Sun Tian Gang v Changchun High & New Technology Industries Development Parent Company

 [2025] HKCA 188 gave important guidance on the application of s.26 of the Limitation Ordinance in cases involving deliberate concealment.

The appeal arose from a trial of preliminary issues concerning whether the running of time for 

 time-barred claims – sought to be added to existing claims by way of amendment – could be postponed under s.26. The preliminary issues before the judge were: (1) whether there was deliberate concealment of facts relevant to the new causes of action; and (2) if so, when the concealed facts were discovered or could with reasonable diligence have been discovered by the plaintiff in respect of two transactions.

In dismissing the plaintiff’s appeal and the defendants’ cross-appeal, the Court of Appeal’s judgment clarified the interplay between ss.26(1)(b) and 26(3):

, led by Ambrose Ho SC, and instructed by Tanner De Witt, appeared for the plaintiff. 

 acted for the plaintiff in the trial below.

, leading Kerby Lau, instructed by Dentons Hong Kong LLP, acted for the 1

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