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Hong Kong land registrationlis pendensshare sale vs asset sale

Smart Edge Limited (Receivers and Managers Appointed) v HG Property Investment HK Limited

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

Key Principle

Instruments relating to the sale and purchase of shares in a company that holds real property do not create an interest in land and are therefore not registrable (including as a lis pendens) against the underlying property under the Land Registration Ordinance (Cap.128), in contrast to instruments dealing with the land itself.

Area of Law

property

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Re Li Sing Kui (deceased) [2025] HKCA 898 [2025] HKCA 898

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