[Case Summary]This case involves an administrative review of government information disclosure. On January 13, 2026, applicant Liu ** submitted two requests for information disclosure to the A Natural Resources Bureau via EMS, requesting disclosure of the land nature (collective/state-owned) of the fishing grounds and the time and red line scope of its inclusion in the wetland protection area. The respondent received the requests on January 15 and requested supplementary materials on January 19. After the applicant submitted satellite maps, the respondent failed to provide a legal response within 20 working days. It was not until March 17 that the respondent replied via a "Letter of Reply", refusing to review Table 1 on the grounds of unclear boundary points and responding to Table 2 with a general statement that "it is not within our scope of responsibility; please consult the relevant units". Liu ** entrusted Beijing Henglu Law Firm to handle the case.Zhi Chao LiThe lawyer filed an administrative review with the People's Government of A City. The core dispute is whether the original response was improperly performed or the procedure was illegal. The applicable legal provisions are Article 29 and Article 36 Paragraph 5 of the Regulations on the Disclosure of Government Information. During the review period, the respondent made a clear response again, and the review organ confirmed that the original response was illegal.

I. Review of the Case Facts

Fishers and land contractors often search for information such as "how to check whether their own land is collective or state-owned", "where to find information on the red line of wetland protection areas", and "what to do if they receive vague responses to requests for information disclosure". Due to their production and living needs, in order to clarify the relevant land and wetland protection information of their own fisheries, the applicant, Liu **, submitted two applications for government information disclosure to the defendant, A Natural Resources Bureau, by EMS express delivery on January 13, 2026: first, the land nature (collective land/state-owned land) of the fishery's location; second, the time when the fishery's location was included in a certain wetland protection area and relevant information such as the red line scope of the protection area.

The respondent signed for receipt on January 15, 2026, and on January 19, requested the applicant to supplement the information on the plot. The applicant immediately submitted the electronic version of the color satellite map through email and clearly marked the location of the fishing farm. However, the respondent failed to respond within the 20 working days stipulated by the "Regulations on the Disclosure of Government Information" and did not go through the formalities of extending the time limit. On March 13, 2026, the applicant submitted an application for administrative reconsideration against the failure to respond; on March 17, the applicant received the respondent's "Reply to Liu **'s Application for Disclosure of Government Information", in which the respondent stated that the land nature could not be inquired due to the unclear boundary points in Table 1, and in Table 2, it was suggested to "inquire with the relevant units" without specifying the specific units and contact information. The applicant was not satisfied with the response and entrusted Beijing Hengluo Law Firm to handle the case.Zhai Chao LiThe lawyer filed an administrative review with the People's Government of A City.

II. The focus of the case

  • Focus 1: Is it a dereliction of duty to refuse to provide information on the grounds that the location of the boundary points is unclear?The applicant has provided a clear satellite map indicating the location. The respondent, as the competent authority for natural resources, is responsible for confirming land ownership. Refusing to do so directly constitutes a failure to perform its duties in accordance with the law.
  • Focus 2: Are the responses in Table 2 too general?It is not in accordance with the duty of notification stipulated in Article 36(5) of the Regulations to only suggest "to inquire with the relevant units" without specifying the specific competent units and contact information.
  • Focus 3: Whether the original response procedure was seriously illegal.The reply exceeded the time limit (from January 15 to March 16, far exceeding 20 working days) and failed to specify the channels for protecting rights, which constitutes a procedural flaw.

III. The professional intervention of Hengluo Law Firm

The applicant (Liu **) claimed that:The applicant requests to revoke the responses to the two application forms in the "Letter of Reply" and orders the respondent to provide a clear and legal response again; if the respondent has no information or no authority, it shall inform the specific holding unit, the inquiry method and the contact information in writing.

The position of the respondent (Natural Resources Bureau):They refused to investigate on the grounds that the land boundary points were not clear, and they suggested a general inquiry outside the scope of their duties, attempting to prove that they had fulfilled their responsibilities.

Legal opinion of Hengluo Law Firm:Zhai Chao LiThe lawyer comprehensively reviewed the facts, fixed the evidence, and accurately applied the law, submitting a detailed application for reconsideration: Firstly, according to Article 29 of the Regulations on Open Government Information and the Land Management Law and the Interim Measures for Unified Right Confirmation and Registration of Natural Resources, the respondent, as the competent authority for natural resources in the jurisdiction, has the statutory duty to confirm the nature of land ownership. The applicant has provided clear satellite maps showing the location, so directly refusing the application on the grounds of "unclear boundary points" constitutes a failure to perform duties according to law; Secondly, according to Article 36(5) of the Regulations, if the information does not belong to the authority's disclosure scope, the authority shall state the reasons and clearly inform the name and contact information of the responsible authority. The respondent failed to indicate the specific competent unit and provide search guidance, and the reply was too general; Thirdly, the original reply was overdue and did not specify the rights protection channels, which constituted a serious procedural violation. Based on the above, the lawyer requested to revoke the original reply and order the respondent to provide a clear reply again.

IV. Outcome of the case

During the reconsideration process, a major turning point emerged: the respondent submitted a response in the administrative reconsideration procedure, re-examined the application, and provided a clear response again. Ultimately, the reconsideration authority confirmed that the original response was illegal - the original "Reply Letter" refused to investigate on the grounds of unclear boundary points, provided vague suggestions for inquiries in Table 2 without fulfilling the obligation to inform, and failed to specify remedial measures within the time limit. This case demonstrates that, with the professional intervention of lawyers, even if the administrative authority subsequently rectifies the situation, the original illegal response will still be confirmed as illegal, effectively safeguarding the applicant's right to information.

5. Henglu Law Firm's Advice

This case is handled by Beijing Henglu Law Firm.Zhai Chao LiAttorney (Practice Certificate No.: 11101202311629788, subject to the document issued by the judicial administrative organ). Beijing Hengluo Law Firm specializes in representing clients in various civil, commercial, administrative, and criminal cases. We have a team of experienced professional lawyers. If you need legal assistance, please contact our firm to obtain a tailored protection plan.

VI. Common Questions and Answers about Government Information Disclosure Cases

  1. Q: What should I do if my application to disclose the nature of the land is rejected on the grounds of "unclear boundary points"?
    A:If you have provided clear location markings (such as satellite maps), the natural resources authorities still have the responsibility to confirm ownership, and may review the claim if they believe the reasons for their refusal are unfounded or their duties have been improperly performed.
  2. Q: Does the authority's statement that "go and check with the relevant unit" count as performing one's duties?
    A:No. According to Article 36 Paragraph 5 of the Regulations on the Disclosure of Government Information, it is necessary to clearly inform the name and contact information of the specific responsible authority. Suggesting vaguely "to go to the relevant unit" is a failure to provide information in accordance with the law.
  3. Q: What is the statutory time limit for replying to requests for information disclosure?
    A:The administrative organ shall respond within 20 working days after receiving the application. If the response period needs to be extended, it shall be subject to the consent of the responsible person and the applicant shall be informed of the extension, with the maximum extension period not exceeding 20 working days.
  4. Q: Who should I apply to for information on the red line boundaries of the wetland protection area?
    A:They are usually handled by the natural resources authorities; if the application is rejected, it can be appealed. The applicant can request a clear response or be informed of the specific holding authority and the way to inquire about the information.
  5. Q: Is it illegal to reply to a request beyond the deadline and fail to provide a remedy option?
    A:This is illegal. Both the failure to reply within the time limit and the failure to specify the time limit and channels for the right to appeal are procedural defects. You can claim that the original reply process is illegal and request its confirmation during the appeal process.