Henan human rights defender Li Xin’s appeal in his case involving the crimes of picking quarrels and provoking trouble and bigamy rejected

(Report by the Information Center of Civil Rights and Livelihood Watch) On July 23, 2026, this website learned that recently, Henan human rights defender Li Xin’s appeal in his case involving the crimes of picking quarrels and provoking trouble and bigamy was rejected. The following are his petition for a criminal appeal and the court’s notice rejecting the appeal.

Petition for Criminal Appeal

Appellant: Li Xin, born on October 12, 1978, whose registered household location and address are No. 141, Ziyou Alley, Dashangpo, Lüxiang Village, Chengguan Town, Huixian City, Henan Province; citizen identification number 130182197810120030; telephone number 18568517931.

I. Appeal Matter

The appellant appeals the criminal judgment issued by the Huixian City People’s Court (2021) Yu 0782 Xing Chu No. 48 and the criminal ruling issued by the Xinxiang Intermediate People’s Court (2021) Yu 07 Xing Zhong No. 228, and requests that the court conduct a retrial review of the case in which the appellant is alleged to have committed the crimes of picking quarrels and provoking trouble and bigamy, revoke the original judgments in accordance with the law, rehear the case, and amend the judgment in accordance with the law, declaring the appellant not guilty.

II. Facts and Reasons

(I) Basic background of the case

In March 2018, after the appellant Li Xin and his spouse He Fangmei took their daughter Li Qi to the Huixian Center for Disease Control and Prevention to receive vaccinations, Li Qi developed symptoms including fever, weakness in her limbs, and difficulty breathing in May of that year. She was diagnosed by the First Affiliated Hospital of Xinxiang Medical University and Beijing Children’s Hospital, Capital Medical University, with conditions including an inflammatory demyelinating disease of the central nervous system. She became unable to care for herself and required long-term rehabilitation treatment. The appellant and his wife believed that their daughter’s illness was related to the vaccination, and therefore reported the situation to the relevant departments, but were instead held criminally responsible by the judicial authorities for the crimes of picking quarrels and provoking trouble and bigamy. The court of first instance sentenced the appellant to five years’ imprisonment. The court of second instance rejected the appeal and upheld the original judgment without conducting a hearing. The appellant believes that the handling of this case involved serious procedural violations, errors in factual findings, and improper admission of evidence, and that the effective judgment completely deviated from fairness and justice.

(II) Core unlawful problems in this case

1. The effective judgments in this case contain fundamental errors in determining the basic facts, and the conviction and sentencing do not conform to the statutory elements of criminal law

Criminal convictions and sentencing should adhere to the principles of taking facts as the basis and the law as the criterion, and strictly follow the basic principles of legality of crimes and punishments and proportionality between crime, responsibility, and punishment. Only when the conduct of the offender fully meets the elements of a crime stipulated in the Specific Provisions of the Criminal Law may the offender be held criminally responsible in accordance with the law. In this case, the guilty judgment issued by the original judicial authorities completely deviated from the objective truth in its determination of the core facts, contained fundamental errors in the application of criminal law, and lacked lawful and valid factual and legal support for its finding of guilt.

Regarding the finding of guilt for picking quarrels and provoking trouble, the original judgment completely confused the legal boundary between citizens’ lawful rights-protection activities and criminal conduct. The core origin of this case was that, after the appellant’s minor daughter Li Qi was vaccinated, she developed a serious inflammatory demyelinating disease of the central nervous system, became unable to care for herself, and needed to receive long-term professional rehabilitation treatment. As the legal guardian, the appellant’s seeking medical treatment, reasonable assistance, and remedies for his child’s rights were legitimate rights granted to citizens by law. All of his demands concerned the medical protection and safeguarding of the minor child’s rights and interests. He never engaged in any conduct that disrupted social order or forcibly seized or extorted public or private property, and his conduct did not meet the statutory elements of the crime of picking quarrels and provoking trouble under Article 293 of the Criminal Law of the People’s Republic of China. The original judgment incorrectly characterized the government aid funds and reasonable loss compensation received by the appellant in response to his child’s medical-treatment needs as illegal proceeds obtained by “forcibly seizing or extorting”; distorted the appellant’s reasonable conduct of living in Beijing for an extended period to ensure the effectiveness of his child’s rehabilitation treatment into criminal conduct of “threatening to petition in Beijing”; and at the same time incorrectly conflated the independent conduct of different appellants, attributing to Li Xin the consequences of conduct unrelated to him. This completely violated the basic principles in criminal proceedings that individuals bear responsibility for their own crimes and that subjective and objective circumstances must be consistent. This finding of guilt constitutes a typical error in fact-finding and application of law.

Regarding the finding of guilt for bigamy, the original judgment not only violated the objective facts of the case, but also violated the rules governing criminal prosecution. On the one hand, the marital relationship between He Fangmei and a person outside the case was lawfully dissolved on April 13, 2017, and Li Xin and He Fangmei legally registered their marriage in August 2017. Their marital relationship fully met the legal and valid requirements stipulated in the Civil Code. Their cohabitation during the period when He Fangmei’s marital relationship was still in existence did not meet the core elements of the crime of bigamy stipulated in the Criminal Law, and the original judgment’s finding of guilt on this point lacked objective factual support. On the other hand, according to the Criminal Law of the People’s Republic of China and relevant provisions on criminal procedure, bigamy is a private-prosecution case that is handled only upon complaint. Only under the statutory exception in which the conduct seriously harms social order and national interests may the procuratorial authorities proactively initiate a public prosecution. In this case, no statutory circumstance met the conditions for proactive prosecution by the procuratorial authorities, and the relevant rights holder did not file a complaint regarding the matter, but instead expressly indicated that no prosecution should be pursued. The original judicial authorities’ proactive initiation of criminal prosecution for the conduct completely violated the statutory prosecution principle applicable to private-prosecution cases. At the same time, the relevant facts had already been handled by the local public-security authorities. The original judicial authorities’ initiation of criminal prosecution again on the same facts also violated the basic criminal-procedure principle of “no double jeopardy.” This finding of guilt contains serious errors from both a procedural and substantive perspective.

2. The entire litigation process in this case involved serious procedural violations, directly depriving the appellant of core procedural rights and causing the fair trial of the case to lose its statutory procedural foundation

Procedural justice is the prerequisite and guarantee of substantive justice. A trial that violates statutory procedures will inevitably cause the judgment to lose its fairness and legality. China’s Criminal Procedure Law clearly stipulates the statutory procedures for the entire process of criminal investigation, review for prosecution, and trial. Its core purpose is to protect the lawful procedural rights of criminal suspects and defendants and ensure that cases are tried fairly. In this case, however, from the investigation stage through the issuance of the final ruling, the original judicial authorities committed multiple serious violations of the mandatory provisions of the Criminal Procedure Law throughout the process. The appellant’s core procedural rights were deprived throughout, and the trial of the case lacked procedural legitimacy from beginning to end.

At the investigation stage, the original investigating authorities engaged in serious unlawful investigative conduct. Without displaying legally required law-enforcement credentials or issuing a summons or other lawful legal documents, investigators forcibly took Li Xin from his residence in Beijing and illegally controlled him for more than 20 hours. They interrogated him without informing him of the statutory grounds or fulfilling the statutory notification obligations, and only later supplemented this by issuing a decision on criminal detention. This was a typical unlawful investigation involving “arresting a person first and fabricating charges afterward,” seriously violating the statutory procedures governing criminal coercive measures under the Criminal Procedure Law. The handling of the case lost its lawful foundation from the very beginning of the investigation.

Throughout the litigation process, the appellant’s right to defense was unlawfully deprived. The right to defense is the defendant’s most fundamental statutory procedural right in criminal proceedings. China’s Criminal Procedure Law clearly stipulates that, from the date of the first interrogation or the imposition of a coercive measure, a criminal suspect or defendant has the right to retain a defense counsel, and the people’s courts may not deprive defendants of their right to defense. In this case, after Li Xin was detained, he repeatedly applied to the authorities handling the case to retain a defense lawyer, but the authorities refused on improper grounds and unlawfully prevented lawyers from meeting with him. During the trial stage, the appellant repeatedly and clearly refused the legal-aid lawyer appointed by the court and insisted on retaining a lawyer himself to exercise his right to defense. However, the original court ignored his lawful request and forcibly appointed a legal-aid lawyer to appear in court, resulting in the appellant never receiving effective legal assistance and being unable to fully exercise core defense rights such as cross-examination and debate. The trial completely lost the statutory prerequisite of equal contest between the prosecution and the defense, making the fairness of the trial procedure impossible to discuss.

In the second-instance proceedings, the original court committed serious procedural violations. After the appellant appealed the first-instance judgment, he raised clear objections to the facts and evidence determined in that judgment, and those objections directly affected the conviction and sentencing, meeting the statutory circumstances under Article 234 of the Criminal Procedure Law requiring a second-instance trial to be conducted in court. However, the second-instance court did not conduct a hearing as required by law and issued a final ruling upholding the original judgment merely through a written review of the case files. At the same time, the ruling made substantive changes to the core facts determined by the first-instance judgment, completely depriving the appellant of his statutory rights to cross-examine evidence and engage in courtroom debate during the second-instance proceedings. As a result, the errors in fact-finding, errors in the application of law, and procedural violations in the first-instance proceedings were not corrected in accordance with the law, and the issuance of the final ruling lacked even the most basic procedural legitimacy.

(III) Specific unlawful problems in this case

1. Serious procedural violations deprived the appellant of his lawful procedural rights

(1) The investigating authorities arrested the appellant without lawful procedures, involving the unlawful practice of arresting him first and fabricating charges afterward. On the afternoon of October 14, 2020, officers of the Huixian City Public Security Bureau, without wearing police uniforms and without showing work credentials, a summons, or any other lawful legal document, forcibly took the appellant from his residence in Beijing to the case-handling center in the basement of the Huixian City Public Security Bureau and illegally controlled him for 20 hours. During that period, the officers interrogated the appellant without explaining any lawful reason, and did not notify him that he had been criminally detained for the crime of picking quarrels and provoking trouble until the evening of October 15. They later arrested him on suspicion of picking quarrels and provoking trouble and bigamy. This conduct seriously violated the statutory procedures governing criminal coercive measures under the Criminal Procedure Law of the People’s Republic of China and constituted a typical form of investigation through unlawful detention.

(2) The public-security, procuratorial, and judicial authorities deprived the appellant throughout the process of his right to retain a defense lawyer. After being detained, the appellant repeatedly requested to hire a lawyer through his family, but the investigating authorities refused to notify his family on the grounds that they were “afraid of leaks” and also refused to allow a lawyer to meet with him. During the trial stage, the appellant clearly refused the legal-aid lawyer appointed by the court and insisted on hiring his own lawyer for the defense. However, the court ignored his lawful request and forcibly appointed a lawyer to appear in court. That lawyer was unfamiliar with the basic facts of the case and was entirely unable to perform the duties of defense, resulting in the appellant receiving no effective legal assistance throughout the proceedings. His right to defense was completely deprived, in violation of the mandatory provisions concerning the right of criminal suspects and defendants to a defense under Article 34 of the Criminal Procedure Law of the People’s Republic of China.

(3) The second-instance court changed the first-instance factual findings and upheld the original judgment without conducting a hearing, in violation of procedure. After the appellant appealed the first-instance judgment, the second-instance court determined merely through a review of the case files that “the facts of the case are clear.” It did not conduct a hearing as required by law, yet substantively changed in its ruling the facts concerning picking quarrels and provoking trouble determined by the first-instance court (the first instance found that the appellant “used his wife’s petitioning as a threat,” while the second instance upheld this core characterization despite a lack of supporting evidence). Under Article 234 of the Criminal Procedure Law of the People’s Republic of China, an appeal in which the defendant raises objections to the facts and evidence determined at first instance that may affect the conviction and sentencing must be heard in court. The second-instance court’s conduct deprived the appellant of his rights to cross-examine evidence and debate in court and seriously violated the procedural provisions governing second-instance proceedings.

(4) The jurisdiction and prosecution procedures for the bigamy charge were unlawful. Bigamy is a private-prosecution case. Unless the circumstances seriously harm social order and national interests, the procuratorial authorities may not initiate prosecution on their own. In this case, the alleged “bigamy” facts had already been truthfully confessed to the Shenzhen public-security authorities in 2016. The Shenzhen public-security authorities had opened a case and handled it, and had made arrangements for the appellant’s placement. The Huixian City Public Security Bureau knew about this and assisted He Fangmei in completing divorce procedures. The appellant and He Fangmei legally registered their marriage in August 2017. Without a complaint by the victim and without evidence proving that the case harmed social order, the public-security, procuratorial, and judicial authorities of Huixian proactively prosecuted the alleged “crime of bigamy,” which had already been handled. They also unlawfully exercised jurisdiction even though neither the appellant’s habitual residence nor the place of the alleged criminal conduct was in Huixian, completely violating the jurisdictional provisions of criminal procedure and the prosecution principle applicable to private-prosecution cases.

2. Errors in fact-finding; the charge of picking quarrels and provoking trouble lacks a factual basis

(1) The appellant’s reports to the relevant departments constituted lawful rights protection, not picking quarrels and provoking trouble. Li Qi became ill after receiving a vaccination. The Forensic Medicine Research Institute of Beijing Jingcheng Mingjian issued a Forensic Medical Demonstration Opinion stating clearly that it “cannot rule out a causal relationship between the child’s illness and the administration of the DPT vaccine.” This key evidence was deliberately ignored by the public-security, procuratorial, and judicial authorities. The appellant and his wife incurred enormous expenses treating their daughter and were living in difficult circumstances. Reporting the situation to government departments and seeking assistance was a lawful right of citizens, not “making trouble out of nothing or being unreasonable.” The Chengguan Town People’s Government of Huixian City signed an assistance agreement with the appellant and paid 7,500 yuan per month in aid, further demonstrating that the appellant’s demands were reasonable and justified.

(2) The alleged “forcible seizure or extortion of 19,000 yuan” consisted of government aid and loss compensation, not illegal proceeds. The first-instance judgment found that the appellant had demanded money five times “by threatening to petition in Beijing,” which was completely inconsistent with the facts:

The 1,000 yuan in October 2019 was aid paid to Li Qi by the village committee in order to cooperate with the maintenance of stability;

The 3,000 yuan in May 2020 was compensation from the government departments for the appellant’s rental losses in Beijing;

The 10,000 yuan in June 2020 was medical expenses reimbursed to Li Qi under the assistance agreement;

The 5,000 yuan in August 2020 was a reasonable subsidy from the government for rent expenses after the appellant’s cooperation with stability-maintenance efforts delayed his child’s rehabilitation treatment;

The unsuccessful demand for 20,000 yuan in August 2020 was a reasonable request made by the appellant in an agitated state because his father was hospitalized, his child’s rehabilitation had been obstructed, and stability-maintenance personnel had been following and monitoring him; it was not a threat involving petitioning.

All of the above payments are evidenced by receipts, which clearly identify them as aid or compensation. The appellant never engaged in “forcibly seizing or extorting,” and the nature of the payments was entirely inconsistent with the “illegal possession of another person’s property” required for the crime of picking quarrels and provoking trouble.

(3) The appellant’s living in Beijing with his daughter was necessary for rehabilitation treatment, not an effort to build momentum for petitioning. Li Qi’s condition required long-term professional rehabilitation treatment, and Beijing’s medical resources were better able to meet her treatment needs. From June 2018, the appellant began renting a residence in Beijing and living there with his daughter while she underwent rehabilitation. This fact is supported by evidence including hospital records and the rental contract. The appellant never engaged in any unlawful petitioning activity in Beijing, much less demanded money by “threatening to petition in Beijing.” The first-instance court distorted normal medical-treatment conduct into preparation for the crime of picking quarrels and provoking trouble, constituting a typical error in fact-finding.

(4) The appellant did not engage in conduct endangering public order. The crime of picking quarrels and provoking trouble requires the conduct of the offender to “disrupt social order.” In this case, however, the appellant consistently raised his demands through reasonable channels and did not engage in conduct disrupting public order, such as holding up signs, shouting slogans, or gathering to cause trouble. The first-instance judgment found that the appellant had “disrupted social-management order” but provided no valid evidence, making the finding entirely subjective and speculative.

3. The bigamy charge has no factual basis and was an erroneous prosecution

(1) The appellant and He Fangmei initially had an unlawful cohabitation relationship and legally registered their marriage after her divorce. The first-instance judgment contained a fundamental factual error in its determination of the marital relationship. He Fangmei and Weng Jianhua registered their marriage in 2005, after which their marital relationship completely broke down. During the period when the appellant met He Fangmei (the appellant was single and unmarried before meeting He Fangmei) and lived with her, he knew that she had not yet divorced and consistently believed that they were in an unlawful cohabitation relationship. Although de facto marriage is no longer recognized under civil law, he also clearly understood the relevant determination of bigamy under criminal law. Therefore, he never publicly claimed to be married to her and never engaged in any act of entering into a marriage. He Fangmei and Weng Jianhua later divorced by agreement on April 13, 2017, at the Civil Affairs Bureau of Kecheng District, Quzhou City, Zhejiang Province. The marital relationship was formally dissolved, and the appellant and He Fangmei subsequently legally registered their marriage in August 2017. Their marital relationship was lawful and valid. The public prosecution authorities alleged that the appellant “knowingly cohabited with He Fangmei as husband and wife while she had a spouse,” but regarding the period when the appellant and He Fangmei lived together in Shenzhen, no witness could establish that they cohabited as husband and wife. After the appellant returned to Huixian, he lived in a house rented with the assistance of the Huixian City Public Security Bureau. Although two village-committee employees provided testimony alleging that the two lived together as husband and wife, those two witnesses only had substantial contact with the appellant and his wife after an incident involving their daughter’s vaccination, when the couple were designated as petitioners. Before that, because the appellant had lived away for a long period, he had had no interaction with the two village officials and was merely a fellow villager. Their testimony was not objectively credible and could not serve as a basis for determining the case. The first-instance judgment failed to comprehensively examine all the facts of the case and instead made a one-sided finding based only on superficial circumstances, constituting a serious error in fact-finding.

(2) The alleged “bigamy” facts had already been handled by the Shenzhen public-security authorities, and the public-security, procuratorial, and judicial authorities of Huixian were pursuing the case again. At the beginning of 2016, the appellant truthfully confessed to the Shenzhen public-security authorities regarding his relationship with He Fangmei. After placing the appellant under residential surveillance, the Shenzhen public-security authorities arranged for him to return to Huixian and assisted He Fangmei in completing divorce procedures, expressly informing the appellant that he would no longer be held criminally responsible for his previous conduct. Despite knowing this, the public-security, procuratorial, and judicial authorities of Huixian still held the appellant responsible for bigamy on the basis of the same facts. This constituted a typical repeated prosecution and seriously violated the principle of “no double jeopardy.”

4. Evidence was seriously and improperly admitted, and the judgment lacked effective evidentiary support

(1) Key evidence was deliberately concealed and ignored.

The Forensic Medical Demonstration Opinion issued by the Forensic Medicine Research Institute of Beijing Jingcheng Mingjian was core evidence proving that there might be a causal relationship between Li Qi’s illness and the vaccination. It directly concerned the legitimacy of the appellant’s rights-protection activities, but the public-security, procuratorial, and judicial authorities did not include this evidence within the scope of courtroom examination and cross-examination and deliberately ignored it. Meanwhile, the so-called “Investigation and Diagnostic Certificate for an Abnormal Reaction to Preventive Vaccination” reached the conclusion of “coincidental illness” without the parties’ participation and without an expert’s signature. This excluded the appellant’s daughter’s right to obtain legitimate state compensation. The health authorities, as the vaccination provider, then issued a diagnostic conclusion unfavorable to the party concerned, creating an obvious conflict of interest and raising questions about its credibility. Nevertheless, the first-instance court admitted it as evidence.

(2) Witness testimony lacked authenticity and objectivity.

The witnesses Zhang Wen, Zhang Jianzhen, Zhao Haitao, and others were all employees of the Chengguan Town government and village committees in Huixian City, as well as the people directly responsible for stability-maintenance work, and therefore had interests connected to the case. Their testimony was largely subjective speculation, its contents were mutually similar, and it was not corroborated by other evidence. It could not prove that the appellant had engaged in “forcibly seizing or extorting” or “threatening by petitioning.” The first-instance court used testimony from such interested parties as the basis for its judgment, violating the rules on the admission of evidence.

(3) The chain of evidence was broken and could not form a complete system of proof.

The first-instance judgment found that the appellant had committed the crimes of picking quarrels and provoking trouble and bigamy, but provided no direct evidence proving that he had criminal intent or engaged in criminal conduct. The alleged “criminal facts” relied solely on witness testimony and subjective inferences and lacked corroboration by objective evidence such as documentary or physical evidence. This completely failed to meet the criminal conviction standard of “clear facts and reliable and sufficient evidence.”

III. Legal Basis

1. Article 41 of the Constitution of the People’s Republic of China provides that citizens of the People’s Republic of China have the right to criticize and make suggestions to any state organ or state employee; they have the right to submit appeals, complaints, or reports to relevant state organs regarding unlawful or derelict conduct by any state organ or state employee, but may not fabricate or distort facts to make false accusations or frame others. Relevant state organs must ascertain the facts and responsibly handle citizens’ appeals, complaints, or reports. No one may suppress or retaliate against them.

2. Article 258 of the Criminal Law of the People’s Republic of China provides for the crime of bigamy and requires the offender to have either “a spouse and contracting another marriage” or “knowingly marrying another person who has a spouse.” The offense requires, as its core elements, the objective conduct of cohabiting as husband and wife and the subjective intent to commit bigamy. The appellant and He Fangmei registered their marriage after her lawful divorce, and before that they were only in an unlawful cohabitation relationship. There was no subjective intent or objective conduct constituting bigamy, no bigamy occurred, and the appellant did not commit this crime.

3. The crime of picking quarrels and provoking trouble under Article 293 of the Criminal Law of the People’s Republic of China requires the offender to have the subjective intent and objective conduct of “disrupting social order.” The appellant in this case was lawfully protecting his rights and did not engage in any conduct disrupting social order; his conduct did not meet the elements of the crime.

4. Article 6 of the Criminal Procedure Law of the People’s Republic of China provides that the people’s courts, people’s procuratorates, and public-security organs, when conducting criminal proceedings, must rely on the masses and take facts as the basis and the law as the criterion. All citizens shall be equal in the application of the law, and no privilege is permitted before the law.

5. Article 34 of the Criminal Procedure Law of the People’s Republic of China provides: “A criminal suspect has the right to retain a defense counsel from the date of the first interrogation by the investigating organ or the imposition of a coercive measure; during the investigation period, only a lawyer may be retained as defense counsel. A defendant has the right to retain a defense counsel at any time.” The deprivation by the public-security, procuratorial, and judicial authorities of the appellant’s right to retain a defense counsel constituted a serious procedural violation.

6. Article 52 of the Criminal Procedure Law of the People’s Republic of China provides: “Judicial personnel, procuratorial personnel, and investigators must collect, in accordance with statutory procedures, all kinds of evidence capable of proving whether criminal suspects or defendants are guilty or innocent and the severity of the criminal circumstances. It is strictly prohibited to extort confessions through torture or collect evidence through threats, inducements, deception, or other unlawful methods. No one may be compelled to prove his or her own guilt.” In this case, the investigating authorities unlawfully collected evidence and the public-security, procuratorial, and judicial authorities deliberately concealed key evidence, seriously violating the above provisions.

7. Articles 252 and 254 of the Criminal Procedure Law of the People’s Republic of China provide that the parties and their legal representatives and close relatives may submit appeals to the people’s courts or people’s procuratorates against judgments or rulings that have taken legal effect. If the Supreme People’s Court discovers a definite error in a legally effective judgment or ruling of a people’s court at any level, or a higher people’s court discovers such an error in a legally effective judgment or ruling of a lower people’s court, it has the authority to bring the case up for trial or order a lower people’s court to conduct a retrial. If the Supreme People’s Procuratorate discovers a definite error in a legally effective judgment or ruling of a people’s court at any level, or a higher people’s procuratorate discovers such an error in a legally effective judgment or ruling of a lower people’s court, it has the authority to lodge a protest with the people’s court at the corresponding level in accordance with the trial-supervision procedure.

IV. Appeal Requests

In summary, the effective judgments in this case contain serious errors in fact-finding, application of law, and litigation procedures, constituting a typical wrongful and erroneous case. As a father, the appellant’s conduct in seeking justice for his sick daughter was entirely lawful and justified, yet he was held criminally responsible on fabricated charges. This not only caused him to suffer an injustice, but also left his sick daughter without support for her rehabilitation treatment and living needs.

For this reason, the appellant requests that the Xinxiang Intermediate People’s Court immediately initiate the supervisory review procedure in this case, conduct a comprehensive, objective, and impartial review, safeguard the appellant’s lawful personal and procedural rights, correct in accordance with the law the unlawful handling of the case and the erroneous judgment by the original trial authorities, revoke the criminal judgment and criminal ruling at issue, declare the appellant not guilty, and restore justice to the appellant.

Respectfully submitted to

Xinxiang Intermediate People’s Court

Appellant: Li Xin

Date:

Attachments:

Copy of the first-instance judgment

Copy of the second-instance ruling

Copy of the appellant’s identity card

Other evidentiary materials

(1) An audio recording of the appellant’s conversation at the office of the Lüxiang Village Committee, Chengguan Town, Huixian City, which directly proves that I did not engage in picking quarrels and provoking trouble, while the public-security, procuratorial, and judicial authorities of Huixian nevertheless considered me to have done so. This core evidence was specifically raised by the appellant when he filed his appeal, but the second-instance court directly ignored it.

(2) Forensic expert opinion (3) He Fangmei’s divorce agreement (4) Copy of the marriage certificate of the appellant and He Fangmei (5) Record of conversation with Weng Jianhua (He Fangmei’s former husband)