Temple Chambers is delighted to announce that Lord Sales, Deputy President of the Supreme Court of the United Kingdom, will deliver the HKU-Temple Chambers Law Lecture on 24 September 2026.

The lecture, entitled: “The Role of Equity in the Law of Contract”, will address the distinct moral foundations of contract law and Equity, and how contract law and Equity interact as legal categories. Contract draws on the morality of promise-making and also the morality of reasonable reliance, which is the foundation for the objective approach to the interpretation of contracts. The theme of the lecture is that Equity operates as a corrective mechanism to bring contract back into line with the requirements of promise-based morality when the balance struck by contract law in its objective approach to interpretation and enforcement of contracts unjustifiably departs from that morality. The lecture will address substantive doctrines such as fraud on a power and relief from forfeiture as well as remedies in contract and Equity.

The HKU–Temple Chambers Law Lecture series began in 2024. Previous speakers have included Lord Briggs of Westbourne and Lord Richards of Camberwell of the Supreme Court.

Lord Sales was appointed a Justice of the Supreme Court in January 2019, and took up appointment as Deputy President of the Court in January 2026. He was educated at the Royal Grammar School in Guildford, before reading law at both Churchill College, Cambridge, and Worcester College, Oxford. He was called to the Bar of England and Wales at Lincoln's Inn in 1985 and was appointed First Treasury Junior Counsel in 1997. He was an Assistant Recorder from 1999 to 2001, Recorder from 2001 to 2008, and Deputy High Court Judge from 2004 to 2008. Lord Sales became a Queen's Counsel in 2006 and continued to act in the re-named post of First Treasury Counsel (Common Law) until his appointment to the High Court, Chancery Division in 2008. He was a member of the Competition Appeal Tribunal between 2008 and 2015, and Vice-President of the Investigatory Powers Tribunal between 2014 and 2015. Between 2009 and 2014, Lord Sales served as Deputy Chair of the Boundary Commission for England. He was appointed as a Lord Justice of Appeal in 2014.

Academic Conference Room, 11/F Cheng Yu Tung Tower, The University of Hong Kong

If you would like to attend, please register via the QR code in the poster.

[2026] HKCFI 4283, the Court of First Instance found a joint liquidator guilty of five counts of contempt of court for giving false evidence – once in an affirmation and four times during the giving of evidence under cross-examination in previous proceedings.

The Defendant, acting as a joint and several liquidator of NHD Systems (Asia) Ltd, caused the company to sue the Plaintiff for the recovery of an alleged loan. That action was dismissed at trial after the Court acceded to the Plaintiff’s submission of no case to answer.

The Plaintiff subsequently brought committal proceedings. Harris J found that the Defendant had either knowingly or recklessly given false evidence on multiple occasions in the earlier action – including falsely claiming he believed the company’s accounts were lost (having made no adequate attempt to search for them) and misrepresenting his understanding of well-established discovery obligations. In reaching this conclusion, the Court bore in mind the Defendant’s considerable experience in insolvency litigation.

The judgment provides important clarifications on the law of contempt by false evidence:

: The substantive requirements for common law contempt by false evidence and Order 41A r.9 contempt (false statement of truth) are identical.

: A specific intention to interfere with the administration of justice is unnecessary. It is sufficient that the statement maker had no honest belief in the statement’s truth and knew it was likely to interfere with the administration of justice.

: A complete lack of honest belief can be established if the statement maker was reckless as to whether the statement was true.

The judgment also serves as a cogent reminder that liquidators, as officers of the court, are held to the highest standards of candour and diligence.

See also the earlier judgment of the Court of Appeal ([2026] HKCA 912) dismissing the Defendant’s proposed appeal against Harris J’s refusal to recuse himself, which clarifies the principles on recusal on grounds of apparent bias: 

, instructed by Anthony Siu & Co, acted for the Plaintiff.

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