Cases Civil

CFI granted Interim Injunction against Director of Lands to restrain him from obtaining possession of two pieces of land wanted for MTR Northern Link Project

23 Mar 2026

๐‘ฏ๐‘ช๐‘จ๐‘ณ 592/2026 ๐‘บ๐’‰๐’Š๐’– ๐‘ฉ๐’Š๐’–, ๐’ƒ๐’š ๐’‰๐’Š๐’” ๐’…๐’‚๐’–๐’ˆ๐’‰๐’•๐’†๐’“ ๐’‚๐’๐’… ๐’๐’†๐’™๐’• ๐’‡๐’“๐’Š๐’†๐’๐’…, ๐‘บ๐’Š๐’– ๐‘ด๐’†๐’† ๐‘ฒ๐’–๐’†๐’ ๐’— ๐‘ซ๐’Š๐’“๐’†๐’„๐’•๐’๐’“ ๐’๐’‡ ๐‘ณ๐’‚๐’๐’…๐’” ๐’‚๐’๐’… ๐’๐’•๐’‰๐’†๐’“๐’”

Last Friday, Coleman J granted an interim injunction to restrain the Director of Lands (โ€œDirectorโ€) from enforcing a notice (โ€œNoticeโ€) under Land (Miscellaneous Provisions) Ordinance (Cap.28) against an occupant of two pieces of land (โ€œSubject Landsโ€). In ongoing proceedings against the Government, it is the occupantโ€™s case that he has, by virtue of sections 7 and 17 of Limitation Ordinance (Cap.347), extinguished the Governmentโ€™s title in the Subject Lands and has become a freeholder thereof.

Although the Director is keen to obtain possession of the Subject Lands to kickstart construction work for the MTR Northern Link Project, Cap.28 only gives the Director โ€œself-helpโ€ remedies to repossess unleased Government land. Hence, the Director acted ultra vires of Cap.28 when issuing the Notice against the Subject Lands since they are no longer โ€œGovernment landโ€. Instead, the Director ought to have acquired the Subject Lands pursuant to the statutory mechanism set out in Land Acquisition (Possessory Title) Ordinance (Cap.130).

This case involves the novel question of when and how the Director should invoke Cap.130 when facing an adverse possession claim against the Government, and the interaction between Cap.130, Cap.28 and Cap.347.

The substantive hearing of the injunction summons together with the rolled up hearing of application for leave to apply for judicial review and the substantive application for judicial review will be heard on 8 June 2026.

Ernest Ng,ย  Raphael Leung and Joshua Lai instructed by Kenny Chun of Messrs. Y.T. Chan & Co., acted for the Applicant.