December 20, 2025
Chan Wai Tong v Li Ping Sum (Hong Kong) [1984] UKPC 49
A passenger injured in a Hong Kong road accident appealed against damages awarded. The Privy Council considered whether courts should compare awards across jurisdictions and whether future loss of earning capacity required specific pleading and evidence. The appeal succeeded in part, deleting the unpleaded and unproven future earning capacity award. Facts The respondent, a 25-year-old female accountant, was injured as a passenger in a minibus involved in a road traffic accident on 30th January 1981 in Hong Kong. She sustained compression fractures of three vertebrae, resulting in permanent disability assessed by different doctors at between 15% and 25%. Liability was
