Temple Chambers is delighted to announce that Lord Sales, Deputy President of the Supreme Court of the United Kingdom, will deliver the HKU-Temple Chambers Law Lecture on 24 September 2026.

The lecture, entitled: “The Role of Equity in the Law of Contract”, will address the distinct moral foundations of contract law and Equity, and how contract law and Equity interact as legal categories. Contract draws on the morality of promise-making and also the morality of reasonable reliance, which is the foundation for the objective approach to the interpretation of contracts. The theme of the lecture is that Equity operates as a corrective mechanism to bring contract back into line with the requirements of promise-based morality when the balance struck by contract law in its objective approach to interpretation and enforcement of contracts unjustifiably departs from that morality. The lecture will address substantive doctrines such as fraud on a power and relief from forfeiture as well as remedies in contract and Equity.

The HKU–Temple Chambers Law Lecture series began in 2024. Previous speakers have included Lord Briggs of Westbourne and Lord Richards of Camberwell of the Supreme Court.

Lord Sales was appointed a Justice of the Supreme Court in January 2019, and took up appointment as Deputy President of the Court in January 2026. He was educated at the Royal Grammar School in Guildford, before reading law at both Churchill College, Cambridge, and Worcester College, Oxford. He was called to the Bar of England and Wales at Lincoln's Inn in 1985 and was appointed First Treasury Junior Counsel in 1997. He was an Assistant Recorder from 1999 to 2001, Recorder from 2001 to 2008, and Deputy High Court Judge from 2004 to 2008. Lord Sales became a Queen's Counsel in 2006 and continued to act in the re-named post of First Treasury Counsel (Common Law) until his appointment to the High Court, Chancery Division in 2008. He was a member of the Competition Appeal Tribunal between 2008 and 2015, and Vice-President of the Investigatory Powers Tribunal between 2014 and 2015. Between 2009 and 2014, Lord Sales served as Deputy Chair of the Boundary Commission for England. He was appointed as a Lord Justice of Appeal in 2014.

Academic Conference Room, 11/F Cheng Yu Tung Tower, The University of Hong Kong

If you would like to attend, please register via the QR code in the poster.

Re Ourgame International Holdings Limited 

[2026] HKCFI 4671, Harris J granted recognition and managerial assistance to Cayman-appointed liquidators of a company whose centre of main interests (COMI) was outside the Cayman Islands, but declined to grant the full range of assistance that may be available to foreign office-holders appointed in the company’s COMI.

The decision clarifies the approach to recognition and assistance where the foreign insolvency process was not opened in the company’s COMI.

Harris J held that the primary criterion for recognition and assistance is whether the foreign collective insolvency process was opened in the company’s COMI. Where this is so, recognition and assistance may be granted under established common law principles of modified universalism.

By contrast, where a collective insolvency proceeding is opened in the company’s place of incorporation, but that jurisdiction is not its COMI, the Court may nevertheless recognise the foreign liquidator and grant managerial assistance – described by Harris J as “agentic powers”. This is founded on the juridical basis that, under ordinary private international law principles, the law of the place of incorporation governs matters concerning a company’s constitution, internal management, and the identity and powers of those responsible for administering its affairs.

There is accordingly an important difference between recognition of a foreign insolvency process under modified universalism which depends on the proceedings having been opened in the company’s COMI, and recognition of an office-holder appointed under the law of the company’s place of incorporation based on ordinary private international law principles.

Harris J observed that the summary of principles set out by Linda Chan J at §59 of 

 [2026] HKCFI 1320 presupposes this distinction, given Linda Chan J’s agreement with 

 [2022] 5 HKC 485 at §50 of the judgment.

Finally, Harris J noted that, if the foreign liquidators require powers available to a Hong Kong liquidator, they may consider applying to wind up the company in Hong Kong.

, instructed by Slaughter & May, appeared for the Applicants.

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