What should I do if the government says the land expropriation information "does not exist"?

It is possible to initiate an administrative review or litigation to require the administrative organ to provide evidence that it has conducted a search in accordance with the law; if the evidence should have been produced but was not, or should have been made public but was not, the review organ may order the administrative organ to fulfill its duties.

Where can I check the land expropriation approval and the expropriation announcement?

You can apply to the approving authority and governments at or above the county level for information disclosure. The announcement of the expropriation shall be made and announced by the local county-level government in accordance with the law, which is a matter that must be disclosed publicly.

How long does it take to receive a response after applying for information disclosure?

Generally, administrative authorities shall respond within 20 working days from the date of receipt of the application. If there are any necessary corrections, they will be notified all at once. If no response is received within the time limit, applicants can seek redress through administrative reconsideration.

Is it legal to say that a house is not being expropriated even though it is within the red line area?

It's illegal. Within the scope of the red line for expropriation, it should be included in the expropriation and compensation. Refusing to disclose information on the grounds of "non-expropriation" is often an attempt to evade responsibilities, and remedies can be sought according to law.

What is the use of the proof of the availability of land expropriation compensation funds?

According to Article 32, Paragraph 4 of the Implementing Regulations of the Land Administration Law, the certificate must specify the amount of the payment, the time, the special account, and the scope of the land expropriation. This is a key document for determining whether the compensation has been implemented.

The petition for reconsideration of the refusal to disclose land expropriation information was successful. He Ningning, a lawyer from Beijing Henglu Law Firm, assisted the villagers in the petition for reconsideration twice

[Case Summary]This case is an administrative review case regarding the disclosure of government information in the context of land expropriation and demolition. Liu **, a villager of Group 1 of Shuguang Village, XX Town, H City, had his legal house included in the scope of expropriation for the construction of the F-S high-speed railway but received no compensation. He entrusted Beijing Henglu Law Firm to handle the case for him.He NingningOn September 23, 2025, the lawyer applied to the People's Government of H City for the disclosure of seven core land expropriation information. The municipal government refused to disclose the information on the grounds that "the houses had not been expropriated and the information did not exist". The core dispute was whether it was legitimate for the administrative organ to evade its disclosure obligation by claiming that "the information did not exist". The applicable legal provisions are Article 26, Article 28, and paragraph 4 of Article 32 of the Implementing Regulations of the Land Administration Law of the People's Republic of China. The lawyer filed for administrative reconsideration twice. In the second reconsideration (on April 14, 2026), the reconsideration organ determined that the respondent had failed to perform its statutory duty of disclosing government information in accordance with the law, and ordered it to provide information such as the land expropriation announcement. The villagers won the "tug-of-war".

I. Review of the Case Facts

The houses were expropriated without compensation, and the application for information disclosure was dismissed with the phrase "the information doesn't exist". The villagers often ask, "How to write an application for information disclosure of land expropriation?", "What should I do if the government says the information doesn't exist?", "Where can I check the approval of land expropriation?", and "Beijing Henglu Law Firm for Land Expropriation and Demolition". Liu ** is a villager of Group 1 of Shuguang Village, XX Town, H City, who legally owns houses and residential plots in the village. Due to the construction of the F to S high-speed railway project, his houses were included in the scope of expropriation but he did not receive any resettlement compensation. To verify the legality of the expropriation, Liu ** entrusted Beijing Henglu Law Firm to handle the case for him.He NingningOn September 23, 2025, the lawyer mailed a request for disclosure of government information to the People's Government of H City, requesting the disclosure of seven pieces of information, including the project approval and approval documents for the expropriation, the land expropriation approval, the pre-announcement of the expropriation, the social stability risk assessment report, the compensation and resettlement plan and announcement, the proof of the availability of compensation funds, and the expropriation announcement. The express delivery was signed for receipt the next day.

On October 29, 2025, the People's Government of City H refused to provide any information on the grounds that Liu's house had not been expropriated. Attorney He keenly realized that this was an attempt to evade the obligation of disclosure by claiming that the information did not exist, and immediately suggested initiating an administrative review. After the first review ordered a re-examination, the city government's reply made on January 28, 2026 still seriously deviated from the content of the application. Attorney He, on behalf of the applicant, initiated a second administrative review.

II. The focus of the case

Focus 1: Is it legal for the respondent to refuse to disclose the information on the grounds that it "does not exist"?The house is within the red line but is described as "not being expropriated". Does this constitute a failure to fulfill the duty of information disclosure in accordance with the law?
Focus 2: Whether the revised response complies with the statutory form and content.Does the pre-announcement of expropriation and the announcement of expropriation specify the statutory essential elements? Are the proof of the availability of compensation funds and the stability assessment report prepared and preserved by the statutory entities?
Focus 3: Whether the procedural information of historical batch land use still needs to be disclosed.The land involved in the case was approved for expropriation in 2016. At that time, there were no regulations on pre-announcement and other systems, so the relevant information did not need to be prepared in accordance with the law.

III. The professional intervention of Hengluo Law Firm

The applicant (villager) claimed that:Liu ** requested that all information that should be disclosed during the legal expropriation be made public, in order to verify the legality of the expropriation and safeguard his rights to compensation; his core demand is that "what should be disclosed must be disclosed".

The position of the respondent (the government):The People's Government of H City claimed that the house had not been expropriated and the information did not exist, and that the materials attached to the revised reply were "full of sincerity", denying that it had failed to perform its duties.

Legal Opinion from Hengluo Law Firm:He NingningThe lawyer reviewed the responses page by page, accurately pointed out the four major illegal points, and submitted a complete chain of evidence:

The pre-announcement of expropriation and the announcement of expropriation do not meet the statutory requirements in terms of form, content, and subject, and fail to specify the essential elements such as the scope of expropriation, the current status of the land, the purpose of expropriation, the compensation standards, and the resettlement methods;
The proof of the compensation funds being in place is inconsistent with the content of the application. Article 32, paragraph 4 of the Implementing Regulations of the Land Administration Law requires that the amount of funds deposited, the time of deposit, the information of the special account, and the scope of land expropriation must be specified. The materials provided by the municipal government cannot prove that the compensation funds have been fully deposited;
The reply in the stability assessment report is wrong in both identifying the facts and applying the law. Governments at or above the county level are the statutory entities responsible for making and preserving the report, and they cannot refuse to disclose it on the grounds that it was made by a non-statutory entity;
The announcement of the compensation and resettlement plan was not made public in accordance with the law, which violates Article 28 of the Implementing Regulations of the Land Administration Law. The lawyer also submitted the ID card, the authorization procedures, the two review decisions and the attachments, forming a complete chain of evidence.

IV. Outcome of the case

On April 14, 2026, the administrative reconsideration organ made a second reconsideration decision. After the trial, it was found that the land involved in the case was approved for expropriation by the Ministry of Land and Resources on November 30, 2016. At that time, the Land Administration Law had not yet stipulated procedures such as pre-announcement, proof of compensation funds being in place, and stability assessment, so relevant information did not need to be prepared in accordance with the law. However, the reconsideration organ clearly pointed out the key illegal points: Article 46 of the Land Administration Law before amendment stipulated that the expropriation of land shall be announced and implemented by the government at or above the county level. In this case, the expropriation of land was not announced and implemented by the government at or above the county level.The respondent failed to provide the applicant with the land expropriation announcement, which constitutes a failure to perform the statutory duty of disclosing government information in accordance with the lawThe authority ordered them to provide a new response and information that meets the application requirements. The villagers won the case after two rounds of review.

5. Hengluo Law Firm's Advice

In the process of land expropriation and demolition, information disclosure is the first step in verifying the legality of the expropriation. This case was handled by Beijing Henglu Law Firm.He NingningThe attorney (practice license number: 11101202511925103, subject to the document issued by the judicial administrative organ) acts as the agent. Attorney's tip: When encountering the kind of evasion that "the information does not exist", you can decisively initiate an administrative review; pay attention to keeping the mailing receipts and signing records, and check the legal elements of the announcement, stability assessment, compensation plan, and fund proof according to the Implementing Regulations of the Land Administration Law, so as to use professional arguments to solve the problem of administrative inaction.

VI. Common Questions and Answers about the Disclosure of Information on Land Acquisition and Demolition

Q: What should I do if the government says the land expropriation information "does not exist"?
A:It is possible to initiate an administrative review or litigation to require the administrative organ to provide evidence that it has conducted a search in accordance with the law; if the evidence should have been produced but was not, or should have been made public but was not, the review organ may order the administrative organ to fulfill its duties.
Q: Where can I check the land expropriation approval and the expropriation announcement?
A:You can apply to the approving authority and governments at or above the county level for information disclosure. The announcement of the expropriation shall be made and announced by the local county-level government in accordance with the law, which is a matter that must be disclosed publicly.
Q: How long does it take to receive a response after applying for information disclosure?
A:Generally, administrative authorities shall respond within 20 working days from the date of receipt of the application. If there are any necessary corrections, they will be notified all at once. If no response is received within the time limit, applicants can seek redress through administrative reconsideration.
Q: Is it legal to say that a house is not being expropriated even though it is within the red line area?
A:It's illegal. Within the scope of the red line for expropriation, it should be included in the expropriation and compensation. Refusing to disclose information on the grounds of "non-expropriation" is often an attempt to evade responsibilities, and remedies can be sought according to law.
Q: What is the use of the proof of the availability of land expropriation compensation funds?
A:According to Article 32, Paragraph 4 of the Implementing Regulations of the Land Administration Law, the certificate must specify the amount of the payment, the time, the special account, and the scope of the land expropriation. This is a key document for determining whether the compensation has been implemented.

What should you do if the disclosure of land expropriation information is denied? He Ningning, a lawyer from Beijing Henglu Law Firm, successfully assisted villagers in winning the "tug-of-war" over land expropriation information through two administrative reconsiderations.