expeditious disposal of cases, proportionality, procedural economy and ensurance of fairness between the parties under the CJR. That is how this court considers paragraph 1 of the Schedule.

45.For these reasons, this part of the application fails.

Paragraph 2 of the Schedule

46.Paragraph 2 of the Schedule seeks:

“Those of the documents numbered (1) to (173) (inclusive) referred to in the left hand column of, and elsewhere in, the 104 pages of ‘Minutes’ discovered by the Defendant’s solicitors in their letter to the Plaintiff’s solicitors of 29 August 2013 not disclosed by the Defendant in her Second Supplemental List of Documents filed on 6 December 2013, and all other internal memoranda/notes of the Hong Kong Housing Authority/Lands Department up to the present day in relation to the Property and its owners”.

47.This paragraph actually encompasses two sub-categories of documents ie:

(1) Documents numbered (1) – (173) referred to in the 104‑page “Minutes” disclosed by the Defendant’s solicitors in their letter dated 29 August 2013 (“Minutes Documents”); and

(2) Other internal memoranda and notes of the Hong Kong Housing Authority and Lands Department in relation to the Lots and their owners up to the present (“HA/LD Internal Memo”).

48.The basis of the Plaintiff’s request is set out in Deane 4th at paragraph 8:

“In the Defendant’s solicitors letter of 6 December 2013, they say that relevant undisclosed documents have either already been disclosed, are irrelevant or are privileged, yet provide no details of which ones have already been disclosed, which ones are irrelevant and why and which ones are privileged and why. These documents may relate to the issue of liability in relation to the Plaintiff’s claim against the Defendant in this action.” (emphasis added)

49.There is no further explanation of the relevance of these numbered documents in either Deane 4th or Deane 5th.

50.Regarding the Minutes Documents, the Defendant’s stance, as explained in the Affirmation of Chung Ka Wah Lawrence (“Chung 1st”) is that most of them have already been disclosed under its 2nd Supplemental List of Documents dated 6 December 2013 and it has a valid explanation for the non-disclosure of the remaining ones:

(1) Some of the documents referred to in the Minutes were not disclosed on 6 December 2013 because they have already been disclosed previously either by the Plaintiff or the Defendant.

(2) A total of 8 items of the documents are irrelevant to the present proceedings.

(3) The remaining documents are subject to legal professional privilege. 

51.Regarding those documents already disclosed by the parties one way or another, Mr Chong does not press for them.

52.Regarding the 8 documents said to be irrelevant, Mr Chong complains that the Defendant has failed to explain the factual basis on which they are said to be irrelevant.  He therefore asks this court to make an order for their discovery on the ground that they form part and parcel of the Minutes disclosed. Mr Chong submits that as a matter of law, “a document referred to in adiscovered documentis deemed to be relevant until the contrary is shown”: Ormerod, Grierson & Co. v. St. George’s Ironworks (1906) 95 L.T. 964; Irish Agricultural Society v. M’Cowan (1913) 47 Ir. L.T. 20; Kent Coal Concessions v. Duguid [1910] 1 KB 904.

53.This court has considered the authorities cited by Mr Chong but does not regard them as supportive of the breadth of the legal proposition put forward.

54.Irish Agricultural Society v. M’Cowan supra was an action of slander in which the financial position of the plaintiffs was one of the issues. The plaintiffs had included in their affidavit of documents their balance sheet but not the documents on which it was compiled.  The Court ordered the plaintiffs to make a further and better affidavit on the ground that the admission of the former to be relevant necessarily involved an admission that the latter was also relevant.

55.Similarly, in Kent Coal Concessions v. Duguid supra, the plaintiff company, in pursuance of an order for discovery, had made an affidavit disclosing its directors’ reports and balance sheets which on their face were derived from books of account belonging to the plaintiff company. The English Court of Appeal held the plaintiff was bound to disclose such portions of the books of account as related to the matters set out in the balance sheets and directors’ reports on the ground that the balance sheets were worthless without the books from which they had been made up and once the balance sheets were admitted to be relevant, so much of the books as was the foundation of the balance sheets was also admitted to be relevant. 

56.In the present case, the Plaintiff has not attempted to explain to this court how the Minutes or the 173 numbered documents referred to in them relate to the issues in the action. The Plaintiff has not attempted to argue that the 8 documents in issue are the foundation of the Minutes without which the Minutes would be worthless or unintelligible. The Plaintiff has not even placed the Minutes before this court – it was only upon the request by this court at the hearing that the Plaintiff provided a few pages of them to this court - the few pages simply show that numbered documents appear on their face, period. They are not self-explanatory; nor are the numbers dotted around those pages. At the end of the day, this court is left with a bald assertion from the Plaintiff that all the numbered documents form part of the Minutes, they are deemed to be relevant and should be disclosed.

57.In the view of this court, the fact that certain documents are referred to in the Minutes disclosed does not without more mean they are relevant to the issues in the action. The relevance of a document is fact‑sensitive and there should be no room for the application of any doctrine of “deemed” relevance as suggested by the Plaintiff. The burden remains on the Plaintiff to establish a prima facie case that those documents not disclosed by the Defendant relate to a matter in issue in the action.

58.The matter can also be tested this way.

59.It is well-established and has long been the practice that a party is entitled to cover up parts of a disclosed document which he considers to be irrelevant. If, as common sense dictates, parts of a disclosed document can be considered irrelevant to the issues in the action, there is no reason why documents referred to in a disclosed document (or some of them) cannot. It would be otherwise if the court is satisfied from the documents disclosed, from anything in the Plaintiff’s or the Defendant’s affidavits, or necessarily from the circumstances of the case that the documents withheld by the Defendant in the present case are relevant to the issues in the action. But this court is not so satisfied.

60.Regarding the request for the privileged documents, it suffers the same deficiency as the request for the 8 documents ie the Plaintiff has not attempted to explain to this court how they relate to any issues in the action – it merely relies on the fact that they are referred to in the Minutes disclosed.

61.Further, it is well-established that a statement on oath as to the ground given in support of a claim for privilege is conclusive and the party seeking discovery could not adduce evidence to show that the statement is insufficient or is untrue: Hong Kong Civil Procedure 2014 Vol. 1 para. 24/7/1. In the present case, Mr Deane of the Plaintiff is not suggesting that Mr Chung lied when he claimed the documents in question were subject to legal professional privilege. Nor is he suggesting that Mr Chung has proceeded on a misconception of the law. Mr Deane is simply saying without sight of the documents, it is impossible for him to verify the claim for privilege. That, in the view of this court, is hardly sufficient to “override” the Defendant’s claim to privilege.

62.Lastly, regarding the HA/LD Memo, Mr Chong’s submission consists of these two paragraphs:

“42. This category does not add anything further than the documents referred to in the Minutes concerning the Government’s dealing with the Land Lots save and apart from internal documents explaining how the correspondence came into existence.

43. Should they form part and parcel of documents concerning any of the 5 issues, it is submitted that, irrespective of P’s present application, D would, nevertheless, be obliged to discover the same under the system of voluntary mutual discovery.”

63.There is no further explanation in Mr Chong’s skeleton submission as to what “correspondence” he was referring to in paragraph 42, exactly which of these internal documents explain how such correspondence “came into existence” and in what respects these internal documents are able to explain “how the correspondence came into existence”. In the view of this court, the Plaintiff has not even begun to demonstrate the relevance of the HA/LD Memo to any matter in issue in the action or their discovery is necessary for the fair disposal of the cause or matter or for saving costs.

64.Moreover, the Plaintiff has not placed any temporal limit to its request for the HA/LD Memo. Strictly speaking, if this court were to accede to the request, the Defendant will have to dig into the whole database of the Housing Authority and the Lands Department from inception up to the present day to search for records relating to the Property and its owners.  In the view of this court, this part of the Plaintiff’s application is clearly oppressive and fishing.  

65.For the above reasons, this part of the application fails.

Paragraphs 3, 4 and 5 of the Schedule

66.These three paragraphs can be dealt with together as they all seek a specific document from the Defendant ie a letter from the Hong Kong Housing Authority to Madam Chu dated 25 February 2004 (para. 3); a Notice under section 6(1) Land (Miscellaneous Provisions) Ordinance posted by the Hong Kong Housing Authority on the Property on 25 February 2004 (para. 4); the response by the Lands Department to a letter from LCL dated 3 June 2005 (para. 5).

67.The Defendant’s response in correspondence and subsequently confirmed on oath (in the form of Chung 1st) is in substance the same - it does not have the document, whether original or copy, after search. On the authorities, this is a sufficient answer to the Plaintiff’s application for specific discovery: Hong Kong Civil Procedure 2014 Vol. 1 para. 24/7/1; Tai Fook Futures Ltd v Cheung Moon Hoi Jeff supra.

68.While the Plaintiff asserted in paragraphs 9 to 11 of Deane 4th that this is difficult to believe, with respect to Mr Deane, his belief is irrelevant for the present purpose: courts, in the exercise of their discretion, do not make an empty order for specific discovery: Berkeley Administration Inc v McClelland [1990] FSR 381 at 382-3.

69.Further, with regard to paragraph 5 of the Schedule, it is pointed out by the Defendant that LCL’s letter dated 3 June 2005 was addressed to the Housing Department and not the Lands Department.  The Defendant submits and this court agrees that the Plaintiff has failed to show the Lands Department has in fact replied to LCL’s said letter. In other words, the Plaintiff has failed to show a prima facie case of “existence” of the document sought in the first place.

70.For these reasons, this part of the application fails.

Paragraph 6 of the Schedule

71.Paragraph 6 of the Schedule seeks:

“Copies of all correspondence, emails, memoranda, notes, plans, notices, agreements and other documents passing between the Lands Department and the Hong Kong Police in relation to the Lands Department’s enforcement action against the Property on 20 and 21 August 2012 and all records, memoranda and notes of the Lands Department and the Hong Kong Police in relation to such action”.

72.In paragraph 12 of Deane 4th, Mr Deane said:

“…In particular, I believe Police records of the enforcement action may be relevant to a consideration of the Defendant’s conduct of the enforcement action…These documents are relevant to the issue of liability and quantum in relation to the Plaintiff’s claim against the Defendant in this action.”

73.To start with, this court has difficulty understanding why the Defendant’s conduct of the enforcement action in August 2012 is said to be an issue in the action. On the parties’ pleaded cases, it is common ground that the Lands Department did take enforcement action at the Property (and/or the Land surrounding it) on or about 21 August 2012.  It is also not disputed by the Defendant that the Lands Department did carry out or attempt to carry out certain demolition works to the structures, most notably the iron gate on the site. The only issue between the parties is whether this was lawful land control action pursuant to the Land (Miscellaneous Provisions) Ordinance, Cap 28, which in turn depends on whether the Plaintiff can establish a squatter’s title to the Land: see paragraph 24 of the amended Statement of Claim and paragraph 19 of the amended Defence and Counterclaim.

74.If and in so far as the Plaintiff is seeking to find out whether the Police has recorded anything which suggests the land control action was or might have been unlawful, this is clearly fishing and not necessary for disposing of the case fairly or for saving costs.

75.This court also has difficulty understanding how the documents sought are relevant to the issue of quantum of the Plaintiff’s claim for damages. According to the particulars of damages pleaded in paragraph 25 of the amended Statement of Claim, the Plaintiff is seeking from the Defendant the costs of reinstatement of the iron gate and the Stone Wall. It is inherently improbable that the Lands Department and the Police would discuss such matters in their exchanges but the bottom line is that the burden is on the Plaintiff to show a prima facie case of relevance and the Plaintiff has failed in this regard.

76.The Defendant’s short answer to this request is that other than a handful of memos and emails which have been disclosed, it does not have any other documents relating to the enforcement action: paragraphs 67 and 69 Chung 1st.  On the authorities, this is a sufficient answer to the Plaintiff’s application for specific discovery: Hong Kong Civil Procedure 2014 Vol. 1 para. 24/7/1; Tai Fook Futures Ltd v Cheung Moon Hoi Jeff supra.

77.For these reasons, this part of the application fails.

Paragraph 7 of the Schedule

78.Paragraph 7 of the Schedule seeks:

“All internal emails between staff within Government departments and between different Government departments relating to the Government’s dealings with the Property and its owners from 1 January 1999 to 21 August 2012 other than those emails that have already been disclosed”.

79.From its wording, this paragraph substantially overlaps with Classes 2 and 3 [4] of Paragraph 1 of the Schedule, save that the period in question has changed from February 1981 – October 2006 to January 1999 – August 2012. According to Mr Chong, January 1999 was the time when the fish farm business under the control of Madam Chu was in “active operation”.

80.In paragraph 13 of Deane 4th, Mr Deane, after complaining that the Defendant has only disclosed a few emails during the period in question when there should have been many more, said:

“…These documents relate to the issue of liability in relation to the Plaintiff’s claim against the Defendant in this action.”

81.In the view of this court, this request suffers the same deficiency as the request under Paragraph 1 of the Schedule.  There was no attempt by the Plaintiff to demonstrate to this court the existence of these internal emails other than those already disclosed or why these emails within any Government Department or between any two (or more) Government Departments during the 13‑year period, if exist, are relevant to any of the issues in the proceedings.

82.Again, if the Plaintiff chooses to cast the net so wide as to encompass documents which would clearly be irrelevant to the issues in this case, for instance, internal emails among staff of the Fire Department or the Health Department, it runs the risk of its request being considered a fishing exercise, oppressive, not necessary for disposing of the case fairly or for saving costs and inimical to the objectives of cost effectiveness, expeditious disposal of cases, proportionality, procedural economy and ensurance of fairness between the parties under the CJR. That is how this court considers paragraph 7 of the Schedule.

83.For these reasons, and for reasons stated in relation to Paragraph 1 of the Schedule, this part of the application fails.

Disposition and Costs Order nisi

84.In the exercise of its discretion, this court hereby dismisses the Plaintiff’s application. There shall be an order nisi that costs be to the Defendant, to be taxed if not agreed.

(Peter Ng)
Judge of the Court of First Instance
High Court

Mr K M Chong, instructed by Deacons, for the plaintiff

Ms Teresa Wu, instructed by Secretary for Justice, for the defendant



[1] The term is intended to include the Colonial Hong Kong Government before 1 July 1997 and the Government of the Hong Kong SAR on and after 1 July 1997. 

[2] Structure 1 in the Schedule G Plan is the Stone Wall.

[3] See para.1 of the Summons.

[4] See paragraph 41 above.