The Temple Chambers Moot 2025 was held on Saturday, 9 August 2025. This year’s moot problem centred on the “legitimate interest” test set out in 

White & Carter (Councils) Ltd v McGregor 

[1962] AC 413. Set in the context of a fictional dispute concerning a commercial rental agreement, teams addressed the question of whether liability in misrepresentation can arise if a statement of present intention as to future action is made negligently.

Teams from Hong Kong and UK universities presented arguments across three rounds. Judges praised the high standard of competition shown by all teams. We extend our heartfelt congratulations to all participants for their contributions to this memorable event.

The winning team – Ryan Li Hok Yu (who was also awarded Best Speaker) and Alric Wong Tung Fai – edged out Maurice Yim Man Leung and Timothy Chow Hoi Yan in the Grand Final, appearing before a panel comprising the Hon Mr Justice Thomas Au, Justice of Appeal (a former member of Chambers), 

Special thanks go to Mr Justice Au JA for graciously presiding over the final and sharing invaluable insights on advocacy in court proceedings. We would also like to thank 

 for judging the preliminary rounds of the Moot.

We look forward to welcoming another group of talented law students for the 2026 edition!

Rashid Safar Ghori v Secretary for Justice

 [2025] HKDC 1313, the Court considered a novel question concerning whether a non-refoulement claimant (NRC), after losing on 

, may still seek civil damages for alleged unlawful detention. This issue had not previously been addressed by the courts, either in Hong Kong or in other common law jurisdictions.

The Plaintiff, a NRC, sought damages for alleged unlawful detention. He had previously filed three unsuccessful 

 applications before the High Court. The Director argued that the Plaintiff was barred by 

 and abuse of process from bringing a civil claim based on the same detention.

After considering submissions from members of Chambers acting for the Director and as 

 appointed by the Court, Chief District Judge Ko held that 

 applies. In particular, the Court held that 

 decisions amount to judicial ‘decisions’, drawing a distinction with the situation in 

[1979] 1 WLR 1417 which concerned successive 

 applications for distinct or longer periods of detention. Here the Plaintiff sought a parallel civil claim over the very same facts and the same period already found lawful by the High Court.

The Court went on to observe that the historical foundations underpinning 

 have been rejected in subsequent cases and that, whatever their historical merit, those foundations have been overtaken by statutory intervention in Hong Kong.

applications and a civil claim for damages are of a different nature and purpose, citing the recent UKSC decision of 

The Father v Worcestershire County Council

 [2025] UKSC 1, and held that if the Plaintiff felt aggrieved, the proper course was to appeal the 

 decisions, not to bring a civil claim. The latter does not put his liberty in issue – the Court would not have jurisdiction to release him even if it were to award damages.

, instructed by Department of Justice, for the Secretary for Justice and the Director.

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