• The Hong Kong Court determined that it could recognise a foreign voluntary liquidation of a Company.
• The Court distinguished Supreme Tycoon  from Lord Sumption’s obiter dicta in Singularis  noting that the key is whether the foreign proceeding was “a process of collective enforcement of debts for the benefit of a general body of creditors.”
• The mere fact that the foreign liquidation was voluntary did not bar the Hong Kong Court from recognition and assistance under the principle of modified universalism.

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