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ARTICLE · 11 NOVEMBER 2026

Hong Kong And Singapore Diverge On Public Policy Exception

Des Voeux Chambers
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Despite sharing similar reciprocal enforcement frameworks, the Courts in Hong Kong and Singapore have recently taken different stances on whether enforcing a judgment arising from foreign gaming debts...

Hong KongLitigation, Mediation & Arbitration
Martin Lau
Martin Lau

Despite sharing similar reciprocal enforcement frameworks, the Courts in Hong Kong and Singapore have recently taken different stances on whether enforcing a judgment arising from foreign gaming debts violates their local public policy.

Hong Kong: Resorts World at Sentosa Pte Ltd v. Tsang Yeuk Kwan

In Resorts World at Sentosa Pte Ltd v. Tsang Yeuk Kwan [2026] HKCFI 4928, the Hong Kong Court was concerned with a S$10.38 million debt judgment rendered by the Singapore Court.  The underlying debt related to gambling activities which took place in a licenced casino in Singapore.

The debtor applied to set aside the registration under section 6(1) of the Hong Kong Foreign Judgments (Reciprocal Enforcement) Ordinance (Cap. 319), arguing that enforcing a gaming debt would violate Hong Kong public policy.

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