In the recent high-profile decision of Re: Li Yonghong[2025] HKCFI 3307, the Honourable Madam Justice Linda Chan made a bankruptcy order against Mr. Li Yonghong — a businessman best known for his prior ownership of AC Milan. The judgment offers important takeaways for bankruptcy and insolvency practitioners on, inter alia, the resolution of inaccuracies or defects in statutory demands and petitions.

Background

In a highly anticipated decision issued last Thursday (on December 19, 2019), the United States Court of Appeals for the Third Circuit held in In re Millennium Lab Holdings II, LLC that a bankruptcy court may constitutionally confirm a chapter 11 plan of reorganization that contains nonconsensual third-party releases. The court considered whether, pursuant to the United States Supreme Court’s decision in Stern v. Marshall, 564 U.S. 462 (2011), Article III of the United States Constitution prohibits a bankruptcy court from granting such releases.