In the recent case of Joint and Several Liquidators of Yes! E-Sports Asia Holdings Limited (In Liquidation) v Holman Fenwick Willan (A Firm) [2024] HKCFI 1197, the court criticized the respondent law firm for imposing unwarranted conditions for compliance with a document production request made by the liquidators of their former client.  The liquidators stood in the shoes of the former client upon its liquidation, and there can be no question that the client is entitled to the return of its own files.  The court further made clear that there is no basis for the recipient of a document production request to insist on payment on account before compliance.

See full judgment here.