Judicial Reform in Late Qing China: The Yang Naiwu Case

The Yang Naiwu case represents a pivotal moment in Chinese legal history that began with the mysterious death of Ge Pinlian in Hangzhou’s Yuhang County in 1873. What started as a routine death investigation snowballed into a complex legal battle that would shake the foundations of Qing dynasty’s judicial system.

The case centered on Yang Naiwu, a recently successful civil service examination candidate, and his tenant Xiao Baicai (Little Cabbage), who were accused of poisoning Ge Pinlian, Xiao Baicai’s husband. Local magistrate Liu Xiqing, influenced by personal prejudice and neighborhood gossip, conducted a flawed investigation that relied heavily on forced confessions obtained through torture.

The proceedings revealed deep systemic issues within the Qing legal system:

First, the case highlighted the problematic practice of secret trials and forced confessions. Both Yang and Xiao Baicai were tortured until they confessed to a crime they didn’t commit. The medical examination was conducted improperly, with the coroner failing to follow standard procedures.

Second, the case demonstrated the power of emerging public opinion. The Shenbao newspaper played a crucial role by providing detailed coverage of the case, making it China’s first major legal case to receive extensive media attention. This coverage generated unprecedented public discourse about judicial reform.

Third, the involvement of Empress Dowager Cixi proved decisive. She recognized an opportunity to reassert central authority by using the case to reign in the power of provincial governors who had gained considerable autonomy in judicial matters during the Taiping Rebellion period.

The watershed moment came when a proper autopsy in Beijing revealed that Ge Pinlian had died of natural causes, not poison. This finding led to the exoneration of Yang Naiwu and Xiao Baicai after three years of imprisonment. More significantly, it resulted in the punishment of over 100 officials involved in the miscarriage of justice.

The case’s lasting impact was profound. It led to reforms in capital punishment procedures, with the central government reclaiming authority over death penalty cases from provincial officials. This represented a crucial step toward modernizing China’s legal system and establishing greater judicial oversight.

The Yang Naiwu case thus marked a turning point in Chinese legal history, demonstrating how a single case could catalyze institutional reform when it intersected with media scrutiny, public opinion, and political will for change. In many ways, it represented China’s first modern legal cause célèbre and helped establish precedents for judicial review and reform that would influence Chinese law well into the modern era.