Background: Wai Yee Cheng, represented by her litigation guardian Lowena Louie, appealed an order from a trial management conference. Cheng alleged that her son, Chung Yeung Chow, and his ex-wife, Ling Linda Chan, made unauthorized withdrawals totaling approximately $5 million from her Canadian bank account. She claimed the funds, which she deposited, were used by Chow and Chan for luxury purchases without her permission.

Legal Arguments/Issues: Cheng argued that the trial management order, which required the production of documents to demonstrate the source of the deposits before the trial could proceed, was made without proper application or affidavit evidence. She contended that this requirement was outside the judge's discretion and unfairly delayed the trial. The main legal issue was whether the judge erred by imposing additional terms to the adjournment order without sufficient procedural grounds.

Court's Ruling: The Court of Appeal found that the additional terms of the order were made without proper notice or evidence and that the facts about the source of the deposits were disputed and required affidavit evidence. The court ruled that the terms of the order were inappropriate as they indefinitely delayed the trial without clear criteria for compliance. As a result, the appeal was allowed, and terms 2 and 3 of the October 23, 2020, order were set aside.

Costs/Damages Awarded: The judgment did not mention any specific costs or damages awarded in favor of the successful party, Wai Yee Cheng.