[Case Summary]This case is an administrative review case concerning the disclosure of government information. The applicant, Liu **, is a villager of Shuguang Village, Qianjin Town, A District, Shuozhou City. Due to a dispute over the ownership of land contracting rights, he needs to verify the history of direct grain subsidies issued for a specific plot of land and therefore applied to the Agriculture and Rural Affairs Bureau of A District, Shuozhou City for the disclosure of government information. However, the respondent's "Reply to the Application for Information Disclosure" contained problems such as confusion of plot information, failure to provide an accurate response to the applicant's request, and failure to disclose the subsidy details of the specific plot in accordance with the law. Beijing Henglu Law FirmI respect and admire you, YiThe lawyer filed an administrative reconsideration application on behalf of the applicant to the People's Government of A District of Shuozhou City, claiming to revoke the original reply and order the respondent to handle the matter again. The reconsideration organ accepted the lawyer's opinion and, in accordance with Article 64 Paragraph 1 Item 1 of the Administrative Reconsideration Law of the People's Republic of China, revoked the original reply and ordered the respondent to handle the matter again within 20 working days. The core legal basis is Article 36 and Article 6 of the Regulations on Open Government Information.

I. Review of the Case

In land contract disputes, finding out whether and how much grain subsidies have been paid for one's own plots of land over the years is the first step for many farmers to protect their rights. The applicant, Liu **, is a villager of Shuguang Village, Qianjin Town, A District, Shuozhou City. Due to a dispute over land contract ownership, he needs to verify the payment history of direct grain subsidies (subsidies for arable land protection) for a specific plot of land (south to Huantian Road, west to the village collective wasteland, east to Huantian Road, and north to Wang **) over the years.

On December 15, 2025, the applicant mailed the "Government Information Disclosure Application Form" to the Agriculture and Rural Affairs Bureau of A District, Shuozhou City via EMS, requesting the disclosure of the applicant's direct grain subsidy distribution records from 2004 to 2015, as well as the subsidy distribution records of the plot after the subsidy was discontinued in 2015. Many farmers often encounter such problems as: "How to appeal if they are not satisfied with the government's information disclosure response?" "What should they do if the administrative authority refuses to disclose information on the grounds that they do not have the detailed records?" "What should they do if their request to check the grain subsidy information for a specific plot is rejected?" This case provides a clear path for protecting one's rights.

The respondent signed for the application on December 17, 2025, and issued a "Reply to the Application for Information Disclosure" on January 8, 2026. However, the reply mistakenly identified the plot specified by the applicant as another plot, and refused to disclose the details of the specific plot on the grounds that "only the summary figures are available, and the specific details are not available". On February 23, 2026,I respect and admire you, YiThe lawyer, on behalf of the applicant, filed an administrative review application with the People's Government of A District of Shuozhou City, requesting the revocation of the original reply and ordering a re-handling of the case.

II. The focus of the case

  • Is there any confusion about the plot information in the respondent's reply, or unclear factual determinations, and did the respondent fail to provide an accurate response to the applicant's request?
  • The respondent refused to disclose the information on the grounds that "they only have the summary figures and do not have the detailed information". Does this constitute a failure to fulfill the statutory duty to disclose government information?
  • The respondent failed to provide a clear response in accordance with Article 36 of the Regulations on the Disclosure of Government Information, distinguishing different circumstances. Does this comply with the requirement of providing an "accurate and complete" response?

III. The professional intervention of Hengluo Law Firm

In terms of the arguments and defenses of both parties, the respondent argued that the response procedure was legal and the facts were clear. It had provided an accurate response to the information about the application plot and there was no confusion about the plot. For the information that it "did not have", it had explained it in accordance with the law and there was no refusal to perform its statutory duties. It also claimed that the county-level agricultural and rural departments only kept the summary data of farmers' subsidies and did not keep the detailed information of individual plots, which was an objective management status. The applicant argued that the response to the plot was incorrect and that it was essentially a refusal to fulfill the obligation of public disclosure due to inconvenience in internal management.

I sincerely wish you all the best.The lawyer made his argument from three perspectives:

Firstly, it points out that the information about the plot is confusing. The four boundaries clearly marked by the applicant do not correspond to the plot code and place name wrongly identified by the respondent, indicating that the facts of the administrative act have not been clearly determined.

Secondly, it points out that the respondent failed to fulfill its statutory duty of information disclosure. The respondent refused to disclose the details of specific plots on the grounds of inconvenient internal management, which violates the provision in Article 6 of the "Regulations on the Disclosure of Government Information" that the information provided should be "accurate and complete".

Thirdly, it points out that the procedure is illegal. The respondent failed to make a clear reply according to Article 36 of the Regulations on the Disclosure of Government Information, and the content of the reply did not meet the requirements of "accuracy and completeness", which constitutes a failure to fully and accurately fulfill the obligation to reply.

IV. Outcome of the case

The review organ concluded after trial that the respondent failed to provide a clear response in accordance with Article 36 of the Regulation on the Disclosure of Government Information, and the content of the response did not meet the requirements of "accuracy and completeness" stipulated in the regulation, which constituted a failure to fully and accurately fulfill the obligation to respond. The People's Government of A District of Shuozhou City issued the Administrative Review Decision Letter No. Shuqizhengfu [2026] X2, in accordance with Article 64 (1) (1) of the Administrative Review Law of the People's Republic of China, deciding to: revoke the "Reply on the Application for Information Disclosure" issued by the respondent on January 8, 2026; and order the respondent to reprocess the applicant's application for information disclosure within 20 working days after the decision takes effect.

The results of this case include: the request for reconsideration was supported, laying a procedural foundation for the applicant to obtain accurate government information in the future; it clarified that administrative organs have the legal obligation to provide clear and accurate responses to information disclosure applications based on different circumstances, and the information provided must be existing information that has been produced or stored; the administrative organs' improper responses to information disclosure requests were supervised and corrected according to the law, and the parties achieved a partial victory.

5. Henglu Law Firm's Reminder

When encountering situations where government information disclosure applications are evaded, rejected, or receive responses that do not correspond to the requested matters, it is recommended to: first, ensure that the application clearly specifies key information such as specific plots, years, and matters, to facilitate accurate retrieval by administrative authorities; second, after receiving an unsatisfactory response, pay attention to initiating an administrative review within the statutory time limit, emphasizing that the response is "inaccurate, incomplete", or fails to fulfill statutory duties; third, distinguish between "information not existing" and "not having detailed information". If the administrative authority refuses to disclose information due to internal management inconvenience, the applicant may legally demand that the authority fulfill its disclosure obligations.

This case is handled by Beijing Henglu Law Firm.I sincerely wish you all the best.The attorney (practice license number: 11101202510973791, subject to the document issued by the judicial administrative organ) acts as the agent.

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

  1. Q: How to appeal against an unsatisfactory response to a request for government information disclosure? A: Within the statutory time limit from the date of receipt of the response, you may apply for administrative reconsideration to the people's government at the same level as the administrative organ or to the competent department at the next higher level, requesting the revocation of the original response and ordering the administrative organ to handle the request again.
  2. Q: What should I do if the administrative organ refuses to disclose information on the grounds that it does not have the detailed information? A: You can request them to provide a clear response in accordance with Article 36 of the "Regulations on the Disclosure of Government Information". If the information has indeed been produced or stored, it should be disclosed in accordance with the law, and they cannot refuse to disclose it on the grounds of inconvenience in internal management.
  3. Q: What should I do if the information on grain subsidies for the plots I applied for is incorrectly matched? A: In the review or litigation process, the key evidence to present is that the plot boundaries and codes of the application items do not match those of the plots being responded to. The claim is that the administrative act's factual determination is unclear and the response is inaccurate.
  4. Q: What materials should be prepared for a review of government information disclosure? A: Typically, these include an information disclosure application form and mailing receipts, the original response document, proof of identity, and evidence of ownership or interest related to the application matter, among others.
  5. Q: After the original response is revoked through the review process, does the administrative organ still need to handle the case again? A: Yes. The review decision usually orders the administrative organ to provide an accurate and complete response to the original application within a specified timeframe (e.g., 20 working days).