Court of Appeal dismisses appeal by Andrew Left

26 Feb 2019

The Court of Appeal has dismissed the appeal by Mr Andrew Left of Citron Research against the determination of the Market Misconduct Tribunal (MMT) on points of law under the Securities and Futures Ordinance (SFO) (Note 1).

This came after the rejection of a separate application for leave to appeal by Left against the determination of the MMT on the questions of facts following MMT’s findings of misconduct against him over the publication of a research report on Evergrande Real Estate Group Limited in 2012 (Evergrande) (Notes 2 & 3). 

In the judgment, the Court of Appeal said: 



  1. The judgment is available on the Judiciary’s website.
  2. On August 2016, the MMT found that Left, the head of research of Citron Research, was culpable of disclosing false or misleading information inducing transactions in the publication of a report on Evergrande in June 2012.  The MMT imposed several orders on Left including a “cold shoulder” order banning him from trading securities in Hong Kong for five years.    

    For further details of the MMT proceedings, please see the Securities and Futures Commission’s (SFC) press releases dated 22 December 201419 March 20152 November 2015 and 26 August 2016.
  3. Left applied for leave to appeal against the determination of the MMT on questions of fact in November 2016.   His application for leave was dismissed by the Court of Appeal.  For further details of the appeal hearing, please see the SFC’s press release dated 13 January 2017.
  4. Sin Kam Wah v HKSAR (2005) 8 HKCFAR 192.

Page last updated : 27 Feb 2019