Despite sharing similar reciprocal enforcement frameworks, the Courts in Hong Kong and Singapore have recently taken different stances on whether enforcing a judgment arising from foreign gaming debts violates their local public policy.
Hong Kong: Resorts World at Sentosa Pte Ltd v. Tsang Yeuk Kwan
In Resorts World at Sentosa Pte Ltd v. Tsang Yeuk Kwan [2026] HKCFI 4928, the Hong Kong Court was concerned with a S$10.38 million debt judgment rendered by the Singapore Court. The underlying debt related to gambling activities which took place in a licenced casino in Singapore.
The debtor applied to set aside the registration under section 6(1) of the Hong Kong Foreign Judgments (Reciprocal Enforcement) Ordinance (Cap. 319), arguing that enforcing a gaming debt would violate Hong Kong public policy.
The Court upheld the registration. DHCJ Alan Kwong held that as a matter of Hong Kong public policy, gambling is not regarded as an “immoral, sinful, improper, or worthy of public condemnation”. Instead, “[t]he public policy is that gambling should be controlled and directed”. His Lordship further held that money lent in a foreign country for the purpose of being used by the borrower for gaming lawfully in the foreign country is recoverable, and enforcing such a lending transaction would not be contrary to any public policy in Hong Kong.
Singapore: Venetian Macau Limited v. Hu Yangning
A week after the Resorts World decision, the Singapore Court in Venetian Macau Ltd v. Hu Yangning [2026] SGHC 180 dealt with a similar issue, and yet reached a different result.
The case concerned a HK$19.35 million gambling debt incurred in Macau. The Plaintiff applied for judgment in Hong Kong, and then sought to register the same in Singapore.
The Singapore Court set aside the registration. It invoked the “public policy” ground under section 5(1) of the Singapore Reciprocal Enforcement of Foreign Judgments Act 1959. It held that, as a matter of Singapore public policy, gambling in general and gambling on credit are contrary to Singapore’s public policy. Just because regulated gambling was permitted in Singapore, it did not mean that all other forms of gambling were no longer against Singapore’s public policy.
Takeaways
The two cases illustrate that “public policy” is a highly local concept. A similar set of facts can yield different results depending on specific public policies in the enforcing jurisdiction.
Parties must factor in divergences in local public policies at the earliest stage of asset-mapping and jurisdiction selection. If required, local advice should be obtained so that detailed and strategic planning can be made.
Read the Hong Kong Judgment here: https://legalref.judiciary.hk/lrs/common/ju/ju_frame.jsp?DIS=184383&currpage=T
Martin Lau acted for the Plaintiff in Resorts World at Sentosa Pte Ltd v. Tsang Yeuk Kwan.
