Glas Sas (London Branch) v European Topsoho S.À R.L. & Ors [2026] EWHC 1759 (Comm)

[2026] EWHC 1759 (Comm)Case No CL-2021-000666
IN THE HIGH COURT OF JUSTICE
KING'S BENCH DIVISION
BUSINESS AND PROPERTY COURTS OF ENGLAND AND WALES
COMMERCIAL COURT
Venue Royal Courts of Justice, Rolls Building, Fetter Lane, London, EC4A 1NLDate 14 th July 2026Peter MacDonald Eggers KC(Sitting as a Deputy Judge of the High Court)
GLAS SAS (LONDON BRANCH)ClaimantEUROPEAN TOPSOHO S.À R.L.DefendantsDYNAMIC TREASURE GROUP LIMITEDDefendantCHENRAN QIUDefendant(4) WUHU RUYI XINBO INVESTMENT PARTNERSHIP ENTERPRISE (LIMITED PARTNERSHIP)Defendant(芜湖如意信博投资合伙企业(有限合伙)Defendant
Mr Alex Barden KC (instructed by Jenner & Block London LLP) for ClaimantMr Christopher Langley (instructed by CMS Cameron McKenna Nabarro Olswang LLP) for First Defendant for The Second, Third and Fourth Defendants were not represented.Hearing Hearing dates: 4 th and 5 th March 2026
Approved Judgment

Peter MacDonald Egger KC :

[1]The Claimant (“GLAS”) is the Trustee of tradeable bonds (“the Bonds”), governed by English law, with a principal value of €250 million. The First Defendant (“ETS”), a company incorporated in Luxembourg, was the issuer of the Bonds and had defaulted in its payment obligations under the Bonds. Summary judgment against ETS for the sum of €250 million, plus interest, was granted by the Court by an order dated 27th October 2022.[2]SMCP SA (“SMCP”) is a French fashion company. ETS owned approximately 53% of the shares in SMCP (“the SMCP Shares”). Some of those shares were pledged to GLAS as security for the Bonds (“the Pledged Shares”). Other shares were unpledged (“the Unpledged Shares”) which had a value in October 2021 of approximately €85 million.[3]This trial was concerned with the claims of GLAS, in its capacity as Trustee of the Bonds, arising from the alleged misappropriation of the Unpledged Shares in October 2021, as a result of which GLAS has been prejudiced, so that the bondholders (“the Bondholders”) will recover less than they otherwise would have. GLAS maintains that during the almost five-year period since the misappropriation, the value of both the Pledged and Unpledged Shares has fallen, while the sums outstanding under the Bonds have continued to accumulate.[4]GLAS’s case is that the misappropriation of the Unpledged Shares was brought about by the Second Defendant (“Dynamic”), the Third Defendant (“Ms Qiu”) and the Fourth Defendant (“Xinbo”), who are related parties connected to the Shandong Ruyi Group, the ultimate majority owner of ETS.[5]According to GLAS, the misappropriation was effected by means of an unauthorised and wrongful transfer of the Unpledged Shares (described by GLAS as “the Disposal”) in order to put the Unpledged Shares out of reach of GLAS and the Bondholders.(1) Ms Qiu is a senior executive of Shandong Ruyi Technology Group Co Ltd (“Shandong Ruyi”) and was an “A Manager” of ETS appointed by Shandong Ruyi.(2) Dynamic was incorporated on 5th April 2017 in the British Virgin Islands and, was at its incorporation, a company controlled by Ms Qiu as the sole shareholder and director.(3) Ms Qiu procured the transfer of the Unpledged Shares to Dynamic purportedly under a Shares Sale Agreement dated 22nd October 2021 (“SSA”) for a consideration of one single euro (€1).(4) Dynamic then converted the Unpledged Shares to bearer form and transferred them to its account with JP Morgan Chase Bank NA Singapore (“JPM Singapore”).(5) Xinbo, an entity in which Shandong Ruyi has a controlling interest, has asserted an interest in the Unpledged Shares and claims the Unpledged Shares were transferred to Dynamic as Xinbo’s nominee to protect a claimed security interest over the Shares in SMCP arising under a purported “2018 Agreement”. Xinbo has sought to rely on a purported Arbitration Award said to have been obtained in Beihai, China in January 2023 (“the Beihai Award”).[6]This trial was not concerned with GLAS’s claims against ETS (against whom summary judgment has already been ordered).[7]On 28th February 2023, ETS was declared bankrupt in Luxembourg and a court-appointed bankruptcy administrator, Ms Valérie Kopéra (“the Curateur”), assumed responsibility for ETS’s legal affairs. Mr Max Mailliet later replaced Ms Kopéra as the Curateur.[8]GLAS claims relief against Dynamic, Ms Qiu and Xinbo declaring the Disposal as invalid and seeking orders under section 423 of the Insolvency Act 1986, and damages in tort. There is also an alternative claim made by GLAS if the Court considers that Luxembourg law applies.[9]When I refer to “the Defendants”, that should be taken as a reference to Dynamic, Ms Qiu and Xinbo (rather than ETS), unless the context plainly demonstrates otherwise.[10]ETS, by the Curateur, is represented in these proceedings and does not contest GLAS’s claims against Dynamic, Ms Qiu and Xinbo. The Curateur agrees with GLAS’s case that the Disposal was not a genuine commercial arrangement. In fact, the Curateur stated that, based on his own investigation and the investigation of his predecessor, GLAS’s submissions as to the suspicious and often inexplicable nature of the Disposal largely mirrored their own independently-reached conclusions.[11]GLAS was represented at the trial by Mr Alex Barden KC. The Curateur was represented at the trial by Mr Christopher Langley. I had the benefit of their helpful written and oral submissions and, in addition, further written submissions provided after the trial, at my request.[12]Dynamic, Ms Qiu and Xinbo were not represented at the trial. In fact, they have been debarred by the Court from defending GLAS’s claims by reason of their non-compliance with earlier orders of the Court. The result of such debarring orders was explained by Bright J in his judgment dated 12th February 2025 as to the effect of the debarring orders on the Second, Third and Fourth Defendants, namely that they could not take steps prior to the trialas may be required to enable them to contest the claims at trial or to do so by specific means, or to appear at trial to contest GLAS’s claims on their merits, by making opening submissions, by testing the evidence served by GLAS, by calling any evidence of their own, and by seeking to persuade the Court by argument in closing submissions that the claims should be rejected.[13]Notwithstanding the debarring orders, GLAS accepts that it must prove its case on the balance of probabilities on the relevant issues. The evidence included documentary evidence and the statements of a number of witnesses, including those made by the legal representatives of GLAS (Mr Mark Fennessy, Mr Jason Yardley, Mr Christian Beatty, Ms Lucille Madariaga, and Mr Romain Sabatier) as well as the Curateurs of ETS (Ms Valérie Kopéra and Mr Max Mailliet), and the witness statements made on behalf of the Defendants, including those of Ms Qiu, Ms Qiu’s father, Su Xiao and Zhang Yu of Xinbo, and their legal representatives.[14]In assessing the evidence and in determining the issues, I have had regard to the following principles:(1) Where GLAS is advancing a case based on serious misconduct, the nature of the allegation must be factored into the balance of probabilities, the Court being more astute to assessing the likelihood or unlikelihood of such misconduct having taken place.(2) The Court is entitled to consider the defences and arguments which have been advanced on behalf of the Defendants who have been debarred (Times Travel UK Ltd v Pakistan International Airlines Corp [2019] EWHC (Ch) 3732, para. 55(6)). In this case, some of the Defendants have served defences or draft defences and/or witness statements.(3) The Court is entitled to draw adverse inferences by reason of the Defendants having failed to disclose documents in accordance with the orders of the Court or not adducing evidence of particular witnesses whose evidence might otherwise be expected to be called (Aegean Baltic Bank SAS v Renzlor Shipping Ltd [2020] EWHC 2851, para. 30-34). That said, there are limits to the drawing of such inferences. The Court must consider whether the possibility that the Defendants’ decision not to disclose documents or adduce evidence might be motivated by factors other than to distort the evidential picture, even assuming one might be confident that such evidence otherwise exists.[15]As mentioned above, the Court has already granted summary judgment against ETS. In addition, on 12th July 2024, the Court granted partial summary judgment against Dynamic and ETS for the return of the Unpledged Shares to the Curateur. Those orders do not bind Ms Qiu and Xinbo and the latter order expressly permits the claim for further relief against Dynamic to be tried.[16]The Unpledged Shares were belatedly returned to ETS by JPM Singapore in August 2025, following orders made by this Court and the Court in Singapore, but the Unpledged Shares have not yet been sold. In light of a fall in the share price, and the accrual of interest for almost five years, and the incurring of additional costs, the creditors are said to be likely to recover less than on an equivalent sale of the 53% majority interest in October 2021, and a much smaller percentage of the overall debt.

The factual background

[17]I set out below the factual background, which I have distilled from the evidence before the Court. ETS[18]ETS was incorporated in Luxembourg and is a wholly owned indirect subsidiary of the Ruyi Group, a major Chinese industrial group. ETS has been at all material times a wholly-owned subsidiary of Ruyi International Fashion (China) Ltd (“Ruyi International”), which is in turn indirectly owned by Shandong Ruyi. The majority owner of Shandong Ruyi is Beijing Ruyi Fashion Investment Holding Co Ltd (“Beijing Ruyi”), of which Mr Yafu Qiu (Ms Qiu’s father) was the majority shareholder.[19]Xinbo is a PRC limited partnership in which the principal interests are held by Shandong Ruyi (64.97%) and China Cinda Asset Management Co Ltd (“Cinda”) (33.84%). Cinda is a major Chinese financial institution, majority-owned by the Chinese state. Although Ms Qiu and Xinbo have denied that the Ruyi Group controls Xinbo, the “general partner with operational control” of Xinbo is a company wholly owned by Beijing Ruyi and Shandong Ruyi’s annual audit reports identified Xinbo as a consolidated subsidiary of Shandong Ruyi.[20]In October 2016, ETS acquired a majority shareholding in SMCP, a French fashion group. In October 2017, SMCP conducted an IPO on the Euronext Paris exchange, following which ETS was the holder of a 53.7% majority of SMCP’s shares.[21]ETS had A Managers and B Managers in accordance with its Articles of Association dated June 2018, which provided that ETS was bound by the joint signatures of any two Managers, one Class A and one Class B Manager, although if there was only a single Manager, that sole Manager might exercise the powers of the Managers. The Articles were amended on 7th January 2019 requiring the shareholders to appoint two classes of Managers, requiring that one of the Class A Managers was to be appointed from a list supplied by Sino Power, a Chinese company (defined as the “Nominated Manager”), and requiring any decision in relation to any matter relating to the SMCP Shares to be approved by all the Managers, and approved by the Nominated Manager, and requiring that any transaction to dispose of the SMCP shares must not be entered into without the prior written consent of Sino Power.[22]The A Managers of ETS included Ms Qiu (who is now CEO of Shandong Ruyi and was at that time Vice-Chairman and Executive President), and Mr Tan Huang (a representative of Sino Power). The B Managers were Luxembourg professionals (until they resigned in September-October 2021).

The 2018 Agreement

[23]Reliance has been placed by Ms Qiu and Xinbo on a purported agreement dated 25th July 2018 between ETS, Shandong Ruyi and Xinbo, under which ETS purportedly guaranteed the substantial indebtedness of Shandong Ruyi and pledged all of the SMCP Shares to Xinbo in support of that guarantee (the 2018 Agreement). The underlying indebtedness was said to relate to liabilities to Cinda (a state-owned investment company), with Cinda’s rights assigned to Xinbo (an entity jointly owned by Cinda and the Ruyi Group). The 2018 Agreement included a Jining (or “Jinan”) arbitration agreement.[24]Mr Barden KC on behalf of GLAS questioned the authenticity of the 2018 Agreement, an issue which is discussed below.

The Bonds

[25]On 12th September 2018, ETS issued the Bonds, raising funds in a principal sum of €250 million, with a maturity date of 21st September 2021. The Bonds are each exchangeable into fully paid ordinary shares of nominal value of €1.10 each in SMCP or Substitute Shares or Offered Property.[26]At that time, BNP Paribas Trust Corporation UK Limited (“BNP Trust”) was the Trustee. The Bonds were secured against the Pledged Shares in SMCP, with the remainder of the SMCP Shares being the Unpledged Shares.[27]On 18th September 2018, the Custody Agreement (governed by English law) designated BNP Securities Services (“BNPSS”), London Branch, as the Custodian. Under the Paying, Transfer and Exchange Agency Agreement dated 21st September 2018, governed by English law, BNPSS Luxembourg was appointed the Payment Agent for ETS.[28]On 21st September 2018, a Trust Deed (governed by English law) was entered into between ETS as the Issuer, BNP Trust as the Trustee and Forever Winner International Development Limited (“Forever Winner”), a company in the Ruyi Group, as Guarantor, guaranteeing the due and punctual payment of all amounts payable by ETS pursuant to the Conditions and the Trust Deed.[29]Clause 2 of the Trust Deed provided that ETS must unconditionally and immediately pay or procure to be paid to or to the order of the Trustee the principal amount of the Bonds on any date when the Bonds become due to be redeemed or repaid. Clause 4.1 of the Trust Deed provided that ETS, “with full title guarantee and as continuing security” for its obligations under the Bonds and the Trust Deed, assigned in favour of the Trustee all of ETS’s present and future rights, title and interest against the Custodian under the Custody Agreement and in the Cash and Securities Accounts and in sums held by Agents (defined as “Secured Property”). By clause 4.7, if the Trustee enforces the Security, it may take possession of the Secured Property.[30]The Trust Deed was varied in 2020, following certain defaults by ETS. Clause 6 of Schedule 4 contained various covenants, including a “negative pledge” not to create any security interest over the Secured Property, and that all cash amounts receivable in respect of the Shares in the Securities Account be credited to the Cash Account with the Custodian, and Clause 10 contained a Financial Covenant not to incur, create, assume or guarantee any “Indebtedness”.

Appointment of GLAS as Trustee

[31]GLAS was appointed as Trustee in late 2020, after there had been Events of Default under the Bonds, as a result of legal actions commenced on 2nd November 2020 and 22nd December 2020 by Hang Sang Bank and Industrial Bank respectively, against Ruyi Group Companies including Forever Winner (the guarantor under the Bonds).[32]On 24th December 2020, a written resolution was passed, and BNP Trust and GLAS then entered into a Deed of Appointment dated 24th December 2020, by which BNP Trust appointed GLAS as Co-Trustee, and GLAS accepted that appointment. BNP Trust then gave notice to the Issuer (ETS) and Guarantor (Forever Winner) by way of a Notice of Retirement that it would cease to be Trustee.[33]On 31st December 2020, GLAS issued a Default Notice against ETS in relation to Events of Default under Condition 14(a)(iii) of the Trust Deed.[34]ETS subsequently disputed that an Event of Default had occurred, and that GLAS was validly appointed as Trustee. This dispute was resolved on 17th June 2021 by a Deed of Confirmation of Appointment and a Supplemental Trust Deed between ETS, Forever Winner and GLAS.[35]On the same date, on 17th June 2021, two Managers of ETS, Ms Qiu as A Manager and Mr Joost Mees as B Manager, gave a Managers’ Certificate to GLAS confirming that the shares which ETS “holds which are not subject to the Security are not otherwise subject to any mortgage, charge, pledge, lien, encumbrance or other security interest … or any other agreement or arrangement having a similar effect”. The Managers’ Certificate was approved by ETS’s board, including Ms Qiu and Mr Kelvin Ho of the Ruyi Group, and three Luxembourg Class B Managers.

ETS’s Default

[36]The Maturity Date under the Bonds was 21st September 2021. On that date, ETS did not repay, in whole or in part, any sum due to GLAS as the Trustee under the Bonds, constituting Events of Default.[37]On 22nd September 2021, GLAS issued a written notice to ETS of its breaches. ETS did not cure its default within five Business Days of that written notice. Following a Default Notice issued by GLAS on 4th October 2021, ETS did not remedy the defaults set out in the Default Notice, such that the Expiry Date under Condition 14(a) of the Trust Deed occurred on 18th October 2021, and the Acceleration Date occurred on 19th October 2021.[38]On 19th October 2021, the Bondholders wrote to BNPSS referring to ETS’s default and stating that “In light of the above, our clients believe that any instruction purportedly given for or on behalf of ETS to effect or facilitate any transfer or disposal of the ETS Unpledged Shares or any interest therein could be invalid and may result in fraudulent transfers or dissipation of the assets of ETS while it is insolvent”.[39]On 22nd October 2021, GLAS served a petition for ETS’s bankruptcy, which was filed in the District Court of Luxembourg on 9th November 2021.

The Disposal

[40]Ms Qiu was the sole shareholder in and director of Dynamic from 2017 to July 2021. On 30th July 2021, Ms Qiu transferred the entire issued share capital of Dynamic to Precious Pearl Candy Holding Ltd (“Precious Pearl”), which was inserted as an intermediate holding company, and Grandall International Holding Ltd (“Grandall”) (an Intertrust service company) was appointed as corporate director, replacing Ms Qiu as Dynamic’s director. In March 2022, Dynamic Day Enterprises Ltd (“Dynamic Day”) was appointed as director of Precious Pearl. Precious Pearl and Dynamic Day were incorporated on 28th July 2021.[41]Ms Qiu has previously sought to explain those arrangements, and the position of Dynamic as the transferee of the Unpledged Shares, by alleging that in July 2021, a “Precious Pearl Trust” was established by Ms Qiu for the benefit of her two children (“the Precious Pearl Trust”), with Intertrust Singapore Limited, as trustee, and on 28th September 2021, Ms Qiu entered into a written trust agreement (“the Qiu-Xinbo Trust Agreement”) by which she purportedly transferred any right or control over Dynamic to Xinbo, and agreed to use Dynamic as a nominee for Xinbo to receive the Unpledged Shares, and that in March 2022, the shares in Precious Pearl were transferred back to Ms Qiu. No documents have been disclosed in relation to the creation, terms or operation of the alleged Precious Pearl Trust other than certain bank statements. The purported Qiu-Xinbo Trust Agreement has been disclosed, but no documents relating to its creation have been produced.[42]In September and October 2021, all of the Managers resigned, except Ms Qiu and Mr Tan Huang (of Sino Power). The B Managers subsequently informed the Curateur that they had resigned because they were not happy with the financial viability of the structure. In a report prepared in March 2023 in the context of bankruptcy proceedings, it was recorded that “The Managers explained that they resigned since they did not receive satisfactory answers to the questions they [posed] to the client about the financial viability of the structure, the negotiations ongoing with the bondholders and so, everything related to the potential refinancing of the repayment of the notes. They specified that they were not involved in the negotiations”.[43]On 5th October 2021, ETS issued a press release, stating that it had received an “alleged” default notice, noting that there were “claimed” Events of Default making the Bonds immediately payable and that “The Company is actively considering its options in relation to the current situation and will keep the market informed”.[44]It is alleged by the Defendants that, on 8th October 2021, a Notice was issued by Xinbo to Ms Qiu personally, directing her to transfer the Unpledged Shares out of ETS, with the (unidentified) transferee to pledge them to Xinbo, to avoid “damage to the interests of state-owned assets” (“the8 October Notice”). It is also alleged that a further, but materially different, Notice dated 9th October 2021, was sent by Xinbo to ETS, directing the transfer of the Unpledged Shares to Dynamic’s account with BNPSS (“the9 October Notice”). Ms Qiu stated that she received these Notices by WeChat, but the WeChat records were said to have been lost (Ms Qiu’s sixth witness statement, para. 31-33; Ms Qiu’s seventh witness statement, para. 4-5).[45]In her instruction to BNPSS, Ms Qiu stated that “On behalf of European Topsoho, I confirm that the consideration has been received and the transfer of shares can be effected immediately”. Ms Qiu supplied BNPSS with the SSA, under which ETS purported to sell the Unpledged Shares to Dynamic for the consideration of €1.[46]The SSA was dated 22nd October 2021 and is an English-language document but purported to be governed by PRC law. The SSA was purportedly signed by Ms Qiu as “authorized signatory” on behalf of ETS, and purportedly signed by two Intertrust employees, Ms Kanchana Boopalan and Mr Song Yongtao on behalf of Grandall as a corporate director of Dynamic. However, in their second affidavit sworn on 7th February 2022 in the Singapore proceedings, Ms Boopalan and Mr Song exhibited the SSA and stated that “We did not sign the Exhibited Agreement on behalf of [Dynamic] and believe that the Exhibited Agreement is not authentic”.[47]The recitals to the SSA provided that ETS (defined as “the Vendors”) wishes to transfer and assign to the Dynamic (defined as “the Purchasers”) “all rights, title and interest of the Vendors in the Shares”. The SSA provided that the Purchaser will “purchase” the Shares “free and clear of any liens, charges and encumbrances” for a total price of €1. The SSA included representations and warranties that the “Vendors are the beneficial owners of the Shares and have the right and will at the Completion date have the right to sell”, and that “prior to Completion the Company will keep its financial status and will not do or suffer not whereby its financial position shall be materially altered” [sic]. Mr Barden KC noted that there is no mention in the SSA of Xinbo, the 2018 Agreement or the Qiu-Xinbo Trust Agreement, or Xinbo or any other party having security rights over the Unpledged Shares.[48]ETS’s Articles of Association (Article 9.2.4) required Sino Power to consent to any transfer of ETS’s shares. Even so, as evidenced by Mr Beatty’s witness statement, at para. 15-19, Sino Power did not consent to the Disposal.[49]On 18th October 2021, Dynamic opened a securities account with BNPSS in Paris. On 26th October 2021, Ms Qiu emailed BNPSS as Custodian of the Unpledged Shares, directing it to transfer the Unpledged Shares to Dynamic. BNPSS did so. In support of her instruction, Ms Qiu attached a purported delegation of power (“the Delegation”) from ETS’s Board to her personally, giving her the power to give instruction “for the purpose of operating the securities account”, and also attached a copy of the purported SSA. The Delegation was dated 25th October 2021 and signed, purportedly on behalf of ETS, by Ms Qiu and Mr Tan, who are stated in the Delegation to be the only Managers of ETS. It gave Ms Qiu (as “delegate”) the power to give instructions to BNPSS, as she may determine, for the purposes of operating the Securities Account and the assets therein. As Mr Barden KC noted, the Delegation made no reference to the SSA and Disposal.[50]As at 27th October 2021, the day of the Disposal, the share price of SMCP was €7.01 per share, ETS held 40,135,102 shares in ETS (over 53%) with a total market value of €281 million. There were 28,028,163 Pledged Shares with a market value of €196 million. The number of Unpledged Shares was 12,106,939, which had a total market value of €85 million.[51]On 28th October 2021, unaware of the Disposal, on the instructions of the Bondholders, GLAS took possession of 21,952,315 of the Pledged Shares (representing approximately 29% of the share capital of SMCP) and appointed receivers in respect of the remaining 6,075,848 Pledged Shares held by BNPSS.[52]On 3rd November 2021, Dynamic instructed BNPSS to transfer the Unpledged Shares into bearer form from a registered form, which were placed in the custodianship of JPM Singapore.[53]At this stage, GLAS and the Bondholders remained unaware of the Disposal.[54]On 4th November 2021, they were granted a “conservatory seizure order” in Paris.[55]On the same day, on 4th November 2021, SMCP issued a press release announcing the Disposal of the Unpledged Shares but did not disclose the identity of the transferee. This was the first time that GLAS and the Bondholders were aware of the Disposal. On 5th November 2021, GLAS obtained an order from the President of the Paris Commercial Court against BNPSS, which(i) required BNPSS to provide information relating to the identity of the transferee of the Unpledged Shares, and(ii) required BNPSS not to comply with any instruction to transfer the Unpledged Shares or to convert them into bearer form.[56]Over the period from 9th to 12th November 2021, BNPSS provided information in accordance with the order of the Paris Commercial Court, including that ETS had transferred the Unpledged Shares on 27th October 2021 to Dynamic, into an account with BNPSS, and that Dynamic had instructed BNPSS to convert the Unpledged Shares into bearer form, which had taken place on 3rd November 2021. On 12th November 2021, BNPSS stated that JPM Singapore was currently the Custodian of those shares.[57]On 13th November 2021, ETS issued a press release stating that “there are on-going unresolved legal proceedings between [ETS] and GLAS … in particular, [ETS] has commenced a legal action against, among others, GLAS in England seeking discovery of the relevant documents and identifying all wrongdoers involved in a suspected conspiracy. In consideration of the chain of the relevant events, GLAS has been named as one of the defendants in the said action … pending the determination of the legal proceedings, of which GLAS is obviously aware, GLAS’ appointment as the trustee under the Bonds as well as the Enforcement Action are subject to dispute …”.

ETS’s bankruptcy

[58]On 22nd October 2021, GLAS served a petition for ETS’s bankruptcy. ETS, at the instance of Ms Qiu, defended this petition on the grounds that GLAS’s appointment as Trustee was invalid and that the value of the Pledged Shares was sufficient to discharge the debt owed.[59]On 28th February 2023, ETS was declared bankrupt and Ms Valérie Kopéra was appointed the Curateur by the Luxembourg Court of Appeal.[60]Shortly thereafter, on 15th March 2023, the Curateur was presented with the Beihai Award (purportedly dated 10th January 2023), and with an ex parte Recognition Order made by the Singapore Court which Xinbo had obtained. The Beihai Award purported to relate to an arbitration between Xinbo, Shandong Ruyi and ETS, in which ETS (still under the control of Ms Qiu) had acknowledged its liability under the 2018 Agreement and the validity of the pledge. The Curateur confirmed that there is no record in ETS’s documents of the Notice of Arbitration, or of any communications surrounding the arbitration proceedings (Ms Kopéra’s first witness statement, para. 67-69).[61]On 13th March 2023, Xinbo issued an Arbitration Claim Form in England seeking recognition/enforcement under section 101 and/or section 66 of the Arbitration Act 1996, in respect of the purported Beihai Award. The named defendants were Shandong Ruyi and ETS. However, this Claim Form was never served and the proceedings were not pursued.[62]Instead, Xinbo pursued enforcement proceedings in Singapore, obtaining, on 14th March 2023, an ex parte order from the Registrar (with liberty to apply to set aside) giving permission to enforce the Beihai Award. The Curateur gave instructions to her counsel to apply to set aside the ex parte Order. That application was contested by Xinbo. On 20th November 2023, the Singapore Court made an order requiring Xinbo to disclose documents relating to the Beihai Arbitration, but Xinbo failed to give full disclosure, and on 28th February 2024, the Singapore Court made an unless order against Xinbo, with which Xinbo failed to comply. As a result, on 25th March 2024, an order was made dismissing the enforcement proceedings in Singapore and setting aside the ex parte order. Xinbo appealed, but its appeals were dismissed by the Singapore High Court on 3rd December 2024 and the Singapore Court of Appeal on 4th July 2025.[63]On 5th May 2023, the shareholding in Dynamic was transferred by Precious Pearl to Jining Ruyi High Performance New Materials Co, a company said to be beneficially owned by Xinbo.[64]On 26th January 2024, Ms Kopéra was replaced by Mr Max Mailliet as the Curateur.[65]In August 2025, the Unpledged Shares were returned to ETS by JPM Singapore, following orders made by this Court and the Court in Singapore.

Procedural history

[66]GLAS commenced proceedings in France before the Paris Commercial Court, obtaining various orders including for the provision of information by BNPSS and a freezing order.[67]GLAS also commenced proceedings in the British Virgin Islands and in Singapore. The BVI and Singapore proceedings were subsequently stayed in favour of the determination of the substantive claims in these English proceedings.[68]On 15th November 2021, GLAS commenced the current proceedings. On 17th November 2021, the Court made a freezing order against ETS and Dynamic, which was continued on 1st December 2021.[69]ETS and Ms Qiu filed Acknowledgments of Service in these proceedings, but Dynamic did not. ETS (still under the control of the Ruyi Group) filed a Defence which disputed the validity of GLAS’s appointment as Trustee and asserted that the Disposal was valid. Ms Qiu did not file a Defence.[70]GLAS applied for summary judgment on its claims under the Bonds and in relation to the validity of its appointment. On 17th October 2022, that application was determined by the Court (Mr Simon Salzedo KC sitting as a deputy High Court judge) in favour of GLAS by granting summary judgment under the Bonds for:(1) €250,000,000 principal plus €13,232,876.72 in interest on the Bonds as at 17th October 2022.(2) Further interest of €383,561.64 from 18th October 2022 to 31st October 2022.(3) Interest to run at the Judgments Act 1838 rate thereafter.[71]As at the first day of the trial, the total amount owing was €339,520,900 before any other costs and expenses (such as the costs of these proceedings as the Trustee’s costs).[72]By an order dated 12th July 2024 (Robin Knowles J), at a time when Xinbo was not a party to the proceedings, summary judgment was granted in favour of GLAS “on its claims against ETS and Dynamic for the return of the 12,106,939 shares in SMCP SA (the “Unpledged Shares”) currently held in Dynamic’s account with JP Morgan in Singapore”. No summary judgment was granted against Ms Qiu. In his judgment [2024] EWHC 1841 (Comm), Robin Knowles J held at para. 10:
“… the transfer of shares for €1 consideration did not have the required consents. Further, there was not the actual or valid signature of the professional trustees. In the circumstances detailed in the Claimant’s evidence, the challenge to the transfer is clearly, to my mind, good on the basis, first, of absence of authority and, second, by applying section 423 and following of the Insolvency Act.”

The issues for determination

[73]GLAS’s claims are for:(1) Declaratory relief in relation to the invalidity of the Disposal.(2) Relief under section 423 of the Insolvency Act 1986.(3) For relief by reason of unlawful means conspiracy and/or for inducing breach of contract.(4) If (contrary to GLAS’s primary case) Luxembourg law governs, for relief against Ms Qiu under the Luxembourg Law on Commercial Companies and under the Civil Code, and against Dynamic and Xinbo as parties complicit in her breach.[74]The following issues which arose at trial require determination (which I have slightly re-ordered from the list of issues filed with the Court):(1) What is the governing law of the claims and what is its content?(2) Is the purported 2018 Agreement valid and genuine? If so, what rights - if any - did Xinbo have in relation to the Unpledged Shares?(3) Is the purported Qiu-Xinbo Trust Agreement a valid and genuine document? In what circumstances was it created?(4) Are the purported Notices of 8th October and 9th October 2021 valid and genuine documents? In what circumstances were they created and sent?(5) Is the purported SSA dated 22nd October 2021 valid and genuine? In what circumstances was it entered into?(6) What were the circumstances in which the Disposal took place, and was it invalid, a transaction at an undervalue or a breach of duty?(7) In what circumstances was the purported Beihai Award obtained? What effect (if any) does it have in relation to the Unpledged Shares?(8) Did Ms Qiu act in breach of duty by causing ETS to advance defences in these proceedings and/or the Luxembourg bankruptcy position, for the purposes of delaying or frustrating the resolution of the position in relation to the Unpledged Shares and the Pledged Shares?(9) Subject to any relevant requirement to prove loss and damage, and subject to the existing judgments, are the Second, Third and Fourth Defendants liable to the Trustee under section 423 of the Insolvency Act 1986, under English tort law and/or Luxembourg law?(10) What relief (if any) is appropriate?[75]There had been an assertion by Xinbo that it was entitled to an order that the Unpledged Shares be transferred to it, but as Xinbo has not satisfied the conditions imposed on it by prior orders of the Court, this claim is not open to Xinbo.[76]The quantum of any damages and/or monetary relief against Dynamic, Ms Qiu and Xinbo which might be ordered are to be determined at a subsequent trial.

Position of the Defendants who are debarred

[77]In considering these issues, Mr Barden KC submitted that the Court should draw adverse inferences against Dynamic, Ms Qiu and Xinbo, because:(1) The Court’s prior orders, non-compliance with which have resulted in Xinbo, Ms Qiu and Dynamic being debarred, recognise the importance of disclosure to the issues in this case.(2) There are a number of key documents in respect of which the Defendants have not given disclosure of “wet-ink signature originals”, or of soft copy versions with metadata from the relevant time.(3) Very few contemporaneous communications between and within the Defendants have been disclosed.(4) Ms Qiu through her solicitors has maintained that all of ETS’s documents were in the Curateur’s possession and promised to disclose the ETS documents in her possession to the Curateur, but has not done so.(5) As stated in the twelfth witness statement dated 19th May 2025 of Mr Jason Yardley (of Jenner & Block London LLP, GLAS’s solicitors), at para. 18-34, (a) The Defendants stated that the large majority of messages were exchanged using the Chinese app WeChat, and due to the loss or upgrading of mobile phones, messages were not retained. GLAS disputes the plausibility of that explanation; this argument was foreshadowed by the Singapore High Court in Wuhu Ruyi Xinbo Investment Partnership v Shandong Ruyi Technology Group Co Ltd [2024] SGHC 308, at para. 109(b), but the Singapore Court made no relevant findings. (b) On 30th April 2025, Xinbo’s solicitors stated that an “unexpected number of documents [had been] identified”, many requiring translation, and proposed tranched disclosure, but the only documents disclosed had already been produced in these proceedings or in Singapore, and no further disclosure was ever provided.(6) In Wuhu Ruyi Xinbo Investment Partnership v European Topsoho S.àr.l [2025] SGCA 32, para. 24, the Singapore Court of Appeal concluded in related proceedings that Xinbo had breached its orders (a) by failing to give an adequate explanation of how it had lost possession or control of WeChat messages between representatives of Xinbo and ETS, (b) by failing to disclose WeChat messages in Mr He Hanchu’s possession; and (c) by failing to produce original documents for ETS’s inspection.(7) The dispute in this case arose almost instantaneously after the Disposal, with Ms Qiu having been served with proceedings in November 2021. It would follow that the WeChat messages and documents would have existed then and should have been preserved (Mr Yardley’s second witness statement, para. 124).(8) In proceedings concerning the Beihai Award, in Wuhu Ruyi Xinbo Investment Partnership v Shandong Ruyi Technology Group Co Ltd [2024] SGHC 308, para. 23, the Singapore High Court stated that a production order was made to “fill the gaps in the Curator’s knowledge about the Arbitration and the Award” and held that Xinbo’s breach of the relevant “Unless Order” was “intentional and contumelious” (para. 169).[78]I am satisfied that the failure of the Defendants to produce documents in answer to Court orders on numerous occasions justifies the drawing of adverse inferences where appropriate. However, as will be clear, as I dispose of the issues for determination, there is sufficient evidence (even without such adverse inferences) to conclude that the Disposal was invalid and not genuine.[79]This conclusion is further supported by the investigation undertaken by the Curateur which I shall now discuss.

The position of the Curateur of ETS

[80]As mentioned above, the Curateur was appointed in 2023. Under Luxembourg law, the Curateur of ETS operates under the supervision of the Luxembourg Court and is obliged to recover and realise ETS’s assets, to verify the existence and extent of claims against the insolvent estate, and to pay creditors and distribute sums recovered according to the applicable priority rules. Those duties encompass an obligation to review the position that ETS has taken in these proceedings, including on an ongoing basis as new facts and matters come to light.[81]Mr Langley on behalf of the Curateur stated that Ms Kopéra as Curateur undertook “a careful and detailed investigation into the matters which underpin these proceedings”, including:(1) inspecting ETS’s books and records, insofar as they had been provided to the Curateur by ETS’s former domiciliary agent (JTC Corporate Services (Lux) SARL);(2) reviewing public filings by ETS;(3) interviewing the former Luxembourg legal counsel of ETS;(4) interviewing ETS’s former B Managers;(5) interviewing ETS’s former auditor, KPMG.[82]As a result of that investigation, the Curateur did not come across any material which supported the defences that had been advanced by ETS prior to bankruptcy or any material that would be expected to exist if the underlying transactions were genuine had not been found.[83]Mr Langley submitted that the Curateur’s investigations were said to have been impeded both prior to and during the currency of these proceedings by a lack of co-operation and repeated failures to provide information and documentation when requested in that:(1) Prior to bankruptcy, ETS was represented in these proceedings by Ince & Co (“Ince”). After the Curateur had been appointed, Ms Kopéra instructed CMS Cameron McKenna Nabarro Olswang LLP (“CMS”) as ETS’s new solicitors. Ince were asked to transfer their ETS file to CMS. In purported compliance with that request, Ince transferred two tranches of documents in July and August 2023. From the Curateur’s initial review of those documents, it was apparent that Ince should have had more material from ETS. In December 2023, CMS wrote to Ince to inquire into the significant gaps in key categories of documents. However, CMS were informed by way of automated response that Axiom Ince Ltd (of which Ince formed part) had been closed in October 2023 following an intervention by the Solicitors Regulation Authority. The file that was provided to CMS by the Intervention Agent was remarkably thin and filled no gaps in the documentary record.(2) Ms Qiu has been persistent in her lack of co-operation with the Curateur’s investigations, in not making herself available for interview, which is not the conduct of a person with a straightforward account to give. Further, Ms Qiu had a tendency to refer in her various witness statements to documents that the Curateur had not seen and could not find within ETS’s files. The Curateur pressed Ms Qiu to provide copies of all ETS documents in her possession but was met with resistance. Accordingly, on 19th January 2024, CMS wrote to Ms Qiu’s solicitors (Mackrell Solicitors) to refer to these exchanges and asked again for confirmation that the documents would be handed over immediately. The inference to be drawn is that Ms Qiu was withholding relevant documentation from the Curateur and/or the documentation did not exist, either of which undermines the credibility of Ms Qiu.(3) The Curateur was first made aware of the existence of the arbitration proceedings and the Beihai Award by an email on 15th March 2023 sent by a Chinese lawyer acting for Xinbo after Xinbo sought to enforce the Beihai Award in Singapore. On 3rd April 2023, the Curateur filed an application to set aside the enforcement order. Xinbo was given every opportunity to produce documents going to the legitimacy of the arbitration but deliberately chose not to do so, which necessarily hampered the Curateur’s ability to verify the authenticity of any documents that had been produced.[84]The Curateur’s investigations, and the lack of transparency in response to those investigations, ultimately led to the conclusion that ETS’s defence to GLAS’s claims, which was advanced at a time when ETS was under the ownership and/or control of Ms Qiu, could not be supported and it was duly withdrawn. The basis for that decision was explained in Ms Kopéra’s first witness statement dated 29th August 2023. In summary:(1) Neither the purported 2018 Agreement nor the SSA was co-signed by a B Manager. Both were signed by Ms Qiu alone, in apparent breach of Article 12 of ETS’s Articles of Association. The Curateur found no evidence that ETS had delegated authority to Ms Qiu to sign either document. The only delegation of power she could identify was one signed by Ms Qiu and Mr Huang dated 25th October 2021, authorising Ms Qiu to give instructions to BNPSS in connection with the transfer of the Unpledged Shares, but that post-dated the SSA by three days and did not refer to it. The Curateur concluded that the SSA did not appear to be valid or binding on ETS as the requirements of Article 12 had not been met.(2) The B Managers had no knowledge of the purported 2018 Agreement or of any security interests over the SMCP Shares other than those pledged under the Trust Deed.(3) There was no record in ETS’s files of the circumstances leading to the execution of the 2018 Agreement, or of any communications or evidence relating to its negotiation, execution, or existence. The 2018 Agreement was not disclosed in ETS’s 2018, 2019, or 2020 financial accounts, in the Managers’ Certificate, or in any press statements.(4) The Curateur had been unable to locate any pledge of the Unpledged Shares registered in France. The consequence was that the purported pledge was invalid and unenforceable as a matter of French law.(5) As to the SSA, the Curateur noted that the Grandall directors had stated in a sworn affidavit filed in Singapore that they did not sign the SSA and did not believe it to be an authentic document.(6) The SSA did not refer to the 2018 Agreement, the 8 October Notice, or the 9 October Notice. It was also unclear why Xinbo would have had to procure Dynamic to purchase the Unpledged Shares for €1, when the SMCP Shares were purportedly already pledged to Xinbo under the 2018 Agreement. The Notices were themselves deficient. The 8 October Notice was addressed to Ms Qiu personally rather than to ETS; it did not mention Dynamic; and it referred to the transfer of all of the SMCP Shares, rather than just the Unpledged Shares. The 9 October Notice contained a bank account number that, as BNPSS subsequently confirmed, did not exist until 18th October 2021, suggesting that it was backdated.(7) The Curateur had not seen any evidence of Xinbo asserting a default by the Shandong Ruyi Group on the underlying loan, or claiming under the guarantee purportedly issued by ETS, at any point prior to ETS’s default under the Bonds.(8) The Curateur had not seen any evidence of Sino Power’s consent (as required by Article 9.2.4 of ETS’s Articles).(9) The Curateur ultimately concluded that the Transfer of the Unpledged Shares was ultra vires.[85]Since that decision to withdraw ETS’s defence to GLAS’s claims was taken, the interests of GLAS and the Curateur have broadly aligned in seeking and obtaining the return of the Unpledged Shares to ETS, with a view to realising the proceeds of sale for the benefit of ETS’s creditors.[86]As the focus of the current trial is on GLAS’s causes of action in tort and under the Insolvency Act 1986 against the Defendants other than ETS, the Curateur takes no position on whether those claims are established. However, GLAS’s claims against the other Defendants are focused on the underlying documents and arrangements which led to the Disposal and GLAS contends that the Disposal was not a genuine commercial arrangement. The Curateur agrees with GLAS’s case in that regard. Indeed, GLAS’s submissions as to the suspicious and often inexplicable nature of the transactions relating to the Disposal largely mirror the conclusions that the Curateur independently reached, and which prompted the withdrawal of ETS’s Defence to GLAS’s claims.[87]It is said that the outcome of this trial is of real significance to ETS’s bankruptcy estate in that Xinbo’s alleged claims against ETS and alleged entitlement to the Unpledged Shares have been used as a tool to interfere with the bankruptcy process. Unlike the Curateur, the other Defendants have never accepted that the underlying arrangements are not valid or genuine, and so the Curateur would welcome the clarity that a judgment from this Court would bring.

Issue (1): The governing law

[88]Mr Barden KC on behalf of GLAS submitted that GLAS’s claims are to be determined in accordance with English law. If, however, Luxembourg law is applicable, GLAS claims it is entitled to relief under Luxembourg law.[89]The claim under English law is for relief under section 423 of the Insolvency Act 1986 and for relief resulting from alleged economic torts.

Section 423

[90]For the reasons developed by Mr Barden KC, in respect of the claim under section 423 of the Insolvency Act 1986, I accept that the Court has jurisdiction to make an order under section 423 notwithstanding the fact that the debtor (ETS) and the recipient of the Shares (Dynamic) are not domiciled, resident or located in England. Section 423 contains no territorial limit. If the claim is made under section 423, the Court is entitled to exercise its discretion, which involves considering whether there is a sufficient connection to make it just and proper to make an order despite the foreign element.[91]In Orexim Trading Ltd v Mahavir Port and Terminal Pte Ltd [2018] EWCA Civ 1660; [2018] 1 WLR 4847, Lewison LJ stated at para. 25-30 that:
“25. The courts have considered the territorial reach of section 423 on a number of occasions. It was first considered by this court in In re Paramount Airways Ltd [1993] Ch 223 together with similar provisions in section 238 of the 1986 Act. Having summarised the legislation Sir Donald Nicholls V-C said, at p 235: “It will have been seen from the above summary that, on its face, the legislation is of unlimited territorial scope.” (Emphasis added.)
26. He considered the policy underlying the court’s powers at p 239:
“Trade takes place increasingly on an international basis. So does fraud. Money is transferred quickly and easily. To meet these changing conditions English courts are more prepared than formerly to grant injunctions in suitable cases against non-residents or foreign nationals in respect of overseas activities. As I see it, the considerations set out above and taken as a whole lead irresistibly to the conclusion that, when considering the expression ‘any person’ in the sections, it is impossible to identify any particular limitation which can be said, with any degree of confidence, to represent the presumed intention of Parliament. What can be seen is that Parliament cannot have intended an implied limitation along the lines of In re Sawers (1879) 12 Ch D 522. The expression therefore must be left to bear its literal, and natural, meaning: any person.” 27. In Bilta (UK) Ltd v Nazir (No 2) [2016] AC 1, para 110 these considerations were said to be “unanswerable”. 28. However, as Sir Donald Nicholls V-C went on to point out, the court has a discretion whether or not to make an order under section 425; and it might refuse to exercise that discretion if the defendant has insufficient connection with England and Wales. He added, at p 240: “in considering whether there is a sufficient connection with this country the court will look at all the circumstances, including the residence and place of business of the defendant, his connection with the insolvent, the nature and purpose of the transaction being impugned, the nature and locality of the property involved, the circumstances in which the defendant became involved in the transaction or received a benefit from it or acquired the property in question, whether the defendant acted in good faith, and whether under any relevant foreign law the defendant acquired an unimpeachable title free from any claims even if the insolvent had been adjudged bankrupt or wound up locally. The importance to be attached to these factors will vary from case to case. By taking into account and weighing these and any other relevant circumstances, the court will ensure that it does not seek to exercise oppressively or unreasonably the very wide jurisdiction conferred by the sections.” 29. The extra-territorial effect of section 423 was confirmed in Revenue and Customs Comrs v Begum [2010] EWHC 1799 (Ch). 30. The effect of the legislation, therefore, is that it confers on the court power to make orders against persons or property outside England and Wales, subject to the court being satisfied that there is a close enough connection with England and Wales.” “Trade takes place increasingly on an international basis. So does fraud. Money is transferred quickly and easily. To meet these changing conditions English courts are more prepared than formerly to grant injunctions in suitable cases against non-residents or foreign nationals in respect of overseas activities. As I see it, the considerations set out above and taken as a whole lead irresistibly to the conclusion that, when considering the expression ‘any person’ in the sections, it is impossible to identify any particular limitation which can be said, with any degree of confidence, to represent the presumed intention of Parliament. What can be seen is that Parliament cannot have intended an implied limitation along the lines of In re Sawers (1879) 12 Ch D 522. The expression therefore must be left to bear its literal, and natural, meaning: any person.” “in considering whether there is a sufficient connection with this country the court will look at all the circumstances, including the residence and place of business of the defendant, his connection with the insolvent, the nature and purpose of the transaction being impugned, the nature and locality of the property involved, the circumstances in which the defendant became involved in the transaction or received a benefit from it or acquired the property in question, whether the defendant acted in good faith, and whether under any relevant foreign law the defendant acquired an unimpeachable title free from any claims even if the insolvent had been adjudged bankrupt or wound up locally. The importance to be attached to these factors will vary from case to case. By taking into account and weighing these and any other relevant circumstances, the court will ensure that it does not seek to exercise oppressively or unreasonably the very wide jurisdiction conferred by the sections.”
[92]At para. 55, Lewison LJ added that “The breadth of the potential scope of section 423 makes it all the more important that in a case with a foreign element the court is scrupulous to ensure that the safeguards are rigorously applied”.[93]Mr Barden KC relied on Evans-Lombe J’s judgment in Jyske Bank (Gibraltar) Ltd v Spjeldnaes (No. 2) [2000] BCC 16, at 34, who said with reference to the Vice-Chancellor’s judgment in In re Paramount Airways Ltd [1993] Ch 223 that:
“I do not read this passage in the Vice-Chancellor’s judgment as laying down that a court should never grant an order under s. 423(2) in the exercise of its discretion in the absence of any of the sort of connections with England which the Vice-Chancellor set out but it has to be accepted that there are no such connections in the present case. I have nonetheless come to the conclusion that I should grant the relief sought …”
I have nonetheless come to the conclusion that I should grant the relief sought …”[94]In Dornoch v Westminster International BV [2009] EWHC 1782 (Admlty); [2010] Lloyd's Rep IR 1, the defendant insureds and the relevant vessel (which had been the subject of a sale) were located outside the jurisdiction, but the claimants who claimed an interest in the vessel were insurers under an English law insurance policy subject to English jurisdiction. In these circumstances, the Court had no difficulty in finding a sufficient connection with the jurisdiction. At para. 132-134, Tomlinson J said:
“132. It is accepted that, as held by Sir Donald Nicholls VC in Re Paramount Airways [1993] Ch 223, the jurisdiction is subject to no territorial limitation. The fact that both the First and the Fourth Defendants are overseas companies and that the transaction in question concerned moveable property situate in Thailand is relevant only to the question whether the court should exercise its discretion to grant relief. On the other hand I fully recognise the special need for care when exercising an extraterritorial discretionary power - see Banco Nacional de Cuba v Cosmos [2000] BCC 910. In the context of winding-up, the subject matter of that case, one is concerned not just with the connection with this jurisdiction of the company which it is sought to wind up, but also with the connection of the potential beneficiaries–see per Knox J in Re Real Estate Development Co [1991] BCLC 210 at 217. What one is concerned to find is a sufficient connection to justify the court setting in motion procedures over a body which prima facie is beyond the limits of territoriality–see again per Knox J at page 217. 133. In Re Paramount Sir Donald Nicholls VC said that the court will need to be satisfied that, in respect of the relief sought against him, the defendant is sufficiently connected with England for it to be just and proper to make the order against him despite the foreign element … 134. I particularly note from the foregoing that Sir Donald Nicholls regarded no one factor as decisive. Each case will turn on its own facts with the weight to be given to connecting factors or their absence dependent on their real significance having regard to the overall situation. In Jyske Bank (Gibraltar) Ltd v Spjeldnaes [1999] 2 BCLC 101 Evans-Lombe J, whose experience in this field is very considerable, exercised the jurisdiction even though as he expressly recognised there were present none of the sort of connections with England which the Vice Chancellor had set out.”
[95]Of course, the extra-jurisdictional connections which exist are an important consideration to be taken into account in the exercise of the Court’s discretion under section 423.In New Media Distribution Company SEZC Ltd v Kagalovsky [2018] EWHC 2876 (Ch), Marcus Smith J said at para. 77:
“This requirement does not exist in the present case, because these proceedings have been commenced as of right. That does not mean that where a section 423 claim is commenced against a defendant as of right, the court should never exercise its undoubted discretion to make no order against that defendant. But it seems to me that a court having jurisdiction as of right should be slow to decline to make an order at all unless it is clear that the making of such an order will cut across the position under some relevant foreign law. Where that is the case, an English court seised as of right must pay careful regard to the exorbitance or potential extraterritorial adverse effect of making an order under the section 423 jurisdiction …”
[96]GLAS submitted that there is a sufficient connection with the jurisdiction in this case, because:(1) The ultimate obligations which the Disposal sought to avoid, namely the Bonds and the Trust Deed in respect of the Bonds, are obligations arising under English law contracts (Dornoch v Westminster International BV [2009] EWHC 1782 (Admlty); [2010] Lloyd's Rep IR 1; Integral Petroleum SA v Petrogat FZE [2023] EWHC 44 (Comm)).(2) Those obligations are owed to GLAS SAS (London branch) and are enforceable in England. The Trust Deed is subject to an English jurisdiction agreement.(3) The Pledged Shares were held by an English Custodian (again pursuant to an English law agreement with an English jurisdiction agreement).(4) In an Event of Default situation (as existed at the time of the Disposal), the ultimate obligation to pay will arise and be enforced through a judgment of the English Courts. GLAS as Trustee has power to require the Payment Agent to surrender everything to GLAS (in London). There is power to appoint English receivers with powers under the Insolvency Act 1986 and the Law of Property Act 1925.[97]I accept those submissions. There is plainly sufficient connection with this jurisdiction to enable the Court to exercise its discretion to grant a remedy under section 423 as a matter of English law, being the law of the forum.[98]In other words, the Court is entitled to exercise a discretion under section 423 being the law of the forum, English law.

Economic torts

[99]As mentioned above, GLAS contends that English law is the law applicable to the claims in respect of economic torts (i.e. conspiracy to use unlawful means and/or inducing a breach of contract). The Defendants do not contend for Luxembourg law. Xinbo’s Defence contends that the law of the PRC is the applicable law.[100]As between GLAS and ETS, clause 25.1 of the Trust Deed provides that “This Trust Deed and any non-contractual obligations arising out of or in connection with it shall be governed by and construed in accordance with English law”.[101]In relation to the other Defendants, the applicable law is determined in accordance with Article 4 of Rome II (as retained), which provides as follows:
“(1) Unless otherwise provided for in this Regulation, the law applicable to a non-contractual obligation arising out of a tort/delict shall be the law of the country in which the damage occurs irrespective of the country in which the event giving rise to the damage occurred and irrespective of the country or countries in which the indirect consequences of that event occur … (3) Where it is clear from all the circumstances of the case that the tort/delict is manifestly more closely connected with a country other than that indicated in paragraphs 1 or 2, the law of that other country shall apply. A manifestly closer connection with another country might be based in particular on a preexisting relationship between the parties, such as a contract, that is closely connected with the tort/delict in question.”
[102]Article 2(1) of the Regulation provides that “For the purposes of this Regulation, damage shall cover any consequence arising out of tort/delict, unjust enrichment, negotiorum gestio or culpa in contrahendo”.[103]In FM Capital Partners Ltd v Marino [2018] EWHC 1768 (Comm), para. 490-497, Cockerill J analysed the applicable principles in a careful exposition, which I quote extensively:
“490. Before me the parties addressed the bulk of their submissions in closing to the case of Dolphin Maritime & Aviation Services Ltd v Sveriges Angfartygs Assurans Forening [2009] EWHC 716 (Comm); [2010] 1 All ER (Comm) 473. In that case, an English company (“Dolphin”) was engaged by Turkish cargo underwriters to recover compensation from shipowners whose vessel had grounded off Gibraltar. The owners’ interests were represented by the defendant Swedish P&I Club. Dolphin entered into an agreement with the underwriters whereby only Dolphin was entitled to conduct negotiations with the Club and the full amount of any recoveries would be paid into Dolphin’s English bank account, from which Dolphin would deduct its commission. The Club provided a Letter of Undertaking addressed to the underwriters securing the shipowners’ liability, which provided for payment of any settlement monies to Dolphin or solicitors appointed by Dolphin. However, in breach of contract the underwriters concluded a settlement directly with the Club, and the Club paid the settlement monies directly to the underwriters’ bank accounts in Turkey. Dolphin sued the Club for, among other things, inducing a breach of the contract between Dolphin and the underwriters, and conspiracy to injure by unlawful means. 491. The issue was whether Dolphin had suffered the damage in England, as the place where it should have been paid the settlement monies, for the purposes of Article 5(3) of the Brussels I Regulation. Christopher Clarke J, as he then was, accepted Dolphin’s submission that it had, rejecting the argument that the harm occurred either where the settlement monies were paid or received. In particular, he held as follows: “… 56. …there is, as it seems to me, a well arguable case that, under the terms and conditions, the underwriters were bound to procure that the sums recovered directly from the Club were paid in the first instance to Dolphin. …. 57. In those circumstances, the arguments on behalf of Dolphin are, in my judgment, to be preferred. Dolphin’s essential complaint is that it suffered harm because it did not receive the $8.5 million into its bank account which it should have done because, despite knowledge that this would involve a breach of the underwriters’ contract with Dolphin, the Club paid it to their accounts in Turkey. …. the contract (which is governed and must be interpreted by English law) calls in terms for ‘Recoveries and quasi-Recoveries (i.e. sums which would otherwise comprise ‘Recoveries’) to be received direct by Dolphin and that the complaint in tort is that the Club wrongfully brought about a breach of that obligation. 58. When, in those circumstances, I ask myself ‘where the damage to the direct victim occurred’ (Dumez: Advocate General para. 52) or ‘where the event giving rise to the damage, and entailing tortious liability, directly produced its harmful effects upon the person who is the immediate victim of that event’ (Dumez (ECJ) para. 20) or ‘where the event giving rise to the damage caused injury’ (Reunion), the answer appears to me that it is in this country, where Dolphin did not receive the money which, if the contract had been performed, it should have received. 59. Further, if I ask myself what would have been the position if the tort complained of had not taken place, the answer is that payment would have been made to Dolphin in England: and the essence of Dolphin's complaint is that that did not occur. … In some cases, e.g. in cases of damage to goods or persons, the question may have no great utility. But in others where the claimant has failed to obtain some property or money which he would otherwise have received the answer to the question may be a guide to identifying where the harm in the particular case occurred. 60. I do not ignore the danger of conflating the place where the damage occurred with the place where the loss was suffered. There is, however, a difference between a case in which the claimant complains that he has lost his money or goods … and a case in which the claimant complains that he has not received a sum which he should have received. In the former case the harm may be regarded as occurring in the place where the goods were lost …or the place from or to which the moneys were paid …, although the loss may be said to have been suffered in the claimant's domicile. In the latter case the harm lies in the non-receipt of the money at the place where it ought to have been received, and the damage to him is likely to have occurred in the place where he should have received it. That place may well be the place of his domicile and, therefore, also the place where he has suffered loss.” 492. The argument before me was as to the applicability of this analysis: in particular whether it encapsulated a statement of general principle or whether (as submitted for Mr Ohmura) the case had to be read more narrowly in light of its facts, in particular that there was a specific contractual obligation on the underwriters to pay any recoveries into Dolphin’s bank account, that that contract was governed by English law, and that Dolphin had given a notification identifying a particular bank account in England for the receipt of the money. 493. I do not think such a narrow reading is justified. There does not seem to me to be anything in Christopher Clarke J’s judgment to suggest that it was intended to be confined in the way suggested by Mr Emmett or why the fact of the existence of a contractual obligation should make a significant difference. When one looks at the judgment the category of cases identified by Christopher Clarke J at [60] to which the principle stated is said to apply was one where “the claimant complains that he has not received a sum which he should have received”
. That is a general category. 494. I note that subsequent cases, in dealing with the Dolphin Maritime case, seem to regard it as encapsulating a general principle. Thus, in Pan Oceanic Chartering Inc v UNIPEC UK Co. Limited, UIPEC Asia Co. Limited [2016] EWHC 2774 (Comm) at [200], Carr J applied the Dolphin Maritime analysis in a case concerning Article 4(1) of Rome II. Similarly in the Brussels cases of Actial Farmaceutica LDA v Professor Claudio De Sione, Mendes SRL, MS Florence Pryen [2016] EWCA Civ 1311 at [34] – [37] and the judgments of both the Court of Appeal and Supreme Court in AMT Futures Ltd v Marzillier, Dr Meier & Dr Guntner Rechtsanwaltsgesellschaft mbH: [2014] EWCA Civ 143, [2015] QB 699 at [37], [50] and [53] and [2017] UKSC 13; [2017] 2 WLR 853 at [26] the principle was applied in the way one would a general principle. 495. Although it is fair to say that in the latter case Dolphin was described as a case where there was a positive obligation to make a payment, that has to be looked at in the context of the specific argument which was in issue there. The focus in both cases was on inducing breach of contract, and so focus on the concept of obligation is natural in both. But the distinctions as noted by the Supreme Court are important. It was a case where (unlike Dolphin) there was no single route to perform the obligation but a variety of ways the obligation could be performed:
“They were under an obligation not to sue in Germany or elsewhere than England. The former clients could have performed their contractual obligations to AMTF either by not raising proceedings in Germany or, having raised those proceedings, by discontinuing them”
. But this was only a distinction … 497. Ultimately, I form the view that the Dolphin principle is a general one - though it is simply one of the permissible methods of trying to discern the country where the damage occurs.” “… 56. …there is, as it seems to me, a well arguable case that, under the terms and conditions, the underwriters were bound to procure that the sums recovered directly from the Club were paid in the first instance to Dolphin. …. 57. In those circumstances, the arguments on behalf of Dolphin are, in my judgment, to be preferred. Dolphin’s essential complaint is that it suffered harm because it did not receive the $8.5 million into its bank account which it should have done because, despite knowledge that this would involve a breach of the underwriters’ contract with Dolphin, the Club paid it to their accounts in Turkey. …. the contract (which is governed and must be interpreted by English law) calls in terms for ‘Recoveries and quasi-Recoveries (i.e. sums which would otherwise comprise ‘Recoveries’) to be received direct by Dolphin and that the complaint in tort is that the Club wrongfully brought about a breach of that obligation. 58. When, in those circumstances, I ask myself ‘where the damage to the direct victim occurred’ (Dumez: Advocate General para. 52) or ‘where the event giving rise to the damage, and entailing tortious liability, directly produced its harmful effects upon the person who is the immediate victim of that event’ (Dumez (ECJ) para. 20) or ‘where the event giving rise to the damage caused injury’ (Reunion), the answer appears to me that it is in this country, where Dolphin did not receive the money which, if the contract had been performed, it should have received. 59. Further, if I ask myself what would have been the position if the tort complained of had not taken place, the answer is that payment would have been made to Dolphin in England: and the essence of Dolphin's complaint is that that did not occur. … In some cases, e.g. in cases of damage to goods or persons, the question may have no great utility. But in others where the claimant has failed to obtain some property or money which he would otherwise have received the answer to the question may be a guide to identifying where the harm in the particular case occurred. 60. I do not ignore the danger of conflating the place where the damage occurred with the place where the loss was suffered. There is, however, a difference between a case in which the claimant complains that he has lost his money or goods … and a case in which the claimant complains that he has not received a sum which he should have received. In the former case the harm may be regarded as occurring in the place where the goods were lost …or the place from or to which the moneys were paid …, although the loss may be said to have been suffered in the claimant's domicile. In the latter case the harm lies in the non-receipt of the money at the place where it ought to have been received, and the damage to him is likely to have occurred in the place where he should have received it. That place may well be the place of his domicile and, therefore, also the place where he has suffered loss.”[104]Mr Barden KC submitted that:(1) The “damage” in respect of the Unpledged Shares is in essence the non-payment of the obligation in respect of the Bonds and the decline in value of the SMCP Shares. After an Event of Default, GLAS was entitled to call for payment in England, in accordance with clause 2.4 of the Trust Deed, where GLAS would hold the proceeds on an English law trust for the Bondholders.(2) Thus, on the application of Article 4(1) of Rome II, the irreversible loss suffered by GLAS (and ultimately the Bondholders) occurred in England.(3) There was no justification for resorting to French or Luxembourg law pursuant to Article 4(3), bearing in mind the “high hurdle” that provision represents (Pan Oceanic Chartering Inc v UNIPEC UK Co Ltd [2016] EWHC 2774 (Comm); [2017] 2 All ER (Comm) 196, para. 206; Committeri v Club Méditerranée SA [2016] EWHC 1510, para. 36, 57; FM Capital Partners Ltd v Marino [2018] EWHC 1768 (Comm), para. 517) and that Xinbo’s assertion that the law of the PRC is applicable is not justified given that the only connection with that system of law is the location of Ms Qiu and Xinbo, and the law governing the agreements which purported to effect the Disposal, but GLAS is not a party to such agreements.[105]In my judgment, Mr Barden KC’s submissions are undoubtedly correct for the reasons given. Therefore, English law is the law to be applied in determining the claims in respect of the economic torts.

Conclusion on governing law

[106]For the reasons explained above, English law is the law applicable to the claim under section 423 of the Insolvency Act 1986 (as the law of the forum) and in respect of the economic torts (as the applicable law under Rome II).[107]I dismiss Xinbo’s argument that the law of PRC is applicable. It was not suggested that any loss was suffered in the PRC at all.[108]Further, I do not consider that the law of Luxembourg need be addressed in this context. The Curateur did not suggest that the law of Luxembourg should be applied.

Issue (2): Was the 2018 Agreement valid and genuine?

[109]GLAS invited the Court to conclude that, on the balance of probabilities, the 2018 Agreement was not entered into in 2018, and was created and backdated to corroborate the Disposal by reliance on the supposed security rights of Xinbo.[110]The 2018 Agreement was said to be concluded between ETS, Shandong Ruyi and Xinbo, by which ETS purportedly guaranteed the substantial indebtedness of Shandong Ruyi to Cinda and pledged all of the SMCP Shares to Xinbo in support of that guarantee.[111]In my judgment, having regard to GLAS’s submissions, there are numerous difficulties with the 2018 Agreement being treated as a genuine document created in July 2018:(1) There are no contemporaneous background documents, and there is no record of the 2018 Agreement in ETS’s files.(2) At the purported date of the 2018 Agreement, the SMCP shares had a value of €960 million, well in excess of Shandong Ruyi’s supposed debt of €177 million (Mr Yardley’s second witness statement, para. 89-91). There is little sense in such an arrangement. As Mr Yardley stated in his second witness statement, at para. 91-92: “91. It does not seem plausible to me that ETS would have signed a document, just two months before issuing the Bonds (which ETS would have been aware would require it to grant security over some of its shares in SMCP), pledging the entirety of its shares in SMCP to a related party. Put differently, if Shandong Ruyi and ETS had genuinely entered into the 2018 Agreement in July 2018, that would have involved the Ruyi group and ETS tying up the entire value of all their shares in SMCP, then valued at just under €1 billion, leaving them legally unable to use any of those shares to raise the further funding under the Bonds just two months later (and requiring them to lie to their own legal counsel, their auditors, the underwriters of the Bonds (and their legal counsel) and the public market at the time when those Bonds were issued and over the course of the subsequent years until at least July 2021). I do not believe they did sign such a document in July 2018. 92. On the other hand, if someone was creating a document in late 2021 or early 2022 (when the existence of the 2018 Agreement was first alleged by ETS), rather than in July 2018, the purported pledge of all the c. 40.1 million shares in SMCP would appear to make much more sense.”(3) Entry into the 2018 Agreement would have needed to be approved by ETS’s Board, including the Luxembourg B Managers, in accordance with ETS’s Articles of Association (Mr Yardley’s second witness statement, para. 85). The Curateur could find no record of the agreement (for example, no minutes of meetings or resolutions) or any such approval, and was told by the B Managers that they were unaware of it; and stated that there would have been an obligation under French law to declare such a pledge, but no such declaration was made; nor was the alleged liability in respect of the underlying pledge referred to in ETS’s Annual Accounts at any point in the relevant period (Ms Kopéra’s first witness statement, para. 23, 51, 53-54, 56).(4) Ms Qiu’s explanation in her sixth witness statement, para. 58, that it was understood that the B Managers would handle only “administrative aspects” is directly inconsistent with the Articles of Association and with the execution of other documents such as the Trust Deed (Mr Yardley’s second witness statement, para. 85).(5) The supposed existence of a pledge of all the SMCP shares under the 2018 Agreement was not identified when the Bonds were issued in autumn 2018, just two months later. The existence of the 2018 Agreement is directly contrary to the security arrangements entered into upon the issue of the Bonds. The better explanation is that the 2018 Agreement did not exist.(6) There is no suggestion that BNPSS as Custodian of the Pledged Shares under the Bond arrangements, was informed or aware of the (now) suggested prior pledge of those SMCP shares, which would have been an encumbrance on the property of which it was the appointed custodian.(7) When, on 17th June 2021, the Managers of ETS (including Ms Qiu, who is the purported signatory to the 2018 Agreement) gave the Managers’ Certificate, they stated that there was no security interest over the Shares other than in respect of the Bonds. In her sixth witness statement, Ms Qiu stated at para. 62 that the “Shares” refer to the Pledged Shares, but that does not sit well with the description of the Shares in para. (ix) of the Certificate being the Shares “which are not subject to the Security”.(8) There was no attempt by Xinbo seeking to enforce any security rights granted by the 2018 Agreement.(9) Indeed, the first reference by the Defendants to the 2018 Agreement was in January 2022, when ETS served its Defence in these proceedings. There was no reference to the 2018 Agreement at any earlier time. It was first produced for inspection in March 2022.(10) The alleged pre-existing pledge of the Unpledged Shares in favour of Xinbo would have been fundamentally contradictory to the commercial interests of ETS.(11) The Disposal and the conversion of the Shares into bearer form were not justified by reference to the 2018 Agreement.(12) I have reviewed the witness statements served on behalf of the Defendants, in particular the sixth witness statement of Ms Qiu, in respect of the 2018 Agreement. I do not consider that that evidence is credible.[112]These considerations inexorably lead to the conclusion that the 2018 Agreement was not in existence in July 2018.

Issue (3): Was the purported Qiu-Xinbo Trust Agreement valid and genuine?

[113]GLAS invited the Court to conclude that, on the balance of probabilities, the Qiu-Xinbo Trust Agreement was not entered into on 28th September 2021, as alleged, and was created and backdated in order to lend credence to the Disposal. That said, this is not a critical issue, being of background relevance only since its validity does not in itself determine the outcome of any of GLAS’s claims.[114]The purported Qiu-Xinbo Trust Agreement has been disclosed, but no documents relating to its creation have been produced.[115]GLAS submitted that if Xinbo had a right to the Unpledged Shares, they would have been transferred to Xinbo, not to Dynamic as the Disposal dictated, and further that the purported Qiu-Xinbo Trust Agreement is fundamentally inconsistent with the existence of the purported Precious Pearl Trust and with the terms of the purported 8 October Notice and the SSA, and that the Qiu-Xinbo Trust Agreement is not mentioned in any of the documents relating to the Disposal.[116]I accept those submissions in the main (even without regard to the alleged Precious Pearl Trust). There is little about the alleged Qiu-Xinbo Trust Agreement which makes sense in the context of the Disposal. Further, there is little or no contemporaneous material which supports it having been genuinely created in September 2021. In addition, as explained above, the 2018 Agreement on which the Qiu-Xinbo Trust Agreement is said to be predicated did not exist in September 2021.[117]Indeed, the Qiu-Xinbo Trust Agreement proposes arrangements which are inconsistent with the 8 October Notice and the SSA, which do not provide for a nominee arrangement of the type described, as Dynamic’s BNPSS account was opened as an absolute property account, not as a trust account, and which make no mention of Dynamic being subject to a trust arrangement of this type.[118]As Mr Barden KC submitted, the more realistic explanation for the use of Dynamic is not that it was subject to a trust arrangement between Ms Qiu and Xinbo, but rather that Dynamic was Ms Qiu’s family offshore “wallet” in which she held some US$8.5 million in cash (Ms Qiu’s eleventh witness statement, para. 7-9) and this was simply a convenient repository to hold the Unpledged Shares out of GLAS’s reach. This explanation fits neatly with the SSA proceeding on the basis of an absolute sale or transfer of the Unpledged Shares to Dynamic.

Issue (4): Were the 8 October and 9 October Notices genuine?

[119]I find that the 8 October and 9 October Notices were not genuine documents for the following reasons.[120]The 8 and 9 October Notices suffer from a lack of contemporaneous corroborative evidence: there are no metadata, no background documents showing how the Notices came into existence.[121]The 8 October Notice purported to instruct Ms Qiu to transfer the Shares out of ETS, with the transferee to pledge them to Xinbo, to avoid “damage to the interests of state-owned assets”. This instruction did not reflect the sale of the Unpledged Shares to Dynamic or to the Qiu-Xinbo Trust Agreement. On the contrary, the 8 October Notice insisted that the transferee should re-pledge the SMCP Shares to Xinbo. None of that happened. The first time the 8 October Notice was referred to was in ETS’s Defence in January 2022 and it was first produced for inspection in March 2022.[122]It is notable that the Curateur’s interview with former B Managers of ETS, Mr Hans De Zwart and Mr Joost Mees, revealed that they had no knowledge of this alleged pledge.[123]It is striking that the beneficiary of the alleged pledge, Xinbo, has itself not asserted that it was enforcing its security rights, if they existed, against the Unpledged Shares due to a default in payment under the 2018 Agreement.[124]The 9 October Notice purported to direct the transfer of (only) the Unpledged Shares to Dynamic’s account with BNPSS, which reflected the Disposal. The 9 October Notice was referred to for the first time by the Defendants only in April 2022 in ETS’s Amended Defence, having not been mentioned in ETS’s original Defence in January 2022. There is no plausible explanation for why this would be the case if it had in fact existed at the time. It is notable that the 9 October Notice is also not referred to in the Beihai Award.[125]Importantly, the 9 October Notice identified the account number with BNPSS to which the Unpledged Shares were to be transferred (11845). However, as Mr Yardley stated in his first witness statement, at para. 65, BNPSS confirmed, through its legal advisors, on 7th March 2023, that the Dynamic BNPSS Account was created on 18th October 2021, nine days after the purported date of the Notice. BNPSS informed Ms Mandy Man of the Ruyi Group and Mr Song Yongtao of Grandall of the creation of the Dynamic BNPSS Account only by email dated 21st October 2021.[126]In November 2023, Ms Qiu sought to explain this by stating that the original 9 October Notice left the bank account number blank and that it was filled in only when the document was disclosed in April 2022 (Ms Qiu’s sixth witness statement, para. 33-34). In December 2023, Ms Qiu stated that “due to lapse of time and there were different persons assisting me across the years, I am unable to point out exactly who inserted the account number into the 9 October Notice and who retrieved the said notice from the internal files” (Ms Qiu’s seventh witness statement, para. 5). Xinbo adds nothing to this evidence: Su Xiao of Xinbo stated that “At that time, I did not pay attention to whether the 9 Oct Notice bears the account number of Dynamic. I also do not know how the account number was inserted to the 9 Oct Notice” (first witness statement, para. 5).[127]There is no corroborating evidence for Ms Qiu’s explanation for the later insertion of the bank account number: I simply do not find it to be credible.

Issues (5) and (6): Was the Disposal/SSA valid and genuine?

[128]GLAS invited the Court to conclude that the Disposal effected by the SSA was a transaction intended to put the Unpledged Shares beyond the reach of GLAS as the Trustee, and that the SSA was not a valid transaction.[129]Having regard to the submissions of Mr Barden KC on behalf of GLAS and Mr Langley on behalf of the Curateur, although I accept that the SSA was created in October 2021, with a view to transferring the Unpledged Shares to Dynamic, in my judgment, it was not a valid or legitimate transaction in that it was agreed without the requisite authority on behalf of ETS and for an improper purpose. In particular, the following considerations compel this conclusion:(1) The SSA was purported to be signed by Ms Kanchana Boopalan and Mr Song Yongtao on behalf of Grandall as a corporate director of Dynamic. However, in their second affidavit sworn on 7th February 2022 in the Singapore proceedings, Ms Boopalan and Mr Song exhibited the SSA and stated that “We did not sign the Exhibited Agreement on behalf of [Dynamic] and believe that the Exhibited Agreement is not authentic”.(2) ETS’s Articles of Association required Sino Power to consent to any transfer of ETS’s shares. As evidenced by Mr Beatty’s witness statement, at para. 15-19, Sino Power did not consent to the Disposal. Indeed, as Mr Barden KC noted, the Delegation made no reference to the SSA and Disposal. Indeed, there was no B Manager signatory (even though a new B Manager was appointed the same day: Mr Yardley’s second witness statement, para. 79).(3) The Delegation dated 25th October 2021 post-dated the SSA dated 22nd October 2021 by three days.(4) The unheralded transfer to Dynamic (a company owned by Ms Qiu personally), and the use of bearer shares are unexplained characteristics of the alleged transaction.(5) The SSA was generally inconsistent with other documents on which the Defendants have relied. The terms of the SSA do not purport to enforce security or use Dynamic as a nominee, but instead purport to sell the shares to Dynamic as owner with full title free from any security. There is no mention in the SSA of Xinbo, the 2018 Agreement, the Qiu-Xinbo Trust Agreement, the 8 October Notice, or the 9 October Notice, all of which are now said to explain the Disposal.(6) There was a complete absence from ETS’s records, as obtained by the Curateur, of any documents and “native” versions of the SSA contemporaneous with the creation of the SSA.(7) There is no reason why Xinbo would have had to procure Dynamic to purchase the Unpledged Shares for €1, when the Shares were purportedly already pledged to Xinbo under the 2018 Agreement.(8) The investigations of the Curateur are consistent with the SSA and the Disposal being manufactured and are inconsistent with their being valid and legitimate transactions.[130]The background to the SSA and the Disposal was that ETS had defaulted on the Bonds, and the value of its assets was less than the value of its liabilities. There is no suggestion that it had any plan to repay the Bonds or that any such plan, if it existed, would have been realistically achievable. The Luxembourg Court fixed the date of cessation of payments (insolvency) as 26th May 2021. Accordingly, ETS was insolvent at the time of the Disposal in October 2021.[131]Having regard to my findings as to the validity and genuineness of the 2018 Agreement, the Qiu-Xinbo Trust Agreement, and the 8 and 9 October Notices, and having regard to the circumstances of the SSA itself, it is impossible to conclude that the Disposal was valid or legitimate.[132]Moreover, as the expressed consideration for the transfer of the Unpledged Shares in the SSA was €1, it is plain that the Disposal as effected by the SSA was a transaction at a substantial undervalue which was intended to put the Unpledged Shares beyond the reach of GLAS as Trustee and the Bondholders.

Issue (7): What is the effect of the Beihai Award?

[133]I do not consider that the Beihai Award has any material effect on the issues which I am determining, other than to corroborate the lengths to which Dynamic, Ms Qiu and Xinbo were prepared to go to seek to lend credence to the Disposal and the other documents relied on by them, which I have found to be neither valid nor genuine.[134]Indeed, Xinbo’s Singapore Recognition Proceedings have been dismissed and Xinbo has chosen not to pursue its English Recognition Proceedings.[135]In any event, there are numerous problems and inconsistencies relating to the Beihai Award, including that:(1) Even on its face, any arbitral process which took place was apparently collusive between the three parties under common control agreeing all substantial points which had purportedly been referred to arbitration for determination, without any argument or substantial evidence. The hearing took place on 30th December 2022. The Beihai Award records that there was almost complete agreement between the parties, apparently because, according to Ms Qiu, ETS had received legal advice to concede (Ms Qiu’s sixth witness statement, para. 46). However, Ms Kopéra noted that there was no record of such legal advice (Ms Kopéra’s first witness statement, para. 67-69). Further, if there had been such advice, the question arises why the arbitration proceedings were pursued to the point of an Award.(2) Ms Qiu and Xinbo gave conflicting accounts of the conclusion of the arbitration agreement in that Ms Qiu stated it was concluded in June 2019 and Xinbo stated initially that it was concluded in April 2022. Xinbo’s initial account is further complicated by the fact that its own application for arbitration on 21st March 2022 purportedly instituting the arbitration proceedings preceded the alleged arbitration agreement. Moreover, the Award refers to the arbitration application being made on 18th November 2022.(3) The Beihai Award (at pages 13-14) concluded that the 2018 Agreement was valid, Shandong Ruyi was liable to repay the principal on the loan in the amount of RMB 600 million, rather than the alleged original loan amount of RMB 1.4 billion and close to the value of the Unpledged Shares (Mr Yardley’s second witness statement, para. 95), and that Xinbo had the right to “discount the shares or to have priority to be repaid within the scope of the creditors’ rights confirmed by the Tribunal at the price of auction or sale”.(4) The Beihai Award proceeded on the false premise that the Unpledged Shares were held by ETS, even though ETS had not had the Shares for almost a year at this time. The Beihai Award made no reference at all to the Disposal.(5) The Defendants have given at least three different and inconsistent accounts of how and when the venue for the Arbitration had been designated as Beihai (over 1,000 miles from the parties’ own location) by a purported Memorandum. (a) In March 2023, in the Singapore Enforcement Proceedings, Xinbo produced the purported Arbitration Memorandum (being an undated document), purportedly signed by Xinbo, Shandong Ruyi and by Ms Qiu on behalf of ETS, which amended the Jining arbitration agreement in the 2018 Agreement. (b) In her sixth witness statement, at para. 27, Ms Qiu claimed that the Arbitration Memorandum was entered into “in around June 2019” because Xinbo had “discovered” that the Jining Arbitration Commission might not have the relevant competence, which account was supported by the evidence of Zhang Yu of Xinbo (witness statement, para. 43). (c) Zhang Yu’s later evidence in Singapore and England (fourth witness statement, para. 35-38), after referring to the 2019 memorandum, was that the arbitration agreement was actually executed following a meeting on or about 9th April 2022, nearly 3 years later, between Zhang Yu, Su Xiao, Ms Qiu and her father, and others. The difficulty with this explanation is that the arbitration was instituted in Beihai on 21st March 2022, before this meeting. (d) Xinbo sought to reconcile these points in its Draft Defence (at para. 33(10)(iii)(i)) by stating that the agreement was made in or around June 2019, but the Memorandum was signed only in April 2022 “to ensure the documents were formally in order”, which is not consistent with the other accounts set out above.(6) Those points are all compounded by the Defendants’ failure to disclose key documents which must exist in relation to the Arbitration, which was sufficiently serious for the Singapore Court to dismiss the Singapore Recognition Proceedings. Indeed, the Curateur was unable to locate in ETS’s company records the Notice of Arbitration or any communications surrounding the arbitration proceedings (Ms Kopéra’s first witness statement, para. 67).(7) Xinbo’s Singapore Recognition Proceedings were dismissed in March 2024 for a failure to give proper disclosure in relation to the Arbitration, and it has given no further disclosure in these proceedings. Further, no further steps have been pursued by Xinbo to have the Beihai Award recognised in England.[136]These difficulties undermine the Defendants’ explanation for and the legitimacy of the arbitration proceedings. These difficulties were magnified by the matters as submitted by Mr Langley on behalf of the Curateur (which submissions I accept), namely that:(1) The timing of the arbitration is questionable given that the request for arbitration was apparently filed on 18th November 2022, only a few weeks after summary judgment was granted in favour of GLAS against ETS on the debt claim on 27th October 2022. There is no reason why Xinbo would have waited nearly a year after the Singapore court granted a freezing order over the Unpledged Shares held by JPM Singapore in November 2021 to initiate the arbitration.(2) Xinbo was given every opportunity to produce documents relating to the arbitration but withheld relevant documents and failed to allow the inspection of the originals, which necessarily hampered the Curateur’s ability to verify the authenticity of any documents that had been produced.(3) Indeed, the Curateur considered the Arbitration to be a further illustration of the suspect nature of the underlying transactions, taking account of the truncated arbitration procedure which was highly irregular, the serious questions which arose in respect of ETS’s legal representation, especially as the Curateur had not identified any documents evidencing any legal advice taken by ETS or the appointment or engagement of ETS’s purported lawyers (Mr Hanchu He and Guangdong Kings Law Firm), and the fact that the arbitration proceedings were uncontested.(4) Indeed, after Ms Qiu provided a copy of Guangdong King Law Firm’s engagement letter, the Curateur asked questions of Mr He and Guangdong Kings, in August 2023, January 2024 and January 2025, but received no response until 11th February 2025, when Mr He offered to assist the Curateur upon payment in advance of a fee of £26,800. When challenged as to the excessive amount sought to be paid, Mr He stated that the “required documentation and payment are, of course, non-negotiable prerequisites for further engagement”.

Issue (8): Did Ms Qiu act in breach of duty?

[137]Ms Qiu was an A Manager of ETS. As such Ms Qiu bore a number of duties under Luxembourg law.[138]I have reviewed the expert report of Professor Gilles Cuniberti dated 12th December 2025 on Luxembourg law. Professor Cuniberti’s evidence, which I accept, was that:(1) Articles 445, 446 and 448 of the Luxembourg Commercial Code provide that: (a) Payments during the “periode suspecte” are null and void in certain circumstances, including (a) “underpriced transactions” and (b) “abnormal payment”, including payment of a sum which is not yet due. (b) Payments after the “cessation of payments date may be annulled if the recipient had knowledge of the “cessation of payments”. (c) Payments made in “fraud of creditors” are void. This entails an “abnormal act” known to be harmful to the general body of creditors.(2) The Luxembourg Law on Commercial Companies of 10th August 2015 (as amended) prohibits (a) the use of a company’s property in a manner known to be contrary to the interest of the company, or for the benefit of another company or undertaking in which it had a direct or indirect interest, or (b) the use of their powers for the same purpose (Article 1500-11). This requires fraudulent intention, but this is presumed in cases of misappropriation and concealment.(3) There is an obligation to disclose any direct or indirect financial interest in conflict with that of the company, and not to participate in deliberations considering that interest (Article 441-7 and 710-15(6) of the 1915 Law). Luxembourg courts have held that where a person is a manager of the relevant company, and of the counterparty, this is a “manifest” conflict.(4) Under Article 441-9, directors and managers are liable towards the company and third parties, for all damages arising from breach of the company’s Articles of Association, in respect of “faults of a particular gravity” which are incompatible with the normal exercise of corporate governance.[139]Having regard to my findings above, the Disposal was purportedly effected by or on the instructions of Ms Qiu in breach of such duties and/or was unlawful, in that it was undertaken contrary to the interests of ETS and in respect of Dynamic and/or Xinbo, in which she had an interest. There was therefore an undisclosed conflict of interest.[140]With this in mind, I find that Ms Qiu breached her duties (arising under Article 1500-11 and 710-15 of the Luxembourg Law on Commercial Companies) by use of her powers contrary to the interests of ETS, and for the benefit of Dynamic and/or Xinbo, or by acting pursuant to an undisclosed conflict, in deliberately causing ETS to defend the proceedings in Luxembourg and England for the purposes of delaying or frustrating the resolution of the position in relation to the Unpledged Shares, especially considering that for this purpose Ms Qiu relied on the 2018 Agreement, and the 8 and 9 October Notices, and the SSA, which I have found not to be valid, legitimate or genuine transactions.[141]In these circumstances, in my judgment, Ms Qiu is directly liable to GLAS as a creditor of ETS for damages resulting from her breaches of duty pursuant to Article 441-9 of the Luxembourg Law on Commercial Companies.

Issue (9): Are Dynamic, Xinbo and Ms Qiu liable to GLAS?

[142]GLAS claims relief under English law, being the applicable law, under section 423 of the Insolvency Act 1986 and/or for the torts of conspiracy to use unlawful means and/or inducing a breach of contract.

Section 423 of the Insolvency Act 1986

[143]Section 423 bears the hearing “Transactions defrauding creditors” and provides that: “(1) This section relates to transactions entered into at an undervalue; and a person enters into such a transaction with another person if -(a) he makes a gift to the other person or he otherwise enters into a transaction with the other on terms that provide for him to receive no consideration; … (c) he enters into a transaction with the other for a consideration the value of which, in money or money’s worth, is significantly less than the value, in money or money’s worth, of the consideration provided by himself. (2) Where a person has entered into such a transaction, the court may, if satisfied under the next subsection, make such order as it thinks fit for - (a) restoring the position to what it would have been if the transaction had not been entered into, and(b) protecting the interests of persons who are victims of the transaction. (3) In the case of a person entering into such a transaction, an order shall only be made if the court is satisfied that it was entered into by him for the purpose - (a) of putting assets beyond the reach of a person who is making, or may at some time make, a claim against him, or (b) of otherwise prejudicing the interests of such a person in relation to the claim which he is making or may make. … (5) In relation to a transaction at an undervalue, references here and below to a victim of the transaction are to a person who is, or is capable of being, prejudiced by it; and in the following two sections the person entering into the transaction is referred to as “the debtor”.” (a) he makes a gift to the other person or he otherwise enters into a transaction with the other on terms that provide for him to receive no consideration; …(c) he enters into a transaction with the other for a consideration the value of which, in money or money’s worth, is significantly less than the value, in money or money’s worth, of the consideration provided by himself. (a) restoring the position to what it would have been if the transaction had not been entered into, and (b) protecting the interests of persons who are victims of the transaction. (a) of putting assets beyond the reach of a person who is making, or may at some time make, a claim against him, or (b) of otherwise prejudicing the interests of such a person in relation to the claim which he is making or may make.[144]It is worth noting what section 423 does not require, before considering whether the requirements of the provision are satisfied.(1) Section 423 does not require the existence of formal insolvency proceedings.(2) Section 423 does not require that the claim be brought by the insolvency officeholder. The claim can be brought by any person capable of being prejudiced by it (sub-section (5)).(3) Section 423 does not require the defendant to have been guilty of fraudulent conduct (notwithstanding the heading of the provision) (Arbuthnot Leasing International Ltd v Havelet Leasing Ltd [1990] BCC 636).[145]In order to be able to exercise a discretion under section 423 in the present case, the Court must be satisfied that:(1) The Disposal was for no consideration or at an undervalue as defined in sub-section (1).(2) The Disposal was made for the purpose of putting assets beyond the reach of a person (in this case, GLAS as the Trustee) who may make a claim against ETS or the Disposal was made for the purpose of otherwise prejudicing the interests of GLAS as the Trustee in respect of such a claim (sub-section (3)). The said purpose need not be a dominant or even a substantial purpose (JSC BTA Bank v Ablyazov [2018] EWCA Civ 1176; [2019] BCC 96, para. 13-14).[146]If these conditions are satisfied, the Court may then exercise a discretion to make orders referred to in sub-section (2), namely, to restore the position to what it would have been if the transaction had not been entered into and to protect the interests of persons who are victims of the transaction. Such an order may include an order for the payment of money for example to compensate the victim for the transaction (New Media Distribution Company SEZC Ltd v Kagalovsky [2018] EWHC 2876 (Ch), para. 83; Sayers v Dixon [2025] EWHC 1886 (Ch), para. 62).[147]In my judgment, the Court should grant the orders sought by GLAS under section 423 of the Insolvency Act 1986 for the reasons given by Mr Barden KC on behalf of GLAS, including that:(1) The Court has jurisdiction because: (a) The consideration for the Disposal was either €1 (if paid) or no consideration at all. (b) It was a relevant purpose of the Disposal to put assets (the Unpledged Shares) beyond the reach of GLAS as the Trustee and the Bondholders, or to prejudice the interests of GLAS as the Trustee and the Bondholders by making it more difficult to recover or enforce against the Shares in due course.(2) Such orders are required to restore GLAS as the Trustee and the Bondholders to the position they would have been in had no such Disposal been undertaken and to protect their interests.(3) There is no substantial discretionary factor against the Court exercising its powers under section 423: (a) The Defendants have not identified any legitimate disadvantage or prejudice in litigating here rather than elsewhere. (b) Although there are connections between the Defendants and jurisdictions outside England and Wales, these do not outweigh the substantial connection with the jurisdiction I found to exist above. (c) The Curateur does not contend that this claim must be determined elsewhere. In any event, there is a like remedy available in Luxembourg under Article 445 of the Luxembourg Commercial Code.(4) Robin Knowles J was earlier satisfied that relief under section 423 should be granted vis à vis Dynamic. There is no rational basis to distinguish the position of Dynamic with that of Ms Qiu and Xinbo.[148]The Unpledged Shares have, since August 2025, been returned to GLAS. However, they have in the interim suffered a very substantial reduction in value in the almost five-year period since the Disposal in October 2021. In those circumstances, in my judgment, GLAS is entitled to an order under section 423 of the Insolvency Act 1986 compensating GLAS as Trustee for the decline in value of those shares.[149]The quantum of such relief is to be assessed at a subsequent trial.

Economic torts

[150]GLAS claims relief by reason of unlawful means conspiracy and/or for inducing breach of contract.[151]A claimant has a cause of action by reason of an unlawful means conspiracy, as stated by the Court of Appeal, Kuwait Oil Tanker Company SAK v Al-Bader [2000] 2 All ER (Comm) 271, at para. 108, where the claimant “has suffered loss or damage as a result of unlawful action taken pursuant to a combination or agreement between the defendant and another person or persons to injure him by unlawful means, whether or not it is the predominant purpose of the defendant to do so”.[152]Accordingly, the claimant must demonstrate that the defendant has agreed with others to use means which are unlawful under an independent rule of law with the intention of causing damage to the claimant, even though that intention is not predominant, and such means are used which causes damage to the claimant (FM Capital Partners Ltd v Marino [2018] EWHC 1768 (Comm), para. 94; Seneschall v Trisant Foods Ltd [2023] EWHC 1029 (Ch), para. 146). The intention to injure might readily exist where the defendant seeks to gain a benefit, and thus to further its own interests, which necessarily involves a loss to the claimant (OBG Ltd v Allan [2007] UKHL 21; [2008] 1 AC 1, para. 164-167; JSC BTA Bank v Ablyazov (No. 14) [2018] UKSC 19; [2020] AC 727, para. 13).[153]There is no requirement of a prior contractual relationship between the claimant and the defendant, as the House of Lords held in OBG Ltd v Allan [2007] UKHL 21; [2008] 1 AC 1, para. 8. In that case, at para. 47, Lord Hoffmann stated that “The essence of the tort therefore appears to be(a) a wrongful interference with the actions of a third party in which the claimant has an economic interest and(b) an intention thereby to cause loss to the claimant”.[154]Unlawful means conspiracy imposes a primary liability and therefore does not require proof of a cause of action independently of the conspiracy (JSC BTA Bank v Ablyazov (No. 14) [2018] UKSC 19; [2020] AC 727, para. 11). However, the unlawful means may be criminal or civil, but not all civil unlawfulness will necessarily engage the tort of unlawful means conspiracy (JSC BTA Bank v Ablyazov (No. 14) [2018] UKSC 19; [2020] AC 727, para. 15). The unlawful means in a civil context for the purposes of this tort may be constituted by a breach of contract or a breach of fiduciary duty (Seneschall v Trisant Foods Ltd [2023] EWHC 1029 (Ch), para. 148) and the wrongful dissipation of funds (Lakatamia Shipping Co Ltd v Su [2021] EWHC 1907 (Comm)).[155]I would add that, in my judgment, a transaction at an undervalue or to prejudice creditors such as to engage the Court’s power under section 423 of the Insolvency Act 1986 is sufficient, at least in this case, to engage the tort of conspiracy by unlawful means (Concept Oil Services Limited v. En-Gin Group L [2013] EWHC 1897 (Comm), para. 50; Avonwick Holdings Ltd v Castle Investment Fund Ltd [2015] EWHC 3832 (Ch), para. 26).[156]Mr Barden KC submitted on behalf of GLAS that there has been a conspiracy to use unlawful means by Dynamic, Ms Qiu and Xinbo, as well as ETS, in that:(1) They engaged in a combination to use, and did use, unlawful action, including (at least) Ms Qiu’s breaches of the criminal provisions of Luxembourg company law, her directors’ duties, ETS’s breaches of the Trust Deed and the Bonds, and breaches of ETS’s Articles, as well as conduct engaging section 423. Such conduct constituted wrongful interference with the affairs of ETS, in which GLAS has an economic interest.(2) The intention was to injure GLAS as Trustee and the Bondholders in that (at least) it would cause ETS not to make the largest and most timely payment it could otherwise have made under the Bonds, and/or that GLAS would receive less (and more slowly) by enforcement.[157]I accept those submissions for the reasons given by Mr Barden KC. Dynamic, Ms Qiu and Xinbo are liable to GLAS for unlawful means conspiracy.[158]As far as the tort of inducing a breach of contract is concerned, the Court of Appeal in Kawasaki Kisen Kaisha Ltd v James Kemball Ltd [2021] EWCA Civ 33; [2021] 3 All ER 978, at para. 21, has endorsed that such a tort will be established if, in the absence of a lawful justification:(1) There has been a breach of contract by person B.(2) Person A induced B to break its contract with person C by persuading, encouraging or assisting it to do so.(3) A was aware of the contract and knew its conduct would have that effect.(4) A intended to procure the breach of contract either as an end in itself or as the means by which it achieves some further end.[159]Mr Barden KC submitted on behalf of GLAS that each of Ms Qiu, Xinbo and Dynamic has persuaded, encouraged or assisted ETS in its breaches of contract:(1) Ms Qiu assumed a leading role in structuring and implementing the arrangements which resulted in the Disposal.(2) Dynamic received, retained and defended its right to retain the Unpledged Shares.(3) Xinbo procured or encouraged the original breach, and in any event resisted the return of the Unpledged Shares by falsely asserting rights in respect of them.(4) They were each aware of the Bonds, the fact that they were maturing, and that ETS was not (under their scheme) intending to pay or permit realisation of the Unpledged Shares to satisfy part of that liability.(5) They intended to induce the breach of contract as a means to an end, namely enhancing the economic position of the Ruyi Group by obtaining/retaining the Unpledged Shares.(6) There had been no legal justification for the Disposal, in that Xinbo did not have the (belatedly asserted) security rights that it claimed, and in any event the Disposal was not (and did not purport to be) an exercise of such rights.[160]Based on the findings above concerning the arrangements engaged in by Dynamic, Ms Qiu and Xinbo leading to and giving effect to the Disposal, I have little hesitation in finding that they are also liable for the tort of inducing a breach of contract to GLAS and that they are liable in damages to GLAS as Trustee.[161]The quantum of such damages is to be determined at a subsequent trial.

Issue (10): What relief is appropriate?

[162]For the reasons explained above, I am satisfied that GLAS as the Trustee is entitled to:(1) An order declaring that: (a) The SSA and the Disposal were invalid and of no legal effect and that the Unpledged Shares were not validly transferred to Dynamic. (b) Dynamic and Xinbo did not acquire any legitimate right or interest in or over the Unpledged Shares pursuant to the 2018 Agreement, the Qiu-Xinbo Trust Agreement and/or the SSA. (c) The title to and property in the Unpledged Shares remained at all times with ETS. (d) ETS was at all times entitled to the return of the Unpledged Shares. (e) The 2018 Agreement, the Qiu-Xinbo Trust Agreement, and the 8 October and 9 October Notices were not valid or genuine.(2) An order against Dynamic, Ms Qiu and Xinbo for compensation, and insofar as it is necessary an order setting aside the Disposal, pursuant to section 423 of the Insolvency Act 1986.(3) An order against Dynamic, Ms Qiu and Xinbo for damages by reason of the economic torts discussed above.(4) Damages to be paid by Ms Qiu to GLAS as a creditor of ETS resulting from her breaches of duty pursuant to Article 441-9 of the Luxembourg Law on Commercial Companies.[163]The precise form of declaratory and other relief is to be discussed as a consequential issue, with a view to identifying what further issues require determination at a future trial. Such issues will include quantification of the monetary remedies I have ordered.

Conclusion

[164]For the reasons explained above, I have concluded that:(1) GLAS’s claims are governed by English law.(2) The 2018 Agreement, the Qiu-Xinbo Trust Agreement, and the 8 October and 9 October Notices were not genuine documents or agreements and therefore were not legally valid.(3) The SSA and the Disposal were not legally valid and represented a purported transaction at a substantial undervalue which was intended to put the Unpledged Shares beyond the reach of GLAS as Trustee and the Bondholders.(4) GLAS as Trustee is entitled to declaratory relief as stated above.(5) GLAS as Trustee is entitled to orders against Dynamic, Ms Qiu and Xinbo for compensation, and insofar as it is necessary an order setting aside the Disposal, under section 423 of the Insolvency Act 1986 and for damages by reason of a conspiracy to use unlawful means and the tort of inducing a breach of contract, such compensation and damages to be assessed at a subsequent trial.(6) Ms Qiu acted in breach of duties under Luxembourg law as an A Manager of ETS and is liable to GLAS for damages resulting from her breaches of duty pursuant to Article 441-9 of the Luxembourg Law on Commercial Companies.[165]I am very grateful to Mr Barden KC and Mr Langley, and those instructing them, for the careful and thoughtful manner in which the case was presented, especially in circumstances where Dynamic, Ms Qiu and Xinbo were not represented.