1. Injunctive Relief in
Family Law
9 October 2015
Azan Marwah
Shaphan Marwah
1

2. Schedule
1. Common Injunctions
2. Injunctions Relating to Children
3. Domestic Violence Injunctions
2

3. Common Injunctions
Part 1: General Issues
Part 2: MPPO Injunctions
Part 3: Mareva and Anton Piller
Part 4: Anti-suit Injunctions

4. Part 1
General Issues

5. Why Consider
Injunctions?
• Preserve property
• Obtain evidence
• Parallel proceedings
• Physical safety
5

6. Ex Parte Applications
• PD 11.1
• On affidavit
• Urgency
• Fixed return date
• Control service
• Full and frank disclosure
6

7. Ex Parte Undertakings
• Undertaking in damages (?)
• Notify the defendant
• Third party costs
• Issue proceedings
• Swear affidavit
7

8. Ancillary Orders
• Disclosure of documents
• Interrogatories
• Cross examination
8

9. Freezing Orders
• S.17(1)(a) MPPO, Cap. 192
• Mareva Injunctions
• Inherent Jurisdiction
9

10. Set-Aside Orders
• S.17(1)(b) and (c) MPPO, Cap. 192
• Alternatives
10

11. Part 2
MPPO Injunctions

12. MPPO, Cap. 192
• Hong Kong divorces (s.17)
• Foreign divorces (ss. 29AJ & 29AK)
12

13. s.17(1)(a) MPPO
Freezing Order
Four elements:
• with the intention of defeating the claim for financial
provision
• about to make
• disposition or transfer out or otherwise deal
• property
“make such order as it thinks fit for restraining the other
party from so doing or otherwise for protecting the
claim”
13

14. “Intent to defeat”
• Subjective test
• Usually draw inference
• Need not be dominant or sole intention
• Statutory presumption (s.17(3))
14

15. “About to make”
Question of fact
15

16. “Disposition”
• Widely defined (s.17(4))
“does not include any provision contained in a
will or codicil but… includes any conveyance,
assurance or gift of property of any description,
whether made by an instrument or otherwise”
16

17. “Or otherwise deal with”
Positive / Negative
?
17

18. “Property”
• Widely defined (s.2)
• HK/Overseas
• Beneficial interest
18

19. Proprietary Rights?
Re Mordant; Mordant v Halls [1997] 2 FCR 378
Sir Donald Nicholls VC:
“The words "or otherwise for protecting the claim" are
wide. I can see no justification for cutting them down so
as to exclude power to make an order which, when
carried out, will have the effect of making property
security for the claim in the same way as a sum paid into
court under R.S.C. Ord.14 or Ord.22. For instance, the
Judge may direct that a sum shall be paid into court to
await the outcome of a claim for financial provision.”

20. s.17(1)(b)
Four elements:
• with the intention of defeating the claim for financial
provision
• disposition
• property
• If the disposition were set aside different financial
provision would be granted to the applicant
“make an order setting aside the disposition and give such
consequential directions as it thinks fit for giving effect to the
order”
20

21. s.17(1)(c)
After a financial order has been obtained
21

22. Third Parties
Caution:
• TL v ML & Ors. [2006] 1 FCR 465 / LWYA v KYW CACV
151/2013, 4 December 2014
“(i) the third party should be joined to the proceedings at the
earliest opportunity;
(ii) directions should be given for the issue to be fully
pleaded by points of claim and points of defence;
(iii) separate witness statements should be directed in
relation to the dispute; and
(iv) the dispute should be directed to be heard separately as
a preliminary issue, before the [Financial Dispute
Resolution].”
22

23. Third Parties
Spouse’s agent, nominees and trustees

24. Third Parties
Doctrine of notice (s.17(2))

25. Effect of Setting-aside
Void or Voidable?
• Void ab initio: AC v DC & Ors [2013] 2 FLR 1499
• Voidable: HKCB Finance Ltd v Yuen Yi Wan
Sandy & Anor., DCMP 2017/2002, 29 November
2004
25

26. Procedure
Mode of commencing s.17 applications:
• Freezing order – summons with affidavit
(r.114 MCR )
• Set-aside order – notice of application for
ancillary relief with affidavit (r.74 MCR )
26

27. Foreign Divorces
With leave (s. 29AJ)
• Freezing orders and set-aside orders
Without leave (s. 29 AK)
• Freezing orders
27

28. Similar Provisions
28
Ordinance
s. 42 Bankruptcy Ordinance, Cap. 6 Restrictions on dispositions
s. 49 Bankruptcy Ordinance, Cap. 6 Transactions at an undervalue
s. 50 Bankruptcy Ordinance, Cap. 6 Unfair preferences
s. 118 Companies Ordinance, Cap. 622 Acts of directors
s. 725 Companies Ordinance, Cap. 622 Unfair prejudice remedies
Common law derivative action
s. 12 Inheritance (Provision for Family
and Dependants) Ordinance, Cap. 481
Dispositions intended to defeat
applications for financial provision

29. Part 3
Mareva / Anton Piller

30. O.29 Mareva Injunction
Elements:
• Substantive legal/equitable right
• Good arguable case
• Assets in the jurisdiction*
• Real risk of dissipation
• Balance of convenience*
30

31. Mareva v. s.17(1)(a)
MPPO
“real risk of dissipation” vs “intention of
defeating the claim”
“good arguable case” vs “balance of
probabilities”
Undertakings
Proprietary interest (?)
31

32. Procedure
• PD 11.1 / PD 11.2
• Ex parte affidavit
• Inter partes summons
• Undertakings
• Third parties
• Foreign proceedings

33. Looking Ahead
The Chief Justice’s Working Party on Family
Procedure Rules:
Recommendation 99 (Proposal 100)
Sections 17(1)(a) and 29AJ of the MPPO and Order
29 of the RHC/RDC should be combined and
incorporated into the New Code with all necessary
modifications.

34. Inherent Jurisdiction
Marital Property
Safeguards*
(Tan Li Cheng v Tan Kian Chee [1997] 4 HKC 94)
34

35. Anton Piller
Elements:
• Extremely strong prima facie case
• Serious actual or potential damage
• Clear evidence documents in respondent’s
possession
• Real possibility of their destruction

36. Caution
“Draconian” and “inherently oppressive”
Self-help / Breach of confidence
Immerman v Tchenguiz, Immerman v Immerman
[2011] Fam 116
36

37. Procedure
• PD 11.1 / PD 11.2
• Ex parte affidavit
• Inter partes summons
• Full and frank disclsoure
• Usually conducted by solicitor
• Follow strict terms of order
• No forced entry

38. Part 4
Anti Suit Injunctions

39. Anti Suit Injunctions
Domestic stay
Foreign anti-suit (Hemain) injunction
(Hemain v Hemain [1988] 2 FLR 388)
39

40. Domestic Stay
Inherent jurisdiction
Forum conveniens
40

41. Domestic Stay
SPH v SA (formerly known as SA) (2014) 17
HKCFAR 364:
“The single question to be decided is whether there
is some other available forum, having competent
jurisdiction, which is the appropriate forum for the
trial of an action i.e. in which the action may be tried
more suitably for the interests of all the parties and
the ends of justice?”

42. Test
Applicant to prove:
• Hong Kong does not have most real and substantial
connection
• There is another forum clearly more appropriate than
Hong Kong
Respondent to prove:
• Deprivation of a legitimate personal or juridical
advantage
Court will balance

43. Procedure
Inter partes by summons
Avoid delay!

44. Hemain Injunction
Inherent jurisdiction
Declarations/ancillary relief
Operates in personam
Where the “ends of justice” require
44

45. “Ends of Justice”
Hong Kong is the ‘natural forum’
Foreign proceedings are vexatious or oppressive
(Delay / prejudice / forensic advantage)

46. Procedure
Ex parte affidavit
Inter partes summons

47. Injunctions Relating to
Children

48. QUESTIONS PLEASE!

49. Introduction / Structure
1. Overview of injunctions relating to children
2. Basic principles
3. Jurisdiction and forum
4. Non-removal orders (and alternatives)

50. Part 1: Overview

51. Varieties of Injunctions (1)
Interlocutory / Final
Temporary / Permanent
Against Parents / Third parties / Non-parties
Mandatory / Prohibitory

52. Varieties of Relief (2)
Wide variety of relief:
• Removal/non-removal from HK
• Surrender of children’s identity documents
• Medical treatment
• Education
• Institutional care, supervision
• Confidentiality and publications related to children

53. Where to begin (3)
Depends upon the forum and jurisdiction
• High Court vs Family Court
• Statutory vs Inherent jurisdicton

54. Part 2: Basic Principles
Children are special!
(i) Court’s duty to protect them
(ii) Best Interests/Welfare Principle

55. Positive Duty of Court (1)
Positive duties on the Government and the Courts to
protect children
• Common Law,
• Statutes, and
• Constitutional Law

56. Positive Duty of Court (2)
Common law
• “Parens patriae” principle – Sovereign is the ultimate
parent of all (see Calvin's Case [1572] Eng.R. 64,
(1572–1616) 7 Co.Rep. 1a, 77 E.R. 377)
• Extended to protect children and non compos mentis
adults
• Exercised by High Court, s 12 of Cap 4 – especially in
wardship jurisdiction (see Re Y (minors) [1984] HKLR
204 at 206 per Jackson-Lipkin J)

57. Positive Duty of Court (3)
Constitutional and Statutory
Hong Kong Bill of Rights (Cap 383, s 8):
Article 19(4)
Spouses shall have equal rights and responsibilities as to marriage,
during marriage and at its dissolution. In the case of dissolution,
provision shall be made for the necessary protection of any children.
Article 20
(1) Every child shall have … the right to such measures of protection
as are required by his status as a minor, on the part of his family,
society and the State.

58. Positive Duty of Court (4)
Basic Law Protections for Children
Article 4
The Hong Kong Special Administrative Region shall safeguard the
rights and freedoms of the residents of the Hong Kong Special
Administrative Region and of other persons in the Region in
accordance with law.
See also Articles 36, 37, 38, 39, and 41, and Chapter VI

59. Positive Duty of Court (5)
Convention on the Rights of the Child (1)
• Life, care and protection (arts 3, 6);
• Non-discrimination (art 2);
• Recognition and protection of personhood including name, nationality, identity,
privacy and liberty (arts 7, 8, 16, 37);
• Civil and political rights including freedom of expression, thought, conscience,
religion and assembly (arts 13, 14, 15);
• Economic and social rights including health care, standard of living and social
security (arts 24, 26, 27);
• Cultural rights including education, development, play, leisure, indigenous and
minority rights (arts 28, 29, 30, 31);
• Protective rights for those deprived of their families, refugees, placed in care,
from violence, drugs, abduction and all forms of exploitation (arts 19, 20, 21,
25, 32, 33, 34, 35, 36); and
• Procedural rights including the right to be heard and protections in penal law
(arts 12, 40)

60. Positive Duty of Court (6)
Convention on the Rights of the Child (2)
Develop the common law
See Derbyshire County Council v Times Newspapers [1992] QB
770, [1992] 3 All ER 65 (CA)
Interpret statutes
See Ubamaka v Secretary for Security (2012) 15 HKCFAR 743, 763 at para
43

61. Best Interests Principle (1)
Best Interests of the Child
Guardianship of Minors Ordinance (Cap 13) (GMO)
Section 3(1)(a)(i)
In relation to the custody or upbringing of a minor … in any
proceedings before any court … the court shall regard the best
interests of the minor as the first and paramount consideration
and in having such regard shall give due consideration to (A) the
views of the minor if, having regard to the age and understanding of
the minor and to the circumstances of the case, it is practicable to do
so; and (B) any material information including any report of the
Director of Social Welfare available to the court at the hearing

62. Best Interests Principle (2)
Welfare Checklist (slimmed down)
• Wishes of child
• Child’s physical, emotional and educational needs;
• Relationship of child with parents and others
• Effect on child of any change in circumstances
• Child’s age, maturity sex, social and cultural background and other relevant
characteristics
• Attitude demonstrated by child’s parents
• Harm child has suffered or is at risk of suffering
• Family violence
• Capability of parents, and other relevant persons of meeting child’s needs …

63. Best Interests Principle (3)
Welfare Checklist (slimmed down)
• …
• Practical difficulty and expense of contact and effect on child’s right to
maintain personal relations and direct contact with parents
• Range of powers available to the court in the proceedings in question; and
• Any other relevant fact or circumstance
Applies in HK:
SMM v TWM (Relocation of Child) [2010] HKFLR 308
see also P v P (Children: Custody) [2006] HKFLR 305

64. Best Interests Principle (4)
Limits to Best Interests
Carefully balanced against rights and freedoms of others
(and the public)
See UN CRC General Comment 14, paragraph 39
Other statutory schemes (eg immigration)
May be totally negated e.g. diplomatic immunity

65. How does this affect
Injunctions? (1)
Interlocutory Injunctions
(modified American Cyanamid test)
• “just or convenient” centers on the child
• Pecuniary loss / adequacy of damages less important
see obiter Garden Cottage Foods Ltd v Milk Marketing Board [1984] AC
130
• “maintaining the status quo” less important
see Zhen Xiao Ting v Yu San Chuen [2001] 1 HKLRD 261 (CA) at 265,
per Le Pichon JA

66. How does this affect
Injunctions? (2)
Court not bound to dispute between the parties
• Quasi-inquisitorial approach (to protect child)
• More likely to make substantive orders sua sponte
Payne v Payne [2001] Fam 473 (CA) at 483 per Thorpe LJ,
Re E (a minor) (wardship: court’s duty) [1984] 1 WLR 156 (HL), 158–
159, per Lord Scarman

67. How does this affect
Injunctions? (3)
Enhanced duties of candour, may override privilege
Essex CC v R [1994] Fam 167, [1994] 2 WLR 407, [1993] 2 FLR 826,
per Thorpe J (as he was then) ordering lawyers to reveal the location of
the child in question

68. How does this affect
Injunctions? (4)
Modified costs rule for Children’s Cases
London Borough of Sutton v Davis (Costs) (No 2) [1994] 2 FLR 569
Followed in HK:
E.g. Re LB (Wardship: Costs) [2012] 1 HKLRD 266

69. How does this affect
Injunctions? (4)
Other procedural differences
Next friends
Official Solicitors
Court meeting children
Separate representation for the child

70. Part 3: Jurisdiction and
Forum
Statutory vs Inherent Jurisdiction
District Court (Family Court) vs High Court

71. Statutory Jurisdiction (1)
Jurisdiction for Injunctive Relief:
General powers of Courts:
HCO s 21L (injunctive relief) / s 21M (interim)
DCO s 52B (injunctive relief)
Relating to children:
• Separation and Maintenance Orders Ordinance s 5 (married couples)
• GMO s 10 (parents and DSW)
• MPPO s 19 (divorce, etc)

72. Statutory Jurisdiction (2)
Normally Injunctive Relief includes:
• Non-removal from jurisdiction by the parties
• Surrender of passport
• Consent to medical treatment
• Education (which school, courses etc)
• Curfew (control the child)

73. Inherent Jurisdiction (1)
Originating Process
Existing cases in the High Court
Pre-Originating Summons relief (ex p on application)
Wardship

74. Inherent Jurisdiction (2)
Inherent Jx Injunctive Relief may:
[all those reliefs set out above under the statutory jx, and …]
• Require Medical treatment by public authorities
• Require supervision by, committal to care of public authorities
• Restrain both named third-parties and unnamed non-parties (i.e. “the
world”):
a. Publication of information relating to the child
b. Others from transporting, contacting, associating, harboring or molesting a child
c. Exclusion orders from child’s residence
• Require person within jurisdiction (e.g. HK PR) of the Court to return a child
from outside the jurisdiction (if the child is a HK PR)

75. Inherent Jurisdiction (3)
BEWARE
This jurisdiction does not extend to the District Court (Family Court)
See recent decision of QMY v GSS, CACV 68/2014 (unrep, 19 August 2015)
If in doubt start the case in the High Court, or transfer proceedings
NB. RDC Orders 4 and 78, RHC Order 78, PD15.14

76. Inherent Jurisdiction (4)
Word about WARDSHIP
Extraordinary, draconian and flexible jurisdiction
Immediate and powerful – virtually “unlimited”
Anyone may apply (directly or as next friend)
Be warned
Court becomes the “parent” of the Child, until further order or adulthood
*that may not be what your client wants!

77. Part 4: Non-removal
orders
The “Bread and Butter” of HK child-related injunctions
Failure to apply may be NEGLIGENCE:
Hamilton Jones v David & Snape (A Firm) [2003] EWHC 3147

78. Jurisdiction for NROs
• GMO / MPPO / SMOO (DCt, HCt)
• Inherent jurisdiction (High Court)
• Wardship (High Court)
NB: No ward of court can be removed from the jurisdiction, without permission
of the court
NB: Inherent jx and wardship not limited to parents (e.g. grandparents)

79. Applying for an NRO
• GMO / MPPO / SMOO (DCt, HCt)
By summons or ex parte to a judge unless unopposed, in
which can it may be made to the Registrar: RDC O 90 r 5,
MCR 94
• Inherent jurisdiction (High Court)
OS / Summons / Ex p application to a judge
• Wardship (High Court)
Originating Summons

80. Enforcing an NRO (1)
Inform the Immigration Department!
Service on ImmD is NOT AUTOMATIC:
Immediately serve sealed copy of the order (plus copy of birth certificate, ID
and other travel docs) by HAND on the Control Branch of the Department
For wardship cases:- (PD23.1)
1. In urgent cases, apply to Registrar for sealed letter: sealed order delivered
later
2. Duty on practitioners to notify ImmD when the wardship ceases

81. Enforcing an NRO (2)
Inform the Immigration Department!
During office hours (except Saturdays, Sundays and public holidays) Monday
to Friday: 8:45 a.m. to 4:30 p.m.
Control Support Section Room 1402, 14/F Immigration Tower 7 Gloucester
Road Wan Chai, Hong Kong Telephone: (852) 2829 3521
Outside office hours
The Duty Senior Immigration Officer Departure Level (North) Hong Kong
International Airport Chek Lap Kok Telephone: (852) 2182 1501

82. Next lecture…
CHILD ABDUCTION!

83. Domestic Violence
Injunctions
Part 1: Overview
Part 2: DCRVO, Cap. 189

84. Part 1
Overview

85. What is Domestic Violence?
What does it look like?
What are its effects?
How common is it?
Who are the victims?
Who are the perpetrators?

86. United Nations
United Nations resolution on the Elimination of domestic violence against women (A/RES/58/147,
of 22 December 2003)
“1. Recognizes:
(a) That domestic violence is violence that occurs within the private sphere, generally between
individuals who are related through blood or intimacy;
(b) That domestic violence is one of the most common and least visible forms of violence against
women and that its consequences affect many areas of the lives of victims;
(c) That domestic violence can take many different forms, including physical, psychological and
sexual violence;
(d) That domestic violence is of public concern and requires States to take serious action to
protect victims and prevent domestic violence;
(e) That domestic violence can include economic deprivation and isolation and that such conduct
may cause imminent harm to the safety, health or well-being of women;”
86

87. Social Welfare
Department
“1.4 Intimate partner violence is a kind of domestic
violence. In using violence or the threat of violence,
physical or psychological harm is inflicted with the
effect of establishing control by one individual over
another. There are many different forms of intimate
partner violence, and a person may be subjected to
more than one form of violence.”
- Procedural Guide for Handling Intimate Partner
Violence Cases (Revised 2011)

88. Social Welfare
Department
Physical violence
Sexual violence
Psychological abuse

89. UK Home Office
any incident or pattern of incidents of controlling, coercive,
threatening behaviour, violence or abuse between those
aged 16 or over who are, or have been, intimate partners
or family members regardless of gender or sexuality. The
abuse can encompass, but is not limited to:
• psychological
• physical
• sexual
• financial
• emotional

90. Features
Escalation
Isolation
Low self-esteem
Lack of confidence
Feelings of guilt
Self-blaming
90

91. Prevalence
- K.L. Chan (2005), Study on Child Abuse and
Spouse Battering: Report on findings of
Household Survey
Physical assault, injury or sexual coercion against a
spouse: 21.7%
Physical violence against children: 29%
Far more than recorded!

92. Victims
Young and old
Same and opposite sex couples
Men and women
Transgender persons
Chinese and ethnic minorities
Hong Kong-born and new arrivals
Social classes and education levels
92

93. International Instruments
The Convention on the Elimination of All Forms of
Discrimination against Women
The Convention on the Rights of the Child
The Universal Declaration of Human Rights
The International Covenant on Economic, Social and
Cultural Rights
The International Covenant on Civil and Political
Rights

94. Part 2
DCRVO, Cap. 189

95. Remedies
DCRVO, Cap. 189
GMO, Cap. 13
Inherent jurisdiction
Civil claims
95

96. DCRVO Orders
Non molestation order
Ouster/re-entry order
Authorization of arrest
Counseling programme
Vary child custody/access
96

97. Parties
• Spouse/former spouse (s.3)
• Specified minor (s.3)
• ‘Cohabitation relationship’ current and
former (s.3B)
• Relatives (s.3A)

98. “Cohabitation Relationship”
(s.2) …a relationship between 2 persons (whether of the same sex or of the
opposite sex) who live together as a couple in an intimate relationship
???
All the circumstances of the case, including (s.3B(2)):
(a) whether the parties are living together in the same household;
(b) whether the parties share the tasks and duties of their daily lives;
(c) whether there is stability and permanence in the relationship;
(d) the arrangement of sharing of expenses or financial support, and the degree of
financial dependence or interdependence, between the parties;
(e) whether there is a sexual relationship between the parties;
(f) whether the parties share the care and support of a specified minor;
(g) the parties’ reasons for living together, and the degree of mutual commitment to
a shared life;
(h) whether the parties conduct themselves towards friends, relatives or other
persons as parties to a cohabitation relationship, and whether the parties are so
treated by their friends and relatives or other persons.

99. Molestation: Definitions
• “To cause trouble; to vex; to annoy, to put to inconvenience”,
Davies LJ in Vaughan v Vaughan [1973] 3 All ER 449
• “Molest is a wide, plain word which I would be reluctant to
define or paraphrase. If I had to find one synonym for it, I would
select ‘pester’.” Stephenson LJ in Vaughan v Vaughan [1973]
3 All ER 449
• “… molestation may take place without the threat or use of
physical violence and still be serious and inimical to mental and
physical health”, Viscount Dilhorne in Davis v Johnson [1979]
AC 264
• “It applies to any conduct which can properly be regarded as
such a degree of harassment as to call for the intervention of
the court”, per Ormrod LJ in Horner v Horner [1982] Fam 90
99

100. Molestation: Examples
• Physical violence, threats, psychological
abuse, sexual abuse, financial abuse, verbal
abuse, bullying, nuisance calls/text
messages/emails, unwelcome visits,
following/watching/stalking, property damage,
publishing insulting material, improper reports
to authorities…
• Personally or by agents
100

101. Mandatory Counseling
Anti-violence Programme, 5 core concepts:
• Rapport building and ownership.
• Control and monitoring of violence.
• Self-understanding (learn, confront and
challenge).
• Emotional control skills training.
• Relapse prevention skills.
12 x 2-3 hour sessions

102. Authorization of Arrest
Test:
• Has caused actual bodily harm (civil
standard!)
• Reasonably believes respondent is likely to
cause actual bodily harm
“any hurt or injury calculated to interfere with the
health or comfort of the victim” – R v Miller
[1954] 2 QB 282

103. Authorization of Arrest
Can attach at a later date
Applies to other injunctions (if married)
Served on Commissioner of Police by Registrar
(or solicitor if urgent)

104. Ouster and Re-entry
Can cover: home, work, recreation or study
Do not require proprietary interest in the home
(but can still be frustrated)

105. Ouster and Re-entry
Consider:
• Conduct of the parties
• Needs and financial resources
• Needs of any specified minor
• All circumstances
Relatives, additionally:
• Legal/beneficial/contractual rights
• Impact on other family members
Needs of minor not necessarily paramount

106. Time Limits
Ouster, re-entry orders and authorizations of arrest
(s.6)
24 months

107. Procedure
• Notice the signs!
• Collect evidence (civil standard)
• ‘Free-standing’ injunction (different from O.29)
• Usually District Court (s.4)
• Inter partes by originating summons
• Ex parte by affidavit (PD 11.1 / full and frank!)
• Scott schedules
107

108. Other Avenues
Assault/battery
Private nuisance
Trespass
Criminal proceedings?
108

109. Immediate Needs?
Housing/Shelter
Financial support/CSSA
Counselling
Legal aid
109

110. List of Shelters
a. Christian Family Service Centre (for women – Serene
Court, tel: 2381 3311);
b. Po Leung Kuk (for women – Sunrise Court, Wai On
Home and Dawn Court, tel: 8100 1155);
c. Harmony House (for women – tel: 2522 0434);
d. Caritas, Family Crisis Support Centre (for both men
and women – tel: 18 288); and
e. Tung Wah (for both men and women – CEASE Crisis
Centre, tel: 18 281).
110

111. Contact Information
Azan Marwah
chambers@azanmarwah.com
Barrister, Gilt Chambers
Shaphan Marwah
shaphan.marwah@gmail.com
Barrister, Baskerville Chambers
111

112. BUY THIS BOOK!
(thank you)