Goldjet Development Limited v Randal Alan Whitecotton & Anor [2025] HKCFI 5268

An adviser or agent who, through coercive and fraudulent conduct (including procuring the kidnapping of the company's authorised signatory), brings about an unauthorised transfer of the company's funds holds the misappropriated sum and its traceable proceeds as a constructive trustee and is liable to account for and repay them with interest.