Feng Zhenghu: Breaking Out of the “Procedural Dead Loop”: 55 Pudong Farmers Who Lost Their Land Confront Legal Flaws in the Supreme People’s Court Ruling with Assistance from the AI Zhenghu Case-Review Team (No. 11 in the Series on Chinese Farmers Who Lost Their Land and Seek to Defend Their Rights Lawfully)

In the grand narrative of moving toward comprehensive rule of law, what truly tests the quality of the rule of law is often ordinary people at the grassroots, who have spent half their lives seeking justice.

Faced with a rejection ruling bearing the seal of the Supreme People’s Court, most ordinary people may have no choice but to remain silent and resigned. However, 55 farmers who lost their land in Shanghai’s Pudong New Area have responded very differently and rationally, with technical and legal assistance from the “AI Zhenghu Case-Review Team” (Feng Zhenghu): a ten-thousand-character, formally issued “Legal Analysis Report on the Administrative Ruling of the Supreme People’s Court ((2025) SPC Administrative Petition No. 9077)” (hereinafter, the “Legal Analysis Report”), setting out its analysis point by point, backed by conclusive evidence and deep legal reasoning.

The report not only dissects the Supreme People’s Court’s administrative ruling (2025) SPC Administrative Petition No. 9077 layer by layer, but also directly identifies the ruling’s multiple flaws in fact-finding, application of the law and procedural justice. This is not only a determined effort by farmers who lost their land to secure property rights worth 355 million yuan and their lawful procedural rights, but also a landmark example of artificial intelligence empowering ordinary people to defend their rights in the digital age and of legal reasoning knocking on the door of judicial justice.

I. A 30-year struggle to defend their rights: Farmers who lost their land blocked by a “procedural wall”

The roots of this lawsuit can be traced back more than 30 years.

In 1992, as Pudong’s development and opening-up gathered momentum, the rural homesteads and houses held by 55 farmers, including Shi Kehua, Yang Defu and Huang Meizhen, were lawfully expropriated and demolished. However, because of problems left over from history, the issue of lawful compensation—concerning property worth a huge amount, with the disputed sum reaching 355 million yuan—remained unresolved for more than three decades. Holding yellowed “Shanghai Rural Homestead Use Certificates” and demolition agreements from that time in their hands, these people, who had been in their prime then and are now white-haired, embarked on a long and arduous journey to defend their rights.

To obtain a “lawful explanation,” beginning in 2018 they lawfully applied to the Shanghai Municipal People’s Government, the Pudong New Area People’s Government and other administrative authorities at various levels, asking them to perform their statutory duties to protect property rights, and also lawfully applied for administrative reconsideration.

However, during their prolonged dealings with the administration, they encountered suffocating “administrative indifference”:

In December 2021, they lawfully submitted an application to the Pudong New Area People’s Government, asking the government to perform its statutory duties and provide reasonable compensation in accordance with the law, but the Pudong New Area People’s Government failed to provide any written reply within the prescribed time limit, leaving the matter in a prolonged state of procedural inaction.

On January 1, 2024, the newly revised “Administrative Reconsideration Law of the People’s Republic of China” formally came into effect. The new law expressly brought administrative authorities’ procedural inaction—“refusing to perform, failing to perform in accordance with the law, or failing to respond”—within the scope of cases accepted for administrative reconsideration, and established a “prior administrative reconsideration” procedure for cases involving applications to perform statutory duties.

On January 19, 2024, the 55 farmers, placing their trust in the new rule of law, strictly followed the guidance of the new law and petitioned the Shanghai Municipal People’s Government for administrative reconsideration, asking it to order the Pudong New Area People’s Government to issue a written reply regarding their earlier application to perform its duties.

Just one week later, on January 26, the Shanghai Municipal People’s Government issued a “Decision Not to Accept an Application for Administrative Reconsideration” (Hu Fu Fu Zi [2024] No. 204), once again turning the elderly applicants away.

After that, the elderly applicants sued the Shanghai Municipal People’s Government. The Shanghai No. 3 Intermediate People’s Court rejected their case at first instance (2024 Hu 03 Xing Chu No. 82); the Shanghai High People’s Court upheld that decision on appeal (2025 Hu Xing Zhong No. 70); and then, in 2025, the Supreme People’s Court issued administrative ruling (2025) SPC Administrative Petition No. 9077, rejecting their application for a retrial.

The doors of justice seemed to be slamming shut one after another.

II. An absurd procedural dead loop: Petition authorities tell the elderly to sue, then courts shut the door because they “have petitioned before”

Reading through the course of rulings in this case, what is most distressing is the “procedural dead loop” in which this grassroots group seeking to defend its rights has become trapped.

In ruling No. 9077, the Supreme People’s Court held that Shi Kehua and the other 54 people had petitioned repeatedly; the Gaoqiao Town Government in Pudong New Area and the Pudong New Area People’s Government had issued opinions on the review of their petitions; the Shanghai Municipal People’s Government had also issued a notice regarding the review of their petitions, and had issued administrative reconsideration notices twice, in 2018 and 2021. Therefore, the case fell under “repeated handling of a complaint filed by a party against an administrative act,” as provided for in Article 1, Paragraph 2, Item 4 of the “Interpretation of the Administrative Litigation Law,” and was not within the scope of cases accepted for administrative litigation.

However, the complete chain of evidence assembled by the AI Zhenghu Case-Review Team reveals an institutional paradox of extreme absurdity:

1. Guidance from petition authorities: Every petition-handling document issued by the Gaoqiao Town Government in Pudong New Area, the Pudong New Area People’s Government and the Shanghai Municipal People’s Government explicitly stated, without exception: “It is recommended that the parties resolve the matter through litigation.” In writing, the petition authorities directed the elderly applicants to the legally prescribed judicial process.

2. Deflection by judicial authorities: When these 55 elderly people followed national laws and regulations, and the explicit guidance of the petition authorities, to knock on the courthouse door, courts at every level—and even the Supreme People’s Court—turned around and cited their history of “repeated petitions” and “previous applications for reconsideration,” characterizing the lawsuit they brought under the new law as a “repeated complaint about the handling of a petition,” and on that basis ruled that it would not be accepted!

Petition authorities push them toward litigation, and then litigation sends their claims back into limbo on the grounds that they “petitioned before.”

The objectively existing unlawful fact that the Pudong New Area People’s Government “failed to respond” within the statutory time limit to citizens’ lawful application for it to perform its duties passed through the hands of township, district and municipal governments and three levels of courts, yet not a single authority at any level ever conducted even one substantive review of the merits. The remedy of rights became a maze of official buck-passing, while procedural justice was left entirely suspended in a cycle of empty procedure.

III. Cutting through the logical fog: The AI Zhenghu Case-Review Team identifies five major legal flaws in the Supreme People’s Court ruling

Faced with the seemingly imposing ruling of the Supreme People’s Court, the 55 farmers who lost their land, empowered by the AI Zhenghu Case-Review Team, produced a “Comprehensive Legal Analysis Report” drawing on a deep grounding in administrative law and a rigorous chain of evidence. It directly identifies five major substantive legal flaws in ruling No. 9077:

1. Evading the temporal effect of the new “Administrative Reconsideration Law,” and nullifying the legislature’s good-governance purpose

Article 11, Paragraph 1, Item (11) of the “new Administrative Reconsideration Law,” which took effect on January 1, 2024, expressly provides that when citizens ask an administrative authority to perform its statutory duties to protect personal and property rights, and the authority “fails to respond,” the matter falls within the scope of cases accepted for administrative reconsideration. This major institutional advance, which changed an ambiguity in the old law, is a remedy specifically designed by the legislature to cure the persistent problem of administrative authorities “turning a deaf ear and dragging out procedures.”

The reconsideration application submitted by the 55 parties on January 19, 2024, was a strict exercise of the statutory right established by the new law. By citing historical disputes that predated the new law’s implementation, the Supreme People’s Court ruling treated a lawful application under the new law as a “continuation of historical conduct.” In substance, it used administrative authorities’ conduct in the old-law era to counter the clear intent expressed by the country’s highest legislative body through the new law, nullifying the effect of its implementation.

2. Incorrectly identifying “repeated handling,” and misapplying the judicial interpretation

Article 1, Paragraph 2, Item 4 of the “Interpretation of the Supreme People’s Court on the Application of the Administrative Litigation Law of the People’s Republic of China” excludes “repeated handling” from the scope of cases accepted in order to prevent endless, unreasonable litigation over the same administrative act, the same object of remedy and the same legal basis.

But in this case:

● Different object: The applicants’ present request is highly restrained. They are not directly asking the court to determine compensation of 355 million yuan; rather, they are seeking a remedy specifically for the Pudong New Area People’s Government’s continuing, independent unlawful conduct of “failing to provide a written reply within the prescribed time limit”;

● Different legal basis: The present application is based entirely on the new procedural rights conferred by the “new Administrative Reconsideration Law” of 2024;

Characterizing legitimate efforts to defend rights, brought under a wholly new law in response to continuing administrative inaction, as “repeated handling” is a typical error in the application of the law and an impermissible expansion by analogy.

3. Confusing the fundamental divide between petition-based recourse and statutory administrative remedies

Petitioning is a non-judicial channel through which citizens report circumstances and make suggestions to state organs, while administrative reconsideration and administrative litigation are mandatory statutory remedies conferred on citizens by the Constitution and laws. The “Regulations on Petition Work” expressly establish a mechanism for diverting matters involving law and litigation away from the petition system. The ruling conflates responses to petitions with administrative adjudications that have judicial force, and uses the existence of “previous petition-handling opinions” as grounds to deprive citizens of their statutory right to sue, thereby reversing the proper relationship between petitions and litigation.

4. Unlawfully depriving citizens of the right to an independent review of “procedural inaction”

Is an administrative authority required to issue a written reply within the statutory time limit? This is an independent procedural-law obligation that does not depend on whether a substantive right is ultimately granted. Even if there is a dispute over the historical substantive claim for land requisition compensation, that absolutely does not mean that local governments may ignore statutory procedural requirements and turn a deaf ear to the public’s applications. The Supreme People’s Court ruling failed to separate “procedural review” from “substantive disputes,” and, citing the complexity of historical issues, extinguished citizens’ fundamental right to receive a procedural response.

5. Seriously inadequate reasoning in the judgment, which failed to address the parties’ core arguments

At every earlier stage, the applicants for a retrial clearly stated that their case was based on the “new Administrative Reconsideration Law” and sought a “remedy for procedural inaction.” Yet in ruling No. 9077, the Supreme People’s Court avoided the central issues of how the new law applied, how its temporal effect should be reconciled, and whether prior administrative reconsideration was required, merely labeling the matter a “repeated application” in a few words. This seriously violates the requirements of the “Guiding Opinions of the Supreme People’s Court on Strengthening and Standardizing the Interpretation of Laws and Reasoning in Judicial Documents.”

IV. Technology for good: When the AI Zhenghu Case-Review Team becomes “legal armor” for ordinary people

The reason this “Legal Analysis Report” has prompted a strong response in legal circles and among groups defending their rights lies not only in its incisive legal analysis, but also in how it came about—with the deep involvement of the “AI Zhenghu Case-Review Team.”

In long-standing judicial practice, ordinary people face the enormous legal resources of administrative authorities, complex changes in statutory provisions and formidable judicial barriers, and are often at an absolute disadvantage in expertise and access to information. Especially when confronting adjudicatory bodies such as the Supreme People’s Court, ordinary people, even when full of grievances, are often ultimately “rejected on procedural grounds” because their documents do not meet formal requirements, they fail to identify legal flaws or they cannot cite statutory provisions precisely.

However, the emergence of Feng Zhenghu and the “AI Zhenghu Case-Review Team” has changed this imbalanced contest:

● Digitally organizing vast facts and historical context: The AI team precisely untangled complex historical evidence spanning more than 30 years and involving dozens of government documents, rulings and notices, and created an indisputable timeline;

● Cutting-edge legal analysis of the transition between old and new laws: The AI model conducted in-depth study of the legislative purpose of the new “Administrative Reconsideration Law,” the Supreme People’s Court’s judicial interpretations over the years and leading theories in administrative litigation, and helped the farmers distill the five core arguments in a short time;

● The production of rigorous, standardized, court-ready documents: The report is properly formatted, cites laws precisely and presents rigorous reasoning. It fully meets the professional standard of senior administrative law scholars and highly skilled litigation lawyers, giving the application for oversight the legal weight to knock on the doors of the Supreme People’s Procuratorate and the Supreme People’s Court.

This is not only a victory for the 55 elderly people, but also a vivid example of legal technology becoming accessible and broadly available to ordinary people. Technology is no longer a cold algorithm; it has become the strongest, most equitable “legal armor” in the hands of vulnerable groups.

V. Conclusion: The life of the law lies in its implementation; the value of rights lies in the availability of remedies

As one legal scholar once said: “If the doors of justice are shut to citizens who ask for nothing more than a reply, the law will turn from a matter of faith into nothingness.”

The average age of these 55 Pudong farmers who lost their land is now over 70. Over more than 30 years, Pudong has changed dramatically, from fields and farm plots into a global financial center. Yet these farmers, who once gave up their land for the city’s development, are still out seeking a lawful response that is rightfully theirs.

They have not resorted to radical or excessive measures, nor have they chosen to give up. With the assistance of the AI Zhenghu Case-Review Team, they have chosen to submit a weighty response to the country’s highest judicial authority in the most rational, civilized and professional language of the rule of law. What they seek is not only a just resolution of their property rights worth 355 million yuan; they also ask society as a whole: Can the procedural rights conferred on citizens by the new “Administrative Reconsideration Law” truly take root at the grassroots? When citizens face procedural indifference from public authorities, can they obtain an explanation in court?

At present, based on this high-quality “Legal Analysis Report,” the 55 farmers are lawfully submitting applications to the procuratorial authorities and relevant departments for oversight of the administrative litigation. We hope that the judicial and procuratorial oversight authorities will acknowledge the flaws in the ruling, break the procedural trap between “petitions and litigation,” and allow these elderly farmers who have passed 70 to genuinely experience the fairness and justice of a rule-of-law China in their remaining years!