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Hong Kong articles of associationminority protection

Chin Choon Onn and Jong Yai Kit v Lai Sum Hung & Ors

[2026] HKCA 149
JurisdictionHong Kong
CourtHK Court of Appeal
Year2026
StatusBinding authority

Summary

Director appointments and share allotments that are not properly executed may be declared invalid by the court.

Key Principle

Director appointments and share allotments can be declared invalid if not properly executed.

Area of Law

company

Related Cases

Shafron v Australian Securities and Investments Commission (2012) 247 CLR 465

A company secretary is an 'officer' under the Corporations Act and owes a duty of care and diligence under s 180 in performing their functions.

Bell Group Ltd (in liq) v Westpac Banking Corporation [2012] WASCA 157

Directors of an insolvent company owe duties to creditors, and bank claims may be subordinated where unconscionable conduct is established in dealings with the insolvent company.

Barclay v Penberthy (2012) 246 CLR 258

The standard of care under s 180 of the Corporations Act is that of a reasonable person in the director's position, having regard to the corporation's circumstances and the director's office.

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