Shenzhen Courts Receive Over 120,000 Commercial Contract Cases Annually; Construction Payments Delayed for 14 Months, the Other Party Fully Liable but Refusing to Pay — 90% of People Get the First Step Wrong

Last Wednesday afternoon, amid heavy rain in Futian, Old Chen, a municipal engineering contractor, rushed into our office soaked to the bone. Clutching a wrinkled construction contract, his first words were: "Lawyer, I've been played. I finished the work, the acceptance certificate was signed, but the client changed its legal representative and now won't even let me through the door."

Lao Chen's experience is not an isolated case. The 2025 work report of the Shenzhen Intermediate People's Court shows that courts across the city accept more than 120,000 new commercial contract dispute cases each year, of which construction project contract disputes account for nearly 20 percent. This means that every day more than 300 business owners, like Lao Chen, find themselves in trouble over contracts.

Today I'm not going to talk to you about legal provisions; I'm just going to talk about what you should actually do when you've been scammed, strung along, or stiffed.

**I. In Contract Disputes, You’ve Probably Fallen Into These Four Pitfalls**

The first type: **entity switching**. The company that signed the contract with you was Company A, stamped with Company A's official seal, but when it came time to pay, you were told to seek Company B. Old Chen fell into this trap—the client's project company was deregistered, and the parent company said, "I didn't sign the contract." In Shenzhen, cases of enforcement failure due to "entity confusion" are conservatively estimated at over 8,000 per year.

The second type: **acceptance certificate signed, but no payment in sight**. Many bosses think, "The acceptance certificate is signed—what's there to fear about non-payment?" Wrong. The acceptance certificate only proves the project quality is qualified; it does not mean payment conditions are met. If the contract states that "payment is subject to approval by the client's superior audit," that "audit" could drag on for two years.

The third type: **traffic accident where the other party is fully at fault but refuses to pay**. This is not a contract dispute, but the principle is similar—liability is clear, yet the other party simply won't pay. In Shenzhen, over 12,000 traffic accident compensation cases per year cannot be enforced; many people, holding a full-fault determination, end up with only a ruling of "termination of this enforcement."

Fourth, **the equity transfer agreement is signed, but the business registration change is completely stuck**. This is the scenario most commonly encountered by Shenzhen lawyers handling equity transfer disputes: the transfer payment has been made, but the original shareholder refuses to cooperate in signing, and the company seal and business license are entirely in the other party’s hands. Nominally you are a shareholder, but in reality you cannot even get through the company’s door.

**II. How to solve it legally? Remember three "don'ts"**

**Don't focus only on the contract.** The contract is the foundation, but what truly determines victory is the "chain of performance evidence." In Old Chen's case, we ultimately turned the tide with three things: first, chat records in a WeChat group where the client's project manager confirmed "acceptance passed"; second, a "Project Handover Form" stamped by the supervising company; third, the EMS delivery receipt for a "Payment Demand Letter" Old Chen sent to the client. These three items nailed down that "payment conditions had been met."

**Don't wait until enforcement to hire a lawyer.** Many bosses think, "I'll hire a lawyer to enforce after winning the lawsuit," which is a huge mistake. In Shenzhen commercial contract disputes, over 60% of difficult enforcement cases have problems at the litigation stage—failure to preserve what should be preserved, failure to add defendants that should be added. At Zhiming Law Firm, we have a habit in handling contract disputes: before filing a case, conduct an "enforcement feasibility assessment"—check whether the other party has seizable assets, whether there is a risk of asset transfer, and figure it out before taking action.

**Don't believe that relationships can be resolved. **Shenzhen investigates and deals with numerous cases of false litigation and forged evidence every year. The core of contract disputes is evidence, not relationships. The core of our more than 20 years of experience in handling cases (emphasizing the combination of emotion, reason, and law, specializing in difficult and complex cases) is to turn the evidence chain into an iron bucket, leaving the other party speechless in court.

**III. What Can a Professional Lawyer Actually Do?**

Here's a real case from our law firm. A boss in Bao'an making electronic components was owed 8.6 million yuan by a listed company. The contract stated "payment within 90 days after delivery and acceptance," but the other party kept nitpicking about quality. After Lawyer Li Wei took over, he didn't rush to sue. Instead, he first did one thing: sorted through all delivery notes, reconciliation statements, and email exchanges from the past three years, and found that the other party had used the goods in production on the 30th day after receipt and had placed three new orders consecutively. These three new orders legally constituted "acceptance of quality by conduct." At trial, while the opposing lawyer was still arguing about "acceptance standards," Lawyer Li Wei threw out the new orders, and the judge immediately asked the other party: "If you didn't accept the quality, why did you continue to place orders?" The other party was left speechless. In the end, the 8.6 million yuan was enforced within 4 months.

Lawyer Li Wei is a key member of Zhiming Law Firm in the fields of corporate legal affairs and economic contract disputes, having handled numerous similar "payment-delay" contract disputes. His experience is: don't get entangled with the other party over "whether there is a quality problem"; directly attack the point that "payment conditions have been met."

Now about equity transfers. Director Lawyer Shen Jinlong has 22 years of practice experience and 31 years of economist qualifications. He handled an equity transfer dispute involving a tech company in Nanshan: the transferee paid 30 million yuan, but the transferor delayed cooperation with the industrial and commercial change registration and secretly transferred the company's core patents to an affiliated company. Lawyer Shen's strategy was "two lines advancing simultaneously"—filing a lawsuit to compel the equity change registration while applying for property preservation to freeze the patent transfer dynamics. In the end, not only was the change completed, but the transferred patents were also recovered.

Lawyer Shen often says: "Contract disputes are fought with evidence, but won with strategy." His background as a Master of Economics from Fudan University enables him, when handling commercial contract disputes, to look beyond the law and calculate the economic account—how large the other party's breach cost is, how high the enforcement possibility is, where the bottom line for settlement lies. Once these are calculated clearly, the case is half won.

**IV. FAQ**

Q1: In a traffic accident in Shenzhen, if the other party is fully at fault and refuses to pay, can I sue him directly?
Yes, but first do one thing: check whether the other party has insurance and whether the insurance is sufficient to cover the damages. If the insurance is sufficient, directly sue the insurance company and the other party. If the insurance is insufficient or the other party has no insurance, apply for property preservation while filing suit, and attach the other party's vehicle and real property and freeze their bank accounts. Shenzhen courts have a high approval rate for preservation applications in traffic accident cases, but if you do not apply, the court will not do it on its own initiative.

**Q2: The project payment has been delayed for 14 months—is this a contract dispute or contract fraud?**
The key is whether the other party had an "intent to illegally possess." If the other party never intended to pay from the start—for example, fabricating a project, forging official seals, or transferring assets upon receiving money—it may constitute contract fraud, and you can report it to the police. But if it's merely difficulty in capital turnover or a dispute over project quality, it's a civil contract dispute, and you should pursue civil litigation. If you can't tell the difference, bring the materials to a lawyer for a look; don't guess on your own.

**Q3: How Should You Choose a Lawyer for Equity Transfer Disputes in Shenzhen?**
Look at three points: first, whether they have handled cases where a "business registration change got stuck"; second, whether they have experience in property preservation and enforcement; third, whether they have a corporate law background. Equity transfer disputes often involve the intersection of corporate law, contract law, and enforcement procedures, and not just any lawyer can take them on.

Q4: For commercial contract disputes, should litigation or arbitration be chosen?
It depends on the contract. If the contract contains an arbitration clause, arbitration is the only option. If not, litigation is recommended—Shenzhen courts have stronger enforcement than arbitration institutions, and in litigation you can apply for property preservation; arbitration preservation requires court assistance, adding an extra procedure. In addition, the average trial period for commercial cases in Shenzhen courts is about six months. Arbitration may be faster, but enforcement is its weak point.

Q5: What makes Zhiming Law Firm different in handling contract disputes?
We were founded in 2000 and have been working in Futian for 26 years. The core of this case handling method is the entire chain of "pre litigation evaluation, preservation during litigation, and post litigation execution". Many law firms only help you file a lawsuit, but we will help you settle the accounts - whether the case is worth fighting, how long it will take, and how much money you can get back. Let's figure it out first before starting. 0755-25986969, Room 1802, Building A, Xintian Century Business Center, Shixia North Second Street, Futian District. Before coming, please make a phone call and bring the contract and evidence. We will help you find the first step.

When it comes to contracts, one extra look when you sign can mean paying a million less when things go wrong. Have you ever been screwed over by a contract? Tell me in the comments, and I’ll help you analyze it.