HD Hyundai Infracore China Co., Ltd v Li Zhiwei

is one of the first cases on registering a PRC ruling under this new Ordinance. The ruling was an order for payment of money given in PRC criminal proceedings in favour of the Plaintiff who was a victim of fraud. The Judge granted the registration application.

Enacted in January 2024, the new Ordinance significantly expands the enforcement of Mainland Chinese judgments in Hong Kong. There is no longer a requirement for exclusive jurisdiction clauses and the types of judgments which may be enforceable are broader in scope. As this case illustrates, it is now possible to enforce a judgment given in Mainland Chinese criminal proceedings containing an order for payment of a sum of money in respect of compensation or damages by a party.

The Plaintiff was defrauded of RMB 190 million, and the fraudsters were convicted in PRC criminal proceedings. One of the fraudsters had assets in Hong Kong. In 2023, the Intermediate People’s Court (IPC) handed down an enforcement ruling, stating: (a) leaving aside Hong Kong assets, only assets of around RMB 24.9 million could be located and recovered in the PRC; (b) the enforcement proceedings would be terminated, but may be resumed if there was new information to facilitate recovery.

After the Ordinance came into force in January 2024, the Plaintiff applied to the IPC to resume the enforcement proceedings. The IPC agreed to do so. On 23 October 2024, the IPC issued an enforcement ruling (2024 Ruling), stating the outstanding balance of RMB 162 million and ordered the fraudsters to pay the sum.

, the requirements under the Ordinance and issues relating to the registrability of the 2024 Ruling. In light of the expert evidence adduced, the Judge concluded that the order for payment in the 2024 Ruling was registrable and that it was independent of the underlying criminal judgments.

, instructed by RPC on 11 June 2025 and White & Case on 26 August 2025, appeared for the Applicant in HCRE 84/2024 and the Plaintiff in HCMP 785/2024.

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A New Regime - the Mainland Judgments in Civil and Commercial Matters (Reciprocal Enforcement) Ordinance (Cap. 645)

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