HKLII

Hong Kong Law Reform Commission

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Chapter 3 - Brief review of the existing law governing the protection of purchasers of completed units in the second-hand market


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Introduction


3.1In this chapter, we shall take a brief look at the existing law governing the protection of purchasers in the second-hand market. We shall try to see if the existing law is adequate to protect purchasers.


Misrepresentation


3.2 At common law, an agreement for sale and purchase of a flat may be rescinded if it has been induced by a misrepresentation, that is to say an untrue statement of fact made by one party to the other. The statement may be deliberately untrue or made recklessly as to whether or not it is true or it may be made negligently or innocently. Most misrepresentations are of the latter type. Once a misrepresentation of the latter type has occurred the contract becomes voidable: the victim of the misrepresentation has the option of withdrawing from the contract but may choose to continue with it. Alternatively, by virtue of statute (the Misrepresentation Ordinance Cap 284) the court may award damages to the victim, in which event the sale stands but the party who is responsible for the misrepresentation must pay compensation to the other party. If the misrepresentation is fraudulent, the contract is automatically void and damages (on a more generous scale) are recoverable.

3.3 It may be difficult for the purchaser to whom misleading information has been given to rely upon the law of misrepresentation. First, if the false statement is not in writing, as is particularly likely to be the case in a sale between private individuals, there will be difficulties in establishing that it was made and precisely what was said or communicated. A representation may be oral, in which case there could well be a clash of evidence as to what was said, or it may be by act or implication. There are particular difficulties where the representation is by silence, ie the failure to correct a false impression gained by the purchaser. Second, even if the court is satisfied as to what was said, the purchaser may not be able to show that the statement induced him to enter into the purchase agreement: typically a variety of factors will have led to his decision to buy, including price, surroundings and convenience of location, and separating the influences of these from that of the false statement is problematic. Third, in order to be actionable, the inaccurate statement must be a statement of fact and not of opinion or of law. It can be particularly difficult to discern whether an assertion is an expression of the speaker or writer's opinion or is a statement of fact (indeed an assertion may contain a mixture of fact and opinion). An example is a general description of the internal decorations of a flat where phrases such as "high quality", "well designed" and so forth may be used. Fourth, the statement must be one of existing fact, not a promise as to future fact.

3.4 A further complication is that, whatever may have occurred during negotiations prior to the signing of the provisional agreement, the formal sale and purchase agreement frequently contains a standard clause to the effect that the agreement contains the whole agreement between the parties and that no representations or warranties other than those in the contract have been made or can be relied upon. A variant of this limits the remedies available for misrepresentation to damages and lays down how any compensation is to be calculated. These are examples of exclusion clauses which, under the provisions of the Control of Exemption Clauses Ordinance (Cap 71), generally would be effective only to the extent that they are reasonable but that ordinance specifically does not apply to contracts for the transfer of an interest in land so such clauses in a sale and purchase agreement are effective.


Breach of contract


3.5 If information concerning a property is incorporated into the contract of sale and is supported by an undertaking in the contract that the information is true or accurate, the purchaser will have an action for breach of contract should the information transpire to be inaccurate. Such stipulations are more frequent where the terms of the contract are influenced by an outside agency. For instance, in sales under the consent scheme, the vendor is obliged to warrant to the purchaser that the flat will be as shown on the plan and will be of the stipulated saleable area and that the sales brochure is accurate and complies with the requirements concerning such brochures laid down by the Lands Department. This approach is, however, unusual in a private sale of second-hand property: it would require the purchaser to insist upon a special clause in the contract and, where as is usual there is a provisional agreement, he can so insist only if the clause has been written into the provisional agreement.

3.6 The law also implies terms into contracts but the circumstances in which this will be done are limited to where the implication is necessary or is prescribed by law.


Fraudulent behaviour


3.7 In Hong Kong, cases involving aspects of fraudulent behaviour are dealt with either as specific offences under the Theft Ordinance (Cap 210) or, where a criminal agreement between two or more persons can be proven, by means of a charge of "conspiracy to defraud."[3]

Obtaining property or pecuniary advantage by deception


3.8 Section 17(1) of the Theft Ordinance (Cap 210) provides:

"Any person who by any deception (whether or not such deception was the sole or main inducement) dishonestly obtains property belonging to another, with the intention of permanently depriving the other of it, shall be guilty of an offence and shall be liable on conviction upon indictment to imprisonment for 10 years."

3.9 Section 18(1) of the Theft Ordinance (Cap 210) provides:

"Any person who by any deception (whether or not such deception was the sole or main inducement) dishonestly obtains for himself or another any pecuniary advantage shall be guilty of an offence and shall be liable on conviction upon indictment to imprisonment for 10 years."

3.10 "Deception" is defined as "any deception (whether deliberate or reckless) by words or conduct as to fact or law ...."[4] Hence, mere silence in itself cannot be a deception within the meaning of the section.[5] It is therefore difficult to base liability on the mere omission (albeit deliberate) on the part of the vendor to provide property information. At present, there is no positive legal duty on the vendor to provide property information except a vendor's statement as to known structural additions or alterations and repairs or improvements to his unit under the Estate Agents Ordinance (Cap 511).[6] Even that vendor's statement on structural alterations and repairs is not supplied to the purchaser direct by the vendor himself. The vendor makes the statement and passes it to the estate agent who will in turn pass it on to the purchaser. As the statement relates to known structural alterations or repairs, a vendor need not make any disclosure so long as he is not aware of any such matters.


Conspiracy to defraud


3.10 In brief, the common law offence of conspiracy to defraud consists of an agreement by two or more persons to commit fraud. It does not apply to one person acting alone. In most cases, the vendor alone supplies the property information and it is difficult to prove the existence of any agreement to defraud the purchaser. It is therefore difficult to find any liability in conspiracy to defraud in respect of the provision of property information.


Substantive offence of fraud


3.11 Acting upon the recommendations of the Law Reform Commission in its report entitled Report on Creation of a Substantive Offence of Fraud,[7] a new section 16A was added to the Theft Ordinance on 16 July 1999.[8] The new section 16A(1) provides:

"If any person by any deceit (whether or not such deceit is the sole or main inducement) and with the intent to defraud induces another person to commit an act or make an omission, which results either –

a)in benefit to any person other than the second-mentioned person; or

b)in prejudice or substantial risk of prejudice to any person other than the first-mentioned person,

the first-mentioned person commits the offence of fraud and is liable on conviction upon indictment to imprisonment for 14 years."

3.12 This new statutory offence of fraud applies to one person acting alone. However, it is hard to prove beyond reasonable doubt deceit and the intention to defraud in the case of vendors providing wrong property information. For instance, the owners of units in old buildings may not know whether there are illegal structures or alterations as the building plans may be missing or may not be readily accessible at reasonable cost. The owners may make an honest mistake in providing wrong or misleading information as to illegal structures or alterations. It would be difficult to find deceit and intention to defraud on the basis of such honest mistake.


Trade Descriptions Ordinance (Cap 362)


3.13 Section 7(1)(a)(i) of the Trade Descriptions Ordinance (Cap 362) provides that it is an offence to apply a false trade description to any goods in the course of any trade or business. Section 2(1) defines "goods" as including "vessel and aircraft, things attached to land and growing crops" which arguably includes the fittings and finishes of flats and even the building itself. However, a private individual selling his unit is usually not doing it "in the course of any trade or business". It is therefore difficult to establish liability for false trade descriptions in respect of misleading or false property information supplied by a private vendor in the second-hand market.

3.14 Moreover, a "trade description" requires a direct or indirect indication under section 2(1). Mere silence on the part of the vendor is therefore not a trade description. The Trade Descriptions Ordinance cannot catch vendors who deliberately withhold material facts.


Existing disclosure requirements under the Estate Agents Ordinance (Cap 511)


3.16 Under the Estate Agents Ordinance, estate agents are required by law to provide seven basic property particulars to purchasers. These are:

lcurrent ownership and encumbrances,
ltotal or entire area,
lyear of construction completion,
luse restrictions,
lunexpired term of Government lease,
lterm of new lease,
lvendor statement on known structural additions or alterations and repairs or improvements.[9]

The estate agent is responsible for collecting these property particulars, except for the vendor statement on structural alterations and repairs. Hence, the vendor's existing duty under the Estate Agents Ordinance is confined to the provision of the statement on structural alterations and repairs. But even that vendor statement covers only any information "within the vendor's knowledge". If the vendor is not aware of the structural alterations or repairs, he is not obliged to make any vendor statement.

3.17 If the property particulars supplied by an estate agent are wrong, the estate agent may be able to rely upon the defence of due diligence.[10] The Estate Agents Ordinance increases the transparency of transactions and provides more sales information to purchasers but falls short of giving them ultimate satisfactory protection.


Lack of vendor's duties of disclosure


3.18 The above review of the existing law indicates that there are few positive duties, if at all, on a vendor of second-hand property to disclose particulars of the property for sale. In second-hand sales, there is no such thing as a sales brochure compiled by the vendor. A vendor is, of course, obliged to provide basic information on the property in the preliminary agreement. It is of little assistance to the purchaser only to obtain the property information after the preliminary agreement is signed. Moreover, the contents of the preliminary agreement are not uniform. Most preliminary agreements contain only the address of the property, the purchase price, payment terms, and date of completion of sale and purchase.


[3] The Law Reform Commission of Hong Kong, Report on Creation of a Substantive Offence of Fraud, (Topic 24, July 1996), paragraph 2.4.
[4] Theft Ordinance (Cap 210), sections 17(4) and 18(3).
[5] Archbold 1998, at paragraph 21-181.
[6] Estate Agents Ordinance (Cap 511), section 36(2)(g).
[7] See paragraph 1 of the Explanatory Memorandum to the Theft (Amendment) Bill 1998.
[8] Ordinance No 45 of 1999.
[9] See section 36(2)(a) to (g) of Estate Agents Ordinance (Cap 511).
[10] Under section 36(5)(b)(ii) of the Estate Agents Ordinance (Cap 511), there is a defence of due diligence available to an estate agent if he shows that (A) he relied on information obtained from a source prescribed for the purposes of this subparagraph in respect of such information; (B) it was reasonable for him to have relied on such information; and (C) he had taken all steps reasonably open to him to avoid the failure.