Abstract: The dual legal nature of traditional paper lottery tickets in Vietnam is intrinsically linked to the random drawing event. Before the drawing, a conventional lottery ticket is typically a tangible movable property (or proprietary right) that establishes ownership primarily through the purchase of the ticket. After the drawing, when a valid, winning number is determined, the winning ticket retains its original physical form while simultaneously becoming the evidence that establishes a conditional, intangible asset right (the right to claim the prize). The anonymity of the ticket and the dialectical relationship between proprietary right (ownership of the physical object) and personal right (the right to the prize money) are the source of complex civil disputes. This article analyzes the dual legal nature of traditional lottery tickets, highlights limitations and inadequacies in the application of law through the examination of typical judicial practices, and references international experiences. Furthermore, it proposes an approach based on core principles of civil law to improve the legal framework regarding traditional lottery tickets and enhance the quality of adjudication in Vietnam.
Keywords: dual legal nature, right to claim the prize, personal right, proprietary right, traditional lottery ticket
Introduction
Prior to the determination of the draw results, a traditional lottery ticket is neither money nor an ordinary object, but a document representing a conditional property right. At the time of purchase, a traditional lottery ticket is a movable property[1] with physical existence. At this stage, the ticket constitutes a tangible asset representing a potential property right - the opportunity to receive a prize in the future - and such right has not yet been established. After the draw results determine that the ticket is a winning ticket, the winning traditional lottery ticket remains a tangible asset, while simultaneously becoming material evidence evidencing an intangible property right that has been established in accordance with law, which in substance is the right to claim payment of prize money from the lottery business enterprise. This right is recognized by law as another type of property right[2], possessing economic value, measurable in monetary terms, and transferable in civil transactions.
In addition to its dual legal nature, the traditional lottery ticket is characterized by its bearer nature - a pervasive feature. A traditional lottery ticket is a paper-based product with a low face value (only VND 10,000), yet it potentially embodies an economic value amounting to billions of Vietnamese dong when it is a winning ticket. This characteristic facilitates free transfer without complicated registration procedures and gives rise to the principle that “whoever holds the ticket is entitled to receive the prize.” Accordingly, any person who directly possesses a valid and winning ticket may establish the right to receive the prize. The combination of a simple form, substantial potential economic value, and the principle of disposition based on physical possession has rendered bearer traditional lottery tickets a type of asset prone to disputes.
I. Theoretical basis for the dual legal nature of traditional lottery tickets
1.1. Prior to the determination of the draw results, a traditional lottery ticket constitutes a tangible movable property (real right)
At this stage, a traditional lottery ticket is a tangible movable property, while simultaneously serving as a document representing a conditional property right - the right to participate in a lottery draw. The dual legal nature of a traditional lottery ticket during this period is manifested through the coexistence of ownership as a real right and a conditional property right, with its bearer nature functioning as the legal linkage between them.
A traditional paper lottery ticket bearing pre-printed numbers, symbols, and the draw period constitutes an object of ownership[3]. Ownership as a real right is established immediately upon the purchaser’s completion of the sale and purchase transaction with the lottery business enterprise or its agent[4]. The lottery ticket serves as the means of certifying the right to participate in the draw[5]. The owner is entitled to possess, use, and dispose of the ticket[6]. The moment of transfer of ownership is determined at the time the ticket is delivered[7]. The value of the traditional lottery ticket is limited to its initial face value (VND 10,000), similar to ordinary movable property. The principle of good faith governs transactions involving the transfer of lottery tickets, ensuring honesty and fairness.
A traditional lottery ticket represents a conditional property right contingent upon the draw results[8]. This right only materializes into a claim right to receive a prize when the ticket matches the draw results. The bearer nature of traditional lottery tickets automatically effects the transfer of ownership without the need for registration or identity verification, constituting the core element linking ownership (as a real right) and the conditional property right. This bearer nature also gives rise to potential disputes over the lawful owner in cases where a ticket is lost or misappropriated, necessitating the tracing of the ownership history for resolution.
Accordingly, a traditional lottery ticket exists as a legally dual-natured entity: it is both an object of real rights (ownership) and a vehicle carrying a latent conditional property right (the right to participate in the lottery draw). It is precisely this combination, grounded in the bearer nature of the ticket, that forms the key basis for identifying the legal nature of a traditional lottery ticket upon winning.
1.2. Upon the determination of winning numbers, a valid and winning traditional lottery ticket constitutes the legal basis for the arising and exercise of the right to receive the prize (claim right)
When the draw results determine that a ticket is a winning one, a valid and winning traditional lottery ticket becomes the legal basis for the arising and exercise of the right to receive the prize (a claim right), reflecting the second layer of its dual legal nature. The lottery ticket remains a tangible movable property but operates under a dual mechanism: it serves both as the legal basis for the establishment of a right and as an object subject to stringent technical requirements. The combination of legal and technical elements gives rise to the specific characteristics of traditional lottery tickets.
From a legal perspective, a valid and winning traditional lottery ticket establishes the right to receive the prize. This right is a property right arising conditionally and may only be exercised when the ticket is both valid and winning and is presented within the prescribed time limit. The technical requirements mandate that a winning traditional lottery ticket must be “intact in form and size, not torn apart, not pieced together, not erased, and not altered”[9], and that the prize claim must be made within a time limit of 30 days[10]. In essence, the claim right to receive the prize is dependent upon ownership as a real right, because only the owner of a valid and winning ticket is entitled to request payment of the prize. Substantively, the right to claim prize payment constitutes another type of property right, bearing similarities to, yet not identical with, a debt claim in a civil law relationship. The lottery business enterprise has the obligation to pay the prize[11] when the person who directly possesses the valid and winning ticket exercises such right in accordance with law. The bearer nature of traditional lottery tickets continues to play a significant role, particularly where disputes arise over the lawful owner, such as cases in which multiple parties claim ownership of a winning ticket or where transfers are unclear.
1.3. Bearer nature as the legal bridge in the relationship between real rights and claim rights
The dual legal nature of traditional lottery tickets manifests its specificity through the relationship between ownership of the lottery ticket and the right to receive a prize arising from winning. More than that, bearer nature is not merely an isolated characteristic but also serves as a pervasive legal foundation, creating a linkage between real rights and claim rights within the legal structure of the ticket. With respect to real rights, bearer nature allows the transfer of ownership of a traditional lottery ticket in a simple manner, without requiring special formalities, thereby ensuring the circulation of the ticket as an ordinary movable property. With respect to claim rights, bearer nature ensures that the right to receive the prize belongs to the person who directly possesses the lottery ticket at the time it is determined to be a winning ticket, regardless of identity or origin. The parallel existence of ownership (a real right) and the right to receive the prize (a claim right) is connected through a legal bridge: bearer nature does not restrict ownership of the traditional lottery ticket (real right) from determining the right to receive the prize (claim right). These two rights intersect, with ownership serving as the legal precondition for the right to receive the prize to arise. This right has high economic value and is protected by law.
From a theoretical perspective, the real right and the claim right embodied in a traditional lottery ticket are clearly distinct in terms of their nature and the timing of their formation. The real right is established immediately upon completion of the sale and purchase transaction, whereas the claim right arises contingently only when the ticket is a winning one, based on the random draw results and the applicable rules. A practical paradox emerges in that the transfer of the real right (the exchange of the lottery ticket) simultaneously entails the transfer of a potential claim right, even though their moments of formation differ. At the time the ticket is handed over, the seller transfers not only ownership but also the opportunity to receive a prize - an as yet undetermined value. Accordingly, the real right and the claim right are organically connected: the real right is the sole means of holding the claim right, while the claim right constitutes the core value that gives meaning to the real right. This opposition yet unity reflects the dual legal nature of the traditional lottery ticket, in which the tangible element (the ticket) is always intertwined with the intangible element (the opportunity to receive a prize).
II. Practical identification of the dual legal nature of lottery tickets: Reference to international experience and shortcomings in adjudication in Viet Nam
2.1. Experience in the United Kingdom and the United States: Parker-Grennan v. Camelot UK Lotteries Ltd (2024) and Rivera v. Castro (California, 2023)
First, Parker-Grennan v. Camelot UK Lotteries Ltd (2024) EWCA Civ 185[12], decided by the Court of Appeal (Civil Division) of the United Kingdom, concerned a civil dispute over contract and entitlements arising from a lottery ticket. The claimant, Ms. Parker-Grennan, participated in an online instant-win game. Due to a software display error, her screen showed two matching number 1s corresponding to a prize of GBP 1 million. She took a screenshot and claimed the prize, but Camelot refused, asserting that the result recorded in its computer system - derived from Camelot’s official list of winning plays - had not been altered.
The Court of Appeal’s conclusion: the Court dismissed Ms. Parker-Grennan’s appeal and upheld the ruling that she had won only GBP 10. The Court held that Camelot had acted reasonably by applying the “click-wrap” procedure, under which the game result was predetermined by the computer system at the moment the player clicked “Play.” The display error affected only the visual effect on the screen and did not change the result recorded in the official database, in accordance with the “Game Procedures” accepted by the player.
The English court’s judgment emphasized the absolute binding legal force of the Terms & Conditions agreed through the click-wrap mechanism. Accordingly, the judgment established the principle of prioritizing verification of the validity of the underlying transaction - particularly electronic transactions - rather than relying solely on material ownership of a lottery ticket.
Second, Rivera v. Castro (California, 2023)[13] in the United States arose from a “complaint for damages” filed by Jose Rivera with the Superior Court of the State of California, County of Los Angeles. Rivera claimed to be the lawful purchaser and the lawful and rightful owner of the “ticket in dispute.” To substantiate his claim, Rivera relied on external evidence, specifically extrinsic evidence in the form of surveillance video from Joe’s Service Center, depicting the individual who purchased the ticket. Rivera further asserted that the California Lottery had a responsibility to review the video to ensure payment was made to “the right person”.
Findings of the Los Angeles County Superior Court: the Court dismissed Jose Rivera’s complaint, primarily on the ground of the absence of physical evidence - namely, the lottery ticket itself. The Court focused on the legal nature of lottery ticket ownership, grounded in the principle of personal responsibility and material evidence[14]. This judgment reaffirmed the principle that a traditional lottery ticket constitutes a “bearer instrument", under which ownership (a real right) belongs to the person who physically possesses the ticket.
International experience thus provides a solid reference basis for proposing improvements to the legal framework governing traditional lottery tickets and for enhancing the effectiveness of adjudication of related disputes in Viet Nam.
2.2. Limitations and shortcomings revealed through adjudicatory practice in Viet Nam
First, the lack of consistency in identifying the dual legal nature of traditional lottery tickets
The resolution of disputes over ownership of traditional lottery tickets remains subject to limitations due to the lack of consistency among adjudicatory bodies in identifying the dual legal nature between real rights (ownership of the ticket) and claim rights (the right to claim prize payment)[15]. The case concerning a “dispute over a contract for donation of property” was, in essence, centered on a dispute over ownership of a traditional lottery ticket at the time the right to receive the prize arose, depending on the moment of transfer of the real right (the ticket had not yet won) prior to the draw. Accordingly, the dispute concerned the transfer of ownership of a traditional lottery ticket, before the draw results were determined (with a face value of VND 10,000), from Mr. Tran Thanh T (the defendant) to Ms. D - representing 18 workers (the plaintiffs) - through an oral donation accompanied by a condition of equal sharing in the event of winning. When the lottery ticket won the special prize (VND 2 billion), Mr. T retrieved the ticket and independently claimed the prize, despite having promised to share the winnings, which he failed to perform. The plaintiffs filed a lawsuit requesting Mr. T to return the amount based on the agreement. The defendant denied this, asserting that he had merely asked them to check the ticket.
The case was adjudicated at the first-instance, appellate, and cassation levels. In Decision No. 125/QĐKNGĐT-VKS-DS dated 25 May 2023, the Chief Procurator of the High People’s Procuracy in Ho Chi Minh City lodged a protest, invoking Article 35 of the Law on Marriage and Family 2014, determining that the winning ticket (the asset having been transformed into VND 2 billion) constituted common property and, due to its large value, its disposition through an oral donation by Mr. T was unlawful and required the consent of his wife. This view conflated real rights and claim rights, equating the initial value of the ticket (VND 10,000, the real right at the time of purchase) with the prize value (the claim right arising after the draw). At the same time, the High People’s Procuracy misidentified the relevant time point by applying the value at the time of the dispute to assess the oral donation of the traditional lottery ticket at the time of transfer, thereby denying the donor’s lawful right of disposition. By contrast, Cassation Decision No. 148/2023/DS-GĐT dated 9 August 2023 of the High People’s Court clearly distinguished between real rights and claim rights and rejected the protest, reasoning that: the oral donation of a traditional lottery ticket (an ordinary movable property, with a face value of VND 10,000, not yet a winning ticket) must be assessed based on the evidence and the parties’ intent at the time the ticket was delivered. Such conduct was lawful[16] and did not require a written form for movable property. The donor was entitled to dispose of a small-value asset serving essential living needs without requiring the wife’s consent, and the case did not fall within the scope of Article 35 of the Law on Marriage and Family 2014. Rights and risks, including the possibility of winning a prize, were transferred to the donee pursuant to Articles 158 and 162 of the Civil Code 2015.
The case resolved under Cassation Decision No. 148/2023/DS-GĐT dated 9 August 2023 (which serves as the basis for Draft Precedent No. 08/2024) represents a significant advancement in tracing the real right at the time of the oral donation (a VND 10,000 ticket) in order to determine the claim right (VND 2 billion), thereby ensuring an accurate application of the bearer nature of traditional lottery tickets.
Second, shortcomings in the assessment of the bearer nature of traditional lottery tickets
A judgment concerning a dispute over recovery of property[17] was adjudicated on appeal by the People’s Court of Soc Trang Province under Appellate Judgment No. 83/2022/DS-PT dated 20 June 2022. Accordingly, the plaintiff, Mr. Ho Van Th, purchased two Tra Vinh lottery tickets (ending in number 648) on 13 March 2020 and asked Mr. Le Van M (a drinking companion) to check the tickets on the morning of 14 March 2020. Mr. M reported that the tickets were not winning and retained them. Suspecting that Mr. M had misappropriated a ticket that won the special prize (number 438648), Mr. Th filed a lawsuit demanding that Mr. M pay VND 3.6 billion. Mr. Le Van M denied the claim, asserting that the winning ticket was one he had separately purchased and that Mr. Th’s tickets were not winning ones. The court of first instance (Thanh Tri District, Soc Trang Province) rejected Mr. Th’s claim. Mr. Th appealed, and the appellate court (Soc Trang Province) dismissed the appeal and upheld the first-instance judgment. The court’s approach prioritized real rights based on the presumption of lawful possession[18], recognizing the person holding the ticket as the owner and, consequently, as the holder of the claim right (VND 3.6 billion). However, the bearer nature of the ticket created difficulties in verifying the origin of the transfer (checking the ticket on behalf of another), resulting in a disadvantage to the plaintiff due to the lack of evidence demonstrating good faith. The absence of physical examination of the ticket (such as serial numbers or fingerprints) and the disregard of the risk of sophisticated ticket substitution obscured the basis for identifying both the real right and the claim right. As a result, the principle that “risk lies with the owner”[19] could not be accurately applied, because it was impossible to determine who the true owner was at the time the relevant event occurred.
A judgment concerning a dispute over ownership of property[20] was adjudicated on appeal by the People’s Court of Ca Mau Province under Appellate Judgment No. 15/2019/DS-PT dated 28 January 2019. The plaintiff (Mr. Le Van D) filed a lawsuit requesting Mr. Ngo Van H and Ms. Hua Thi P to pay VND 1,780,000,000 (the value of the special prize of a Hau Giang lottery ticket bearing number 739607, purchased from Mr. Phan Van T1 on 12 August 2017, with the prize claimed after deduction of tax and commission). Mr. D asked Mr. T1 to check the ticket on 13 August 2017 while he was intoxicated; upon learning that the ticket had won a prize, he continued sleeping. Ms. P claimed the prize and gave Mr. D VND 8,000,000, corresponding to a consolation prize. When Mr. D later learned that the ticket had won the special prize, he demanded its return but was unsuccessful, leading to the dispute. The court of first instance (Ca Mau City) accepted Mr. D’s claim and ordered the defendants to pay VND 1,722,000,000 after deducting amounts already paid. Ms. P appealed, and the appellate court (Ca Mau Province) ordered Mr. H and Ms. P to pay Mr. D approximately VND 890 million (after set-off, approximately VND 826.5 million), while maintaining the freezing of a savings account until enforcement of the judgment. In this case, the court applied the concept of dual legal nature by identifying the initial real right, but divided the prize equally (approximately VND 890 million for each party) based on an oral promise and Mr. H’s limited capacity for civil acts (as concluded in Forensic Conclusion No. 256/2018/KLGĐTC). The bearer nature of the ticket made it difficult to verify the transfer and good faith, leading to an incorrect application of joint ownership[21]. The division of the prize lacked a persuasive legal basis, because bearer nature establishes independent ownership based on physical possession, irrespective of transparent agreements. This approach blurred the principle of independent possession, increased the risk of fraud, and caused harm to the original owner.
The bearer nature of traditional lottery tickets creates difficulties in verifying evidence and assessing the good faith of the parties, particularly in the case adjudicated in Ca Mau. The regulations on ticket authentication conditions[22] are not sufficiently stringent, resulting in judgments that lack objectivity. Therefore, it is necessary to improve a unified legal framework that clearly distinguishes between the transfer of real rights and the property rights arising therefrom, in order to standardize the resolution of disputes concerning prize money.
III. Recommendations for improving the legal framework governing traditional lottery tickets
First, formalizing a precedent derived from Cassation Decision No. 148/2023/DS-GĐT dated 9 August 2023
This section analyzes a specific case adjudicated under Cassation Decision No. 148/2023/DS-GĐT dated 9 August 2023 concerning a “Dispute over a Contract for Donation of Property,” the substance of which is currently published for public consultation in Draft Precedent No. 08/2024/AL. On that basis, the Supreme People’s Court should promptly formalize Precedent No. 08/2024/AL in order to unify the application of law in disputes related to winning lottery tickets. The precedent would clarify the time at which ownership of a traditional lottery ticket is transferred through an oral donation pursuant to Article 458 of the Civil Code 2015, thereby establishing a real right as the prerequisite for the claim right to receive the prize. This would ensure the stability and predictability of judicial decisions, prevent inconsistency in the application of law, and enhance legal certainty for civil transactions.
Second, amending regulations toward the digitization of traditional lottery tickets and the application of technology in lottery administration
The bearer nature of paper-based traditional lottery tickets currently creates difficulties in determining lawful ownership in court disputes, leading to inconsistent judgments. The existing provisions under Circular No. 75/2013/TT-BTC dated 4 June 2013 of the Ministry of Finance guiding lottery business activities have not yet incorporated rules adapted to digital transactions and modern technological forms, thereby reducing the effectiveness of dispute resolution. To address these limitations, amendments should be made in the following directions:
First, digitizing paper lottery tickets: integrating a unique QR code or barcode on each ticket containing transaction information (ticket code, time, and place of sale), enabling traceability of origin and registration of ownership through a mobile application. This solution draws on the California Lottery model (United States)[23] and is suitable to the mobile distribution characteristics of Viet Nam.
Second, recognizing the legal validity of electronic and supplementary transactions, including bank statements, e-wallet transaction histories, electronic receipts, transaction confirmation messages, and images or videos of tickets accompanied by digital data verifying their origin. Such amendments would provide a clear legal basis for courts to assess evidence comprehensively, overcoming obstacles arising from the bearer nature of paper-based traditional lottery tickets. At the same time, this approach would promote the application of digital technology in lottery administration, ensuring consistency and fairness in adjudication and aligning with the trend toward modernization of the legal system.
Third, proposing a roadmap for improving the presumption-of-ownership principle in relation to traditional lottery tickets
The mechanical application of the presumption-of-ownership principle under Article 184 of the Civil Code 2015 in disputes over lottery tickets entails the risk of inadvertently legalizing the rights of possessors who acquired the property through unlawful acts. Such an approach directly conflicts with the foundational principles of civil law concerning good faith and equity. International legal trends, exemplified by the experience of the United Kingdom Gambling Commission (2022)[24], are also consistent in refusing to recognize rights to property originating from unlawful sources.
To remedy this deficiency, a two-phase roadmap is proposed, combining interim measures with long-term institutional reform:
Phase 1 (Short-term, guidance-oriented solution): Within its authority to guide adjudication, the Supreme People’s Court should promulgate a Resolution interpreting and guiding the application of Article 184 of the Civil Code 2015. This Resolution should establish an exception principle, clearly providing that: “The presumption that the possessor is the owner shall not apply where there exists objective evidence proving that the possession of the lottery ticket originated from an unlawful act.” This solution would enable courts to exercise flexibility, grounded in the principles of equity and good faith, to immediately adjust the resolution of ongoing disputes and protect the lawful interests of the parties.
Phase 2 (Long-term, foundational solution): At the legislative level, it is necessary to move toward codifying the above exception principle. This may be achieved either by amending and supplementing Article 184 of the Civil Code 2015 with an additional paragraph or by stipulating a separate provision in a future specialized Law on Lottery. This approach aims to establish a clear norm with the highest legal effect, eliminating ambiguity and inconsistent interpretation, thereby creating a stable and transparent legal framework.
This dual-track roadmap ensures feasibility and timeliness through the adjudicatory guidance mechanism of the Supreme People’s Court, while simultaneously advancing toward sustainability and predictability through legislative codification.
Conclusion
The anonymity of traditional lottery tickets, functioning as a legal bridge, gives rise to a dual legal nature (real rights and personal rights), thereby creating distinctive challenges for adjudication in practice in Viet Nam. Experience from the United Kingdom and the United States highlights the importance of employing modern authentication mechanisms and flexible evidentiary standards to overcome the barriers inherent in anonymity. To enhance adjudicatory effectiveness, Viet Nam needs to: officially recognize case law grounded in the dual legal nature of lottery tickets; amend regulations toward the digitalization of traditional lottery tickets and the application of technology in lottery management; and, concurrently, codify an exception to the presumption of ownership in order to prevent the protection of unlawful interests. These recommendations aim to establish a transparent legal framework, safeguard legitimate rights and interests, and strengthen public confidence in justice.
REFERENCES
1. Civil Code 2015.
2. Decree No. 30/2007/ND-CP dated 1 March 2007 of the Government on lottery business.
3. Decree No. 78/2012/ND-CP dated 5 October 2012 of the Government amending and supplementing a number of articles of Decree No. 30/2007/ND-CP dated 1 March 2007 on lottery business.
4. Circular No. 75/2013/TT-BTC dated 4 June 2013 of the Ministry of Finance guiding lottery business activities.
5. Supreme People’s Court (2024), Draft Case Law No. 08/2024/AL on “Dispute over a contract for donation of property” (excerpted from Cassation Decision No. 148/2023/DS-GDT of the High People’s Court in Ho Chi Minh City).
6. People’s Court of Soc Trang Province (2022), Judgment No. 83/2022/DS-PT dated 20 June 2022 on “Dispute over recovery of property.”
7. People’s Court of Ca Mau Province (2019), Judgment No. 15/2019/DS-PT dated 28 January 2019 on “Dispute over ownership of property.”
8. California Lottery (2022), Annual report 2021–2022. Sacramento,
CA, https://www.calottery.com,
(accessed on 21 September 2025).
9. UK Gambling Commission (2022), Annual enforcement report 2022.
Birmingham: Gambling Commission, https://www.gamblingcommission.gov.uk,
(accessed on 20 September 2025).
10. Rivera, J. (2023), Complaint for declaratory relief and damages,
Rivera v. Castro (Superior Court of California, Los Angeles County, https://storage.googleapis.com/www-courttv-uploads/2023/05/77ce6897-rivera_v_lottery_complaint.pdf,
(accessed on 18 September 2025).
11. Parker-Grennan v. Camelot UK Lotteries
Ltd (2024) EWCA Civ 185 (Court of Appeal of England and Wales), retrieved from https://www.judiciary.uk/wp-content/uploads/2024/03/Parker-Grennan-v-Camelot.pdf , (accessed on 22 September 2025).
12. Yang, M. (2024, February 18), Powerball winner wins lawsuit to hold onto $2bn prize after he was accused of stealing ticket, https://www.independent.co.uk/news/world/americas/crime/powerball-winner-lawsuit-jose-rivera-edwin-castro-b2623375.html (accessed on 22 September 2025).
[*]PhD, Faculty of Law, Saigon University. Email: nthphuoc@sgu.edu.vn. Date of acceptance for publication: 31 December 2025.
[**] Private Lawyer Law Firm Limited Liability Company. Email: anthuong8685@gmail.com.
[1] Article 107 of the Civil Code 2015.
[2] Article 115 of the Civil Code 2015.
[3] Article 158 of the Civil Code 2015.
[4] Article 11 of Decree No. 30/2007/ND-CP dated 01 March 2007 of the Government on lottery business (as amended and supplemented by Decree No. 78/2012/ND-CP dated 05 October 2012).
[5] Clause 8 Article 2 of Decree No. 30/2007/ND-CP dated 01 March 2007 of the Government on lottery business (as amended and supplemented by Decree No. 78/2012/ND-CP dated 05 October 2012).
[6] Article 192 of the Civil Code 2015.
[7] Clause 1 Article 161 of the Civil Code 2015.
[8] Article 4 of Decree No. 30/2007/ND-CP dated 01 March 2007 of the Government on lottery business (as amended and supplemented by Decree No. 78/2012/ND-CP dated 05 October 2012).
[9] Clause 1 Article 31 of Decree No. 30/2007/ND-CP dated 01 March 2007 of the Government on lottery business (as amended and supplemented by Decree No. 78/2012/ND-CP dated 05 October 2012).
[10] Clause 1 Article 30 of Decree No. 30/2007/ND-CP dated 01 March 2007 of the Government on lottery business (as amended and supplemented by Decree No. 78/2012/ND-CP dated 05 October 2012).
[11] Article 16 of Decree No. 30/2007/ND-CP dated 01 March 2007 of the Government on lottery business (as amended and supplemented by Decree No. 78/2012/ND-CP dated 05 October 2012).
[12] Parker-Grennan v. Camelot UK
Lotteries Ltd (2024) EWCA Civ 185 (Court of Appeal of England and Wales),
retrieved from https://www.judiciary.uk/wp-content/uploads/2024/03/Parker-Grennan-v-Camelot.pdf, (accessed on 22 September 2025).
[13] Rivera, J. (2023), Complaint
for declaratory relief and damages, Rivera v. Castro (Superior Court of
California, Los Angeles County),
https://storage.googleapis.com/www-courttv-uploads/2023/05/77ce6897-rivera_v_lottery_complaint.pdf,
(accessed on 18 September 2025).
[14] Yang, M. (2024, February 18), Powerball
winner wins lawsuit to hold onto $2bn prize after he was accused of stealing
ticket,
https://www.independent.co.uk/news/world/americas/crime/powerball-winner-lawsuit-jose-rivera-edwin-castro-b2623375.html,
(accessed on 22 September 2025).
[15] Supreme People’s Court of Viet Nam (2024), Draft Precedent No. 08/2024/AL on “Dispute over a Contract for Donation of Property” (excerpted from Cassation Decision No. 148/2023/DS-GDT dated 09 August 2023 of the High People’s Court in Ho Chi Minh City).
[16] Article 458 of the Civil Code 2015.
[17] People’s Court of Soc Trang Province (2022), Judgment No. 83/2022/DS-PT dated 20 June 2022 on “Dispute over Claim for Return of Property”.
[18] Article 184 of the Civil Code 2015.
[19] Article 162 of the Civil Code 2015.
[20] People’s Court of Ca Mau Province (2019), Judgment No. 15/2019/DS-PT dated 28 January 2019 on “Dispute over Ownership of Property”.
[21] Articles 208 and 457 of the Civil Code 2015.
[22] Article 31 of Circular No. 75/2013/TT-BTC dated 04 June 2013 of the Ministry of Finance guiding lottery business activities.
[23] California Lottery (2022), Annual
report 2021–2022. Sacramento, CA, https://www.calottery.com, (accessed on 21 September 2025)[1] Article 107 of the Civil Code 2015;
[24] UK Gambling Commission (2022), Annual enforcement report 2022, Birmingham: Gambling Commission.
