[Case Summary]This case involves an administrative review of the disclosure of government information. The applicants, Liu * and Wang *, were originally herders at a government-run ranch in H County and legally held land use certificates for the grasslands they contracted. However, the grasslands they contracted were successively expropriated for multiple public welfare projects, including a water purification plant, a brick factory, a county bus parking lot, a county national middle school, a law enforcement and case-handling center, a detention center, a photovoltaic power plant, a gas station, and an elementary school. To verify the legality of the expropriation and claim compensation, the two individuals applied to the H County People's Government for the disclosure of government information on September 9, 2025, requesting the disclosure of two categories of information: documents related to land expropriation and documents on the conversion of the ranch. The H County Government received the application on September 12, 2025 and was legally required to respond within 20 working days (before October 17, 2025), but delayed its response until May 27, 2026 and delivered it on June 2, exceeding the time limit by more than seven months without notifying the applicants of the delay. Moreover, the response only selectively disclosed some of the requested information. Beijing Henglu Law FirmHe NingningThe lawyer represented the client in the administrative reconsideration, and the reconsideration organ fully adopted the lawyer's opinion. According to Article 64 Paragraph 1 of the Administrative Reconsideration Law, the reconsideration organ revoked the "Reply Letter on Government Information Disclosure" involved in the case and ordered the H County government to provide a detailed reply within 20 working days.

I. Review of the case

During the land expropriation and demolition process, many landowners encounter such confusion: the land expropriation information is not transparent, they want to know which projects their land has been expropriated for, and what the compensation plan is. What should they do if the government does not disclose the information? The applicants in this case, Liu * and Wang *, faced such a situation. The two were former herders at the H County government ranch and legally held land-use certificates for the grasslands involved in the case. The grasslands they contracted were expropriated for multiple local public welfare projects. To verify the legality of the land expropriation and claim their compensation rights according to the law, they submitted a request for government information disclosure to the H County People's Government on September 9, 2025.

Applicants apply for the disclosure of two main categories of information: The first category includes documents related to land expropriation, including the application for and approval of the project for land expropriation, feasibility study reports, land transfer contracts, land expropriation approvals, compensation plans for expropriation, proof of compensation funds being in place and distributed, compensation and resettlement agreements, and expropriation announcements; The second category includes documents related to the reform of the original government-owned pastures, including the implementation plan and approval for the pasture reform, compensation plans for the pasture workers' living security, and minutes of meetings related to the pasture reform and transfer.

The email was signed for receipt by the People's Government of H County on September 12, 2025. According to Article 33 of the Regulations on the Disclosure of Government Information of the People's Republic of China, the county government should give a reply within 20 working days, that is, before October 17, 2025; if an extension is necessary, it must be approved by the head of the government information disclosure work unit and notified to the applicant, and the extension period shall not exceed 20 working days. However, the county government did not issue the "Reply on the Disclosure of Government Information" until May 27, 2026, and delivered it on June 2, 2026. This was more than seven months after the email was signed for receipt, and there was no notification of the extension or any legitimate reason for it.

What's more unacceptable to the applicants is that the reply letter only selectively disclosed some project information, but refused to provide core information such as the expropriation announcement, the complete land expropriation approval, the compensation and resettlement agreement, the detailed list of compensation funds, and the complete set of documents on the transformation of government-owned farms. The reply letter either refused to disclose the information on the grounds of involving personal privacy or state secrets, or completely failed to respond to some of the applicants' requests. The applicants were dissatisfied with the reply letter and therefore entrusted Beijing Henglu Law Firm to handle the case for them.He NingningThe lawyer helps protect the client's rights and interests.

II. The focus of the case

  • The respondent exceeded the statutory 20-working-day response period by more than seven months and failed to notify the applicant of the extension. Does this constitute a procedural violation?
  • The respondent only selectively disclosed some information and failed to disclose or respond to multiple core pieces of information without a valid reason. Does this constitute a failure to fully perform the statutory duty of information disclosure?
  • The respondent refuses to disclose the information in its entirety on the grounds of confidentiality and privacy, and fails to handle it differently in accordance with the law. Does this constitute a misapplication of the law?

III. The professional intervention of Hengluo Law Firm

Applicant's request for reconsideration:It is confirmed that the People's Government of H County has not fully performed its statutory duties of information disclosure and its response beyond the time limit is illegal; the involved "Reply Letter" is revoked; and the People's Government of H County is ordered to fully disclose all the requested information within a specified time limit.

He NingningAttorney's Opinion:

Firstly, the response exceeded the statutory time limit, which constitutes a procedural violation. According to Article 33 of the Regulations on the Disclosure of Government Information of the People's Republic of China, the respondent shall provide a response within 20 working days from the date of receipt of the application. If an extension is necessary, the respondent must obtain the consent of the responsible person and inform the applicant of the extension. The respondent signed for receipt on September 12, 2025, but did not respond until May 27, 2026, which is more than seven months overdue and without any notice of the extension. This constitutes a serious violation of the statutory procedures.

Secondly, the respondent failed to perform its duties comprehensively and the responses provided did not meet the requirements of the application. With regard to the land expropriation approval, the expropriation compensation plan, the expropriation announcement, etc., according to Article 47 of the Land Administration Law, the expropriation announcement is a statutory duty document of the county-level people's government and should be made public in accordance with the law; the compensation and resettlement agreements, the proof of the availability and distribution of compensation funds, etc., belong to the government information that should be actively disclosed according to Article 19 of the Regulations on the Openness of Government Information. The respondent refused to disclose some project materials on the grounds that the transfer note did not indicate a detailed address, which is not a valid reason; and it failed to respond to the entire set of documents on the transformation of the pasture at all.

Thirdly, the law was applied incorrectly and the information was not dealt with in accordance with the law. Even if the information contains personal privacy or state secrets, the administrative organ should deal with it in accordance with Article 15 and Article 37 of the Regulations on the Disclosure of Government Information, remove the content that should not be disclosed, and provide the parts that can be disclosed and explain the statutory reasons for non-disclosure item by item. The respondent directly refused to disclose the information as a whole without any distinction, which violates mandatory provisions and fails to issue a legal document on confidentiality determination or specify the legal basis for confidentiality.

IV. Outcome of the case

After review, the reconsideration organ fully adopted the arguments put forward by Party A in its appealHe NingningThe attorney's opinion on the case states that the response in question violates the law in three aspects: First, it violates legal procedures by responding more than seven months after the deadline, without extending the review period or providing notification of the extension; Second, the main facts are unclear and the evidence is insufficient, failing to fulfill the obligation of reasonable search, and refusing to disclose or respond to multiple core information; Third, the application basis is illegal, failing to fulfill the obligation of distinguishing and handling information according to law, and directly refusing to disclose information on the grounds of privacy and confidentiality without legal classified materials.

In the end, the review organ made a decision in accordance with Article 64 Paragraph 1 of the Administrative Review Law of the People's Republic of China: First, revoke the "Reply to the Application for Government Information Disclosure" issued by the People's Government of H County on May 27, 2026; Second, order the People's Government of H County to respond to the applicant's application for government information disclosure in accordance with the law within 20 working days from the date of receipt of this decision, and handle each item in accordance with the Regulations on Government Information Disclosure: Disclose the information that can be disclosed according to law, explain the reasons and provide legal basis for the information that cannot be disclosed, and provide the disclosable content for the parts that can be handled separately. All the core demands put forward by the attorney, He Ningning, on behalf of the client have been fully satisfied.

5. Hengluo Law Firm's Reminder

The disclosure of government information is an important window for citizens to observe the operation of government power. There are clear statutory time limits for responding to requests for information disclosure: administrative authorities shall generally respond to requests for information disclosure within 20 working days, and the maximum extension period shall not exceed 20 working days. The extension must be notified to the applicant in writing; if no such notification is made, the response beyond the time limit shall be deemed a procedural violation. Refusing to disclose information cannot be a simple one-size-fits-all approach. Administrative authorities have the responsibility to distinguish and handle requests and provide evidence to support their decisions.

This case is handled by Beijing Henglu Law Firm.He NingningAttorney (Practice Certificate No.: 11101202511925103, subject to the certificate issued by the judicial administrative organ) acting as the agent.

VI. Common Questions and Answers about Cases Involving the Disclosure of Government Information

  1. Q: How long does it take for the government to respond after receiving a request for information disclosure? A: Administrative authorities generally respond to requests within 20 working days. If a response needs to be extended, the head of the authority must approve it and inform the applicant. The extension period may not exceed 20 working days. Otherwise, it will constitute an illegal delay in responding.
  2. Q: What should I do if the government refuses to disclose information on the grounds of confidentiality or privacy? A: Even if the information contains confidential or private content, administrative authorities should handle it differently. They should remove the parts that should not be disclosed, provide the content that can be disclosed, and explain the reasons for each item. Otherwise, you can apply for administrative reconsideration to protect your rights.
  3. Q: What should I do if the government fails to make public the expropriation announcement and compensation plan during the land expropriation and demolition? A: According to the law, information such as the expropriation announcement and compensation and resettlement agreements should be actively disclosed or disclosed upon request. You can apply for disclosure of this information, and if your request is denied, you can file an administrative appeal.
  4. Q: How should an application for information disclosure be written to be effective? A: It should clearly list the content description, format requirements, and acquisition methods of the requested information, and refer to specific document names or categories to facilitate the administrative authority's retrieval and response. This helps avoid having the application rejected due to unclear descriptions.
  5. Q: How to seek remedies if you are dissatisfied with the response to an information disclosure request? A: You can file an administrative review request with the higher-level administrative authority or the local people's government within the statutory time limit, requesting that the response be confirmed as illegal, revoked, and ordered to be redone.