Introduction
On 17 November 2025, the Hong Kong Court of Appeal delivered its reasons for judgment in Target Insurance Company Limited (in compulsory liquidation) v Nerico Brothers Limited [2025] HKCA 1024. In this ruling, the Court imposed personal costs liability on a company’s sole director for pursuing an appeal against a winding-up order that it deemed unarguable and an abuse of process.
Background
The petitioner, Target Insurance Company Limited, itself in liquidation, was an authorised insurer and covered around 60% of the taxi insurance market in Hong Kong in 2021. Prior to its own liquidation, Target had transferred around US$154m to a securities account with Nerico (the company). Following repeated failed demands for…