立法动态截止到 2026 年 11 月，需持续跟踪。

一、一氧化二氮的性质、用途与吸入风险

（一）性质

一氧化二氮（N₂O）也叫氧化亚氮，俗称笑气，CAS 号是 10024-97-2，EC 号是 233-032-0，在欧盟作为食品添加剂时的编号是 E 942。

笑气在常温、常压下是气体。它的临界温度约为 36.4℃，通常室温低于这个温度，所以在室温下施加足够压力，就能把它变成液体。以装有约 2 千克笑气的 3.3 升罐为例，罐内大部分笑气以液态储存。只要罐内仍有液态笑气，20℃时的压力就约为 50 巴（bar）。打开阀门后，气体膨胀，罐内液体也会继续汽化并吸热，导致罐体、阀口和喷出的气体迅速降温。直接从罐口吸入可能造成冻伤。

图 1 N₂O 的物质身份与关键数字。临界温度高于室温，这一性质决定了它能以液态装在小气弹和大罐里。

笑气本身不燃烧，但能助燃。在特定温度和压力条件下，它还会分解成氮气和氧气，同时释放热量。在密闭设备中，这种反应可能使压力迅速升高。2016 年，美国一家气体厂发生槽车爆炸，造成 1 人死亡。美国化学安全委员会认定，最可能的直接原因是输送泵使笑气过热，引发的分解反应从泵内蔓延到槽车。

笑气排入大气后也会影响气候和臭氧层。按相同质量、以 100 年为尺度计算，笑气的全球增温潜势（GWP，即温室效应相对二氧化碳的倍数）约为二氧化碳的 273 倍。欧盟公布的一氧化二氮统一危害分类也列入了对臭氧层的危害。

（二）生产工艺与产品等级

工业上通常用加热硝酸铵的办法制取笑气，再把生成的气体洗涤、压缩、干燥并液化。己二酸、硝酸等化工生产的尾气中也可能含有笑气，可以回收、提纯后得到产品。

食品级、医用级和电子级分别对应不同的用途和质量要求。以食品级为例，联合国粮农组织和世界卫生组织共同设立的食品添加剂联合专家委员会（JECFA）要求：笑气含量按体积算不得低于 99%。每升气体中，一氧化氮和二氧化氮分别不得超过 1 微升，一氧化碳不得超过 10 微升。欧盟对 E 942 还有自己的法定规格。美国药典规定的一氧化二氮含量下限同样是 99.0%。所以，光看纯度百分比，无法直接判断出产品适合哪种用途。

（三）产品类型

此外，医疗用途中还有将笑气与氧气按 50∶50 混合的产品，这类产品按药品管理。

图 2 市场上的四类 N₂O 产品。下方标签表示 2027 年 2 月 1 日起个人能否购买，以欧盟底线为准，德国、法国等国另有更严的规定。

大罐之所以受到关注，是因为它摊薄了每次使用的成本，也让消费者更容易一次买到大量笑气。欧盟毒品管理局（EUDA）报告称，大约从 2017 年起，就有商家向娱乐用途市场销售较大规格的气瓶。英国药物滥用咨询委员会在 2023 年的报告中也记录到，有商家向这类用户销售约 600 克装和 2 公斤装的产品。

（四）娱乐性吸入的风险

把笑气当消遣吸食，快感通常几分钟就过去。大量或反复吸入，会让维生素 B12 无法正常发挥作用，进而损伤周围神经和脊髓，可能出现手脚麻木、肌无力、走路困难。

图 3 娱乐性吸入造成的损害。神经损伤源于维生素 B12 失活，冻伤、缺氧和意外事故则是吸入时的直接伤害。

欧盟毒品管理局（EUDA）引用的资料显示，荷兰在 2018 至 2019 年间有 64 名年轻成年人因使用笑气导致脊髓部分损伤并接受治疗。部分患者治疗后可以恢复，另一些可能留下感觉或运动障碍。吸入时还可能因缺氧而窒息。如果直接对着高压气罐吸，还有冻伤和肺损伤风险。

为减少公众从零售渠道买到笑气后用于消遣吸食， 欧盟委员会公布的草案拟限制向公众供应笑气，只为部分食品用途保留例外。 按草案，用作食品添加剂的小气弹须符合单个容量、每日销售总量和购买年龄等条件。不过，以笑气为推进剂的食品喷雾罐，以及使用笑气制成的食品，暂时处在拟议例外范围内。

二、欧洲的管控逐步收紧

（一）三个阶段

欧洲对笑气的管控大致经历了三个阶段。

2020-2022 年，各国主要禁止向未成年人销售，丹麦、比利时、法国先后立法。2023-2026 年，管控转向限量、列管和入刑。荷兰把 N₂O 列入《鸦片法》，英国把它列为 C 类管制药物，丹麦只允许专业用途。法国限制个人购买数量，并把超量持有定为犯罪。比利时依据毒品法禁止不当使用。德国禁止大罐交易和网络销售。2027 年 2 月 1 日起，欧盟层面开始统一规则：新的危害分类开始适用，REACH 限制拟于同日起禁止向公众供应大罐，法国也在同一天改为只允许法令列明的专业类别购买。

图 4 2020–2027 年欧洲主要国家的 N₂O 管控。三段色带对应三个阶段：禁止向未成年人销售。限量、列管与入刑。欧盟统一规则。

到 2027 年之后，向欧洲个人销售一次性大罐的合规空间基本消失。小气弹也只能在严格的数量和年龄限制下卖给成年人。

（二）收紧的因素

一是健康损害已有数据可查。丹麦、法国和荷兰三国中毒中心的 N₂O 相关报告数，在几年间增长了 4.6-13.4 倍。欧盟毒品管理局的前身欧洲毒品和毒瘾监测中心在 2022 年特别提到 15 千克的大型气瓶，认为肺损伤多与这类气瓶有关。与此同时，荷兰实施禁令后，成人使用率从 2019 年的 3.2% 降到 2023 年的 0.9%，这类数字增强了邻国跟进立法的意愿。

二是垃圾焚烧厂频繁发生爆炸。一次性大罐用完后常被混入生活垃圾，进入焚烧炉就会爆炸。荷兰 2023 年约有 1 万个空瓶在废物处理设施中爆炸，行业损失超过 6500 万欧元。比利时 2024 年 1-7 月共发生爆炸 2008 次，14 座生活垃圾焚烧厂中有 12 座受到影响。巴黎大区三座焚烧厂 2025 年接收约 100 万个气瓶，爆炸超过 2.5 万次，损失约 1500 万欧元。这些损失主要由地方政府和垃圾处理企业承担，大罐因此成为各国优先监管的对象。

三是单一国家的禁令容易被绕开。荷兰部长承认，过境气瓶常经他国流回荷兰。德国 2026 年 4 月跟进立法。同年 9 月，法国海关拦截一辆立陶宛货车，连同随后查获的货物共计约 29 吨。各国因此转而寻求欧盟统一立法，荷兰的推动最为积极。

四是欧盟的危害分类为统一禁售提供了法律依据。条例 (EU) 2025/1222 将 N₂O 定为生殖毒性 1B 类物质，而按照 REACH 附件 XVII 第 30 项，这类物质原则上不得向公众供应，剩下的一步只是把 N₂O 列入相应附录。波兰卫生部在答复议员质询时也明确表示，不另行立法，等待欧盟层面的规则。

图 5 推动各国同步收紧的四方面因素。健康损害、焚烧炉爆炸和单国禁令被绕开，促使各国寻求统一立法；欧盟的危害分类提供了法律依据。

（三）执法力度

近一年的执法大致有三类。

第一类是大宗查获：法国 2026 年 9 月查获约 29 吨，西班牙特内里费 8 月查获约 13 吨并逮捕 6 人，德国慕尼黑 4 月在一家餐饮店查获约 1.7 吨。

第二类是零售检查：德国勒沃库森检查 23 家售货亭，对其中 1 家刑事立案。哈勒检查 20 家店铺，发现 4 家仍向个人销售 1-2 千克的气瓶。布鲁塞尔北区检查 5 家夜店，扣押 3345 瓶。

第三类是刑事判决：荷兰东布拉班特法院 2026 年 10 月判处一名销售 N₂O 的男子 24 个月监禁（其中 6 个月缓刑），并处约 89.7 万欧元罚款，罚款按违法所得计算。

荷兰的数字最能说明执法强度：警方 2023 年扣押约 6.8 万个气瓶，2024 年约 6.6 万个，2025 年前 9 个月约 3.5 万个。检察院登记案件 1801 件，其中 750 件诉至法院。

图 6 荷兰列管之后警方扣押的 N₂O 气瓶数量。

三、CLP分类

CLP 是欧盟关于化学品分类、标签和包装的法规。分类本身并不禁止销售，它决定的是标签上必须写什么，同时也是 REACH 限制向公众供应的前提。

（一）新的统一分类

欧盟委员会授权条例 (EU) 2025/1222 为 N₂O 新增了一个统一分类条目，索引号是 007-031-00-9。这个条目列了四项危害：

• 生殖毒性 1B 类（H360Df）。
• 单次接触特异性靶器官毒性 3 类（H336，可引起昏昏欲睡或眩晕）。
• 反复接触特异性靶器官毒性 1 类（H372，损害神经系统）。
• 危害臭氧层 1 类（H420）。

对应的象形图是 GHS08 和 GHS07，信号词是“危险”。

这份条例 2025 年 4 月 2 日通过，6 月 20 日公布，7 月 10 日生效，从 2027 年 2 月 1 日起适用。企业可以提前按新分类标注。统一条目没有列入氧化性气体和加压气体这两项物理危害，这两项仍由供应商自行分类，业内通常标为 Ox. Gas 1（H270）和 Press. Gas（H280）。

图 7 2027 年 2 月 1 日前后标签上的危害信息。新增的两个象形图和四条 H 语句来自统一分类，H270 和 H280 仍由供应商自行分类。

要特别注意的是，2025/1222 没有给库存设置过渡期。CLP 里的“投放市场”，是指把产品供应给第三方，进口、仓库发货和经销商转售都算投放市场。所以，仓库里贴着旧标签的货，只要在 2027 年 2 月 1 日之后发出，就应当换成新标签。

（二）新标签须载明的要素

CLP 第 17 条规定的标签要素包括：产品标识，供应商的名称、地址和电话，象形图，信号词，H 语句（危害说明），P 语句（防范说明）和补充信息。向公众销售的，还要标注标称数量。P 语句一般不超过 6 条，按具体危害从附件 IV 里选。标签须使用销售国的官方语言。

气瓶和小包装有一些便利规则。水容积不超过 150 升的可移动气瓶，可以按 ISO 7225 制作标签，也可以把规定信息放在耐久的信息盘或挂牌上。125 毫升以下的小包装，可以省略部分 H 语句和 P 语句，但生殖毒性、神经系统损害和臭氧层危害这三项以及对应的 P 语句不能省，象形图和信号词也不能省。标签放不下的，可以印在外包装或挂签上。

向公众销售时，STOT RE 1 分类还会触发两项包装要求：儿童安全封口，以及供视障人士识别的触觉警示。CLP 附件 II 对“可移动气体容器”免除了触觉警示，但条文没有定义这个用语，小气弹能不能适用并不明确。即使能适用，免掉的也只是触觉警示，儿童安全封口的要求仍然存在。

（三）销售对象决定适用哪套标签

CLP 第 1(5)(e) 条规定，成品状态、供最终用户使用的食品不适用 CLP，作为食品添加剂使用的也包括在内。这项豁免对 N₂O 是否适用，要看产品销售给谁。

欧洲化学品管理局（ECHA）的问答把“最终用户”解释为：不在食品经营活动中使用该食品的最终消费者。食品添加剂的生产商或供应商把物质供应给另一家企业的，仍须履行分类、包装、标签和通报义务。法国最高行政法院 2025 年 5 月 19 日的判决则认为，N₂O 作为获批的食品添加剂，原则上不适用 CLP，但超过 500 克且无法连接任何厨具的容器不属于添加剂用途，应当适用 CLP。

由此可以得出三种情形：

• 向消费者零售的小气弹，较可能豁免 CLP，改按食品添加剂的标签规则标注。
• 向餐饮和食品企业销售的产品不能豁免 CLP，须同时加贴 CLP 标签和食品添加剂的企业信息。
• 向个人销售一次性大罐，本身就难以认定为食品添加剂用途。

还要注意，豁免 CLP 不等于豁免 REACH。REACH 只免除食品用途的注册义务，限制条款仍然适用。

图 8 买方决定 N₂O 适用哪套标签。即使零售小气弹豁免了 CLP，REACH 的限量规定照常适用。

（四）法国的红框警示将于 2027 年失去欧盟层面的临时准许

法国第 2023-1224 号法令要求，仅含 N₂O 的产品须在包装上印制警示。单件销售的，须印在直接容器上。内容是：反复或长时间吸入会严重损害神经系统。警示采用红框、白底、红字，字高至少 0.9 毫米。包装最大面超过 80 平方厘米的，至少 1.2 毫米。并配有红色菱形图案，与销售名称处于同一视野内。后续法令放宽了互认条款：按 CLP 标注了 STOT RE 1 的产品也可以接受。

欧委会曾以实施决定 (EU) 2024/2797 临时准许法国的这项措施，期限为 36 个月，或者截至 STOT RE 1 统一分类开始适用之日，以先到者为准。因此这项准许将于 2027 年 2 月 1 日终止。不过，决定并没有要求法国废止法令，法国最高行政法院还认为，食品添加剂产品另有欧盟食品信息条例作为依据。不过，2027 年之后法国如何执行，仍有待观察。

（五）网店展示和排版要求推迟适用

2024 年的 CLP 修订条例 (EU) 2024/2865 新增了几项与电商有关的要求：广告须列明危害信息，远程销售须在页面上展示标签要素，标签排版和最小字号也有了具体标准。这些条款原定 2026-2027 年适用，后被 (EU) 2025/2439 推迟到 2028 年 1 月 1 日。

欧盟正在推进的化学品简化立法还会继续调整：理事会与欧洲议会于 2026 年 6 月 17 日达成临时协议，理事会称相关条款将推迟到 2030 年 1 月 1 日适用。欧洲议会已于 2026 年 10 月 22 日一读通过，尚待理事会通过和公布。按照目前的妥协文本，最小字号要求只适用于向公众销售的产品。只面向专业用户的广告无须列明危害信息，但面向专业用户的网店，只要普通消费者也能下单，仍须在页面上展示标签要素。

下面这版在保留技术细节的前提下，尽量改成顺口的中文：

四、REACH

（一）注册

N₂O 已在欧洲化学品管理局（ECHA）完成注册，年吨位在 1000-10000 吨，共有 16 个有效注册。REACH 第 2(5)(b) 条规定，用于食品（包括食品添加剂）的物质免于注册，但安全数据表和限制的规定仍然适用。所以，只用于食品用途的部分无须注册。而工业、电子、赛车等非食品用途，每年进口 1 吨以上的，须完成注册。非欧盟制造商可以通过协议指定欧盟境内的唯一代表，由唯一代表承担进口商的注册义务。

（二）安全数据表更新

物质符合 CLP 分类标准的，供应商须在首次供货时免费提供安全数据表（SDS）。向公众销售且已提供充分信息的，可以不提供 SDS，但下游用户或分销商索要时除外。出现新的危害信息或新的限制时，SDS 须立即更新，标注修订日期，并免费发送给过去 12 个月内的所有接收方。2027 年的统一分类和 REACH 限制都会触发这项义务。

REACH 第 2(6) 条对食品另有一项豁免，但条文只适用于成品状态的混合物。纯 N₂O 属于物质，用不上这项豁免，向企业销售时仍须提供 SDS。

（三）原则上禁止向公众供应

REACH 附件 XVII 第 28-30 项规定，致癌、致突变和生殖毒性 1A、1B 类物质不得向公众供应。相关产品的包装须清晰、易读、不可擦除地标注“Restricted to professional users”（仅限专业用户）。N₂O 被分类为生殖毒性 1B 类之后，欧盟委员会又起草了一份修订，将 N₂O 正式列入附件 XVII 的相关附录，并为它规定了四项例外。按 2026 年 7 月的送审稿，个人仍可购买的情形只有以下四种：

1. 食品用小气弹：每支不超过 18 克，用作食品添加剂。每次供货合计不超过 90 克，且只能供应给年满 18 岁的个人。
2. 以 N₂O 作为推进剂、专为食品添加剂用途设计的食品气雾罐，例如喷射奶油罐。
3. 使用 N₂O 作为食品添加剂制作或包装的其他食品。
4. 赛车用途：只能供应给在供应国持有特定赛事个人执照的车手。

送审稿还规定，欧盟委员会须在条例生效后三年内复审前三项食品类例外，并明确成员国可以采取更严格的国家措施。草案没有规定年龄核验的具体方式，也没有为例外产品设定专门的标签或渠道条件。

图 9 REACH 附件 XVII 修订送审稿的结构。向公众供应原则上禁止，四项例外以外的产品只能销售给专业用户。

据此，豁免以外的产品，包括 0.95-3.3 升的一次性大罐和可充装钢瓶，只能销售给专业用户。整箱销售的小气弹同样受到限制：按每支净含量 8 克计算，每次最多向个人销售 11 支（88 克）。单支净含量超过 90÷11 克（约 8.18 克）的，每次最多 10 支。24 支、50 支一箱的包装只能销售给专业用户。

图 10 每次 90 克的上限折算成支数。8 克装每次最多 11 支，8.4 克装每次最多 10 支。

（四）修订条例尚待公布

这份修订于 2026 年 4 月 29 日获得 REACH 委员会支持，理事会和欧洲议会的审查期于 2026 年 10 月 9 日届满，截至本文写作时尚未在欧盟官方公报公布。按送审稿，条例在公布后第 20 日生效，其中 N₂O 部分自 2027 年 2 月 1 日起适用，与新分类同日。如果条例迟至 2027 年 1 月 12 日之后才公布，生效日就会晚于 2 月 1 日。

图 11 REACH 修订条例的立法进度。审查期已经届满，条例尚待欧委会通过并在官方公报公布。

此外，符合生殖毒性 1A、1B 类标准的物质，还可以被认定为高度关注物质（SVHC）。目前 ECHA 数据库中没有 N₂O 的相关记录，但从长远看，如果 N₂O 进入授权清单，食品用途不受影响，工业和电子用途则会受到影响

五、食品添加剂规则

（一）E 942 可以按需用于所有食品

N₂O 在欧盟是获批的食品添加剂 E 942。根据《食品添加剂条例》(EC) 1333/2008 附件 II，E 942 属于第 I 组，可以按需（quantum satis）用于所有食品，不限功能，也可以直接销售给消费者。“按需使用”不设数值上限，以良好生产规范下达到预期目的所需的用量为限，且不得误导消费者。在功能上，N₂O 既是推进剂，把奶油从容器里推出来。又是包装气，也就是在食品装入容器之前、期间或之后充入容器的非空气气体。在奶油枪里，它还使奶油起泡。

（二）“食品级”的意思

欧盟法规里并没有“食品级”这个用语。法律上能够主张的，是产品列入了欧盟食品添加剂清单，并且符合 (EU) 231/2012 规定的规格。E 942 的法定规格与国际上常用的两套规格对比如下：

出口商的检测报告宜直接以 231/2012 为依据，JECFA 规格可以作为补充。

（三）B端C端要求不同

食品添加剂向企业销售时，适用 1333/2008 第 22 条：包装上须标注名称或 E 编号、“供食品用”等声明、贮存和使用条件、批号、使用说明、制造商或销售者的名称和地址、净含量和保质期等信息。其中使用说明、名称地址等可以只写在随货单据上，但包装上须醒目标明“不供零售”。

向消费者销售时，适用第 23 条。除名称、E 编号和“供食品用”等声明外，还须按《食品信息条例》(EU) 1169/2011 标注强制信息。通过网络销售的，这些信息须在消费者下单前提供。

由于向餐饮企业销售的产品不能豁免 CLP，这类产品须同时加贴 CLP 标签，并标注上述企业信息。

（四）食品经营者

有意加入食品的物质本身就属于“食品”，进口、贮存、运输和销售都是食品经营环节。因此，欧盟进口商、仓库和经销商原则上都属于食品经营者，须履行两项基本义务：一是追溯，应当能够识别上一手供货方和下一手企业买方，并在主管机关要求时报送。二是登记，每个经营场所都须向主管机关登记，法律有要求的还须经过批准。

小气弹的钢壳、气瓶内壁和阀门密封件会与 N₂O 接触，而 N₂O 本身是食品，因此这些部件应当符合《食品接触材料条例》(EC) 1935/2004。金属材料在欧盟层面没有专门措施，书面合规声明是否强制由成员国决定。塑料部件须按 (EU) 10/2011 出具合规声明。涂层和橡胶部件须遵守 (EU) 2024/3190 关于双酚 A 的禁令。生产过程须按良好生产规范留存记录。尚未接触食品的空瓶投放市场时，须标注“for food contact”字样或杯叉符号。

（五）EFSA 的再评估

欧洲食品安全局（EFSA）正在对气体类食品添加剂进行再评估，数据征集已于 2024 年 3 月 31 日截止。按 EFSA 食品添加剂专家组 2026-2027 年的工作计划，N₂O 的意见正在起草，预计在 2026 年底至 2027 年中完成。如果意见建议收紧规格或用途，E 942 的授权条件可能随之修改。

（六）食品用途的证明

欧盟法律没有规定食品用途的证明方式。德国新法的例外是“公认的商业、工业、科研用途”，同样没有规定证明程序。德国律师普遍认为，仅有买方的用途声明可能不够，还需要留存发票、SDS 和经营记录。荷兰的立法说明则给出了更具体的判断标准：食品用气瓶只能由生产商直接供应给食品企业。个人持有超过 10 支小气弹的，视为非食品用途的强烈迹象。

执法机关依据整体事实作出判断，下面七个方面宜相互印证：

图 12 判断食品用途与娱乐用途的七个方面。任何一项单独符合都不足以证明食品用途，执法机关看的是各方面能否相互印证。

据此，经营者宜准备的证据包括：每批产品符合 231/2012 规格的检测报告。分别符合第 22 条和第 23 条的企业版、零售版标签。买方的营业执照和食品经营登记号。买方载明用途和预计年用量、承诺不向个人转售的用途声明。订单与经营规模的匹配记录。网站和广告内容的审查记录。阀门、密封件和涂层的食品接触合规声明。“食品级”因此是一整套合规责任，仅凭一份检测报告不足以支撑。

六、容器、运输、仓储与废弃物

N₂O 充装在压力容器中，除化学品和食品规则外，还须满足容器、运输和仓储三方面的要求。一只合规的气瓶身上通常有三套标记：容器的 π 标志、危险货物运输标志和 CLP 标签，作为食品添加剂销售的还有食品信息。缺少任何一套，货物都会在相应环节受阻。

图 13 一只气瓶上的四套标记。π 标志、危险货物标志、CLP 标签和食品信息分别对应容器、运输、化学品和食品四套规则。

（一）π 标志

《可运输压力设备指令》2010/35/EU（TPED）适用于运输第 2 类气体的压力容器。它不区分可充装容器和一次性容器，因此一次性大罐同样须带有 π 标志。π 标志只能由制造商加贴，加贴前须由公告机构完成合格评定，π 标志之后还须标注公告机构的编号。进口商应当核查 π 标志和相应证书。产品不合规的，主管机关可以要求整改、禁售或召回。

可运输压力设备使用的是 π 标志，而不是 CE 标志，因为《承压设备指令》把 TPED 范围内的设备排除在外。供应商只能出具 CE 证书的，宜进一步要求其提供 π 证书。荷兰执法部门 2023 年起专门核查一次性气瓶是否符合 ISO 标准，当年即以不合规为由扣押了 4.5 万个，2024 年又开始核查若干型号是否与型式批准的样品一致。

小气弹的情况有所不同。TPED 把小型气体容器纳入范围，但排除了按危险货物运输规则的特殊规定免于构造和试验要求的设备，因此满足 ADR 特殊规定 SP 584 或 SP 191 条件的小气弹不在 TPED 范围内。另外，只用于欧盟与第三国之间运输的设备不适用 TPED，但这项例外不适用于进口后在欧盟境内销售和使用的气瓶。

一次性金属气瓶的现行国际标准是 ISO 11118:2025，而《危险货物国际道路运输欧洲协定》（ADR）2025 年版引用的仍是 ISO 11118:2015 及其 2019 年修正案。

（二）运输

N₂O 的联合国编号为 UN 1070。按 ADR，它属于 2.2 类，次要危险为 5.1 类（氧化性），包装指南为 P200，运输类别为 3，隧道代码为 (C/E)。它的有限数量为 0，例外数量为 E0，也就是说，大罐不能以有限数量或例外数量的简化方式运输，快递小包通常难以承接。海运按《国际海运危险货物规则》（IMDG）同样属于 2.2 类，次要危险 5.1 类。空运按国际民航组织的包装说明 200 办理，部分小气弹品牌的 SDS 明确写明其产品不得空运。

图 14 N₂O 在陆运、海运和空运中的主要规则。陆运和海运都把它列为 2.2 类气体，次要危险为 5.1 类。

小气弹能否作为普

通货物运输，关键在 ADR 的特殊规定 SP 584。这项规定须同时满足六项条件：呈气态。含空气不超过 0.5%。充装在无缺陷的金属胶囊内。封口密封。每个不超过 25 克。每立方厘米容积不超过 0.75 克。奥地利曾在 2009 年提议修改这些条件，但没有获得通过，条文沿用至今。

市面上主要品牌的充装密度约在 0.72-0.83 之间：有的品牌 8.4 克装在 11.4 毫升的容器里，约为 0.74。有的 8.5 克装在 10.3 毫升里，约为 0.83，已经超出上限。业内的 SDS 目前有两种写法，一种按 UN 1070 援引 SP 584，另一种按 UN 2037（小型气体容器）援引 SP 191，充装密度超出上限的产品通常依据后者。

图 15 四个品牌小气弹的充装密度。数据按各品牌公开的充装量和容积计算，虚线为 SP 584 规定的每立方厘米 0.75 克上限。

（三）仓储

《塞维索指令》（Seveso III）将“氧化性气体，类别 1”的存量门槛定为下限 50 吨、上限 200 吨，存量按任一时刻的最大量计算，并与其他危险物质加和。按每罐净含 580 克计算，50 吨约合 8.6 万罐。按每罐 2 千克计算，约合 2.5 万罐。旺季备货的海外仓，存量很容易接近下限。2027 年新增的生殖毒性分类不属于 Seveso 的危害类别，存量判断仍以氧化性气体为准。

员工防护方面，欧盟《致癌、致突变和生殖毒性物质指令》经 2022 年修订后，已经覆盖符合 1A 或 1B 类生殖毒性分类标准的物质，成员国须在 2024 年 4 月 5 日前完成转化。雇主应当评估员工的接触情况，优先替代，无法替代时使用封闭系统，将接触降至最低，并保存接触工人名单，生殖毒性物质的记录至少保存至接触结束后 5 年。这项指令以“符合分类标准”界定适用范围，并不以 CLP 新分类的适用日期为准。N₂O 的统一分类已经通过，仓库、灌装场所和餐饮后厨的雇主宜从现在起按生殖毒性物质评估员工防护，最迟在 2027 年 2 月 1 日前完成。

（四）废弃物

空罐进入焚烧炉会发生爆炸，由此造成的损失目前主要由地方政府和垃圾处理企业承担，各地的应对方式包括设置回收点、给予回收奖励和推动押金制度。荷兰议会已有动议要求建立全国统一的回收体系，并通过生产者责任向生产者追偿。焚烧行业也致函欧委会，要求统一押金规则。瑞典哥德堡的市政文件提出对气瓶生产者采取监管措施。由生产者承担废罐处理成本，很可能成为下一项监管手段。

图 16 空罐进入焚烧炉后造成的损失，以及各地的应对措施。损失目前主要由地方政府和垃圾处理企业承担。

欧盟《包装和包装废弃物条例》(EU) 2025/40（PPWR）自 2026 年 8 月 12 日起适用。气瓶是否属于“包装”，目前没有官方结论：旧的包装指令附件曾把可充装钢瓶列为包装，欧委会 2026 年的指南则称，构成产品不可分割部分的物品不属于包装，但没有提到气瓶。被认定为包装的，生产者须在包装成为废物的成员国注册、报告并缴纳费用。德国已于 2026 年 8 月 12 日起以新的《包装法实施法》取代原《包装法》，在德国没有分支机构、直接向终端用户销售的境外企业，须指定授权代表。

七、产品安全、产品责任与电商平台

（一）GPSR 适用于器具

《通用产品安全条例》(EU) 2023/988（GPSR）自 2024 年 12 月 13 日起适用，食品不在其适用范围内。N₂O 本身属于食品，不适用 GPSR。奶油枪、气瓶、减压阀等器具则适用，钢壳的物理风险也可能落入其范围。

GPSR 对器具的主要要求有四项：产品须有欧盟境内的经营者负责，方可投放市场，该经营者的名称和联系方式应当标示在产品、包装或随附文件上。网上销售须展示制造商和欧盟责任人的信息、产品图片和警示信息。发生造成死亡或严重损害健康的事故时，制造商须通过欧盟的安全商业门户及时通报事发国主管机关。在线市场须设立联络点，在 2 个工作日内执行下架命令。

（二）境外制造商的产品始终有人承担责任

新《产品责任指令》(EU) 2024/2853 的转化期限为 2026 年 12 月 9 日，适用于此后投放市场或投入使用的产品。新指令下的“产品”包括原材料，并不排除食品，N₂O 气体本身也在适用范围内。判断产品是否存在缺陷时，须考虑可合理预见的使用，序言将其解释为包括“并非不合理的误用”，吸入滥用是否属于这种误用，目前还没有定论。

新指令最重要的变化在于责任主体。制造商在欧盟境外的，由进口商和制造商的授权代表承担责任。两者都不在欧盟境内的，由履约服务商承担。仍无法确定责任人时，分销商乃至在线平台也可能被追究责任。因此，2026 年 12 月 9 日之后投放市场的产品，进口商、海外仓和平台都可能成为首先被追究的一方，合同和保险安排宜相应调整。

图 17 制造商在欧盟境外时，产品责任的追溯顺序。前一层主体不在欧盟境内或无法确定时，责任依次落到下一层。

（三）电商平台的规则严于法律

主要电商平台已经先于法律收紧。eBay 的欧洲主要站点禁售 N₂O，禁售范围包括小气弹，德国站还禁售奶油枪。荷兰和比利时的 Bol.com 在品类政策中明确禁售小气弹。德国 Kaufland 的禁售清单没有 N₂O 专项，只有“毒品及相关配件”这一概括条款。波兰 Allegro 没有 N₂O 专项，但毒品、精神药物和有害物质都在禁售之列。法国新法还把网上兜售 N₂O 和提取工具的内容纳入下架和屏蔽程序，平台在法国会更主动地删除相关链接。通过电商平台向个人销售 N₂O 的空间已经很小。

（四）广告和营销的边界

各国对营销内容的限制越来越具体。法国规定，教唆或美化吸入 N₂O 的，可处 2 年监禁和 1.5 万欧元罚金。德国禁止以邮购和自动售货机方式交易 N₂O，网店本身即不得向个人销售。比利时王室法令禁止的行为包括“要约”和“居间”，线上和线下均适用。年龄方面，REACH 草案限定小气弹只能销售给成年人，法国要求卖方查验年龄并在网店页面写明禁止向未成年人销售，比利时也有类似要求。

营销内容宜只涉及烘焙、甜点和饮品，不宜展示气球，不宜使用派对、快乐之类的暗示，也不宜搭配销售开瓶器和气球套装。在执法中，单个广告画面就可能成为认定“娱乐用途”的证据。

八、主要成员国的国内规则

REACH 限制是欧盟的统一底线，成员国可以在此基础上规定更严格的措施。目前，德国和法国已经立法限制个人购买，比利时依据毒品法禁止一切“不当用途”，荷兰将 N₂O 纳入毒品法管制，西班牙和波兰尚无专门立法。主要国家的规则对比如下：

图 18 各国对个人购买 N₂O 的限制程度。实心部分为现行规则，虚线部分为 2027 年 2 月 1 日起的变化。

（一）德国

德国《新型精神活性物质法》（NpSG）的修订法于 2026 年 1 月 12 日公布，4 月 12 日生效。修订后的法律将 N₂O 及其制剂列入附件 2，受监管的情形有两种：单个容器装量超过 8.4 克，或一次销售超过 10 个装量 8.4 克以下的容器。对这两种情形，法律禁止交易、投放市场、制造、运入、运出、过境、取得、持有和施用。此外，无论容量大小，一律禁止以邮购（含网购）和自动售货机方式流通，禁止向未成年人交付。

公认的商业、工业和科研用途以及官方用途不受上述禁止，喷射奶油这类难以提取 N₂O 的成品另有豁免。违法交易、投放市场或施用的，处 3 年以下有期徒刑或罚金。职业性或团伙作案、21 岁以上的人向未成年人供给或危及多人健康的，处 1-10 年有期徒刑。单纯的取得和持有不入刑。海关有合理怀疑即可扣押货物。

实践中有三个问题需要注意。第一，邮购禁令的条文不区分企业和个人，立法理由书说明例外条款覆盖全部禁止行为并应作宽泛解释，所以以邮购方式向企业发货，只有在买方用途落入例外时才合法。第二，法律没有规定商业用途的证明程序，立法理由列举的例子包括食品添加剂和奶油推进气，实务中宜留存发票、SDS 和经营记录。第三，运入装量超过 8.4 克的容器本身就在禁止之列，海关凭怀疑即可扣押，进口商实际上需要能够证明用途落入例外。

图 19 面向德国买方的一笔交易在 NpSG 下的判断路径。先判断是否属于公认的商业用途；其余交易只有经由门店、面向成年人且不超过数量限制，才属合法。

立法过程中，装量标准从 8 克改为 8.4 克，是为了避免厂商调整生产线。10 支的上限则是为了防止个人囤货。新法生效后，慕尼黑、勒沃库森和哈勒都已出现执法案例。在德国，面向个人的合法渠道只剩一种，即在实体门店向成年人销售小气弹。通过网店、电商平台或跨境直邮向德国个人销售，均属违法。

（二）法国

法国是收紧最快的国家，2027 年之后的规则也比欧盟底线更严。

法国第 2021-695 号法律在《公共卫生法典》中增设了 L.3611 条以下的规定：不论何种包装，均不得向未成年人销售 N₂O，卖方须查验年龄，网店须在页面上载明这一禁令。酒吧和烟草店即使面对成年人也不得出售。禁止销售开瓶器等提取工具。2023 年 7 月 19 日的部令自 2024 年 1 月 1 日起施行，规定向个人每次只能销售单支不超过 8.6 克、每盒不超过 10 支的小气弹，其他包装一律不得销售给个人，门店和网店均适用。食品和餐饮业的专业用户凭 3 个月内的商业登记摘要可以豁免。政府在答复议员时，将“10 支”理解为每次销售最多 10 支。

2026 年 8 月 18 日的第 2026-798 号法律（RIPOST）进一步收紧。已经施行的部分规定，个人持有、运输的数量超过购买上限即构成犯罪。出于医疗以外目的吸入的，可处 1 年监禁和 3,750 欧元罚金。教唆或美化吸入的，可处 2 年监禁和 1.5 万欧元罚金。省长可以关闭违规店铺。2027 年 2 月 1 日起，任何人都不得持有、运输、转让或提供 N₂O，只有法令列明的专业类别可以买卖、持有和运输。违者处 2 年监禁和 1.5 万欧元罚金。针对未成年人、在学校周边或通过网络实施的，处 3 年监禁和 3 万欧元罚金。有组织实施的，处 5 年监禁和 10 万欧元罚金。

专业类别、流通渠道、溯源要求、卖方和平台核验买方身份的义务以及包装规格，都有待配套法令规定，截至本文写作时，这份法令尚未发布。从 2027 年 2 月 1 日起，在法国连 8 克的小气弹也不能再销售给个人，只剩下专业渠道。在法令发布之前，哪些买方属于专业类别仍不确定。

图 20 法国 2021–2027 年的五次收紧。

（三）比利时

比利时的规则分为两层。2021 年的法律禁止向未满 18 岁者出售家用奶油枪所用的 N₂O 金属气弹，电商页面须载明这一禁令，包装须印制警示语。2024 年 3 月 11 日的王室法令于 4 月 8 日生效，以毒品法为依据，禁止为不当用途实施十四种行为，包括进口、出口、过境、制造、储存、贴标、运输、持有、居间、销售、要约、开处方、交付和取得，线上线下均适用。用于医疗、技术目的或作为食品添加剂的除外。违者适用毒品法的罚则，实务中对为不当使用而持有的，检察院通常按 150 欧元的标准提出即时和解。

比利时众议院 2025 年 12 月 18 日又通过了一部法律。根据这部法律，销售含 N₂O 的金属气弹时，须对看似未满 25 岁者查验年龄。执法部门可以由未成年人充当神秘顾客。一年内反复违规的，可临时关闭店铺 1 小时至 30 天。违规产品可以当场扣押并销毁。这部法律已送国王签署，尚待公布。

比利时以用途判断合法与否：同一个 2 千克的罐，销售给面包店属于合法，用于派对则落入毒品法的范围。经安特卫普入境、在比利时仓储的货物，需要能够说明最终用途。

（四）荷兰

荷兰自 2023 年 1 月 1 日起将 N₂O 列入《鸦片法》清单 II，检察机关自同年 7 月 1 日起执法。技术用途和食品添加剂用途享有豁免，豁免范围包括进出口。立法说明载明了豁免的条件：食品用气瓶只能由生产商直接供应给食品企业，不得销售给个人。小气弹零售仅限成年人，每次不超过 10 支。个人持有超过 10 支的，视为非食品用途的强烈迹象。故意持有、销售、运输的，处 2 年以下监禁。以此为业的，处 6 年以下监禁。故意进出口的，处 4 年以下监禁。

荷兰司法部长 2025 年 11 月答复议会时表示，如果气瓶的最终目的地是没有禁令的国家，边境不能依据《鸦片法》扣押，但这些气瓶往往又经其他国家流回荷兰。荷兰因此成为推动欧盟统一禁令最积极的国家。经荷兰转运的货物，宜备齐目的地国的合规文件和用途证明。

（五）西班牙

西班牙在国家层面没有专门规则，N₂O 也不在管制物质清单上，但娱乐性销售可以按《刑法典》第 359 条危害公共健康罪追究。据西班牙一名检察官的评论文章介绍，最高法院 2026 年 10 月 1 日的第 569/2026 号判决维持了一例定罪。该案被告持有两瓶 N₂O、100 个气球和 3 个充气器准备出售，一审被判处 2 年监禁并处罚金，省法院和最高法院先后驳回了上诉。法院认为，N₂O 属于需要处方的药理活性物质，第 359 条规定的是抽象危险犯，鉴定结论认定其足以危害公共健康。

地方层面，巴利阿里群岛 2013 年的决议禁止在娱乐场合通过气球等吸入装置销售、供应 N₂O。Sant Antoni 等地的市政条例禁止在公共空间销售、推广 N₂O，违者处 750-1,500 欧元罚款，涉及未成年人的处 1,500-3,000 欧元罚款，当地 2025 年夏季逮捕了 49 名销售者。2026 年，国家毒品计划发布了中毒预警，巴利阿里议会要求中央政府将娱乐用 N₂O 作为麻醉品监管，人民党参议院党团也提交了推动监管的动议。西班牙表面上没有数量和渠道限制，刑事风险却已经出现。

（六）波兰

波兰目前没有专门针对 N₂O 的国家立法。2026 年 1 月，有众议员就 N₂O 中毒问题提出质询，提到网上存在以“餐饮用”名义将 N₂O 与气球、喷嘴搭配销售的情况。卫生部 2 月答复称，N₂O 不属于麻醉品、精神药物或新型精神活性物质，政府寄望于欧盟在新分类适用后通过 REACH 禁止向公众供应。2027 年 2 月 1 日之前，波兰是上述国家中最宽松的市场，之后与欧盟底线一致。从波兰仓库发往德国、法国、荷兰的货物，仍应当按目的国的规则判断是否合规。

（七）其他国家

英国自 2023 年 11 月起将 N₂O 列为 C 类管制药物，为吸入而持有的最高处 2 年监禁，供应的最高处 14 年监禁，合法用途不受影响。丹麦 2020 年起禁止向未成年人销售，2023 年 7 月起除专业用途外禁止向个人销售。瑞典《笑气法》自 2025 年 7 月 1 日起施行，向个人每次最多销售 18 克，最多两支、每支不超过 9 克，超量只能销售给企业，并禁止向未满 18 岁者销售。挪威的新规自 2026 年 7 月 1 日起施行，每人每天不超过 17 克，超量只能销售给登记企业，持证车手除外，个人不得进口。马耳他也在 2026 年 5 月按紧急程序向欧委会通报了禁止娱乐性吸入的规定。

九、规则在不同产品和渠道上的适用

（一）义务主要由欧盟境内首个投放市场的企业承担

同一批 N₂O 产品的合规义务由谁承担，取决于谁在欧盟境内首先将其投放市场。欧盟化学品法的大多数义务落在欧盟进口商身上：REACH 注册、CLP 标签、SDS、食品经营者登记和追溯，以及核查 π 标志和证书，都由进口商负责。非欧盟制造商在欧盟化学品法下大多不直接负有这些义务，但 π 标志只能由制造商加贴，产品责任也可能追及制造商，注册、SDS、标签和证书等实际工作通常也要由制造商通过合同和唯一代表安排完成。唯一代表只能解决 REACH 注册问题，不能替代进口商在 CLP、食品法和各国国内法下的责任。

按商业模式划分，常见的有四种情形：

1. 中国工厂向欧盟进口商或批发商销售：欧盟买方是进口商，会要求工厂提供全套合规文件。2027 年 2 月 1 日之后，大罐只能销售给专业用户，订单结构会随之变化。双方宜在合同中写明合规分工。
2. 中国企业自设欧盟公司或海外仓：REACH、CLP、产品安全、产品责任、各国国内法和食品经营者义务都由企业自己承担，库存也会直接受到新规则的影响。
3. 通过独立站或平台店铺向欧盟个人跨境直邮：欧盟境内实际上没有承担进口商义务的主体，而德国禁止通过邮购和网购向个人销售，法国 2027 年起只允许专业类别购买，平台下架、海关扣押和刑事责任的风险都最高。
4. 为欧盟品牌代工贴牌：品牌方是投放市场的主体，但通常会通过合同把合规成本和风险转嫁给制造商，合规保证、赔偿、召回和法规变化条款需要仔细审查。

图 21 四种商业模式。跨境直邮给个人时，欧盟境内实际上没有承担进口商义务的主体，风险最高。

（二）各类产品的销售对象

假设 REACH 修订按目前的送审稿公布，2027 年 2 月 1 日之后，不同产品和渠道的结果如下：

表中的“高风险”，是指法条没有直接点名，但产品形态和营销方式难以解释为食品用途，执法中很容易被认定为娱乐用途的情形。

图 22 2027 年 2 月 1 日之后各类产品和渠道的可销售性。实心圆为可以销售，斜线圆为有条件销售，叉为不得销售，感叹号为高风险。

（三）三个容易忽视的问题

第一，向公司销售不等于向专业用户销售。便利店、烟草店和派对用品店都是公司，它们的下游买方却可能是个人。核验时宜审查对方的经营范围和实际用途，不宜仅凭营业执照判断。

第二，向专业用户销售一次性大罐虽然合法，却不符合欧洲专业渠道的使用习惯。欧洲正规供应商向餐饮企业提供的是可充装钢瓶，通过减压阀或转接头连接奶油枪，空瓶回收后重新充装。一次性大罐在专业渠道里本就少见，废弃后还会带来焚烧炉爆炸的问题，更容易引起监管部门的注意。

第三，小气弹的包装规格需要调整。欧盟规则要求每次向个人销售合计不超过 90 克，德国、法国另有 10 支的上限，50 支、100 支一盒的零售装今后只能通过专业渠道销售。

（四）2027 年 2 月 1 日之前宜完成的准备

距离新规则开始适用已经不到三个月，库存、标签、合同和买方核验宜同步推进：

1. 标签和 SDS：按新分类准备各销售国语言的标签和 SDS，并在 2027 年 2 月 1 日前发送给过去 12 个月内的所有接收方。新规则没有库存过渡期，此后发出的旧标签货物须重新贴标。
2. 产品线：零售的小气弹改按单次不超过 90 克的规格包装，只销售给成年人。大罐只通过专业渠道销售，包装加注“仅限专业用户”。果味款和气球套装宜停售。
3. 买方核验：建立核验专业用户身份的流程，留存营业执照、经营登记、用途声明和订单记录，并定期检查订单与经营规模是否匹配。
4. 渠道：退出向个人销售大罐的渠道，按目的国规则重新评估网店和平台销售，德国、法国的个人渠道尤其需要调整。
5. 容器和运输：核查一次性大罐的 π 标志和公告机构证书，逐款核算小气弹的充装密度，按危险货物要求安排大罐的运输。
6. 仓储和员工：评估海外仓的存量是否接近 Seveso 门槛，按生殖毒性物质评估仓库员工的防护。

图 23 2027 年 2 月 1 日之前宜完成的六项准备。新规则没有库存过渡期，标签和 SDS 的更新最为紧迫。

十、从中国出口的合规要点

（一）N₂O 在国内按危险化学品管理

N₂O 列入《危险化学品目录（2015 版）》，条目名称为“一氧化二氮[压缩的或液化的]”，别名氧化亚氮、笑气。它不属于剧毒化学品、易制爆化学品或易制毒化学品，也没有列入麻醉药品和精神药品目录。N₂O 同时是获批的食品添加剂，可以作为推进剂、起泡剂等加工助剂用于稀奶油、植脂奶油等食品，质量标准为 GB 1886.350-2021《食品添加剂 氧化亚氮》。出口时的商品编码为 2811.29.0090。

从生产到出口，N₂O 产品须依次经过生产、充装、经营、运输、出口检验和海运申报六个环节。主要依据是 2026 年 5 月 1 日起施行的《危险化学品安全法》、《气瓶安全技术规程》（TSG 23-2021），以及海关总署关于进出口危险化学品检验监管的公告。TSG 23 适用于公称容积 0.4-3,000 升的气瓶，包括一次性焊接钢瓶，因此 0.95-3.3 升的一次性大罐在其适用范围内，容积约 10 毫升的小气弹则不在此列。生产企业在本企业厂区内销售自产产品的，无需另行办理经营许可。

图 24 N₂O 从生产到出口的六个环节。每个环节都有对应的许可或文件，出口报检和海运申报的文件须与欧盟进口商使用的版本一致。

（二）国内执法的重点是向个人销售

国内对 N₂O 的执法集中在无证向个人销售。无证经营 N₂O 的，以非法经营罪追究刑事责任。未达到追诉标准的，依照《治安管理处罚法》处理。少量运输的，多以非法运输危险物质为由处以行政拘留。在电商平台搜索“笑气”会跳转至禁毒页面，部分商家改用暗语，以“二氧化碳发泡弹”等名义上架商品。北京朝阳的一起案件说明，持有经营资质并不意味着可以向任何人销售：该案被告在外地注册公司、办理危化品经营资质作为掩护，仍被认定构成非法经营罪。

（三）出口环节的三项主要风险

第一是匿报、谎报。将 UN 1070 作为普通货物托运，违反《危险化学品安全法》，由交通运输主管部门处 20 万-30 万元罚款。未按规定提交 SDS、标签等托运材料的，另处 5 万-50 万元罚款，船公司还可能追偿损失。2025 年 10 月，曼谷港查获的 2,600 罐 N₂O 就藏匿在其他货物中，没有列入舱单。

第二是资质与实际不符。经营许可、充装许可载明的地点，应当与实际生产、充装地点一致，宁波一家公司就曾因骗取许可被撤销经营许可证。

第三是文件版本不一致。出口报检所用的危险特性鉴别报告、SDS 和标签，应当与欧盟进口商使用的版本一致。2027 年 2 月 1 日欧盟分类变更之后，国内的出口文件也宜同步更新。

出口前宜逐项确认：危险化学品安全生产许可证和经营许可证在有效期内。具备气瓶充装许可和制造许可，出口欧盟的气瓶已取得 π 标志。食品级产品具备食品添加剂生产许可、GB 1886.350 检测报告，并符合欧盟 E 942 规格。危险特性分类鉴别报告和包装性能检验结果齐全。中文和欧盟各国语言的 SDS、标签已按新分类准备。订舱时如实申报 UN 1070，货物描述与报关单、提单一致。与欧盟买方的合同写明了合规分工和法规变化的处理方式。

十一、需持续关注

N₂O 的监管仍在快速演变，以下几件事值得持续关注：

1. REACH 修订条例的公布。修订已过审查期，但截至本文写作时仍未在欧盟官方公报公布，最终文本中的数字和适用日期以公报为准。
2. 法国的配套法令。专业类别、流通渠道、溯源要求和买方核验义务都要等这份法令确定，它须在 2027 年 2 月 1 日之前发布。
3. CLP 简化立法。网店展示、广告和标签排版等条款最终推迟到哪一天，要看理事会通过后公布的文本。
4. EFSA 的再评估意见。如果 EFSA 建议收紧规格或用途，E 942 的授权条件可能随之修改。
5. 比利时的新法。查验年龄、神秘购买和临时关店的规定，要等国王签署并公布后施行。

几个关键日期如下：

从这几年的走向看，欧洲对 N₂O 的监管重心已经从产品本身转向买方和渠道，监管机构关注的是产品销售给了谁、如何核验、是否留有记录。修改标签只是第一步，今后合规的重点在于证明每一笔交易都落在合法用途之内。

一、新手入门

（一）湿气农场的制水流程

最容易上手的副业是制水。

1. 购买湿气农场，放进店里后双击打开。
2. 在电源槽中插入一块充满电的电池，在容器槽中放入一个空水罐或空水瓶。
3. 次日早上打开湿气农场，取出约 1000 毫升幽灵水。
4. 把水倒进装有滤芯的水罐，完成过滤。
5. 用水质试纸或 Aquascan 检测纯度，再对照手册确定等级。
6. 用红标签机标注正确的等级，再放进展示柜。 一定要先检测再贴标签，标错等级会引来顾客投诉。
7. 每次分装或混合之后，都要重新检测一次。

二、设备使用说明

机器买来后先放进店里，双击打开操作窗口，再把原料拖进对应的槽位。 大多数机器要过一夜才会产出，原料放进去后没有立即反应属于正常情况。本节数值来自社区实测和 1.0 版补丁说明，以游戏内提示为准。

（一）各类机器的通用操作

机器窗口通常分为四个区域：电源槽、模块区、原料或容器槽、产出槽。

图 1 机器窗口的四个区域。具体位置因机器而异，辨认槽位时可以把鼠标停在槽位上查看提示。

机器没有产出时，可以按以下顺序排查：

1. 电力：检查这台机器的电源槽里有没有电池、电池还剩多少电量。放在店里其他位置的电池不会为它供电。
2. 原料：检查原料种类是否正确、数量是否足够、是否装在正确的容器里。外观相似的物品不一定能够替代。
3. 产出空间：产出槽已满，或者应当放空容器的位置没有放，机器都会停止运转，表现与断电相似。
4. 时间：需要过夜的机器，要等玩家睡过一晚才会结算。
5. 模块：把新装的模块逐个拆下，确认是哪一个造成了问题。

电池的充电方式

充电器和 Powerbloc 都需要在睡前界面支付 电费服务才会工作。在王尔德处解锁“窃电”后，电费服务会持续生效，不必每晚支付。

模块的安装与属性

把模块拖进机器窗口的模块区。放不下时，可以用 Q、E 旋转，用 F 翻转。安装完成后，窗口会显示品质、性能、效率三项总值：

第一批产出最好不装模块，先得到一个基准，再逐个加装模块进行对比。模块卡住无法取出时，可以使用模块提取器。

（二）净水工具与净水流程

净水工具一览

图 2 按污染物选择净水工具。处理前先扫描，确认主要污染物。滤芯无法去除重金属和化学物，这两类污染只能依靠净水器或 HydraTech 处理。污染严重的水先用 HydraTech 提纯至 98%，再进行过滤，可以延长滤芯的使用寿命。

净水器的操作步骤

1. 双击打开净水器，在电源槽中插入电池。
2. 把装有待处理水的容器拖进容器槽。
3. 过一夜后，用 Aquascan 扫描，查看各项污染物下降了多少。
4. 尚未达到目标纯度时，继续放置过夜。纯度越接近 100%，每晚的降幅越小。
5. 如果要制作纯净水（99.9% 以上），直接使用原水时，品质模块需要达到 100%；先用水罐预过滤一遍，品质达到 75% 即可。

湿气农场的操作步骤

1. 在电源槽中插入电池，在容器槽中放入一个空水罐或空水瓶。
2. 过一夜后，取出约 1000 毫升水。
3. 出水等级取决于品质模块：品质 0% 时产出幽灵水，50% 时为基础水，100% 时为高品质水，150% 时直接产出纯净水。
4. 较省力的做法是把品质提升到 50%，出水后再倒进装有滤芯的水罐过滤一遍，可以稳定得到高品质水。

出售前的检测与标注

1. 用试纸或 Aquascan 检测，对照手册确定等级。
2. 用红标签机标注正确的等级。一定要先检测再贴标签；标错等级会引来顾客投诉，出售劣质水还可能导致顾客死亡。
3. 每次分装或混合之后都要重新检测。两份水混合后的纯度 =（体积 A × 纯度 A + 体积 B × 纯度 B）÷ 总体积。例如，450 毫升纯度 97.4% 的水与 2000 毫升纯度 99.4% 的水混合，纯度约为 99.03%。

水的定价规则：每满 25 毫升的基础价为 1 信用点，再按等级调整：纯净水 +100%，高品质水 +50%，基础水不变，幽灵水 −33%，锈水 −75%，下水道水 −90%。

（三）老鼠养殖

设备安装

1. 把动物笼放进店里，双击打开，再把老鼠拖进笼中。
2. 把牲畜喂食器放进笼中并装入食物。喂食器会把食物转化为卡路里储存，按需投喂。 不要放入鼠肉，否则老鼠会感染朊病毒病；如果已经放入，需要点击“清空”，仅看到数字归零并不代表已清理干净。
3. 基因扫描仪： 右键点击扫描仪，选择“切换”，使其处于开启状态。把扫描仪拖到老鼠身上不会生效。开启后，把鼠标悬停在老鼠上即可查看全部基因。
4. 清洁机器人：插入电池后放在笼子附近，夜间会自动收集粪便，每次消耗 4 点电量。使用一个普通电子件可以加装焚化炉，耗电量翻倍，粪便会被直接焚毁；如果需要保留粪便另作他用，可以关闭焚化功能。

老鼠属性面板说明

每项性状显示两个数值，分别对应两个等位基因。挑选种鼠时，两个数值都需要查看。

日常管理要点

• 繁殖：一只公鼠最多可以同时使 3 只母鼠怀孕。
• 淘汰：不再用于繁殖的老鼠可以用钳子绝育，或者饲养到约 400 克时宰杀，获得大块鼠肉。老鼠在第 1–4 天每天增重约 75 克，之后增速放缓，10 天后体重开始下降。
• 拥挤：笼子占用率超过 52.5%、70%、90% 时，分别会出现拥挤、打斗和生命值下降。
• 维修：把废金属拖到笼子上，可以恢复最大耐久的 50%。
• 疾病：绿色免疫血清可以提高免疫力，但会加快饥饿；红色生长血清可以加快生长，但会降低免疫力。
• 补给：每周会有退休养殖户上门出售老鼠、笼子、扫描仪和药品。

（四）鱼类养殖

1. 打开循环水养殖系统。水箱已经装好，但里面没有水。
2. 在电源槽中插入一块充满电的电池。
3. 把水倒进水箱。
4. 把受精鱼卵拖进水箱。先阅读鱼卵的说明，一份鱼卵可能代表一群鱼，需要为它们预留生长空间。
5. 在喂食器中放入饲料原料，点击“混合”制成鱼饲料。
6. 每晚睡前逐项检查电量、水量、滤芯、喂食器和水箱空间。把鼠标悬停在系统和水箱上，可以查看食物、水、污染物和电量。
7. 把鼠标悬停在鱼卵或鱼苗上，可以查看距离孵化或长成还需多久。
8. 收获时先留好种鱼，再用刀处理多余的鱼。鲟鱼的鱼子酱可以用手术工具从活鱼身上提取（会使鱼受伤），也可以在宰杀时取得。

肉食鱼不能使用罗非鱼的饲料，投喂前要先确认食性。不能繁殖的鱼种需要持续购买新的鱼苗。

（五）水培种植

1. 先用植物分析仪查看种子所需的水量和矿物质含量。
2. 在水培系统中插入电池，并在容器槽中放入水。《水培手册》建议使用幽灵水或基础水，品质较高的水可以留作出售。
3. 加入矿物质或营养片。浓度已经偏高时，继续添加只会使情况恶化。
4. 放入种子后过夜。新手可以种植营养果（Nutrifruit），一到两天即可收获。
5. 每晚检查生长进度、水量和电量，及时补充不足的部分。
6. 界面提示可以收获时再进行收获。收获的果实不一定能用作种子，需要预留购买种子的资金。

（六）熔炉冶炼

1. 插入电池，熔炉每晚消耗 8 点电量。
2. 放入 2 份原料，可以是废料或金属矿石，过一夜后产出 1 块金属锭。
3. 金属锭的纯度取决于原料搭配：2 份废料为低纯度，1 份废料加 1 份矿石为一般纯度，2 份矿石为高纯度。
4. 加入一份助熔剂，纯度提升一级。熔炉品质达到 +100% 后，助熔剂不再消耗。
5. 品质模块每满 100% 提升一级纯度，99% 不计入；效率每满 12.5% 增减 1 点耗电；性能模块对熔炉无效。
6. 特殊模块中，爆破模块可以用 3 份原料产出 2 块金属锭；废料处理模块可以把 6 份垃圾转化为 4 份废金属。

（七）化学加工

化学机器需要按顺序使用：先后经过搅拌机、加热板和蒸发器，最后在化学精制机中选择配方成型，每一步的产物都可以用光谱仪检查。具体配比以游戏内配方书为准，本手册不展开介绍。成型失败时，先检查容器中的液体是否已经完全蒸干、配方是否选择正确。

三、游戏概况

游戏的核心循环是收货、验货、议价和出售，玩家用经营所得按周缴纳租金，最终目标是买下店铺。游戏中的各项系统都围绕每周日的租金展开。

图 3 每周的经营循环。加工是可选环节，单纯倒卖可以从议价直接进入出售；缴纳租金后仍有结余，才有可能买下店铺。

游戏的世界观设定较为简单。故事发生在一座按贫富分层的巨型空间站，上层住着精英，下层是艰难求生的普通人。玩家原本是一名拾荒者，靠一笔贷款在下层租下一间店铺。来到柜台前的，可能是钓鱼执法的治安员、寻找筹码的反抗军、家道中落的上层精英，也可能是被失控 AI 芯片控制、外表与常人无异的“改造体”。

四、九种开局与流派

游戏共有 9 种开局，每种开局附带一套起始装备，对应一条盈利路线和一类专属问题：经营武器会引来安检，经营化学品会使顾客成瘾，经营水需要承担质量责任，经营违禁品可能遭到查抄。

图 4 开局货物与对应风险。选择开局，也就选择了要承担的风险类型。

（一）九种开局一览

（二）开局只决定初期的经营方向

起始装备只决定第一周的经营内容。进入中期后，玩家可以通过乔·王尔德（Joe Wild）的人脉网络解锁“退休水商”“退休养鱼人”等渠道，购买其他行业的设备和货源。社区中“化学家开局”“鉴定流”“水培流”等说法，指的是玩家的主要收入来源。

（三）难度与开局分开选择

游戏设有 4 档难度，与开局分开选择。困难模式取消零售加价和租金宽限期，部分服务价格更高，租金涨幅翻倍。谷底开局可以与高难度叠加，是难度最高的玩法。此外还有无尽模式，剧情节奏会相应改变。

（四）开局特性（Perks）按点数选择

开局时可以用点数选择特性。选择正面特性会消耗点数，选择负面特性则会增加可用点数。下表为社区记录的试玩版数值，正式版新增了部分特性，具体以游戏内为准。试玩版最多可使用 3 点、选择 4 个特性。

新手常用的搭配是“存款 + 警觉”，开局资金充足，夜间也不会丢失货物。负面特性换来的点数，往往要用每周的持续成本抵偿。

五、道具图鉴

道具分为五类：鉴定工具、制水设备、生产设备、养殖设备、安保与走私设备。几乎所有机器都需要插入电池才能运转，并且可以安装模块，模块分为品质、性能、效率三种属性。价格以信用点计，数据来自 1.0.0.2 版补丁和社区实测，后续可能调整。本节插图为示意画，并非游戏原画。

（一）鉴定工具

图 5 鉴定工具。从左到右依次为：放大镜对照烟盒、鉴定手册与色卡、紫外滤镜照出的隐藏标记、工具箱。

（二）制水设备

图 6 制水设备。从左到右依次为：水瓶与试纸、湿气农场、多级净水器、瓶子打印机。

（三）生产设备

图 7 生产设备。从左到右依次为：熔炉与金属锭、加热板与化学精制机、水培系统、电池与 Powerbloc。

（四）养殖设备

图 8 养殖设备。从左到右依次为：动物笼、基因扫描仪、循环水鱼缸、带焚化炉的清洁机器人。

（五）安保与走私设备

图 9 安保与走私设备。从左到右依次为：地板下的走私暗格、海报后的藏货格、警报系统、幻影投影仪。

六、经营规则与风险

（一）收货之前必须验货

验货是当铺经营的基础。卖家常常夸大物品的价值，违禁品的问题往往在钱货两清之后才会暴露。鉴定流程如下：用放大镜对照手册找出具体破绽，在验货栏中选择对应的理由，再点击“对质”。指认错误会损失声望，甚至导致交易直接失败。连续完成 10 次完美鉴定，可以获得成就“鉴定眼”。

部分顾客只是前来估价。玩家查看物品后，通过估价服务发出一张报价单即可。

（二）议价影响声望，吸引力决定客流

每次讨价还价都会付出代价：压价幅度越大，获得的声望越少。买入和卖出两个方向的声望倍率分别计算。

每天的随机顾客最多 4 位。店铺吸引力达到 200、250、400 时，各增加 1 位顾客；前一晚外出拾荒，次日会减少 1 位。展示柜中陈列的货物决定了来访的买家类型：想清理库存，就陈列准备出售的那类货物；想收购原料，就挂出对应的招牌。

（三）租金逐周上涨，买下店铺即可通关

无论当周经营状况如何，租金都会持续上涨。拖欠租金会降低店铺吸引力，导致顾客减少、收入下降，资金缺口随之扩大。买下店铺是游戏的正式结局，在第 50 天前买下还可以获得成就“惊人的经营手腕”；全程不出售赃物和违禁品而通关，可以获得成就“两袖清风”。成就名称均为意译，以游戏内中文为准。

（四）违法交易会留下证据并引发调查

违法交易会留下证据，证据会推高“嫌疑犯罪等级”，等级达到一定程度后，治安部会立案调查。调查结束后的第二天早上，警官会上门，根据玩家当时的犯罪记录决定罚款还是逮捕。犯罪记录每晚会自然衰减。

图 10 治安调查流程。警官上门前的最后一夜最为关键。只要犯罪记录在警官到达前降至罚款区间，就只会罚款，不会被逮捕。

玩家也可以选择守法经营，举报携带赃物的小偷和携带违禁品的顾客，或者打电话约通缉犯前来送货，再由治安部实施抓捕，从而领取赏金。

（五）改造体可以通过外貌和言行识别

一枚具有自我意识的 AI 芯片失控后控制了宿主。各派系一致同意对改造体就地击毙，柜台下备有一把枪。治安部的识别指南列出了以下信号：

误杀正常顾客和放走改造体都会带来损失。困难模式下放走的改造体过多，会进入“被改造”的失败结局。部分关键常驻顾客无法被射击。

（六）声望分属五个派系

界面上显示五个派系的声望：下层区、上层区、治安、黑市、革命。声望能够带来渠道和保护，也会让玩家成为攻击目标。治安声望高时，检查次数减少，举报赏金增加；黑市声望高时，黑市商人和地下交易所才会开放，小偷带来的货物也会增多。

（七）成瘾带来回购，过量导致中毒

出售带有“快感”效果的物品后，顾客第二天可能回来购买同样的商品，带来额外收入。但如果单件物品超过毒性阈值，回购的概率就会变为“险些致死”的概率，随之而来的是退款和声望损失。具体数值比例可参考社区攻略。

七、游戏机制背后的现实科学

本作的许多机制在现实中都有依据。

（一）封闭空间站依赖水的循环回收

游戏中的水分为六个等级，从纯净水到下水道水。现实中的空间站同样珍视每一滴水。2023 年，NASA 宣布国际空间站的环境控制与生命保障系统已经能够回收约 98% 的水，每名宇航员每天的用水量约为一加仑（约 3.8 升）。尿液通过真空蒸馏回收，剩余的浓盐水再由新增的盐水处理装置提取最后的水分，回收率由此从 93%–94% 提高到 98%。

图 11 六级水质。等级划分来自游戏中的《水贸易手册》。湿气农场产出的是幽灵水，需要经过过滤和净化，才能以较高的价格出售。

在封闭的空间站中，水主要依靠循环回收获得，掌握净化设备就意味着掌握了生存的关键。游戏把售水设计成责任重大的行业，这一设定符合现实逻辑。

（二）湿气农场的原理是大气取水

湿气农场在夜间从潮湿空气中取水。现实中，这种技术称为大气取水：把空气冷却到露点以下，水蒸气就会凝结成液态水，原理与空调滴水相同。国际空间站的除湿装置承担的正是这项工作，它收集宇航员呼吸和出汗产生的水汽，再送去净化。下层区人口密集，空气湿度较高，取水设备正好适用。

（三）紫外消毒与过滤分工不同

游戏中先用紫外线照射，再倒进水罐过滤，出水量略多。现实中两者的分工不同：紫外线破坏微生物的 DNA，使其无法繁殖，但对重金属和化学物没有作用；过滤和吸附负责去除颗粒物和部分化学污染物。现实中通常先过滤再进行紫外消毒，因为浑水中的颗粒会遮挡紫外线，使藏在颗粒后方的细菌得以存活。

（四）纯度越高，净化速度越慢

根据社区实测，某类污染物浓度高于 50% 时，净水器一天能去除几十毫升；浓度降到 4% 以下，一天只能去除几毫升。每种污染物还有一条去除不了的底线，只有装上高品质模块才能继续降低。

现实中的净化过程也有同样的规律。污染物越少，被过滤材料捕获的机会就越小，去除速度大致与剩余浓度成正比。所以把水从 98% 提纯到 99%，比从 90% 提纯到 98% 更难。现实中，反渗透、离子交换、蒸馏分别针对不同类型的污染物，制取超纯水需要多级串联处理。游戏中的纯净水（99.9% 以上）售价较高，原因也在于此。

（五）助熔剂能够提高金属纯度

游戏中加入助熔剂，金属锭的纯度会提升一级。现实中的冶炼同样离不开助熔剂，例如炼铁使用的石灰石。助熔剂与矿石中的杂质和氧化物结合，形成熔渣；熔渣比金属轻，会浮在表面并被撇除，留下的金属因此更纯。游戏中用废料炼出的金属锭纯度较低，用矿石炼出的纯度较高，这也符合现实，因为回收材料中混有涂层、焊料和其他合金。

（六）水培种植不需要土壤

水培系统需要加水和矿物质。植物生长真正依赖的是水中的氮、磷、钾等矿物营养和根部的氧气，土壤只起承载作用。《水培手册》建议用幽灵水或基础水进行水培，避免用饮用水浇灌作物，这一做法与现实中的分级用水相似。国际空间站在用 Veggie 等装置试种生菜，目的同样是减少太空基地对补给的依赖。

（七）用鼠肉喂鼠会引发朊病毒病

这是游戏中最具科学性的一处细节。把鼠肉放进喂食器喂给老鼠，会使老鼠感染朊病毒病。

这一设定与现实完全一致。朊病毒是错误折叠的蛋白质，会诱导正常蛋白发生同样的错误折叠。英国 1980 年代的疯牛病，起因就是用含有病牛、病羊残骸的肉骨粉喂牛，禁用这类饲料后疫情才逐渐消退。巴布亚新几内亚的库鲁病，则与当地在丧葬中食用亡者的习俗有关。游戏中只有点击“清空”才能切断感染源，这一点也很写实。

（八）选育遵循孟德尔遗传规律

基因扫描仪会显示老鼠每项性状的两个等位基因值。两只均为“一优一劣”（G/x）的老鼠交配，后代获得两个优良基因（G/G）的概率为 1/4；三项性状同时纯合的概率为 1/4 × 1/4 × 1/4 = 1/64。因此，有经验的玩家每次只改良一项性状，留好种鼠后再推进下一项，这与现实育种中的“回交”和“保种”相对应。

图 12 单一性状的遗传概率。每次只改良一项性状，四分之一的概率已经足够高；同时追求三项性状，平均每 64 只后代中才会出现一只。以上结果基于概率独立、不考虑突变的理想模型。

（九）鱼缸依靠氮循环净化水质

养鱼需要持续关注水质和过滤。现实中，循环水养殖系统（RAS）的核心是一座看不见的微生物工厂：鱼类排出的氨具有毒性，硝化细菌先把氨转化为亚硝酸盐，再转化为毒性低得多的硝酸盐，最后通过换水或植物吸收移出水体。过滤器除了拦截残渣，还是这些细菌的栖息地。新缸一次放入过多的鱼，细菌尚未繁殖起来，氨就会使鱼中毒死亡。

图 13 鱼缸中的氮循环。过滤器中的两类细菌承担了鱼缸的主要净化工作。

（十）香烟手册的检查项目对应真实的防伪手段

游戏中的香烟手册包含四项检查：字体、Logo、颜色和防伪封条。现实中的烟草和药品防伪也采用这几种手段：特殊字体和微缩文字难以仿制，专色油墨需要对照标准色卡，防伪封条和税票带有全息图案或紫外荧光图案。游戏中的紫外滤镜，对应的就是验钞灯的原理。

（十一）柠檬市场理论解释了鉴定的价值

经济学家阿克洛夫在 1970 年提出“柠檬市场”理论：买家无法分辨商品好坏时，只愿意按平均质量出价，优质商品的卖家随之退出，市场上最终只剩下次品。游戏中的整个下层区就是一个柠檬市场。玩家的鉴定能力越强，越能低价收进好货、拒绝假货，利润来自信息差。反过来，玩家给假货贴上真标签卖给上层精英，同样是在利用对方的信息劣势。

（十二）改造体的设计借用了恐怖谷效应

识别改造体的信号，例如表情诡异、异常静止、措辞过分书面等，对应机器人学家森政弘在 1970 年提出的“恐怖谷”理论：外形越接近人类却仍有细微差异的事物，越容易让人感到不安。游戏中的盘问类似一场反向的图灵测试，玩家要判断的是眼前的人是否像机器。

（十三）剂量决定毒性

化学加工中的“快感值”和“毒性阈值”，对应药理学的经典原则：剂量决定毒性。同一种物质，用量低于某个限度时是商品，超过限度就会酿成事故。游戏把这一原则直接设计成经营风险，药效越强的商品，越容易招来退款和死亡通知。

过去，监管提出的问题是：“孩子看到了什么内容”。现如今，则还要叩问：“如何判断用户年龄、家长有哪些管理权限、产品默认开启哪些设置”，以及“这些责任应由操作系统、应用商店还是 App 承担”。从澳大利亚的 16 岁社媒禁令、英国《在线安全法》的儿童保护准则，到欧盟 DSA 第 28 条指南、美国各州的应用商店法和巴西的 ECA Digital，相关规则在 2025 至 2027 年间陆续出台或生效，便是这一转向的体现。

这些规则各有侧重，却也有不少相通之处。本文尝试将它们放在同一框架下梳理：先区分几种主要的监管思路，再将具体义务拆解为六个可落地的模块，逐项比较主要国家和地区的要求。在此基础上，进一步讨论一家业务横跨终端、操作系统、应用商店和互联网服务的公司，可以如何建立一套既能应对各地差异、又可在全球范围内复用的未成年人保护合规体系。

中国部分在 2023 年的《未成年人网络保护条例》合规亮点一文中已有过一些讨论，本文仅补充此后的配套规则与新变化。

注：文中信息截至 2026 年 10 月，各国规则仍在持续变化，需持续关注。

一、背景

（一）为什么是现在？

2024 年以来，主要国家和地区的未成年人网络保护规则进入密集落地期。下图按时间梳理了其中一些重要节点：

这些节点大多集中在 2025 年下半年至 2026 年上半年，后续还有一批规则等待落地，包括土耳其的 15 岁社交网络禁令、中国的未成年人模式国家标准、加州的操作系统年龄信号法，以及印度的儿童数据条款。

比时间上的集中更值得关注的，是监管方向的变化：各国逐渐从“发现违法内容后再删除”，转向要求企业在产品设计之初，就考虑用户年龄、默认设置和家长参与。这意味着，未成年人保护不再只是内容审核的事，也与产品如何设计、各方如何分担责任密切相关。

（二）先厘清几个概念

“未成年人”与“儿童”的年龄界限并不相同

不同法律对年龄的划分差异很大。同样是“儿童”，在一部法律中可能指不满 14 岁的人，在另一部法律中则可能涵盖所有未满 18 岁的人。开展跨国合规，首先需要厘清各个市场、各部法律的年龄界限：

这些差异会直接影响产品设计。例如，即使全球统一设置“年满 13 岁即可注册”，在中国、英国、印度、巴西等市场，获准注册的用户中仍有相当一部分属于法律保护的未成年人，企业仍需履行相应的保护义务。

对本文的年龄表述做一下统一的说明：“13 岁以下”“16 岁以下”均指未满相应年龄，不含本数，与中国法律中“以下”通常包括本数的用法不同。涉及中国法律时，沿用原文的“不满”“未满”等表述。

年龄保障的三种主要方式

“年龄保障”（age assurance）是一个统称，涵盖用于判断用户年龄或年龄区间的各类方法。常见方式主要有三种：

• 自我声明（self-declaration）：由用户自行填写出生日期，或勾选“我已满 18 岁”。这种方式成本最低，也最容易被绕过，越来越多的监管文件已明确，仅凭自我声明不足以满足相关要求。
• 年龄估算（age estimation）：根据面部特征、声音、行为数据等推测用户年龄，较常见的是面部年龄估算。这类方法提供的是估计结果，通常以年龄区间呈现，存在一定误差。
• 年龄验证（age verification）：通过身份证件、银行卡、运营商实名信息、数字身份钱包等可靠来源确认年龄或出生日期。相比前两种方式，验证通常能提供更强的年龄证明，但实施成本和个人信息保护要求也更高。

近两年，另一个值得单独讨论的概念是 年龄信号（age signal）：由操作系统或应用商店通过接口，将已确认的用户年龄区间传递给 App，减少各个 App 重复验证的需要。美国加州、犹他州、德州及巴西的新法，都在推动这一机制，本文第四部分将作专门讨论。

家长控制、儿童模式与未成年人模式

这三个概念在日常表达中经常混用，但在合规分析中需要区分：

• 家长控制（parental controls）：供家长管理孩子设备或账户的一组功能，例如限制下载、设置使用时长、过滤内容、查看使用情况等。重点在于赋予家长管理权限，通常也支持远程管理。
• 儿童模式：在设备中为孩子设置一个受限的使用空间，常见做法包括系统分身、应用白名单和数据隔离。重点在于划定孩子可以使用的范围，不一定支持家长远程管理。
• 未成年人模式：中国监管语境下的专门概念，指《移动互联网未成年人模式建设指南》所规定的，由移动智能终端、App 和应用分发平台联动实施的保护模式，并根据不同年龄段设置内容、时长等要求。

这种区分关系到企业能否准确回应法律要求。有些国家要求建立“家长控制系统”，并明确列出应具备的功能，仅提供一个儿童模式未必足够，中国的未成年人模式则有更具体的分龄要求和平台联动安排，也不能简单等同于一般的家长控制功能。

年龄分级与年龄门槛

年龄分级是标明内容或产品适合哪个年龄段，例如游戏的 PEGI 12、应用商店的 13+； 年龄门槛则是规定用户达到几岁才能使用某项服务，例如社交媒体的 16 岁使用门槛。

前者回答“适合谁使用”，后者回答“谁可以使用”。落实到产品中，两者分别对应内容标签体系和账户准入体系，需要分别设计，不能相互替代。

二、四种监管类型

将各国规则放在一起看，大致可以归纳出以下监管逻辑：按年龄设门槛、按内容定规则、按服务风险管设计。此外，还有一些国家主要通过个人信息保护法中的儿童条款，提出未成年人保护要求。

这几种逻辑并不相互排斥。英国、欧盟、澳大利亚、中国的规则中，都能看到多种逻辑并行。这里的区分，主要是为了看清各地监管的重心，以及企业需要据此建立哪些合规能力。

（一）年龄准入型

年龄准入型规则首先关注的是：用户是否达到使用某项服务的年龄。

澳大利亚是典型例子。自 2025 年 12 月 10 日起，被认定为“受年龄限制的社交媒体平台”的服务，须采取合理步骤，防止 16 岁以下的澳大利亚用户持有账户。土耳其修订后的第 5651 号法则自 2026 年 11 月 1 日起，禁止社交网络向 15 岁以下用户提供服务。

越南采取了不同的安排。第 147/2024/ND-CP 号法令第 27 条规定，16 岁以下儿童的社交网络账户，应由父母或监护人使用自己的信息注册；2026 年 7 月 1 日起施行的新《网络安全法》，又将这一要求扩展至网络空间的增值服务。中国对网络游戏的时段限制，也体现了按年龄限制服务使用的思路：未成年人只能在周五、周六、周日和法定节假日的 20 时至 21 时使用网络游戏服务。

这类规则对应的合规工作相对集中：在注册或首次使用时识别年龄，完成符合监管要求的核验，再根据适用规则限制使用，或进入家长同意流程。其中的难点是，年龄究竟要核实到什么程度，才足以满足要求。第三部分的年龄保障模块将进一步讨论这一问题。

（二）内容监管型

这类规则以内容本身为出发点，关注哪些信息适合向儿童提供，以及应如何限制不适宜内容的传播。

俄罗斯第 436-FZ 号联邦法要求信息产品按照 0+、6+、12+、16+、18+ 进行分级标识，并限制向儿童传播特定类别的信息。日本《青少年网络环境整备法》要求移动运营商为未满 18 岁的用户提供过滤服务，终端厂商也需预装过滤软件，或为其启用提供便利。韩国同样要求为青少年使用的手机提供有害信息拦截手段。

这类规则对视频、游戏、阅读、应用分发等业务的影响尤为直接。企业需要为相关内容建立分级或标签，并在分发和展示环节，根据用户年龄进行过滤或限制访问。其工作量往往随内容规模增长，合规重点也较为明确：内容如何分类，标签是否准确，访问限制能否落实。

（三）服务风险型

这类规则关注儿童在使用服务的整个过程中可能遇到的风险，要求企业主动识别、评估，并通过产品设计降低风险。

英国《在线安全法》要求可能被儿童访问的服务开展儿童风险评估，并按照 Ofcom 的儿童保护准则采取相应措施。欧盟 DSA 第 28 条要求可被未成年人访问的在线平台确保“高水平的隐私、安全和安保”；欧盟委员会于 2025 年 7 月发布的指南，进一步将其细化为默认设置、推荐系统、商业行为、家长工具等方面的要求。英国 ICO 的《适龄设计准则》、印尼的 PP TUNAS、巴西的 ECA Digital，也体现了这一监管思路。

这类规则通常涉及更广泛的产品改造。企业需要逐项审视注册流程、默认隐私设置、推荐算法、陌生人私信、直播、虚拟货币与开宝箱机制，以及推送、自动连播等功能，判断它们可能给儿童带来什么风险，并采取相应措施。新增功能或重大调整，也需要纳入评估。未成年人保护由此成为产品开发和运营中的持续工作。

（四）隐私驱动型

还有一些国家，主要依靠个人信息保护法律中的儿童条款，规范企业与未成年用户之间的关系。

美国联邦层面是典型例子。在缺少综合性未成年人网络保护立法的情况下，1998 年制定的 COPPA 是核心依据，主要规范面向 13 岁以下儿童的网站和在线服务收集、使用儿童个人信息的活动。印度《数字个人数据保护法》（DPDP Act）则将 18 岁以下的人视为儿童，要求处理其数据前取得可验证的家长同意，并禁止追踪、行为监控和面向儿童的定向广告。

这类规则虽然从数据处理切入，影响却会延伸到产品的多个环节。取得“可验证的家长同意”，通常需要先识别用户年龄，并确认家长身份；限制画像和定向广告，则可能要求企业调整推荐与广告系统。因此，隐私驱动型规则涉及的产品改造，未必比服务风险型少。

三、六大核心模块

落实到产品上，各国的要求大致可以拆分为六个模块：年龄保障、家长控制与安全模式、年龄门槛、儿童隐私、年龄分级、内容过滤。前两个模块是各项业务共用的基础能力，后四个模块则需要结合业务特点和风险分别配置。第七部分会进一步解释这一划分。

下面逐一讨论。每个模块先说明要解决的问题，再比较主要国家和地区的规则，最后归纳落地要点。

（一）年龄保障：如何知道用户几岁

年龄保障要解决两个问题：用户多大，以及这一判断有多可靠。其他五个模块都不同程度地依赖它——无论是设置使用门槛、保护儿童隐私，还是按年龄分级和过滤内容，都需要先判断用户所属的年龄段。

仅凭自我声明已难以满足主要市场的要求

让用户勾选“我已满 18 岁”，或自行填写出生日期，曾是最常见的年龄识别方式。如今，主要市场的规则和监管文件越来越明确：在需要可靠识别年龄的场景下，仅凭用户自报并不足够。

欧盟指南的表述很直接：

Guidelines on measures to ensure a high level of privacy, safety and security for minors online, para. 52（节选）
self-declaration does not meet all the requirements above, in particular the requirement for robustness and accuracy
自我声明并不满足上述全部要求，尤其不满足稳健性和准确性要求。

执法也已经在跟进。欧盟委员会于 2026 年 3 月初步认定，四家色情平台采用的自我声明、模糊处理和警示提示等措施均未奏效；4 月，又初步认定 Meta 未能有效阻止 13 岁以下用户使用服务，其中一个问题就是注册时仅由用户自填出生日期，缺少核验。

英国 ICO 于 2026 年 2 月对 Reddit 处以 1447 万英镑罚款，理由之一是其在 2025 年 7 月以前未采取任何年龄核验措施，而 2024 年约有 22.6 万名 13 岁以下的英国用户使用该平台。印尼主管部门在新规实施后披露的数据则更为直观：每五名儿童中，就有三名谎报年龄。

美国更多通过个案提出具体要求。FTC 于 2024 年 7 月针对匿名社交应用 NGL 作出的命令，直接禁止其向 18 岁以下用户提供服务，并要求以中立方式询问年龄，不得暗示用户填写多大年龄才能使用。

核验强度应与风险相称

自我声明不足以满足要求，并不意味着所有服务都要查验身份证件。主要监管框架采取的是按风险分层的思路：风险越高，对年龄判断可靠性的要求就越高。

英国法尤其强调核验的实际效果。采用某种验证或估算方法，只是起点；方法本身及其使用方式，还必须足以准确识别儿童：

Online Safety Act 2023, s.12(6)（节选）
the age verification or age estimation must be of such a kind, and used in such a way, that it is highly effective at correctly determining whether or not a particular user is a child.
年龄验证或年龄估算所采用的方法及其使用方式，必须能够高度有效地准确判断某一用户是否为儿童。

实际效果

英国是目前公开数据较多的市场。Ofcom 于 2026 年 7 月发布的法定报告显示，2025 年下半年，32 个服务共完成约 6900 万次年龄核验，是上半年的 23 倍；色情网站的核验中，68% 采用面部年龄估算。在被要求核验年龄的儿童中，遇到自我声明以外核验方式的比例，也从 2025 年 7 月的 25%，升至 2026 年 1 月的 43%。

这些数据说明，年龄核验正在从形式要求转为实际操作，但绕过措施的情况仍然存在。同一份报告显示，5% 的 11—17 岁儿童表示，自己在过去半年中曾使用 VPN 访问受限内容。报告还特别提醒，平台基于行为数据进行的“年龄推断”，并不在高度有效的方法清单中；平台需要证明其有效性，否则就应更换方法。

澳大利亚的年龄保障技术试验于 2025 年 9 月发布最终报告，测试了 48 家厂商的 60 多项技术。报告认为，年龄保障可以兼顾隐私、稳健性与有效性，不存在重大的技术障碍；但没有一种方法适用于所有场景，更可行的做法是组合使用，并根据需要逐步提高核验强度。

年龄估算的误差，正好说明了为什么需要这种组合。澳大利亚试验中，表现最好的面部年龄估算技术，平均绝对误差为 1.3—1.5 岁；但在年龄门槛上下约 2—3 岁的范围内，判断仍不够可靠。以 13 岁为门槛时，真实年龄为 13 岁的儿童中，有 22% 被误判为未满 13 岁；真实年龄为 15 岁时，这一比例降至 6%。

美国 NIST 2024 年的评测也显示，表现最好的算法在签证照片上的平均误差约为 3.1 岁，女性的误差普遍更高。因此，当估算结果接近年龄门槛时，有必要再用另一种方式确认，而不能仅凭一次估算作出决定。

图的上半部分呈现试验数据：越接近年龄门槛，误判越多。下半部分则将这一发现转化为核验流程：估算结果远离门槛时，可以直接采用；接近门槛时，再通过另一种方法确认，最终在系统中仅保留必要的判断结果。

相关技术标准也在逐步完善。2025 年 12 月发布的 ISO/IEC 27566-1:2025《年龄保障系统 第 1 部分：框架》，区分了年龄验证、年龄估算和年龄推断；IEEE 2089.1-2024 则专门针对在线年龄验证。这些标准可以作为企业评估供应商和技术方案的参照。

核验本身也是个人信息处理

提高核验可靠性，往往意味着需要处理更多、甚至更敏感的个人信息。如何在确认年龄的同时避免过度收集，是各国共同面对的问题。目前的应对方式，大致有以下四种。

第一，只传递结论。欧盟年龄验证蓝图的思路是，用户先通过护照、身份证等可信来源完成验证，之后仅向网站证明“已满 18 岁”，网站无需获取其姓名和出生日期。

该蓝图于 2025 年 7 月发布首版，并在部分成员国试点；2026 年 1 月和 7 月，安卓和 iOS 版本先后加入零知识证明。2026 年 4 月，欧盟委员会发布建议（Recommendation (EU) 2026/1035），请成员国在 2026 年 12 月 31 日前至少提供一种年龄验证方案，既可以纳入欧盟数字身份钱包，也可以采用独立 App 的形式。

法国和意大利对色情网站的年龄验证，还要求实现“双重匿名”：出具年龄证明的一方不知道用户要访问哪个网站，网站也不知道用户的身份。

土耳其同样采用只传递结论的方式。社交网络通过电子政务平台 e-Devlet 的令牌核验年龄，平台获得的仅是用户是否已满 15 岁、是否已满 18 岁的结果。

第二，限制留存和传递的数据。澳大利亚社媒禁令要求核验信息在使用后销毁；巴西则要求，操作系统和应用商店发出的年龄信号不得包含出生日期、身份和画像数据。两者着眼点不同，但都在减少年龄核验带来的额外信息处理。

第三，为核验所必需的信息收集作出专门安排。COPPA 原则上要求企业先取得家长同意，再收集儿童个人信息。这就带来一个程序上的难题：为判断是否需要家长同意，企业可能需要先收集信息核验年龄。

FTC 于 2026 年 2 月发布政策声明，对面向一般受众或混合受众的运营者作出安排：仅为核验年龄而收集信息，且满足六项条件的，FTC 将不采取执法行动。这六项条件包括：信息仅用于核验、使用后删除；交由第三方处理前，须完成审查并取得删除承诺；在隐私政策中告知相关处理；采取合理的安全措施；核验方法合理、准确。

第四，明确年龄保障应遵守的基本原则。EDPB 于 2025 年 2 月发布的《年龄保障声明》提出十项原则，包括措施应与风险相称、不得借年龄保障进行画像或追踪，以及遵守数据最小化要求。这些原则为技术选择和流程设计划定了边界。

落地要点

• 需要用户申报年龄时，用出生日期替代简单勾选。出生日期可以随时间换算用户所属的年龄段，单次勾选则难以支持后续调整。但自行填写出生日期仍属于自我声明，不能因此视为已完成可靠核验。
• 按风险配置核验方法。一般功能可结合账户信号或年龄估算；成人内容及受年龄门槛限制的服务，则需配置更可靠的验证方式。同时，为每个市场维护可用方法清单，确保技术方案符合当地要求。
• 提供替代方式和申诉渠道。欧盟指南要求提供不止一种方法，并允许用户申诉；澳大利亚要求在政府证件核验之外提供替代方式。产品流程需要同时考虑无法使用某种方法和被误判的用户。
• 仅保留必要的核验结论。原始证件和人脸图像在使用后删除，系统中仅保留年龄段、核验方式等必要记录，减少长期保存敏感信息带来的风险。
• 将防绕过纳入流程设计。澳大利亚 eSafety 在执法中指出的问题，包括允许用户反复重试年龄检测。多账户注册、借用家长账户等情况，也应纳入考虑。
• 为措施的有效性留存依据。采用某种方法的理由、准确率测试结果，以及误判和申诉数据，都是日后说明措施为何“合理”、是否“高度有效”的重要证据。

（二）家长控制与安全模式

这个模块要解决两件事：让家长能够参与、管理孩子的使用，同时确保即使家长没有主动设置，未成年人账户也处于较为安全的默认状态。前者通常称为“家长控制”，后者则体现为“安全模式”或安全的默认设置。

设备和系统层：欧洲多国将义务直接落实到厂商

在欧洲，越来越多的规则要求设备制造商和操作系统提供者直接提供家长控制功能，让家长在设备启用时就能找到并使用这些工具。

德国的一项规定，对安卓手机厂商尤其值得关注：

JMStV § 12 Abs. 1 Satz 2
Passt ein Dritter die vom Anbieter des Betriebssystems bereitgestellte Jugendschutzvorrichtung an, besteht die Pflicht aus Satz 1 insoweit bei diesem Dritten.
第三方改造操作系统提供者所提供的青少年保护装置的，第 1 句规定的义务，在其改造范围内由该第三方承担。

这意味着，如果厂商改造了谷歌提供的保护装置，就需要对改造范围内的合规承担责任。

几国之间还有一个容易忽略的区别：法国和德国要求在首次开机或首次设置时， 提示用户启用家长控制，并不要求默认开启；西班牙草案则要求在初始设置时 默认启用。对此，有议会党团提出修正，主张改为“提供”即可，理由是没有自有操作系统的厂商，未必能够控制相关设置。

法国的规则已经进入执法阶段。主管机关 ANFR 于 2026 年 6 月发布的抽检报告覆盖 19 台设备，已结案的 11 件中，有 4 件不符合要求。其中，iPhone 16 和 Pixel 9 在为 15 岁以上未成年人设置用户资料时，没有提示启用家长控制，相关问题已在 iOS 26 和 Android 16 中修复；另外两件涉及技术文档。报告显示，其中 2 件已被催告并启动罚款程序，ANFR 还建议提高罚款额度。此前，游戏发行商协会曾请求撤销这部实施细则，法国最高行政法院于 2024 年 7 月驳回了该请求。

服务和网络层：平台与运营商也有各自的义务

设备之外，平台和网络服务提供者同样需要提供家长管理工具，具体功能则因市场而异。

• 爱尔兰：《在线安全准则》第 14 节要求，允许 16 岁以下用户使用的视频分享平台，应在注册时提供家长控制，至少涵盖陌生人互动限制、有害内容和广告限制，以及观看时长设置。这部分要求自 2025 年 7 月 21 日起适用，最高可罚 2000 万欧元或营业额的 10%。监管机构于 2026 年 9 月对 X 启动了首起正式调查。
• 巴西：ECA Digital 要求，16 岁以下用户的社交网络账户应关联监护人账户，应用商店和操作系统也须提供家长监督设置。第 18 条详细列举了工具应具备的功能：查看、配置和管理孩子的账户及隐私设置；限制购买和金融交易；识别与孩子交流的成年人账户；汇总使用时长；开启或关闭各项保护措施；提供葡萄牙语界面。工具启用时，还须有清晰可见的提示（第 17 条）。
• 土耳其：修订后的第 5651 号法自 2026 年 11 月 1 日起，要求社交网络提供家长工具，支持管理账户设置、审批付费交易，以及查看和限制使用时长。实施条例进一步加入消费限额和位置共享功能。游戏平台的要求相对有限，主要包括年龄分级、家长管理账户设置，以及购买和付费会员须经家长许可。
• 阿联酋：平台须提供家长控制功能，包括每日使用时长管理和强制休息。
• 意大利：AGCOM 第 9/23/CONS 号决定要求互联网接入服务提供者免费提供家长控制；面向未成年人的套餐，须预装并开启相关功能。该要求自 2023 年 11 月 21 日起适用。
• 墨西哥：2025 年的新《电信与广播法》第 191 条要求，运营商应用户请求屏蔽内容、应用或服务，并向提出要求的用户提供家长控制服务。2026 年 10 月 14 日公布并于当日施行的总统令，又要求社交网络、游戏、应用商店等数字平台向家长提供监督工具。
• 中国：未成年人模式本身包含家长管理功能。家长可以查看使用情况、调整默认设置，退出未成年人模式须经家长验证。

家长工具不能替代平台自身的保护义务

欧盟 DSA 指南第 80 段明确指出，家长工具属于补充措施，平台不能仅靠这些工具履行第 28 条规定的义务。

指南也对工具本身提出了要求：第 81 段要求家长工具能够跨设备、跨操作系统使用，并在启用时清楚告知未成年人本人；第 82 段列举的功能包括管理默认设置、设定屏幕时间、查看孩子与哪些账户互动、管理账户设置，以及设定默认消费上限。2026 年 7 月，欧盟委员会初步认定 Meta 旗下 Instagram 和 Facebook 存在成瘾设计及家长控制不足的问题，也将产品设计与家长工具一并纳入审视。

英国 ICO 则提醒，家长控制本身也会涉及孩子的隐私。《适龄设计准则》要求，以适合儿童年龄的方式告知家长控制的存在；儿童受到监控或定位时，应有明显提示。

家长获得管理权限的同时，孩子也应知道这些权限何时、以何种方式被使用。

默认安全：家长没有操作时，产品如何保护儿童

默认设置决定了未成年人在没有主动调整、家长也未介入时，会处于怎样的使用环境。各地规则正逐步将这种初始状态纳入要求。

• 欧盟：DSA 指南第 57、61 段建议，未成年人账户默认只能与已接受的账户互动，定位、摄像头、自动播放、睡眠时段推送和账户推荐等功能默认关闭，并避免无限滚动和人为制造的通知。欧盟委员会于 2026 年 2 月初步认定 TikTok 的成瘾设计违反 DSA，KIDS Act 提案也拟禁止成瘾设计。
• 英国：政府于 2026 年 7 月发布的最终回应提出，16—17 岁用户默认在 0 时至 6 时受到访问限制，推送同时静音；自动播放和个性化信息流默认关闭，用户本人可以修改。相关条例计划于 2026 年底前提交议会。
• 中国：每日 22 时至次日 6 时，终端默认不向未成年人提供服务；App 默认关闭陌生人私信。
• 墨西哥：2026 年 10 月的总统令要求，新账户默认采用最严格的隐私和安全设置，并在产品设计阶段纳入安全考量。
• 马来西亚：据律所对《儿童保护守则》的概述，相关要求包括默认采用最高或适龄的隐私设置、默认开启安全搜索、限制无关成年人直接联系儿童，以及限制操纵性设计。
• 埃及：13 岁至未满 15 岁的用户账户须强制开启安全模式，儿童本人无法关闭。
• 美国：目前没有统一立法，具体的默认设置要求主要见于诉讼和和解。2026 年 8 月，Meta 与多州检察长达成和解，加州检察长公布的金额为十年内最高 170 亿美元。Meta 承诺，18 岁以下用户默认每日使用上限为两小时，且只有家长可以解除；0 时至 6 时限制访问，上学时段不推送，隐藏点赞数，并识别和清退 13 岁以下用户。更早的 2022 年，Epic Games 因《堡垒之夜》对儿童默认开启语音和文字聊天等问题，被处以 2.75 亿美元的 COPPA 罚款，另须退款 2.45 亿美元。
  美国相关诉讼的关注点，也已延伸至产品设计本身。2026 年 3 月，洛杉矶高等法院审理的首个“社交媒体青少年成瘾”陪审团案件（K.G.M. 案），认定 Meta 和 YouTube 的设计存在过失，判赔 600 万美元。同月，新墨西哥州陪审团认定 Meta 在儿童安全问题上误导公众，判决其支付 3.75 亿美元；8 月，法官又判令其出资 5.67 亿美元，设立青少年损害消减基金。Meta 均表示将提起上诉。

这些案件值得关注的，除了赔偿金额，还有其责任认定思路：产品设计本身可能成为过失判断的对象。对于面向青少年的产品，这意味着默认设置、互动机制和使用时长安排，都可能受到独立审视。

落地要点

• 对照各地功能要求逐项核查。法国规定了最低功能，德国列明浏览器、应用安装和应用使用三类限制，爱尔兰要求覆盖陌生人互动、有害内容、广告和时长管理，巴西则列出六项功能。仅有一个名为“家长控制”的入口，并不足以说明已满足要求。
• 在首次设置流程中落实提示或默认启用。具体采用哪种方式，应按市场要求配置。法国 ANFR 抽检发现的问题，正出在这一环节，尤其需要覆盖不同年龄段的未成年用户。
• 确保相关功能免费。法国、意大利及西班牙草案均有明确要求，应在功能设计和收费安排中一并落实。
• 让系统设置能够在 App 中生效。德国要求 App 考虑系统的年龄设定，欧盟指南要求家长工具跨设备、跨操作系统可用。系统、应用商店与 App 之间，需要有相应的衔接机制。
• 改造系统保护组件前，先评估责任变化。在德国，第三方改造操作系统提供者的保护装置后，须承担改造范围内的义务。基于系统级方案进行定制的厂商，应在改造前明确责任，并验证改造后的功能是否仍符合要求。
• 限制家长控制数据的用途。法国、意大利均对相关数据用于商业目的或画像作出限制，应在设计阶段明确数据的收集范围、用途和流转方式。
• 同时做好默认设置。家长工具是补充措施，平台自身仍须履行保护义务。即使家长没有启用工具，未成年人账户也应具备相应的默认保护。

（三）年龄门槛

这个模块要回答的是：用户是否已达到使用某项服务或功能的年龄。2025—2026 年，这方面的变化尤为明显：在部分市场，社交媒体的最低使用年龄，正从行业惯例中的 13 岁，提高到法律规定的 15 岁或 16 岁。

社交媒体最低年龄

下图将各地规则放在同一条年龄轴上：深色表示不得开户或使用，浅色表示可以有条件使用，例如取得家长同意、由家长管理，或强制开启安全模式。已经生效的门槛较多集中在 16 岁；仍处于提案或草案阶段的规则，则多采用“13 岁以下禁止、13 岁至未满 15 岁受限”的两段式安排。

这些规则背后，有三个动向值得关注。

第一，欧洲仍在协调各国立法与欧盟统一规则的关系。2025 年 10 月，25 个欧盟成员国和两个欧洲自由贸易联盟国家签署《日德兰宣言》，呼吁在欧盟层面立法。11 月，欧洲议会以 483 票赞成通过非立法性决议，建议将社交媒体、视频平台和 AI 伴侣的使用门槛设为 16 岁，13—16 岁可经家长同意使用。2026 年 7 月，欧盟委员会专家组提交了 39 条建议；9 月，委员会提出 KIDS Act。该提案不允许成员国另设更严格的门槛。如果最终按这一方向通过，法国、丹麦、希腊和西班牙各自的方案，都需要与欧盟规则重新衔接。

第二，普遍性的年龄禁令面临基本权利审查。法国宪法委员会在 2026 年 8 月 14 日作出的第 2026-911 DC 号决定中认为，不区分服务风险、也不允许家长授权解除的一般性禁令，侵害表达自由；要求成年人证明年龄，却缺少相应法律保障，也会侵害隐私。此后的新稿因此转向以“高风险功能”划定范围。美国各州的社交媒体年龄法同样持续受到诉讼挑战，执行状态随法院裁决而变化。

第三，规则能否落实，仍取决于核验和执行。截至 2025 年 12 月中旬，澳大利亚已有约 470 万个账户被删除或限制。但 eSafety 的调查也发现，一些平台允许用户反复重试年龄检测，或在注册时仍仅依赖用户自报年龄。2026 年 10 月，主管部长确认，eSafety 正准备起诉 Meta、TikTok、Snap 和谷歌。印尼新规实施后，TikTok 则停用了约 900 万个账户。

阿联酋、巴基斯坦等国也有类似的政府表态或立法动议，但官方文本。

功能级门槛：哪些功能可以开放

年龄限制也可以落实到具体功能，例如聊天、直播、游戏时长或付费交易，而不必覆盖整个服务。

• 中国：未满 16 周岁的未成年人不得注册直播发布账号（《未成年人保护法》第 76 条）；自 2026 年 9 月起，多渠道网络服务机构（MCN）也不得为未满 16 周岁者提供直播发布相关服务。网络游戏则仅可在周五、周六、周日和法定节假日的 20 时至 21 时向未成年人提供服务。
• 越南：第 147/2024/ND-CP 号法令规定，未满 18 岁的玩家，每款游戏每日使用时间不得超过 60 分钟，使用同一企业提供的所有游戏，合计每日不得超过 180 分钟；游戏中每 30 分钟须提示一次“每天玩超过 180 分钟有害健康”。
• 英国：政府拟禁止 16 岁以下用户被陌生人联系，以及使用直播功能，适用范围也包括游戏。
• 美国：Roblox 于 2026 年 4 月分别与内华达州、阿拉巴马州和西弗吉尼亚州检察长达成和解，每州金额约为 1100 万至 1220 万美元。其承诺包括，在开放聊天前进行年龄核验或面部年龄估算，16 岁以下用户只能与“可信好友”聊天。
• 印尼：为满足 PP TUNAS 的要求，Roblox 禁止 13 岁以下用户聊天，13—15 岁用户仅可与已知联系人交流。
• 法国新稿：将自动播放、无限滚动和直播列为“高风险功能”；社交网络只要具备其中一项，就纳入对 15 岁以下用户的限制范围。

将限制落实到具体功能，有助于使保护措施与风险相匹配，也更便于回应比例原则的要求，法国的调整便体现了这一思路。对企业而言，年龄判断因此需要贯穿各项功能的开放与使用，而不能只停留在注册环节。

落地要点

• 按“市场 × 服务类型 × 功能”维护门槛。仅有一张全球统一的注册年龄表，已难以覆盖不同市场对服务和功能的具体限制。
• 同时确定年龄门槛与核验强度。欧盟指南认为，法律规定最低年龄的场景，原则上应采用年龄验证，而非年龄估算。设置了门槛，还需要有相应的核验能力。
• 将存量账户纳入新法实施安排。提前规划通知、核验、转为家长管理账户或停用等流程，并提供申诉渠道。KIDS Act 提案要求在适用后六个月内核查存量账户。
• 让门槛可以配置和调整。相关规则仍在变化，法国在 2026 年内就先后提出两版方案。产品设计应预留调整空间，避免将固定年龄写死在代码中。

（四）儿童隐私

这一模块关注各地对未成年人个人信息的特别保护。即使没有综合性的未成年人网络保护立法，不少国家也会在个人信息保护法中设置儿童专门条款。因此，儿童隐私是六个模块中覆盖面最广的一项。

家长同意的年龄界限：从 13 岁到 18 岁

不同市场对儿童何时可以自行同意、何时需要家长参与，有不同规定：

欧盟 27 个成员国的数字同意年龄分布如下：

从地图上看，这一分布也呈现出一定的地域特点：北欧三国均为 13 岁，德国、荷兰、波兰、匈牙利、罗马尼亚等九国设为 16 岁，南欧则较多集中在 14 岁上下。

这里有一个常见的误读：GDPR 第 8 条规定的是儿童自行同意数据处理的年龄，并非服务的最低使用年龄。它适用于“以同意为合法性基础、直接向儿童提供信息社会服务”的情形。低于这一年龄的儿童，并不因此被禁止使用服务；但在上述情形下，处理其个人信息须取得家长同意或授权。

画像和定向广告：取得同意也未必足够

同意年龄解决的是“由谁同意”的问题。对于画像和定向广告，各地还设置了进一步限制，有些直接禁止，有些要求单独同意，或默认关闭相关功能。

• 欧盟：DSA 第 28 条第 2 款规定，平台在能够合理确定用户为未成年人时，不得向其展示基于画像的广告；AVMSD 第 6a 条也规定，为保护未成年人而收集的数据，不得用于直接营销、画像和行为定向广告。
• 印度：DPDP Act 第 9 条第 3 款禁止对儿童进行追踪、行为监控，以及向儿童投放定向广告。
• 巴西：ECA Digital 禁止通过画像向未成年人投放定向广告。
• 阿联酋：13 岁以下儿童的数据，即使经家长同意处理，也不得用于商业目的或定向广告。
• 美国：COPPA 新规要求，向第三方披露儿童信息，包括为定向广告而披露，须单独取得可验证的家长同意。
• 英国：《适龄设计准则》要求画像功能默认关闭。

印度法的表述尤为明确：

Digital Personal Data Protection Act 2023, s.9(3)
A Data Fiduciary shall not undertake tracking or behavioural monitoring of children or targeted advertising directed at children.
数据受托人不得对儿童进行追踪或行为监控，也不得向儿童投放定向广告。

这一条款及家长同意义务，将随配套规则于 2027 年 5 月 13 日生效。由于印度将所有 18 岁以下用户均纳入儿童范围，对面向大众的产品影响较大，需要提前准备。

默认设置：让隐私保护成为初始状态

英国 ICO 的《适龄设计准则》（Children’s Code）是这一领域的重要参照。它适用于所有“可能被儿童访问”的在线服务，保护范围涵盖 18 岁以下用户。其 15 项标准中，多项直接涉及产品设置：默认采用高隐私保护、遵循数据最小化原则、默认关闭定位和画像功能，不得通过助推设计诱导儿童提供不必要的数据或降低隐私保护。

其中还有一项容易被忽略的要求：提供家长控制时，应以适合儿童年龄的方式告知；儿童受到监控或定位时，应有明显提示。

其他市场也有类似要求。新加坡 PDPC 的指南一般将儿童数据视为敏感数据，建议账户默认不公开、定位默认关闭。欧盟委员会于 2026 年 7 月初步认定 TikTok 违反 DSA，问题之一就是未成年人账户可以设为公开，16—17 岁用户发布的内容会进入推荐流。

中国则将不满 14 周岁未成年人的个人信息直接列为敏感个人信息（《个人信息保护法》第 28 条），要求制定专门的处理规则（第 31 条），并每年开展合规审计。

美国 COPPA 新规则进一步补充了数据管理要求：企业须制定书面的数据保留政策，不得无限期保留信息；须建立书面的信息安全计划，至少每年评估一次；“个人信息”的定义也扩展至生物识别数据和政府证件号码。新规则于 2025 年 6 月 23 日生效，大部分条款的合规期限为 2026 年 4 月 22 日。

执法记录

落地要点

• 分别管理同意年龄和使用门槛。每个市场都应维护同意年龄表，并与服务、功能的年龄门槛表区分。用户可以使用服务，不代表其能够独立同意所有数据处理。
• 识别未成年人后，同步调整数据处理。广告系统切换为非画像广告，推荐系统提供不基于画像的选项，对外共享数据则按适用规则收紧。年龄识别结果需要在相关系统中生效。
• 以较严格的默认设置作为共同基线。账户默认不公开，定位、画像和陌生人私信默认关闭，再结合各地要求作具体调整。
• 让家长同意可验证、可留痕，也可撤回。撤回后的处理应同步至下游 App 和第三方，确保同意状态在各环节保持一致。
• 将保留期限和审计要求纳入制度。COPPA 要求书面的数据保留政策，中国要求每年开展未成年人个人信息合规审计。相关要求应落实到数据清单、保留期限及定期检查中。

（五）年龄分级

年龄分级回答的是“某个产品或内容适合多大的用户”。它与年龄门槛相互配合：门槛判断用户能否使用，分级判断产品或内容是否适龄。将用户年龄与分级结果对应起来，才能真正实现按年龄提供服务。

游戏分级

游戏是年龄分级最成熟的领域，但主要市场各有一套体系，分档标准和法律效力也不一致：有的以行业自律为主，有的则属于法定义务。

将这些体系放在同一条年龄轴上，差异就更直观：12、16、18 岁是最常见的分界线，但也有体系在 13 岁、15 岁分档，或另设 8 岁、9 岁、17 岁等档位。因此，同一产品在不同市场，未必对应相同的年龄标签。

在法定分级体系下，未按要求分级或擅自使用分级标识，都可能带来处罚。以印尼为例，IGRS 分级须经政府核验。2026 年 4 月，主管部门专门指出，Steam 上自行标注的 IGRS 并非官方分级，擅自使用可能受到行政处罚。俄罗斯的 436-FZ 则覆盖所有信息产品，要求制作方自行分类并标注，适用范围不限于游戏。

交互功能开始影响分级

传统分级主要关注暴力、性、粗口、恐怖等内容因素。如今，越来越多的体系也开始考察产品如何与用户互动，以及这些功能可能带来的风险。

• 澳大利亚：自 2024 年 9 月 22 日起，含付费随机物品（开宝箱）的游戏，最低评为 M；含模拟赌博的游戏，评为 R18+。
• 德国：2021 年修订的《青少年保护法》第 10b 条要求，定级时应考虑沟通、购买、类赌博机制及促使过度使用的机制等使用风险。
• 巴西：司法部于 2025 年 10 月发布的第 1.048/2025 号部令新增 6 岁档，并将“数字交互性”纳入分级，考察用户能否接触陌生成年人、是否存在未经授权的购买，以及是否涉及 AI 交互、算法推荐等。ECA Digital 生效后的第一个月，一批产品被上调分级：含开宝箱的 NBA 2K26、WWE 2K26、EA FC 26 升至 18 岁，Roblox、Fortnite、Free Fire 升至 16 岁，TikTok、Kwai 也升至 16 岁。

对于开宝箱，部分市场已经提出分级之外的限制。巴西 ECA Digital 第 20 条禁止向未成年人提供开宝箱，实施细则给出三种处理方式：核验年龄后屏蔽未成年人、提供不含开宝箱的版本，或默认关闭开宝箱。2026 年 10 月，司法部又发出技术说明，请 ANPD 调查六款可能让未成年人接触类赌博机制的游戏。

欧盟也在加强对游戏付费机制的监管。消费者保护合作网络（CPC）于 2025 年 3 月发布《游戏内虚拟货币关键原则》，要求标示真实货币价格，不得通过多种货币、多次兑换或礼包设计掩盖成本、迫使玩家多买，不得直接诱导儿童消费，非成人游戏应默认关闭真实货币消费。2026 年 9 月 30 日，CPC 对 King、Supercell 等九家游戏公司启动协同执法。KIDS Act 提案则要求社交网络和视频平台避免让未成年人接触开宝箱等可变奖励机制；西班牙的未成年人保护草案，也包含禁止向未成年人提供开宝箱的条款。

不过，开宝箱是否构成赌博，各国仍有不同判断。比利时博彩委员会于 2018 年认定付费开宝箱属于赌博；荷兰博彩管理局曾针对 EA《FIFA》系列的卡包下达强制金令，但荷兰国务委员会于 2022 年 3 月撤销了该命令，认为卡包是技巧类游戏的组成部分，不构成独立的赌博。

亚洲的相关执法更多从消费者保护切入。韩国公平交易委员会于 2024 年 1 月，因 Nexon 暗中调低概率型道具的概率并发布虚假公告，对其罚款 116.42 亿韩元。美国 FTC 于 2025 年针对《原神》开发商作出的命令，除禁止未经家长同意向 16 岁以下用户出售开宝箱外，还要求披露概率及多层虚拟货币的兑换比例。

分级也可能成为税收措施的依据。墨西哥于 2025 年 11 月修订《特别生产和服务税法》，对不适合 18 岁以下用户的暴力游戏征收 8% 的特别税。不过，2025 年 12 月 31 日发布的税收刺激法令又规定，自 2026 年 1 月 1 日起，不向消费者转嫁税负的，可享受全额抵免，数字服务同样适用。因此，符合条件的经营者，实际税负可被全额抵消。

让分级与用户年龄真正对应

分级标签只有在分发和使用环节发挥作用，才能实现适龄保护。各地规则正逐步要求应用商店、操作系统和服务提供者，将分级结果与用户年龄连接起来。

• 中国：《未成年人保护法》第 75 条要求网络游戏服务提供者对游戏产品进行分类、作出适龄提示，并采取技术措施，防止未成年人接触不适宜的游戏或游戏功能。《未成年人网络保护条例》第 47 条进一步要求明确产品适合的年龄阶段，在下载、注册、登录界面显著提示；《建设指南》则要求应用分发平台设置未成年人专区，并标注推荐年龄。
• 德国：JMStV 要求操作系统自带的应用商店采用 KJM 认可、可由系统读取的自动分级。家长在系统中设定年龄后，用户只能安装和使用适龄 App。
• 澳大利亚：应用商店须在用户下载或购买 18+ 应用前进行年龄保障，评级应恰当且可复核。
• 新加坡：被指定的应用商店须阻止 18 岁以下用户下载成人应用。视频点播内容按 IMDA 守则分为六档，NC16 及以上须提供家长锁；R21 内容须进行可靠的年龄验证，默认锁定、凭 PIN 观看，且不得免费提供。
• 印度：2021 年《信息技术规则》附带的《道德准则》要求，在线视频平台将节目分为 U、U/A 7+、U/A 13+、U/A 16+、A 五档。U/A 13+ 及以上须提供家长锁，A 级须进行可靠的年龄验证。不过，这部分规则的效力仍有争议：2021 年 8 月，孟买高等法院暂停了要求遵守该准则的第 9 条第 1、3 款。
• 美国德州：开发者须为 App 和内购定级，应用商店据此执行家长同意要求。

平台自身也在调整分级体系。苹果于 2025 年 7 月为 App Store 新增 13+、16+、18+ 三档，保留原有的 4+、9+，并要求开发者在 2026 年 1 月 31 日前完成新版分级问卷。调整后的档位，与各地法律中较常见的 13、16、18 岁门槛更加接近，也便于分级结果与年龄管理衔接。

落地要点

• 建立统一的内部评估维度，再映射各地标签。按照暴力、性、语言、恐怖、类赌博机制、付费、陌生人互动等维度建立内部标签，再对应各市场的分级体系。IARC 等统一问卷可以减少重复工作，但印尼这类要求政府核验的市场，仍须单独履行程序。
• 将重新定级纳入功能上线流程。新增开宝箱、聊天、直播、AI 对话等功能，都可能影响分级。应在功能设计和上线前完成评估，避免到了商店审核阶段才发现需要调整。
• 让分级成为系统可读取的数据。分级除了展示在商店页面上，还应以结构化数据保存，供应用商店、未成年人模式和推荐系统调用，使标签能够转化为实际的分发和使用限制。

（六）内容过滤

内容过滤的目的，是避免未成年人接触不适宜的内容。分级为内容标明适用年龄，过滤则让这些标签在分发中发挥作用：结合用户年龄，决定一条内容是否可以向其展示。推荐、搜索、热榜、弹窗等环节，都需要作出这一判断。

各地如何界定“有害内容”？

英国对有害内容作了进一步区分：对于首要优先内容，须阻止儿童接触，并配合高度有效的年龄保障；对于优先内容，则须按年龄段提供保护。两者对应的处理强度不同，不能采用同一套规则。

保护要落实到分发环节

监管越来越关注内容如何被传播：一条内容推给谁、出现在哪里、是否被算法反复放大，都可能影响未成年人面临的风险。

• 英国：Ofcom 的儿童保护准则自 2025 年 7 月 25 日起适用，要求中高风险服务的推荐算法，从儿童的信息流中过滤有害内容。
• 中国：《分类办法》第 9 条禁止在首页首屏、弹窗、热搜、榜单、推荐、精选等醒目位置呈现可能影响未成年人身心健康的信息，算法推荐和生成式 AI 也不得向未成年人推送这类信息。
• 澳大利亚：第二阶段行业守则要求，搜索引擎自 2026 年 6 月 27 日起对登录用户进行年龄保障，为未满 18 岁的用户默认启用最高安全级别；对未登录用户，则默认模糊处理相关内容。
• 意大利：竞争与市场管理局（AGCM）于 2024 年 3 月对 TikTok 罚款 1000 万欧元，理由是其对“法式疤痕”等危险挑战内容监控不力，推荐算法反而放大了这些内容的传播。

过滤应在哪一层实现

各地的过滤要求，分布在网络、系统和平台三个层面：

这三层保护相互叠加，各自承担责任。网络或系统层已经采取过滤措施，并不免除 App 自身的义务。

落地要点

• 建立统一的有害内容分类。整合各市场的内容清单，并标明各地的适用范围和处理要求，区分哪些内容须阻止所有年龄段的未成年人接触，哪些需要按年龄段提供保护。
• 让年龄判断贯穿分发流程。在推荐、搜索、热榜、弹窗、开屏等环节，结合用户年龄段判断内容是否适合展示，使过滤规则真正作用于用户看到的内容。
• 分别落实各层义务。网络、系统和平台层的过滤可以相互配合，但不能彼此替代。每一层都需要核查自身应承担的责任。
• 为举报和监管要求建立快速处置流程。菲律宾要求在 24 小时内封堵儿童性虐待材料；墨西哥要求设立全年无休的对接点，证据至少保存 90 个工作日，并及时向主管机关预警。新加坡网上安全委员会自 2026 年 6 月 29 日起运作，可以要求删帖、限制账户；不遵从的，可进一步要求接入服务商封锁、应用商店下架。相关时限和措施应提前纳入处置流程。
• 支持按市场单独停用高风险功能。2026 年 8 月，巴西 ANPD 因 Discord 的直播功能被用于暴力、骚扰和诱导自残，依据 ECA Digital 第 6 条，要求其在三个工作日内暂停在巴西的“Go Live”直播功能，经批准后方可恢复。产品需要具备按国家、按功能单独停用的能力，才能及时执行这类命令。
• 让安全功能的宣传与实际效果相符。2026 年 9 月，德州法院认定，TikTok 宣称“限制模式”能够过滤毒品、裸露等内容，但未成年人在该模式下仍可看到相关内容，构成欺诈性营销，罚则另行审理。安全功能的对外表述也应经过法律审核，避免作出超出实际保护能力的承诺。

四、义务正在向上游延伸：操作系统、应用商店与 App

过去，未成年人保护义务主要由 App 承担：谁提供服务，谁负责识别年龄、采取保护措施。2025 年以来，越来越多的立法开始将年龄核验和家长同意的责任向上游延伸，由应用商店、操作系统先行处理，再向 App 传递“年龄信号”。

这一思路有其现实基础。一个孩子的手机上可能装有几十个 App，逐一核验既容易重复收集信息，也未必可靠。操作系统和应用商店作为各类应用共用的入口，可以集中完成年龄识别，再向下游提供必要的结果。对终端厂商而言，未成年人保护因此成为系统设计中需要直接承担的责任。

下图梳理了三个层级各自的义务及代表性立法：

图中从上到下，呈现的是年龄信息的流动方向。在加州模式下，操作系统也可以直接向开发者提供信号，无须经过应用商店。

（一）美国：应用商店核验与操作系统传递信号两条路线

美国各州逐渐形成了两种模式。一种是犹他州率先采用的“应用商店问责法”（App Store Accountability Act）模式，由应用商店核验年龄、取得家长同意；另一种以加州 AB 1043《数字年龄保障法》为代表，由操作系统在账户设置时收集年龄，再通过接口向开发者提供年龄信号。

加州法对操作系统的要求，直接落在账户设置环节：

California Civil Code §1798.501(a)(1)（AB 1043，节选）
Provide an accessible interface at account setup that requires an account holder to indicate the birth date, age, or both…
（操作系统提供者应）在账户设置时提供无障碍的界面，要求账户持有人提供出生日期、年龄或两者……

德州应用商店法的执行状态，则经历了数次变化。2025 年 12 月，联邦地区法院发布初步禁令，暂停执行该法；2026 年 5 月 28 日，第五巡回上诉法院先行暂缓这项禁令，6 月 5 日又裁定，法律可在上诉期间执行，并认为德州很可能胜诉。7 月，最高法院拒绝撤销暂缓决定。

截至 2026 年 10 月下旬，上诉判决尚未作出，法律仍处于可执行状态。苹果已自 2026 年 6 月 4 日起，对德州新建账户执行家长同意流程。犹他和路易斯安那则均在 2026 年将适用时间推迟了一年。

两种模式的责任分配有所不同。应用商店模式要求商店承担年龄核验和逐次同意，介入更深；操作系统信号模式允许用户自报年龄，但开发者收到信号后，就要承担“实际知悉”年龄所带来的法律后果。科罗拉多和伊利诺伊于 2026 年通过的法律，均采用了后一种模式。

（二）美国之外

巴西对上游主体的要求尤为具体。ECA Digital 第 12 条直接将应用商店和操作系统列为义务主体：

Lei nº 15.211/2025, Art. 12（节选）
Os provedores de lojas de aplicações de internet e de sistemas operacionais de terminais deverão:
互联网应用商店提供者和终端操作系统提供者应当：

该条随后列出的义务包括：以相称、可审计的方式评估用户年龄或年龄段；提供家长监督设置；通过默认保护隐私的 API 向应用传递年龄信号；儿童下载应用须取得家长同意，沉默不得视为同意。

2026 年 3 月的实施细则（Decreto 12.880/2026）进一步明确：信号须免费提供，遵循最小化原则，不得包含出生日期、身份或画像数据；开户时须询问年龄，并采用 ANPD 认可的方法核验，优先使用可验证凭证；信号冲突时适用更严格的要求；应用不因接收到信号而免除自身责任。ANPD 自 2026 年 6 月起，已开始监测苹果、谷歌应用商店及 Windows 的年龄核验和信号传递情况。

欧盟目前主要通过 DSA 约束平台。指南允许平台采用操作系统或设备提供的年龄保障方案，但平台仍须对实际效果负责。欧盟委员会曾于 2025 年 10 月向苹果 App Store 和 Google Play 发出信息请求，但针对操作系统和应用商店的专门责任分配机制，尚待进一步建立。

变化可能来自 2026 年 9 月提出的 KIDS Act 提案。该提案将应用商店和操作系统均纳入范围，拟要求应用商店开展分级和年龄保障，拦截不适龄 App；序言还提出，操作系统合规取得的年龄信号，可以在用户同意后共享给其他服务。目前，提案仍处于立法程序的起始阶段。

德国已在系统与应用的衔接上作出规定。2025 年 12 月生效的 JMStV 修订，要求被认定的操作系统提供“青少年保护装置”，并将应用商店和 App 纳入联动：系统自带的应用商店须采用 KJM 认可、可由系统读取的自动分级，App 则须考虑系统中的年龄设定。具体要求见第三部分的家长控制一节。

澳大利亚通过第二阶段行业守则，将义务分配给不同环节。应用商店自 2026 年 9 月 9 日起，须在用户下载或购买 18+ 应用前进行年龄保障；对于可通用上网的手机和平板，操作系统提供者须提供“带安全工具的儿童账户”选项。

新加坡直接对指定应用商店提出要求。《应用分发服务在线安全行为准则》于 2025 年 3 月 31 日生效，指定苹果、Google Play、华为 AppGallery、微软、三星 Galaxy Store 五家应用商店，要求其在 2026 年 3 月 31 日前完成年龄保障，阻止 18 岁以下用户下载成人应用。

各家的实现方式有所不同。据当地媒体报道，有的根据账户信号推断年龄，有的采用国家数字身份 Singpass、证件或自拍估龄，也有的通过绑定信用卡核验。

英国已为将应用商店纳入监管预留路径。Ofcom 须在 2027 年 1 月前，发布关于应用商店在儿童保护中作用的报告；此后，国务大臣可以通过条例，将应用商店纳入《在线安全法》。2026 年 9 月，政府还宣布，将立法要求在设备和操作系统层面，拦截儿童拍摄、分享和查看裸露图像。

中国的终端和分发平台义务，见第五部分。此外，中国还通过国家网络身份认证提供年龄标识。按照 2025 年 7 月施行的办法，相关公共服务可以向互联网平台提供年龄标识信息，为平台判断用户年龄提供另一条路径。

日本则体现出竞争开放与儿童保护之间的协调问题。2025 年 12 月 18 日全面施行的《移动软件竞争促进法》，要求苹果、谷歌开放应用商店和支付，同时为“青少年保护”所必要的行为保留例外。开放要求与保护措施之间如何划定边界，在欧盟 DMA 下也存在类似问题。

（三）苹果和谷歌的回应

苹果和谷歌均在 2025—2026 年推出了年龄信号接口，将相关要求转化为开发者可以调用的系统能力。

苹果的 Declared Age Range API 支持家长为儿童账户共享年龄区间，开发者获得的是区间，而非出生日期。为回应德州等州的法律要求，苹果又补充了重大变更通知接口（PermissionKit 中的 Significant Change API）、StoreKit 年龄分级属性，以及家长撤回同意的通知机制。谷歌的 Play Age Signals API 则提供用户的核验或监护状态、年龄段，以及重大变更的审批状态。

（四）对开发者和终端厂商分别意味着什么

对 App 开发者而言，需要关注四点：

1. 收到年龄信号，可能产生“实际知悉”的法律后果。加州法规定，接收信号后，即视为在所有平台上实际知悉该用户的年龄；除非内部存在“明确且令人信服”的相反信息，否则应以信号为准。一个原本声称“不面向儿童”的 App，一旦收到用户未满 13 岁的信号，就需要据此履行 COPPA 的相应要求。
2. 预留接入多个信号源的能力。除 iOS、Android 外，还需考虑各国身份系统，例如中国的国家网络身份认证、新加坡的 Singpass、马来西亚的 MyDigital ID。
3. 接收信号不等于免除责任。巴西明确规定，年龄信号不构成免责依据，信号冲突时应适用更严格的要求。企业自身掌握的相反信息，也不能忽略。
4. 将重新取得同意纳入版本规划。在美国的应用商店监管模式下，App 发生重大变更，可能触发家长重新同意。产品发布流程需要为通知、审批及未获同意时的处理留出安排。

对终端厂商而言，则需要在系统层面做好以下准备：

1. 支持年龄信息收集，并按市场配置核验方式。系统账户需要能够收集出生日期或年龄。加州允许自报年龄，德州要求采用商业上合理的核验方式，巴西要求使用 ANPD 认可的方法，中国则需考虑与国家身份系统对接。
2. 提供符合最小化要求的年龄信号接口。对外输出必要的年龄段和家长同意状态，避免传递出生日期和身份信息。
3. 打通家庭组、儿童账户与应用商店的同意流程。同时关注预装应用的适用范围，犹他州 2026 年的修订已将预装 App 纳入。
4. 共用底层能力，按市场配置规则。年龄识别、家庭关系和同意管理可以共用一套基础能力，再按各地要求调整参数。这也是第七部分将讨论的“底层能力＋国别规则”。

五、中国：以未成年人模式为核心的体系

中国的规则兼具年龄准入、内容监管和服务风险管理三种逻辑，并以未成年人模式推动终端、应用分发平台与 App 协同落实。2023 年《未成年人网络保护条例》出台后，配套文件陆续发布，到 2026 年，已逐步形成涵盖法律、行政法规、部门规章、规范性文件和国家标准的规则体系。2026 年 9 月公布的国务院规定征求意见稿，还拟将手机的未成年人模式纳入电信设备进网许可检测。

《未成年人网络保护条例》之前已有讨论。这里主要梳理体系全貌，以及此后的配套规则和新变化。

（一）体系一览

（二）终端、分发平台和 App 各自承担什么责任

中国的规则较为明确地区分了终端、应用分发平台和 App 三类主体的义务，并要求它们相互配合。终端层面的保护义务，在 2020 年修订的《未成年人保护法》中已有规定，《未成年人网络保护条例》又作了进一步明确：

《未成年人网络保护条例》第十九条第三款（节选）
智能终端产品制造者应当在产品出厂前安装未成年人网络保护软件，或者采用显著方式告知用户安装渠道和方法。

三类主体的主要分工如下。其中，征求意见稿提出的要求仍待定稿：

下图展示了这套联动机制的基本流程：家长在终端开启未成年人模式，应用分发平台和 App 随之切换。若征求意见稿中的相关要求最终落地，终端的未成年人模式还将纳入进网许可检测。

（三）《建设指南》中的几个关键数字

《建设指南》属于指导性文件，本身未设罚则，但对未成年人模式如何建设作出了具体安排：

• 进入方式：至少提供三种进入方式；在终端一键启动或退出后，App 和应用分发平台自动同步切换。
• 内容配置：按年龄分为五档。不满 3 岁以音频为主，3—8 岁侧重启蒙，8—12 岁侧重通识科普，12—16 岁增加学科教育，16—18 岁以健康向上的内容为主。
• 使用时长：不满 16 岁，默认推荐每日总时长不超过一小时；16—18 岁不超过两小时，家长可以豁免。连续使用超过 30 分钟，应作出提醒。
• 使用时段：每日 22 时至次日 6 时，终端默认不向未成年人提供服务；通话、备案网课不计入使用时长。
• 其他设置：App 默认关闭陌生人私信，分发平台设置未成年人专区，退出未成年人模式须经家长验证。

按年龄展开，内容配置分为五档，使用时长则只分两档，如下图所示。

这里也需要澄清一个常见说法：“不满 8 岁每天 40 分钟”来自 2023 年的征求意见稿。2024 年 11 月发布的正式稿，仅保留了不满 16 岁一小时、16—18 岁两小时的两档安排。

（四）2024 年以来的四个变化

有害信息有了分类标准

《可能影响未成年人身心健康的网络信息分类办法》自 2026 年 3 月 1 日施行，将相关信息分为四类：诱导不良行为、宣扬负面价值观、不当使用未成年人形象、不当披露个人信息。

平台需要根据不同信息载体作出提示，同时注意内容的呈现位置：

《分类办法》第九条（节选）
不得在首页首屏、弹窗、热搜、榜单、推荐、精选等处于产品或者服务醒目位置、易引起用户关注的重点环节，呈现可能影响未成年人身心健康的网络信息。

算法推荐和生成式 AI 也不得向未成年人推送这类信息。这意味着，推荐系统需要在分发前判断内容是否适合向未成年人展示，将保护措施落实到内容触达用户之前。

“大平台”进入认定阶段

认定办法自 2026 年 4 月 1 日施行，分别从用户数量和影响程度两个方面确定适用范围。

“未成年人用户数量巨大”主要看量化指标：专门面向未成年人的平台，注册用户达到 1000 万以上，或月活跃用户达到 100 万以上；其他平台，未成年人注册用户达到 1000 万以上，或月活跃未成年人用户达到 100 万以上。

“对未成年人群体具有显著影响”则需综合判断，考虑平台规模、未成年人的使用时长和消费金额、涉未成年人内容数量、是否属于相关垂直领域的代表性平台，以及近三年涉未成年人违法违规情况等。认定原则上每三年开展一次。

网信办于 2026 年 10 月 19 日发布申报公告，要求相关主体在公告发布之日起 20 个工作日内，向省级网信部门提交申报材料。

被认定后，平台须承担《未成年人网络保护条例》第 20 条规定的一系列义务，包括定期开展未成年人影响评估、提供未成年人模式或专区、设立独立监督机构、发布年度社会责任报告等。违反其中部分义务，情节严重的，可处 5000 万元以下或上一年度营业额 5% 以下罚款。

未成年人个人信息实行年度审计

《未成年人网络保护条例》第 37 条要求，处理未成年人个人信息的主体每年开展合规审计。这是一项独立于一般审计频次的特别要求。

2025 年 5 月施行的《个人信息保护合规审计管理办法》要求，处理超过 1000 万人个人信息的主体，每两年至少审计一次；条例第 37 条则没有设置人数门槛。网信办于 2026 年 4 月发布的问答进一步明确，无论是否识别用户的未成年人身份，都应按第 37 条执行。根据网信办 2025 年 12 月的公告，相关主体还须在每年 1 月底前，向设区的市级网信部门报送上一年度审计情况。

对企业而言，只要处理未成年人个人信息，就需要落实年度审计，不能因用户规模较小，或尚未识别出未成年用户，而免除这一要求。

国务院规定征求意见稿：未成年人模式可能成为进网许可条件

2026 年 9 月 18 日公布的征求意见稿共 25 条，拟将多项指导性要求上升为行政法规义务，主要包括：

• 禁止向未成年人提供陌生人社交服务（设有例外）、虚拟亲属和虚拟伴侣等虚拟亲密关系服务，以及诱导沉迷的服务；禁止为未满 16 周岁者提供直播发布服务。
• 向未满 16 周岁者提供音视频、直播、游戏、社交，以及“可能影响未成年人认知的人工智能服务”，须通过未成年人模式提供。
• 明确身份证件、国家网络身份认证、分布式数字身份、一次性人脸核验、行为识别等年龄识别手段。
• 不得设置诱导未成年人情感依赖、沉迷和过度消费的算法模型。

对终端厂商而言，最值得关注的是第 10 条和第 12 条：

征求意见稿第十条（节选）
智能终端产品制造者应当为智能终端产品设置未成年人模式联动、一键切换、退出核验、防绕过以及使用时段、时长、功能和内容管理等功能。

第 12 条进一步要求，未成年人模式向省级网信部门备案并接受年度核验，同时由国务院电信主管部门将移动智能终端的未成年人模式纳入电信设备进网许可检测。

如果相关要求最终落地，未成年人模式将直接影响手机上市前的检测与准入。终端厂商需要在研发、测试和上市准备阶段完成相应建设，其约束力度在全球范围内也较为突出。

年龄识别的基础设施也在完善。2025 年 7 月施行的国家网络身份认证办法规定，相关公共服务可以向互联网平台提供年龄标识信息。这与第四部分讨论的“年龄信号”思路相通，但信号来源是国家身份系统。

（五）执法和司法的关注重点

将近几年公开的典型案例放在一起看，监管和法院的关注点主要集中在以下五个方面。

第一，未成年人模式是否真正发挥作用。

据国家网络安全通报中心 2024 年 11 月的通报，公安机关因快手青少年模式落实不到位、违法信息处置不及时，依据《网络安全法》给予警告。同年 12 月，网信部门发布的典型案例中，也有平台因青少年模式下仍能搜出色情引流信息而被从严处罚。

司法机关同样关注保护措施的实际效果。最高法于 2025 年 11 月发布的一起敲诈勒索案中，两名被告人以游戏代练为名敲诈 7.5 万余元，作案手法学自短视频。法院专门针对平台“未成年人模式未能发挥实质保护作用”的问题发出司法建议。

2026 年 9 月，上海专项执法发现，某二手潮玩平台在未成年人模式下仍可购买擦边手办，某游戏社区的未成年人模式存在审核漏洞，相关企业因此被约谈、警告。

第二，终端和应用商店也已进入执法视野。

2024 年 12 月发布的典型案例涉及儿童手表语音问答传播有害信息、学习平板应用商店内的短视频 App 存在低俗内容等问题，相关企业被约谈、处罚。

2026 年 7 月启动、为期四个月的“清朗·未成年人网络保护”专项行动，也将多个终端和分发环节列为排查重点，包括儿童手表等智能终端的聊天和输入法、第三方 App 诱导充值、应用商店未成年人专区内的不适龄 App，以及未成年人模式的进入和退出验证。

第三，平台对涉未成年人内容承担更高的注意义务。

2023 年 9 月，网信部门针对 QQ“小世界”版块存在色情引流、诱导未成年人不良交友、招募未成年人陪玩等问题，依据《未成年人保护法》第 127 条，作出暂停版块更新 30 日、没收违法所得、罚款 100 万元的处罚。

民事案件中，平台也可能因未采取必要措施而承担责任。北京互联网法院审理的一起案件中，同学在社交软件上发布造谣视频，包含未成年原告的肖像和微信号。法院认为，平台知道或者应当知道相关侵权行为，却未采取必要措施，应与发布者承担连带责任；涉及未成年人隐私和涉性谣言时，平台应承担更高的注意义务。该案入选了 2025 年 12 月发布的第六届依法维护妇女儿童权益十大案例。

第四，充值和打赏的退款规则更加细化。

最高法 2020 年的指导意见确立了基本规则：限制民事行为能力人未经监护人同意，参与网络付费游戏或直播打赏，支出与其年龄、智力不相适应的款项，监护人请求返还的，法院应予支持。

2026 年 1 月印发的《人民法院审理涉未成年人民事案件工作指引》第 27 条进一步细化了判断标准。支出是否与年龄、智力相适应，需要考虑其与生活的关联程度、未成年人的理解能力及金额；赔偿责任则结合年龄智力、缔约过程和监护履职情况，按过错分担。央视在报道这份指引时提到，判断经营者是否存在过错，主要看适龄提示、实名认证和时长限制是否落实。

退款请求也并非都会得到支持。北京互联网法院于 2026 年 5 月发布的一起案例中，17 岁的原告要求平台退还 650 余万元打赏款，但账号由父母实名注册，父母还曾 20 多次通过刷脸解除限制。法院认定，监护人的放任和配合构成默示同意，驳回了全部诉讼请求。

同批案例中，首次退款后监护仍不到位、导致再次充值的，退款比例被显著降低；平台实名认证不严的，则需退还大部分款项。该院受理的涉未成年人案件，也从 2021 年的 50 件增至 2025 年的 997 件。

第五，检察公益诉讼也在推动平台整改。

2021 年，杭州互联网法院审理了全国首例儿童个人信息民事公益诉讼。某短视频平台未经监护人明示同意，收集儿童的位置、面部、声音等信息，并通过算法推送含儿童信息的视频。案件最终调解结案，平台整改后报网信部门审查，公开道歉，并向儿童公益组织支付赔偿款 150 万元。

最高检于 2024 年发布的指导性案例（检例第 204 号），则涉及向未成年人租售游戏账号。针对电商平台商家不核验身份的问题，检察机关向网信部门发出诉前检察建议，最终清理商品 469 件、关闭店铺 26 家，平台也增设了购买实名和上号二次实名要求。

这些案例表明，执法和司法关注的是保护措施能否实际生效。年龄识别、防绕过、模式内的内容管理、退出验证和充值限制，每一个环节都可能成为处罚或责任认定的依据。企业需要验证整套机制是否有效运行，而不能仅以“已上线未成年人模式”作为完成合规的证明。AI 相关执法将在第六部分讨论。

六、AI 与未成年人：新的监管对象

2025 年以前，AI 在未成年人保护中主要扮演工具的角色，用于审核内容、估算年龄。此后，AI 服务本身也逐渐成为监管对象，其中最受关注的是陪伴型聊天机器人。这类服务以近似人际交往的方式与用户持续对话，可能使未成年人产生情感依赖。美国数起涉及青少年的诉讼及随后的监管调查，推动多个国家和地区在短时间内对这类服务提出专门要求。

（一）中国：直接禁止虚拟亲密关系服务

中国对这类服务划定了明确边界。2026 年 7 月 15 日施行的《人工智能拟人化互动服务管理暂行办法》，针对提供持续性情感互动的 AI 服务作出规定：

《人工智能拟人化互动服务管理暂行办法》第十四条第一款（节选）
拟人化互动服务提供者不得向未成年人提供虚拟亲属、虚拟伴侣等虚拟亲密关系的服务；

对于其他拟人化互动服务，不满 14 周岁的用户使用前须取得监护人同意。服务还须设置未成年人模式，提供现实提醒、时长限制等功能，支持监护人屏蔽特定角色、限制充值；识别出未成年人后，应切换至未成年人模式，并提供申诉渠道。面向所有用户，连续使用每超过两小时，都须作出提醒。

从草案到正式稿，监管要求有一处明显收紧：2025 年 12 月的征求意见稿要求，提供情感陪伴服务须取得监护人同意；正式稿则改为，直接禁止向未成年人提供虚拟亲密关系服务。2026 年 9 月公布的国务院规定征求意见稿延续了这一思路，并要求向未满 16 周岁者提供“可能影响未成年人认知的人工智能服务”时，通过未成年人模式提供。

生成式 AI 也有相应要求。2023 年的《生成式人工智能服务管理暂行办法》第 10 条，已要求防范未成年人用户过度依赖或沉迷；《分类办法》进一步规定，不得通过生成式 AI 向未成年人推送可能影响其身心健康的信息。

相关要求已开始体现于执法。2026 年 9 月，网信办处置了一批发布 AI 生成的“未成年人怀孕、打架”等与其年龄特点不符内容的账号。同月，上海网信部门牵头的专项执法中，一款 AI 陪伴 App 因与未成年人进行低俗对话被罚款，一款 AI 助手因教用户绕过防沉迷措施被约谈。

（二）美国：州法先行

美国对陪伴型聊天机器人的监管，主要由各州率先推进：

继加州之后，多个州陆续就陪伴型聊天机器人立法，相关要求多于 2027 年生效。

联邦层面，GUARD Act 于 2026 年 4 月在参议院司法委员会获一致通过。该提案要求，以具有合理确定性的方法核实用户已成年，仅凭自报出生日期不足以满足要求，并禁止未成年人使用 AI 陪伴服务。对于明知或轻率放任服务与未成年人发生涉性互动、诱导自杀或自伤的行为，提案规定每次最高 25 万美元的刑事罚金。目前，提案尚未交付全院表决。

监管调查与诉讼也在同步推进。FTC 于 2025 年 9 月依据第 6(b) 条款，向 Alphabet、Character Technologies、Instagram、Meta、OpenAI、Snap、X.AI 七家公司发出调查令；44 个州的检察长于 2025 年 8 月联名致函 13 家 AI 公司。私人诉讼方面，Character.AI 和谷歌于 2026 年 1 月，就佛罗里达等地五起涉及青少年心理伤害和自杀的诉讼达成和解，具体条款未公开。

（三）欧盟及其他国家和地区

• 欧盟：《人工智能法》第 5 条第 1 款 (b) 项自 2025 年 2 月 2 日起适用，禁止利用年龄等因素带来的弱点，实质扭曲人的行为并造成重大损害的 AI 系统，最高可罚 3500 万欧元或全球营业额的 7%。欧盟委员会指南第 105 段列举了两个涉及儿童的例子：通过奖励诱导儿童完成越来越危险的身体挑战的 AI 玩具，以及利用 AI 画像和不可预测的奖励诱导儿童过度游戏的设计。2026 年的修订（Regulation (EU) 2026/1744）又在第 5 条中增加两项禁令，禁止生成未经同意的私密影像和儿童性虐待材料的 AI 系统，自 2026 年 12 月 2 日起适用。KIDS Act 提案则拟要求，面向未成年人的 AI 伴侣功能默认关闭。
• 意大利：2025 年的 AI 法（Legge 132/2025）第 4 条第 4 款规定，未满 14 岁者使用 AI 技术，须取得行使亲权者的同意，自 2025 年 10 月 10 日起生效。数据保护机构 Garante 于 2025 年 5 月公布，因 Replika 处理数据缺少合法依据、未采取有效的年龄验证措施，对其开发商罚款 500 万欧元；2026 年 7 月，又对 Character.AI 罚款 15.8 万欧元，责令其确保年龄验证有效，并为未成年人默认采用私密设置。
• 澳大利亚：第二阶段行业守则将“AI 陪伴聊天机器人功能”纳入范围，以此为主要用途的服务被直接列入最高风险档。据律所解读，这类服务须实施年龄保障。
• 英国：政府于 2026 年 7 月发布的最终回应提出，禁止 18 岁以下用户使用以性化内容为主的聊天机器人。此前，ICO 曾于 2023 年 10 月认为，Snap 的“My AI”上线前风险评估不足，并发出初步执法通知。Snap 补充风险评估后，ICO 于 2024 年 5 月结案，未予处罚。

（四）企业的应对

这些措施反映出一个共同趋势：AI 公司开始主动识别用户年龄，并为未成年人设置不同的使用路径。部分服务还采取了更审慎的处理方式——无法确认年龄时，先按未成年人保护，再由成年用户通过核验解除限制。这与第三部分讨论的年龄保障分层思路相通。

（五）落地要点

1. 先区分功能形态。摘要、翻译、修图等工具型 AI 功能，需要遵守一般的 AI 和未成年人保护规则；开放式对话、角色扮演、情感陪伴等功能，已被多个国家和地区单独监管，应作专门评估。
2. 单独设计未成年人的使用路径。中国禁止向未成年人提供虚拟亲密关系服务；美国多州要求提示服务并非真人、定时提醒休息，并防范色情内容；KIDS Act 提案则拟要求 AI 伴侣功能对未成年人默认关闭。
3. 接入适用的年龄信号。加州 SB 1119 要求接入 AB 1043 年龄信号。对于无法确定年龄的用户，先按未成年人处理，也正在成为部分企业的做法。
4. 建立危机识别与应对机制。加州和纽约均要求识别自杀、自伤意图，并转介危机服务；加州还要求公开应对协议。
5. 明确产品设计的边界。华盛顿、俄勒冈对模仿恋爱关系、模拟情感依赖、劝阻休息，以及通过奖励机制延长使用等行为设有限制；欧盟《人工智能法》第 5 条则禁止利用年龄等弱点诱导行为并造成重大损害。
6. 落实记录、报告与审计要求。加州规定了年度报告和独立审计要求，中国也有相应的合规审计要求。相关工作需要进入日常管理流程。

七、落地框架：从逐国修补到一套体系

将前述规则落实到一家企业，常见的做法是逐国应对：哪个市场出台新法、哪项业务被监管点名，就在那里补上一项措施。市场较少时，这种方式尚可维持；业务扩展至二十个市场后，重复建设和规则冲突就会逐渐显现：同一个家长控制功能出现多个版本，同一用户在不同 App 中被划入不同年龄段，每逢新法出台，又要重新排查一遍。

下面以一家同时经营终端、操作系统、应用商店和互联网服务的公司为例，讨论如何按模块建立一套可复用、可调整的合规体系。

（一）面对每条要求，先回答三个问题

拿到一个市场的新规后，可以先从监管强度、责任主体和落地层级三个维度，逐条梳理要求：

监管强度决定优先级和完成标准。禁止性要求需要先明确适用范围，确保相关服务或功能不被违规开放；强制性义务则要根据“合理步骤”“高度有效”等法律标准，确定措施及验证方式。监管指引和最佳实践可以结合实际分阶段落实，但指引往往也是执法的重要参照，需要纳入规划。

责任主体决定任务如何分工。一家集团可能同时是操作系统提供者、应用商店运营者和 App 开发者。同一部法律中的要求，可能需要分别交由三个团队落实，并确保它们在年龄识别、家长同意和信号传递等环节相互衔接。

落地层级决定能力能否复用。判断标准可以很直接：多个市场普遍要求、多项业务反复使用的功能，应尽量建设为共用的基础能力；差异则留在业务策略和国别配置中处理。

（二）分层架构

整体结构如下图所示，自下而上依次为通用基础能力、业务级管控和国别规则：

六个模块可以分为两层：

• 通用基础能力：年龄保障、家长控制与安全模式。这两个模块适合统一建设、供各业务复用。账号体系中的年龄字段和核验能力，决定了各业务能够获得多可靠的年龄信号；系统级家长控制框架，则让家长可以在一个入口统一管理。这一层主要由账号和系统团队建设，法务、隐私和安全团队共同确定基线要求。
• 业务级管控：年龄门槛、隐私保护、年龄分级、内容过滤。这四个模块需要结合业务形态配置：游戏侧重分级、开箱和使用时长，视频侧重内容过滤与推荐，社区侧重陌生人互动，广告侧重画像和投放。各业务根据自身风险落实，法务、隐私和内容安全团队提供基线要求。

国家和地区的差异化规则叠加在这两层之上，主要处理当地特有的年龄界限、指定核验方式，以及单独的备案和报告义务。

两层之间，通过年龄信号和家长设置衔接。基础能力层确认用户所属年龄段、家长设置了哪些限制，业务层据此执行，减少重复询问和核验。如果各业务分别设置年龄弹窗，就容易出现口径不一、用户反复填写、系统限制无法在 App 中生效等问题；监管检查时，也难以说明应以哪个结果为准。

海外安卓设备通常可以借助谷歌 Family Link 等系统级方案，满足基础的家长控制需求。但方案是否覆盖当地法律要求的具体功能，是否满足首次开机提示等要求，仍须逐项核查。已有功能可以作为基础，不能直接替代合规判断。

（三）如何确定业务优先级

AI 功能需要按交互形态分别判断。摘要、翻译、修图等工具型功能，在不触发专门要求的情况下，通常可列入第三档；开放式对话、角色扮演、情感陪伴等功能，已被多个国家和地区单独监管，应根据适用要求和风险进入第一档或第二档。

优先级也需要随规则变化调整。今天尚无专门要求的功能，明年可能就会被纳入监管，因此至少应每半年复核一次。

（四）全球基线与高风险市场增强

全球基线可以从主要市场的共同要求出发，建立一套各业务普遍适用的保护措施。一种可行的组合是：

1. 通过出生日期收集年龄信息，支持后续年龄段更新；未成年人账户默认采用高隐私设置。
2. 默认关闭面向未成年人的、基于画像的个性化广告。
3. 提供系统级家长控制入口，并与各业务的时长、消费和互动管理衔接。
4. 为内容和应用配置年龄分级标签。
5. 在访问成人内容或使用高风险功能前，触发更强的年龄核验。
6. 每年评估未成年人数据处理情况，并按适用要求开展合规审计。

在共同基线之上，再根据各市场的违规后果配置增强措施。后果越重，相关工作越需要提前：

这张表也对应着产品流程中的不同节点：影响上市的要求，应进入研发和出厂验证；影响运营的要求，应在上线前落实并持续监测；涉及高额罚款的市场，则尤其需要完整的评估、实施和验证记录。

（五）项目如何推进

一个完整的未成年人保护合规项目，可以分为三个阶段：首先梳理各地要求，确定国家和产品的优先级；其次制定基线和实施方案，明确每项要求的责任团队；最后逐项评审业务方案，并在上线后验证实际效果。

每个阶段都应形成下一阶段可以直接使用的成果：调研形成要求清单，明确适用范围和期限；方案形成可验收的产品要求，明确责任人和完成标准；评审形成逐项结论，说明已满足、待补充及需要持续验证的事项。

法务需要更早参与产品需求的形成，与产品和技术团队共同明确功能、流程和验收标准。等到上线前才提出未成年人保护要求，往往会带来较大范围的返工。

（六）几个常见误区

1. 将自我声明视为充分的年龄保障。英国 Ofcom 不将其认定为高度有效的年龄保障方法；巴西禁止以自我声明核验用户是否能够访问不适宜 18 岁以下用户的内容；澳大利亚行业守则也认为，仅靠自报年龄不构成适当的年龄保障。
2. 将儿童模式等同于家长控制。法律要求的往往是一组具有明确管理权限和具体功能的工具，部分要求还涉及远程管理。仅提供一个隔离的使用空间，未必足够。
3. 只关注终端功能，忽略账号信息。账号中的年龄信息是下游判断的重要基础。如果出生日期不准确，又缺少可靠的核验或纠错机制，错误就可能传递至各项业务。
4. 认为收到年龄信号即可免责。巴西实施细则明确，应用不因接收操作系统或应用商店的年龄信号而免除责任；信号冲突时，还须适用更严格的要求。
5. 低估 AI 功能的监管风险。情感陪伴、角色扮演等功能已被多个国家和地区纳入专门监管，需要按其交互方式和实际风险单独评估。
6. 完成了功能，却没有留下有效性证据。“是否采取合理步骤”“措施是否高度有效”，都是监管判断的重要标准。风险评估记录、核验方案测试数据、默认设置的决策依据，都需要留存。澳大利亚 eSafety 在执法中指出的反复重试年龄检测、注册时仅靠自报年龄等问题，也说明验证必须覆盖功能的实际使用过程。

附录

附录一 重点法域速查表

截至 2026 年 10 月。各法域的处罚力度见第七部分（四）。

附录二 主要法规与官方来源

附录三 典型执法与司法案例

（一）中国

（二）其他法域

对于新手法务而言，事故的处置无疑是工作内容中的“深水区”。

其一，时效要求高。一个细小的失误，可能已经造成数以万计的损失，需及时完成法律定性、配合拟定处置方案。其二，存在教科书与实践的鸿沟。应急处置需要灵活的变通，照本宣科虽然能将风险降到最低，却可能让资损扩到最大。相反地，能最大程度降低我方的损失的方案，从法律角度上看，往往又不是良策。法务所需要做到的，是在复杂的情境与各方的考虑中，迅速地判断出红线与平衡点。其三，事故与事故大不相同，因而前述的平衡点是不断地变动的。

外部环境也在变化。二〇二五年度，全国12315平台受理的投诉首次超过两千万件，其中网购投诉举报占比过半，“预售定金与尾款价格反差、价保申请被拒”被点名为电商购物节中的突出问题，中国消费者协会二〇二六年上半年的投诉分析中，“AI客服承诺不认账”位列首要热点。《反不正当竞争法》于二〇二五年修订施行，《直播电商监督管理办法》《市场监督管理投诉举报处理办法》《金融产品网络营销管理办法》相继于二〇二六年施行。旧的经验需要放到新的规则下重新检视。

不知幸与不幸的是，电商事故从来不缺样本，每一起都是宝贵的经验。其中更宝贵的，是那些二次客诉。这些二次纠纷往往不是由事故本身引起，而是由处置方式引起——单方取消订单、未经告知的拦截、逐次加码的补偿、与事实不符的解释等等。这提示我们，事故处置本身，也是一项需要审慎对待的法律行为。

下文所称“商城”，泛指品牌自营的线上商城，其中的多数分析，也适用于第三方平台上的店铺。

第一章　通用处置方法论

一、三项应同步启动的工作

事故发生之后，有三项工作应当同步启动：控制影响、固定事实、形成方案。

1. 控制影响，指暂停异常入口，防止错误扩大。常见的做法包括下架价格标示错误的商品、关闭配置有误的优惠券、暂停存在问题的抽奖环节、撤回尚未送达的短信等。

2. 固定事实，指在修改前保全现场，包括前台页面截图或录屏、后台配置及操作日志、活动规则与政策表的当时版本、直播回放、客服会话记录、已发出通知原文等。许多页面、配置，一经修改即难以复原，因而止损与取证应并行推进。

3. 形成方案，指在事实可支持的范围内，提出可执行的处理路径，例如继续履行、采取补救措施、协商调整，或依法主张撤销。方案应区分不同用户群体，不宜一概而论。

二、常见的流程

（一）首轮处置的四个节点

下表为建议的内部响应节点，并非法定期限。监管文书、诉讼程序及网络安全事件报告另有期限的，单独执行。

（二）首报应当回答的六个问题

出现事故之后，业务侧容易手忙脚乱、慌慌张张，急于寻求帮助或做出决定。此时，不宜立即回答，而应至少将以下几个问题问清，否则所作判断可能便是不准确的：

1. 发生了什么样的异常，何时发生，何时发现？

2. 涉及哪些页面、商品、活动、系统与经营主体？

3. 哪些事实已经核实，哪些仍待确认？

4. 可能影响多少订单或用户？

5. 对外的表述有哪些（页面、规则、直播、客服的原话等）？

6. 已经采取了哪些措施，影响是否仍在扩大？计划采取什么措施？

（三）分级与统筹

对于法务而言，事故的级别影响不大，我们所需要做的是依据法律，灵活地给出意见。分级主要用于安排资源，在此做了解即可，可参考如下思路：

出现事故后，业务侧宜确定一名事故统筹人。各职能的分工大致如下：业务与运营还原规则、素材及配置，核对经营主体、库存与活动预算，提出可以履行的补救选项，研发与安全保全日志，解释技术原因，控制故障并复核修复结果，核验数据是否外泄，客服与服务管理统一入口与口径，按影响清单联系用户，记录用户的选择、承诺、异议与执行结果，法务判断责任与证据风险，审核补偿方案及对外回复，管理法定期限，财务、供应链与公关分别核验资金到账、商品或权益交付及对外传播。

由此可见，事故处置需要快速调动各职能资源，团结协作、共同努力。

【案例】法务的重要性

某商城曾发生一起事故，起因平平无奇，结局却颇为棘手：运营发现积分兑换的数字商品只适配部分系统版本，出于“不让用户吃亏”的好意，未经告知即取消了全部兑换订单并退回积分（见事例C-02）。结果，投诉的焦点从“不适配”变成了“擅自取消”。业务侧的好意，在法律上不一定能得到认可，这就是法务及时介入的价值所在。

三、五项法律判断

商城事故的成因千奇百怪，但从法律分析角度而言，大多数都绕不开如下五个问题。

（一）合同是否已经成立？

《民法典》第四百九十一条第二款规定，当事人一方通过互联网等信息网络发布的商品或者服务信息符合要约条件的，对方选择该商品或者服务并提交订单成功时合同成立。《电子商务法》第四十九条重申了这一规则，并于第二款明确：电子商务经营者不得以格式条款等方式约定消费者支付价款后合同不成立，格式条款含有该内容的，其内容无效。

由此得出的第一个结论是： 用户付款之后，商城单方取消订单，在法律上即构成违约。

北京互联网法院审理的一起案件中，消费者在某APP自营商城按抢购规则成功抢购并付款，平台随后以“系统自动审核”为由取消并删除订单。法院认为，消费者按照商品抢购规则成功抢购并付款后，双方即成立信息网络买卖合同关系，经营者单方无故随意取消订单构成违约，判令其交付商品。中国消费者协会也曾明确表示，消费者提交订单并支付货款后，网络购物合同成立并生效，以缺货或标价错误为由取消订单属于违约。

（二）哪些信息构成应当履行的承诺？

事故发生后，需核对商详页、活动规则、订单页、直播表达、通知短信、客服记录等我们已经对外做出的表述。《消费者权益保护法实施条例》第十二条规定，经营者以商业宣传、产品推荐、实物展示或者通知、声明、店堂告示等方式对商品或者服务的数量、质量、价格、售后服务、责任承担等作出承诺的，应当向消费者履行其所承诺的内容。《规范促销行为暂行规定》第六条也要求经营者履行优惠承诺。

需要特别注意的是，内部政策表、后台配置与供应商的解释，均不能当然推翻对外承诺。用户看到的是页面，不是后台。另外，客服与主播对外所说的话属于职务行为，其效果归属于经营者（详见第二章第十节）。

（三）错误能否支持撤销或解除？

价格明显偏离，并不当然导致合同无效。从法律角度而言，商城如果希望以“标错价”为由不履行，唯一的法律路径是依《民法典》第一百四十七条主张重大误解，请求人民法院或仲裁机构予以撤销。《最高人民法院关于适用〈中华人民共和国民法典〉总则编若干问题的解释》第十九条对重大误解作了界定：行为人对标的物的价格、数量等产生错误认识，按照通常理解如果不发生该错误认识行为人就不会作出相应意思表示的，可以认定为重大误解。

这条路径有三道门槛。其一，撤销须向法院或仲裁机构请求，商城自行发布公告或在后台取消订单，均不构成撤销权的行使。其二，重大误解的撤销权应自知道或者应当知道撤销事由之日起九十日内行使（《民法典》第一百五十二条）。其三，法院对“错误”的认定颇为审慎：广州互联网法院在一起牛奶标价错误案中支持了商家的重大误解主张，其考量因素包括优惠幅度与持续时间、历史销售记录，以及商家是否及时更正并通知消费者，而北京互联网法院在当当标价错误案中，未认定重大误解，判令商家履行交付义务。对于因商家自行叠加优惠而导致价格低于成本的情形，法院通常认为属于经营风险，不构成重大误解。

实务中，不少商家会颠倒而为之（先挽回资金损失，用户如有不满的，另外应诉）。只是须清楚，在法院或仲裁机构作出撤销之前，单方取消仍是违约。

（四）是否构成欺诈或违法宣传？

履约错误、引人误解的宣传与民事欺诈，应当分别判断。

就民事欺诈而言，《消费者权益保护法》第五十五条规定，经营者有欺诈行为的，应当按照消费者的要求增加赔偿其受到的损失，增加赔偿的金额为价款的三倍，不足五百元的为五百元。是否构成欺诈，实务中一般考察经营者是否故意告知虚假情况或隐瞒真实情况、该信息是否足以影响消费者的交易决定、消费者是否因此作出交易。《消费者权益保护法实施条例》第四十九条明确排除了“不影响商品或者服务质量且不会对消费者造成误导的瑕疵”，并规定以夹带、掉包、造假等方式骗取赔偿或敲诈勒索的，不适用惩罚性赔偿。

就行政责任而言，价格方面，《明码标价和禁止价格欺诈规定》第十九条列举了价格欺诈行为，第二十一条规定经营者有证据足以证明没有主观故意、或实际成交价格使消费者获得更大优惠的，不属于价格欺诈，宣传方面，《反不正当竞争法》（二〇二五年修订）第九条禁止虚假或者引人误解的商业宣传，第二十五条规定的罚款上限为一百万元，情节严重的为一百万元以上二百万元以下。

由此可见，事故发生当日留存的“并非主观故意”的证据，例如操作日志、正常历史价格、发现与更正的时间等，对于民事与行政两个层面的责任判断都至关重要。

（五）补救是否已经覆盖全部责任？

向用户补发、退款或达成和解，并不当然消除行政监管、信息安全报告或其他法律责任。《市场监督管理投诉举报处理办法》明确，调解不免除经营者依法应当承担的其他法律责任。批量事故中的一件投诉，完全可能引出对整个事故的核查。

尽管如此，主动、及时、完整的补救，是行政处罚中法定的从轻、减轻乃至不予处罚情节。《行政处罚法》第三十二条规定，主动消除或者减轻违法行为危害后果的，应当从轻或者减轻处罚，第三十三条规定，违法行为轻微并及时改正、没有造成危害后果的，不予处罚，初次违法且危害后果轻微并及时改正的，可以不予处罚，当事人有证据足以证明没有主观过错的，不予处罚。《消费者权益保护法实施条例》第五十一条、《明码标价和禁止价格欺诈规定》第二十六条也有相应规定。因此，每一项补救都应当有记录。它们既是对用户的交代，也是面对监管时的全部证据。

“系统异常”是常见的对客解释，其中不乏人为配置失误。对用户不展开内部原因，并无不可，但不宜与事实相悖。若进入监管调查，应如实说明究竟是配置失误还是系统缺陷。

第二章　常见的十一类事故

以下将常见的事故分为十一类。为便于互相援引，各类之下的具体形态以字母加数字编号，如价格类的第一种形态记为A1。

一、价格

（一）概述

价格类事故包括五种形态：标价过低（A1），标价过高或多收价款（A2），多重优惠意外叠加以致“穿底”（A3），定时调价或政策未能按时生效（A4），以及新品首销期间的价格倒挂（A5）。

价格类型的事故非常容易导致资金损失，发生原因大致有三：其一，手工录入失误，如1899元误录为189元，其二，多个优惠工具分属不同系统，彼此不知对方存在，如立减、券、积分抵扣、积分膨胀与会员侧活动同时生效，导致价格过低，其三，商城系统在高负荷下未能执行定时任务。其中，第二种原因近年来尤其多见。为了吸引用户，创造了越来越丰富的优惠工具，忽略了叠加的规则。

（二）法律分析

A1　标价过低

错误地标识了过低的价格，民事定性上比较清晰。订单一经提交成功，合同即告成立，标价过低对用户有利，商城不履行即构成违约。行政层面，《明码标价和禁止价格欺诈规定》第二十一条第（二）项明确，实际成交价格能够使消费者获得更大价格优惠的，不属于价格欺诈，标错价本身也不构成民事欺诈，用户通常无从主张“退一赔三”。

因此，这类事故的风险集中在处理方式上。商城如果想在法律框架内摆脱合同约束，只能依重大误解请求撤销，而法院的尺度并不统一。例如，宁波市中级人民法院在（2022）浙02民终2958号案件中，对员工误标商品数量致单价远低于进货价的情形，支持了以重大误解撤销，《人民司法》刊载的案例也指出，应当结合交易订单的数量、金额、店铺规模等综合判断。但是，与此同时，北京互联网法院在当当案中未予支持。

商家能否胜诉，很大程度上取决于错误是否明显悖离常识，以及事发后的行为是否一贯：是否立即公告致歉、是否主动请求消费者退款、是否给予补偿。例如，柳州市中级人民法院审理的一起案件中，商家先称“预售需调价”，后改称“店长标错价”，前后说法矛盾，法院最终判令发货。

A2　标价过高，多收价款

这一类事故基本上没有讨论余地。《价格法》第四十一条规定，经营者因价格违法行为致使消费者多付价款的，应当退还多付部分。页面标示价低于实际结算价的，还可能落入《明码标价和禁止价格欺诈规定》第十九条第（二）项“以低价诱骗、以高价结算”或第二十条第（一）项“首页标价低于详情页”的情形。能否免于价格欺诈的认定，取决于能否证明并非故意，而证明的最好材料，便是退得快、退得全。该规定第二十六条也明确，及时退还多付价款的，依法从轻或者减轻处罚。

A3　优惠叠加导致击穿底价

民事定性与A1相同，但重大误解的路径在此基本走不通。广州互联网法院在2019年的耳环案中认为，以消费者使用优惠导致合同价格低于成本为由主张重大误解，不符合法律规定，北京互联网法院在“满200减189”案中也提出，商家自身原因导致的标注错误不构成重大误解，拒绝发货属于违约，判令赔偿差价。多重优惠皆为商城自行配置，“未曾预料自己设置的优惠券会叠加”的理由难以为法院接受。

不过，在处置这一类型问题时，可能会出现的关键变量是“薅羊毛”者。北京互联网法院2023年发布的数字消费典型案例中，有一例用户恶意利用网站信息错误低价预订酒店，法院认为此种恶意利用技术错误的行为不受消费者权益保护。焦作市马村区人民法院也曾认定，明显超出生活消费合理限度的购买者不属于消费者，驳回其惩罚性赔偿请求。

据此，对于同一手机号或地址关联多个账号、脚本请求、明显超出个人合理需要的订单，可依用户协议与活动规则中关于恶意刷单、非生活消费的条款处理，但前提是有证据，且筛选规则不致误伤。甚至，“薅羊毛”的情节特别恶劣者，可能会超出民事范畴。广东韶关一起案件中，行为人使用三万余个虚拟手机号领取平台新人券，被以诈骗罪判处有期徒刑十年十个月。

A4　调价或政策未按时生效

首先要考虑是否对用户有利。涨价未能生效、用户按低价成交的，对用户有利，推荐按成交价履行。降价或优惠未能按时上线、用户按宣传时间下单却未享受的，即属A2之情形，应当退差。涉及国补商品者，另须核对调价是否符合价格备案要求，以免“未生效”之外又生出“先涨后补”的问题。

A5　首销价格倒挂

降价本身并不违法，商城享有自主定价权。这一类事故多属舆情问题。它在四种情况下会转化为法律问题：其一，对外承诺过“首销最低价”或“保价若干天”，其二，价保规则覆盖该时段，其三，预售规则写明“预售享最大优惠”之类的表述，其四，为打折而临时抬高标示价格（《明码标价和禁止价格欺诈规定》第十七条）。最后一种情况尤其严重。2020年，市场监管总局就“双十一”期间“先提价后打折、虚假促销、诱导交易”等问题，对三家大型电商平台分别处以五十万元罚款。若倒挂系配置失误所致，则同时应按A3的思路处理已成交订单，对外的解释也应与实际原因一致，不宜以“大促政策变化”一语带过。首销期内，优惠叠加之后的最终到手价，宜由专人复核。

（三）处置要义

1. 止损：下架或恢复正确价格与政策，锁定受影响订单，保留原始配置。

2. 分类：区分多付者与少付者、已发货与未发货、正常用户与有证据的异常订单。
   1. 多付者：全量主动退差，退差记录留档，作为从轻情节的证据。
   2. 少付者：差价不大、单量有限的，应考虑正常发货，差价过大的，外呼协商取消并给予补偿，用户不同意的原则上仍然应当发货。

3. 重大误解：单笔损失巨大、用户坚持不予退还、证据充分的，法务评估在九十日内起诉撤销。起诉之前，建议联合公关伙伴一并评估诉讼的影响。历史上，品牌方起诉用户容易引发舆情关注。

4. 异常订单：依规则取消有证据的恶意订单。

5. 记录：每一通外呼、每一项协商结果，均应有录音或书面记录。

操作边界：不能宣称“错误价格订单无效”或“价格以商城最终解释为准”，不得发货后要求用户补足差价，不得前后口径不一，不得在无证据的情况下将全部低价订单认定为黄牛订单，不得拦截已发放给正常用户的包裹。

（四）他山之石

• 拼多多“百元无门槛券”事件（2019年1月）。2019年1月20日凌晨，拼多多大量百元无门槛券被异常领取，用于充值话费、Q币等。平台声明称“有黑灰产团伙通过一个过期的优惠券漏洞盗取数千万元平台优惠券”，已修复漏洞并向公安机关报案。1月21日平台进一步通报，上海警方以“网络诈骗”立案并成立专案组，依据“财产保全”的相关规定对涉事订单批量冻结，平台预计最终实际资损“大概率低于千万元”。异常订单一旦呈现团伙化、规模化特征，处置重心就可以从民事协商转向刑事报案。但要有确凿的证据，也不宜针对普通消费者。

• 小天鹅授权专卖店标错价事件（2024年8月）。2024年8月28日凌晨，淘宝上一家小天鹅授权专卖店因运营人员未关闭前一场店铺立减、又叠加了平台活动，商品实际售价跌至进货价的4至5折，20分钟内涌入4万余单，下单金额近4000万元（货值7000余万元）。该店仅有6名员工，无力按错价发货，只能发视频恳请消费者退单。小天鹅品牌方随后为店铺提供百万元以上专项支持，用于向已下单消费者发放10元现金红包和100元无门槛券。截至当年的9月3日，过半订单已退款。中国政法大学传播法研究中心副主任朱巍接受采访时认为，此案深夜标价、价格远低于成本，不像是为了引起关注，构成可撤销的合同，消费者可以要求一定赔偿，但商家有权撤销订单。职业“羊毛党”以非法手段获取不正当利益的，则可能涉嫌违法犯罪。不按错价履行、以小额补偿换取退单，这条路走得通的前提是错价足够明显，商家明显是失误而非营销。

• 支付宝“政府补贴”立减事件（2025年1月）。2025年1月16日14:40至14:45，支付宝因后台营销模板配置错误，部分订单付款时被自动立减20%，优惠名目显示为“政府补贴”。次日凌晨，支付宝官方发文称：“既然是我们的错，成本和责任必须我们自己承担。针对已经发出的营销优惠金，支付宝不会向用户追款。”此为以不追回换取舆情平稳的典型选择。

二、优惠券与价保

（一）概述

这一类事故包括：券领了用不了（B1），券面额或门槛配错（B2），券的适用范围配大（B3），有效期或过期时间存在歧义（B4），价保配置错误（B5），以及运费险、包邮漏配（B6）。

它们有一个共同特点：出问题时，用户手里通常有截图。因此，客观的证据比系统设置的意图更重要。

（二）法律分析

券、购物卡、价保、运费险，本质上都是商城对用户的承诺。《规范促销行为暂行规定》第十四条要求，奖品为积分、礼券、兑换券、代金券等形式的，应当公布兑换规则、使用范围、有效期限以及其他限制性条件，第二十二条要求公开以积分、礼券等折抵价款的具体办法。《明码标价和禁止价格欺诈规定》第十九条第（七）项将“通过积分、礼券、兑换券、代金券等折抵价款时，拒不按约定折抵价款”直接列为价格欺诈行为。

券的使用规则由商城单方拟定、重复使用，属于格式条款。《民法典》第四百九十八条规定，对格式条款有两种以上解释的，应当作出不利于提供格式条款一方的解释。而“最终解释权归商城所有”一类条款，依《最高人民法院关于审理网络消费纠纷案件适用法律若干问题的规定（一）》第一条第（三）项，人民法院应当认定无效，监管部门对此也有处罚先例。

B1　券领了无法使用

已经发到用户手中的券，即为一项具体的承诺。中途缩小范围、提前失效，属于单方变更，也即不履行优惠承诺。“停止发放新券”是经营自由，随时可为，“使已领之券失效”则触动了既已形成的承诺。所以，理论上而言，回收券的合法方式只有一种：停止新增领取，已经领取的按原规则使用至期满，或者给予等值补偿。

B2　券面额或门槛配错

对用户不利者（宣传200元而实发100元），是未兑现宣传的优惠，应按宣传补足。若此券系抽奖奖品，同时构成有奖销售中“未按照向消费者明示的信息兑奖”（《规范促销行为暂行规定》第十五条第（五）项）。对用户有利者（“满1000减100”配成“满1000减1000”），按第二章第一节（价格）A3处理：已成交的是合同问题，已领未用的可在告知原因后修正，但不得不声不响地使券作废。

B3　券的适用范围过大

关键在于券面说明如何写。券的说明本身写错（如写成“全店可用”）的，即为对用户的承诺，应按所写范围兑现，说明正确、仅系统允许范围外商品使用的，可以以说明为准向用户解释。已经使用并成交的，原则上应执行。定向券被公开领取的，应将“已领未用”与“已经下单”两群人分开讨论。

B4　有效期或过期时间存在歧义

应当将视角切换为社会上的通常人士，做出合理的理解。例如，券面约定为“30日过期”，用户可能倾向于理解为“30日当天仍可以使用”。依《民法典》第四百九十八条，商城应按此理解兑现。若为抽奖奖品的兑奖期限，还须注意《规范促销行为暂行规定》第十三条“不得影响兑奖”的要求。前述便是在活动规则审核的过程中，经常要求运营伙伴将时间精确到秒的缘故。

B5　价保配置错误

价保并非法定强制义务，而是商家自愿提供的增值服务。但一经承诺，即应在售前完整公示，不得单方更改。北京市市场监督管理局2026年6月发布的价保指引，将优惠计算方式、起算时点、同款认定与规则公示列为四类争议高发点。北京互联网法院审理的一起案件中，页面写明“三十日价保”，平台事后改称价保以原价而非到手价为基准，法院认定平台否认其公示的价保计算规则，违反约定与诚信原则，判令赔付差价。

系统未能配置到位，不能成为拒绝价保的理由。大促页面宣称“超长价保”而系统只给七天的，页面宣传本身即与实际不符（《明码标价和禁止价格欺诈规定》第二十条第（二）项）。

B6　运费险、包邮漏配

属不履行承诺。宣传有运费险而未配置的，退货运费应由商城承担，多收运费的，按A2退还。

（三）处置要义

1. 核对规则：先核查券面说明原文。

2. 恢复使用：配置错误导致用不了的，补配适用范围，已原价下单者需要去做补差。

3. 已领券处理：业务希望回收已发之券的，原则上只可停止新增领取，已领取的应能使用或获得等值补偿。

4. 分类处理：对用户有利的错误，区分已领未用与已经下单两群人分别处理。

5. 价保补救：价保系统无法自助的，开设人工通道，起止时间配反的，改回后将价保期延长至覆盖全部受影响订单。

6. 明确期限：过期时间推荐配置为当日23时59分59秒，前台显示至时分秒。

操作边界：原则上不得通过调整商品价格或门槛，使既有兑换券无法使用，不得以“系统显示不在价保期”拒绝符合公示规则的申请，不得将平台故障导致的过期归责于用户，不得使用“最终解释权归商城所有”之类表述。

（四）他山之石

• 北京互联网法院价保案（2024年）。商品页面显示“30日价保服务”，消费者以优惠后价格519元下单，此后商品降到470元。消费者申请价保时，商家和平台都改口称“价格保护的基准是商品原价，并非到手价”。但平台公示的价保规则写明“单品价保金额=下单时基准价-申请价保时基准价”，其中“下单时基准价=下单商品价-下单优惠金额”。法院认为，价保基准应为优惠后的金额。平台不按自己公示的规则履行，违反了双方约定，也有违诚实信用原则，法院判令平台支付差价49元。

• 最高人民法院网络消费典型案例“限时免单”案（2023年）。网店在“双12”开展限时免单活动并公示了规则，消费者也向客服确认过，免单规则是付款在先者享受。他付款在先，却没有获得免单。北京互联网法院认为，当事人关于限时免单的约定属于附条件履行义务的合同条款。消费者符合免单规则，经营者就应当履行免单义务，否则构成违约。法院据此判令退还货款。最高法在典型意义中指出，本案厘清了经营者为免单、打折等各类促销活动所定规则的法律性质。优惠券也是类似的，规则公布之时，条件即已确定，条件一旦成就，经营者就得兑现。

• 信用卡积分兑换比例调整案（2023年）。持卡人参加银行“零钱包积分赚不停”活动，获赠180万积分。积分全部到账约3个月后，银行发布公告，把积分兑换航空里程的比例由25:1调整为50:1，诉讼中又以“行业惯例”抗辩。北京市朝阳区人民法院认为，积分到账后可能随时调整兑换规则，这是关键信息，银行对此没有尽到充分的提示说明义务。调整距积分到账的时间过近，使积分价值明显低于消费者参加活动时的合理预期。对于银行的抗辩，法院认为“行业惯例不必然合理合法”。法院判令银行按原比例兑换剩余积分。对商城而言的启示是，券和积分的规则不是不能改，但什么时候改、事先有没有讲清楚，都要经得起审查。

• 秦皇岛、淄博两地“最终解释权”处罚案（2023年、2024年）。秦皇岛一家健康管理咨询公司在美容体验卡的项目说明中写有“最终解释权归该公司所有”。秦皇岛市市场监督管理局责令其改正，给予警告，并罚款5000元。淄博张店区一家餐饮店在团购券规则中写有“酒水饮料等问题，请致电商家咨询，以商家反馈为准”。有消费者持美团券用餐，因自带酒水被拒绝用券，张店区市场监督管理局对该店罚款1000元。两案适用的都是《侵害消费者权益行为处罚办法》第十二条第（六）项，即格式条款不得规定经营者“单方享有解释权或者最终解释权”。淄博一案还说明，条款里有没有“最终解释权”这几个字并不是最核心的。“以商家反馈为准”这类把解释权留给自己的写法，同样会被当作单方解释权处理。

三、积分与会员权益

（一）概述

这一类事故包括：积分或成长值少发、迟发、错扣（C1），积分多发或重复发放（C2），积分兑换失败（C3），以及会员权益未生效（C4）。

积分类事故有两个特点。其一，影响人数往往很大，动辄上万，但单人金额较小，因此处置的原则是全量补齐。其二，它是反向风险最大的一类。补发或修复数据时的一个操作失误，即可能造成成批的多发（见事例C-01）。因此，积分类事故中，法务除关注用户一侧，还应提醒业务在操作补救的过程中，要慎之又慎。

（二）法律分析

C1　少发、迟发、错扣

积分规则、会员权益是商城对用户的承诺，少发、错扣均属违约。以积分折抵价款时出错者，还涉及价格问题：《规范促销行为暂行规定》第二十二条要求公开折价计算的具体办法，《明码标价和禁止价格欺诈规定》第十九条第（七）项将“拒不按约定折抵价款”列为价格欺诈行为。

C2　多发、重复发放

多发的积分，在法律上属于用户没有法律根据取得的利益，商城可以依《民法典》第九百八十五条请求返还。用户协议或积分规则里如果约定了“因系统错误发放的积分，商城有权更正”，扣回的依据会更充分。没有专门约定的，扣回多发积分只能直接援引第九百八十五条，因此，积分规则里最好写明系统错误的更正办法。

然而，“能扣”不等于“该扣”，扣回的依据要经得起审查。据报道，浙江一起案件中，银行以持卡人存在虚假交易、串通等不诚信手段为由，将其71万余积分清零。一审、二审法院都认为，银行只提供了部分消费记录，不足以证明持卡人用不诚信手段违规获取积分，清零缺乏事实和法律依据，判令银行返还全部积分。积分记在平台的账上，扣起来只是一个操作。可一旦有了争议，要证明积分确实多发了，责任在平台。

据此，扣回积分须同时满足三项条件。一是事先通知用户，说明多发的原因和数额，相关系统记录留存备查。二是只扣还没有使用的部分，已经用掉的原则上不追索。善意用户本来就只在现存利益范围内返还（《民法典》第九百八十六条），追索已用掉的积分，法律上未必站得住，舆情上更不划算。三是扣到零为止，不把用户积分扣成负数，也不影响用户的其他权益。明知是系统错误还反复领取的另当别论，可以依第九百八十七条请求返还并赔偿损失。

C3　积分兑换失败

积分兑换成功，即成立一项合同。兑换品无货、不适配，均属商城未能履行。这一类事故最要紧的一点，是不得单方取消。运营发现问题后自行批量取消兑换订单并退回积分，表面上没有让用户吃亏，法律上仍是未经同意单方解除合同，实践中也是引发投诉最多的做法。适配范围写错的，同时也落入E1的宣传错误。

C4　会员权益未生效

付费会员的权益是合同的核心内容，未能生效即为违约。免费会员权益（学生专享、等级权益等）是公开承诺，同样应予兑现。权益被提前上线、提前领取的，属反方向问题，按C2的思路处理，已领取者原则上要保障其可用。

（三）处置要义

1. 核对与止损：核对受影响人群，停止重复发放或错误扣减。

2. 补足权益：少发、迟发者全量补足，并合理处理有效期损失，错扣者恢复余额。

3. 数据缺失：数据丢失、无法全量捞取的，给客服一个“用户来询即补”的兜底口径。

4. 多发处理：多发者按“未使用、已兑换未履行、已履行”分群，分别评估通知、返还或协商安排。

5. 追扣复核：追扣、冻结或关联订单取消，均须明确范围、依据、复核及申诉渠道。

6. 执行校验：补发与修复数据的操作，须经试运行、对账后分批执行。

操作边界：不得将多发积分一概认定为用户作弊，不得未经通知直接扣回或扣为负数，不得以积分替代应当退还的现金，不得未经用户同意批量取消兑换订单。

（四）他山之石

• 信用卡积分兑换比例调整案。银行在活动后约三个月即将兑换比例由二十五比一调为五十比一，法院判令按原比例兑换。规则可以调整，但调整的时机与提示须经得起“合理预期”的检验。

• 信用卡积分清零案。银行以虚假交易为由清零积分，因证据不足被判返还。

四、赠品

（一）概述

这一类事故往往数量最多。形态包括：漏绑（D1），错绑（D2），无赠品政策却多送（D3），赠品缺货、换赠或延迟发放（D4），赠品活动临时取消（D5），以及限量条件未显著展示（D6）。

赠品类事故的法律判断并不困难，困难在于执行。受影响的订单分散于不同时段、不同渠道，页面、直播贴片、客服话术、政策表容易出现不同步的问题，需要谨慎地判定补发范围。

（二）法律分析

页面上写明赠送的，赠品即构成交易内容的一部分。《广告法》第八条规定，广告中表明推销的商品附带赠送的，应当明示所附带赠送商品的品种、规格、数量、期限和方式。《消费者权益保护法实施条例》第十二条要求经营者履行承诺。赠品也须保证质量，《消费者权益保护法实施条例》第七条第二款及《最高人民法院关于审理网络消费纠纷案件适用法律若干问题的规定（一）》第八条均明确，经营者不得以赠品属于免费提供为由主张免责。

用户退货时，赠品（包括积分、优惠券）应一并退回，不能退回的，经营者可以要求按事先标明的赠品价格支付赠品价款（《网络购买商品七日无理由退货暂行办法》第十二条）。由此反推，赠品页面更应当标明价格，否则退货时无从折价。

D1　漏绑

应当绑定而没有绑定，即为违约。事后不予补偿，即为虚假宣传。这是法律上最无争议的一种。补发无须征得用户同意，但须告知，否则用户先收到主商品而未见赠品，容易产生不满。

D2　错绑

赠送成价值更低之物者，应补发正确赠品，赠送成价值更高之物者，在法律意义上商城有权主张不当得利，但用户并无过错，追回易生投诉，赠品的价值通常也不高，一般不值得。用户不愿接受错发之物、要求换回原赠品者，应尊重其选择。

部分情况下，原赠品尚有少量库存，但需留作他用，此时可以如实向用户说明情况、提供替代方案，争取用户的理解。

D3　无赠品政策却多送

属不当得利，但对用户毫无损害，法律风险近乎为零，纯属成本问题。需要着重把控的是后续的处理方式，比如追回、协商。

D4　缺货、换赠、延迟

更换赠品是单方变更承诺内容。规则中事先写明“赠品可能替换为同等价值商品”的，可以替换，但须告知。未写明的，已下单用户须征得同意，替换品价值不得低于原赠品，不同意者等候补货或退款。赠品超过规则写明的发放时间，属迟延履行，按第二章第七节（发货与交付）给予补偿。

D5　赠品活动临时取消

取消前下单者，承诺已然成立，需要继续赠送。取消后页面、直播间、客服仍在宣传赠送的，构成虚假宣传。如果用户相信了这些宣传而下单的，理论上也需要赠送，不能托词称只是主播、运营、店铺人员的个人行为。

D6　限量条件未显著展示

“限量若干份”“前若干名”“送完即止”，皆为对用户不利的附加条件。《规范促销行为暂行规定》第二十条要求显著标明，《明码标价和禁止价格欺诈规定》第十九条第（六）项禁止“不标示或者显著弱化标示对消费者不利的价格条件”。《民法典》第四百九十六条第二款规定，提供格式条款一方未履行提示义务，致使对方没有注意或者理解与其有重大利害关系的条款的，对方可以主张该条款不成为合同的内容。

话虽如此，实际情况是，只要事先写明了有限量的条件，一般都能得到用户的认可，不会招致麻烦。

（三）处置要义

1. 补发：冻结可分配库存，按原规则核对资格，优先补绑、补发原赠品。

2. 划定范围：补发范围以“最后一处宣传位下线的时间”为终点。

3. 主动告知：补发前以短信或其他方式告知“赠品将单独寄出”及大致时间。

4. 替代方案：原赠品无法交付的，提出可选替代品或合理差额处理方案，说明差异，取得同意。

5. 客服承诺：客服已对外承诺的，自会话记录中查找对应用户逐一补发。

6. 限量争议：限量条件未显著展示的，先以已经写明的限量规则作为依据，获取用户认可。用户坚持主张的，考虑息事宁人。

（四）他山之石

• 重庆江北赠品“货不对板”案（2024年）。某公司宣传购买课程赠送64GB平板，实际赠送16GB的“三无”产品，半年约四百二十单。市场监管部门以虚假宣传拟罚二十三万元，经诉前调解改为二十万元，公司对消费者“退一赔三”。赠品写错，与主商品写错，在虚假宣传的定性上并无二致。

• 购房抽奖送车未兑现案。消费者抽中价值四万余元的汽车，开发商迟迟不交车。法院认定抽奖说明具体、确定，构成要约，判令开发商支付相应价款。赠与或奖励一旦以具体、确定的方式向公众作出，便具有约束力。

• 北京市网络交易执法典型案例（2023年）。某厨具公司在直播中声称“大礼包还剩最后若干单”等虚假信息，并使用无依据的比较价格，被处罚款二十五万元。“限量”若是虚构的，便从营销技巧变为违法行为。

五、宣传与实物

（一）概述

这一类事故包括：商详参数、功能、适配范围写错（E1），主图与实物不符（E2），活动页、首页、橱窗图与实际政策不一致（E3），以及站外素材、短信、推送内容错误（E4）。

这是最典型的“虚假或者引人误解的宣传”，行政罚款上限最高，用户也最易据此主张“退一赔三”。故这一类事故中，法务最核心的工作是判断是否达到了退一赔三的红线。

对消费电子商城而言，这一类风险尤为敏感。续航、快充功率、屏幕参数、防水等级、适配机型，无一不是用户下单的直接理由，三方配件上架时依赖供应商素材，又最易出错。2026年4月，有媒体报道某快充头醒目标注“120W”，商家承认“120W是产品型号”而非实际功率，律师认为此种醒目标注构成欺诈，即便另有小字说明也不能免责。

（二）法律分析

《消费者权益保护法》第二十条要求经营者提供的商品信息真实、全面，不得作虚假或者引人误解的宣传。《反不正当竞争法》（2025年修订）第九条禁止对商品的性能、功能、质量等作虚假或者引人误解的商业宣传，违者依第二十五条处一百万元以下罚款，情节严重的处一百万元以上二百万元以下罚款，构成虚假广告的，依《广告法》第五十五条处罚。《广告法》第二十八条将“商品的性能、功能、产地、用途、质量、规格、成分、价格……与实际情况不符，对购买行为有实质性影响”的情形列为虚假广告。

民事欺诈的认定，实务中考察三点：商城是否知道或者应当知道信息不实，该信息是否足以影响购买决定，用户是否因此下单。《消费者权益保护法实施条例》第四十九条排除了“不影响商品或者服务质量且不会对消费者造成误导的瑕疵”。据此，可按风险高低作如下区分：

1. 高风险：错误涉及核心功能或购买理由，差距悬殊，用户极可能因此下单。例如电池容量写为实际的十倍，不支持快充写成支持，不适配写成适配，宣称的功能根本不存在。

2. 低风险：明显笔误，差距细微，不影响使用。例如数字换位，厚度小数点错误，示意图的细微偏差。可依实施条例第四十九条及《明码标价和禁止价格欺诈规定》第二十一条“没有主观故意”抗辩，前提是有证据证明系失误且改正及时。

3. 中间地带：数量写错、尺寸有差但尚可使用。可补足或退货并给予补偿，用户坚持三倍赔偿的，视单笔金额与舆情风险权衡。

北京互联网法院审理的一起洗地机案具参考价值：商详页主要展示某一型号的圆盘拖布功能，消费者购买的是另一型号，询问客服能否使用圆盘拖布时，客服未明确说明不兼容。法院认定经营者未在商详页对商品功能作出区分说明，也未在消费者询问时明确答复，导致混淆，构成欺诈，判令退一赔三。此案与商城“适配机型”类事故高度对应。

东莞市第三人民法院的一起案件中，消费者购买的手机系统、机身标签与外包装上的IMEI三者不一致，法院也认定欺诈，判令退一赔三。反之，对于明显超出生活消费合理限度的购买，法院不支持惩罚性赔偿。

“仅供参考”与“以实物为准”

“图片仅供参考”“最终以实物为准”之类的声明，属于格式条款，不能排除商城对商品与描述一致的义务（《消费者权益保护法》第二十六条）。其效用至多在于解释细微的色差与示意差异，无法覆盖参数与功能错误。

三方商品的责任

商城自营销售的三方商品，对消费者而言商城即为销售者（《最高人民法院关于审理网络消费纠纷案件适用法律若干问题的规定（一）》第四条）。商城应先行承担责任，再依采购合同向供应商追偿。事故发生后，应翻查合同中有无“商品信息真实性保证”及相应赔偿条款，没有的，复盘时应予补足。对消费者的处理，不应以供应商先行赔付为条件。

数据的出处

续航、充电时长等数据，须注意《广告法》关于数据应当真实、准确并表明出处的要求。福建一起案例中，某汽车经销店在广告中使用“520KM实际续航里程”而未标明数据出处，被处以罚款。手机商详中的续航、快充角标与页尾注释，正是为此而设。

活动页与站外素材

活动已调整而活动页未改、过期素材未下架、橱窗图写错立减金额，均构成虚假宣传，也可能落入《明码标价和禁止价格欺诈规定》第二十条第（二）项“公布的促销活动范围、规则与实际不一致”。对在错误宣传在线期间下单的用户，宣传内容即为承诺。短信与推送中写有优惠的，对收件人同样构成承诺，仅名称写错而不涉及利益点的，解释即可。

（三）处置要义

1. 修正素材：立即修正错误素材，排查同一SPU在其他渠道、相似商品及历史链接中有无同样错误。

2. 风险分级：判定风险高低。

3. 高风险：主动联系已购用户说明真实情况，退货退款且运费由商城承担，或保留商品并获补偿。单笔金额较小、用户坚持退一赔三的，直接赔付较之走到12315更为划算。

4. 低风险：修正页面，进线咨询的可以视情况予以退货或小额补偿。对惩罚性赔偿请求可以“不构成欺诈”抗辩，并备齐“失误加及时改正”的证据。

5. 供应商追偿：同步下架或将库存改为零，准备向供应商追偿的材料。

6. 新老款区分：商品换代或新老款混发的，于商详写明差异，或按新物料重新上架。

（四）他山之石

• 北京互联网法院洗地机适配案（见前述）。商详不清加客服含糊，构成欺诈。

• 最高人民法院网络消费典型案例“九五成新”笔记本案（2023年）。商家宣传“九五成新”，实为改装且含非原厂部件，构成欺诈。

• 福建某汽车经销店续航数据案（2023年）。未标明数据出处即受处罚。参数本身真实与否之外，出处是否标明也为独立的合规要求。

• 2025年充电宝召回与3C认证事件。多家品牌大规模召回，监管部门暂停或撤销多张3C证书，民航部门自当年6月28日起禁止携带无3C标识或召回批次的充电宝乘坐境内航班。对于商城在售的三方配件，认证状态的变化本身即可能引发一轮“宣传与实际不符”的集中投诉。

六、有奖销售

（一）概述

抽奖、集卡、红包雨、助力、前若干名送礼，在法律上都属于有奖销售。这一类事故单次影响人数最多，资损与舆情往往也最重，事例F-01、F-02即是如此。

形态包括：奖品配置错误或发错（F1），中奖名单错误（F2），错发中奖通知或中奖显示错误（F3），奖品超发（F4），抽不到或“未中奖”与规则不符（F5），兑奖障碍（F6），规则或奖品名称有歧义（F7），以及活动中途变更、暂停或提前结束（F8）。

（二）法律分析

比起一般的促销，有奖销售受到的约束更严格：

1. 事前全面公示。《规范促销行为暂行规定》第十三条要求，经营者在有奖销售前应当明确公布奖项种类、参与条件、参与方式、开奖时间、开奖方式、奖金金额或者奖品价格、奖品品名、奖品种类、奖品数量或者中奖概率、兑奖时间、兑奖条件、兑奖方式、奖品交付方式、弃奖条件、主办方及其联系方式等信息， 不得变更，不得附加条件，不得影响兑奖，但有利于消费者的除外。

2. 不得谎称有奖。第十五条列举了虚构奖项、将中奖奖券不投放或未全部投放、未按照向消费者明示的信息兑奖等情形，第十六条禁止内定中奖。

3. 最高奖限额。第十七条规定抽奖式有奖销售最高奖不得超过五万元，同一人多次获奖的累计计算。

4. 建档留存。第十九条要求如实记录设奖规则、公示信息、兑奖结果、获奖人员，保存两年。

5. 法律层面的强化。《反不正当竞争法》（2025年修订）第十一条将“有奖销售活动开始后，无正当理由变更所设奖的种类、兑奖条件、奖金金额或者奖品等有奖销售信息”明确列为禁止行为，违者依第二十七条处五万元以上五十万元以下罚款。以往“活动中途改一改规则”的做法，如今风险显著升高。

F1　奖品配置错误或发错

未按明示信息兑奖，属“谎称有奖”，是有奖销售中最直接的违规，民事上也构成违约。系统显示的中奖结果与实际发放不一致的，用户所见即为商城的表示，不能简单以“以后台记录为准”搪塞。

F2　中奖名单错误

未按公示规则开奖，既是违约，也可能被认定为未按明示信息兑奖，名单错误还直接动摇活动的公平性，容易使用户怀疑存在内定。在对消费者有利时，更正名单是合法的。因此，更正的原则是：补上遗漏的用户，已公示的中奖用户，原则上应当照发。收回已公示的中奖资格，是对这部分人的不利变更。

F3　错发中奖通知、中奖显示错误

中奖通知是针对特定用户的明确表示，用户有理由相信自己中奖。商城可以主张此为错误表示、并无真实的给付意思，但实践中用户普遍不接受，且常常在小红书、微博等社媒平台截图传播。应区分两种情形：页面对所有人普遍显示错误（如人人皆显示中得百万积分），此时系统错误显而易见，以规则为准解释尚站得住，单独发给某人、写有其昵称等特定信息的中奖短信，说服力强得多，用户的信赖更值得保护。

F4　奖品超发

超出规则的中奖，对商城而言是无依据的给付，对用户而言却是“中奖了”。实践中，按规则参与、偶然多中的正常用户，原则上照发，有证据的黑产（批量账号、脚本、一个手机号对应多个账号），依活动规则中的反作弊条款取消或限发。需要注意的是，对外的口径方面，取消的依据是规则，而非商城无法承担损失。另外，执行的时候需要排查同一人累计中奖金额是否超过五万元，超发之后照发，反而可能构成违规。处理规则应在中奖公示页写明，否则取消本身又成了新的“未按明示信息兑奖”。

F5　“未中奖”与规则不符

规则宣传百分之百中奖而未配兜底奖，奖池远大于参与人数却有人不中，应投放的奖品未投放完即结束……这些都属于第十五条所列的典型“谎称有奖”，也最容易被认定为欺诈，因为在用户看来，就是“说好的奖没给”。补救时，应主动向全部受影响的用户补发抽奖机会，而不是只为来询者补抽。

F6　兑奖障碍

“不得影响兑奖”是第十三条的明文要求，《反不正当竞争法》第十一条第（一）项也禁止因信息不明确影响兑奖。用户未能兑奖系因商城的系统或配置所致者，不能以“过了兑奖期”“未填地址”为由不予发放。

F7　规则或奖品名称歧义

活动规则属于格式条款，有两种以上解释的，应作不利于商城的解释（《民法典》第四百九十八条）。除此之外，有奖销售信息还须“明确”。所以，从法律角度而言，歧义的风险基本由商城承担。用户按字面作出的合理理解，商城难以拒绝。

F8　活动中途变更、暂停或提前结束

这是2025年修法之后风险最高的一类。何谓“正当理由”，法律未作列举。可参考的方向是：第三方平台封禁、不可抗力、系统遭受攻击等商城无法控制的情形，一般可以成立，“预算超支”“效果不佳”则基本不能成立。规则中事先写明的中止情形可以增强正当性，但条款本身也须合理。即便理由正当，已经产生的中奖与权益仍然有效，未完成者应有合理的替代安排。

（三）处置要义

1. 证据保全：保全活动开始时的规则、奖池、概率或数量配置、抽奖日志、排序字段、中奖通知与兑奖记录。

2. 暂停异常：暂停异常环节，公告必要事实与更新节点，保留已产生的争议权益。

3. 名单复核：名单问题由业务与数据双人复算，重新公示并说明原因，旧名单不删不隐。

4. 兑现奖品：已确认中奖且可以履行的，优先按原承诺兑现。库存不足的，协商可接受的替代。

5. 错误通知：普遍显示错误以规则为准解释并给予梯度补偿。针对个人的错误通知，尽快一对一澄清致歉，补偿一次定到位。

6. 奖品超发：区分人群，核查累计金额，公示处理规则，延期发奖的主动告知。

7. 兑奖障碍：延长兑奖期或主动补录，能以既有信息解决的即行解决（如按购机地址发奖）。

8. 中途变更：先判断理由属外部还是内部，内部原因者不宜变更有奖销售信息，确需止损的只可在规则允许范围内调整，并给予已参与者对等补偿。

（四）他山之石

• 广东省市场监督管理局七宗不正当有奖销售典型案例（2021年）。

• 广州番禺“无限赏”案（2024年）。某科技公司未明确公布中奖概率，且随意变更中奖概率，被罚款十三万元。变更概率与变更奖品，在法律上同等对待。

• 市场监管总局盲盒违法典型案例（2026年9月）。某公司宣传“八十九元抽手机、百分之百必中”，实际严重不符，被罚款二十万元。“必中”二字，是有奖销售宣传中最需要慎用的词。

• 北京互联网法院直播“前两单免单”案。商家虚构两个“中奖订单号”拒绝免单，平台核查发现两个订单均不存在，法院认定构成欺诈，判令退款并赔偿三倍。

• 整点免单中途追加限制案。原规则为整点特定时刻付尾款即免单，商家次日追加“每时段仅前两名”，法院认定违约，判令退款，因无证据表明商家欺诈，未支持三倍赔偿。

• 舆情两则。2026年9月，某文创品牌因亲签抽选过程不公开引发质疑，发布致歉声明称“活动中的问题我们存在考虑不周”，已配合主管部门调查，并向全部参与者各赠一只盲盒。同年7月，某地有奖发票活动中，市民于支付应用显示中奖三万元，兑奖时被告知“实际上没中奖，是工作人员复核疏漏导致的差错”，引发广泛讨论。前者说明，抽选过程的透明本身即是一项义务。后者说明，“显示中奖却不兑现”即使发生在公共领域，也会迅速演变为信任事件。

七、发货与交付

（一）概述

这一类事故包括：超卖、预售跳票与超时发货（G1），国补代理主体导致卡单（G2），提前发货或卡单失效（G3），错发（G4），权益包与虚拟商品误发或未发（G5），以及货款两失（G6）。

新品首销是这一类事故的高发时段。流速超出预期来不及切换负卖，工厂排产跳票，分货漏分商城渠道，定制款与普通款在系统中无法区分……产生事故的原因多种多样。

（二）法律分析

交付义务

《电子商务法》第二十条规定，电子商务经营者应当按照承诺或者与消费者约定的方式、时限向消费者交付商品。页面写明的发货时间、订单详情显示的预计时间、客服口头所称的“四十八小时发货”，均属承诺。逾期即为违约，用户有权选择继续等待、请求赔偿，或解除合同退款。更换颜色、版本须经用户同意，不得径行改单发货。

何时越出违约的范围

通常的排产延误与流速超预期，不会被认定为虚假营销。但若明知无货仍以现货名义销售，或预售时根本没有排产计划，则可能构成《网络交易监督管理办法》第十四条第二款第（三）项“谎称现货、虚构预订”的虚假营销。

北京市海淀区人民法院审理的一起案件中，商家承诺“十六时前下单当天发货”，两周后方承认缺货，法院认定其虚构库存诱导消费者下单，构成欺诈，判令履行发货义务并赔偿三倍。可见，分货、排产的内部沟通记录，是证明“并非明知”的关键材料。

用户要求退款而商城拖延不退的，落入《消费者权益保护法》第五十六条第（八）项“故意拖延或者无理拒绝”的处罚情形。

已激活手机与七日无理由退货

这个问题对手机商城尤为紧要。海淀法院还审理过一起已激活手机申请七日无理由退货的案件：商家仅在支付页提示“已激活不退”，未在销售必经流程中设置显著的确认程序，法院支持消费者退货，二审维持。《网络购买商品七日无理由退货暂行办法》第二十条也要求，对于经消费者确认可以不适用无理由退货的商品，应在购买流程中设置显著的确认程序，否则不得拒绝退货。

国补与代理主体

国补代理主体的额度、银联账户、物流合作方的问题，对用户而言都是商城的问题。商城先对用户负责，再依合作协议向代理追责。国补政策另要求，发生退货的，已核销的补贴资格应及时恢复并解除绑定，平台不得无故锁定补贴资格。卡单致使用户国补资格被占用而无法使用的，应尽快释放。

提前发货

提前发货对用户本身并无损害，法律风险较小，主要涉及公平（他人先得）与新品保密。拦截于网点、至首销时间后派送，并无不可，但对外口径不得随意编造原因，否则容易聪明反被聪明误。

错发、权益包异常与货款两失

错发属违约，用户可要求换货或退货，往返运费由商城承担，不得强制要求用户自行寄回并自付运费。权益包该发未发者，为违约。不该发而发者（未购机也收到权益包），商城可以主张不当得利，但用户已为权益包付款的，要更加谨慎地处理。如果决定拦截，须同时处理好退款与购机后能否补发的问题。货已送达而用户又获退款的（货款两失），属于用户不当得利，商城可请求退货或补款，但用户并未欺骗商城，处理应以协商为先。

（三）处置要义

1. 同步时效：一发现超时风险，即将真实可发货时间同步给客服，修正页面与订单上的发货时间。客服无准确时间的，不口头承诺天数。

2. 提前告知：超时之前主动短信或外呼告知，给予三项选择：继续等待（予以补偿），更换有货的版本或颜色，取消退款（保留原订单权益或予以补偿）。分批发送，避免咨询集中涌入。

3. 特殊订单：定制、镭雕等无法重拍的订单，单独讨论。

4. 及时退款：选择退款者，及时退款。

5. 国补卡单：国补卡单的，核实额度、认证与配送限制，确认资格能否恢复、原优惠能否保留后，再议取消重拍。

6. 错发处理：错发的，主动告知并提供换货、退货、保留加补偿三项选择，上门取件，费用由商城承担。

7. 货款两失：货款两失的，先请物流拦截，已签收的，礼貌联系用户寄回（运费由商城承担）或重新付款，保留物流签收与退款记录。

（四）他山之石

• 北京互联网法院自营商城抢购取消案。首销场景中，“系统自动审核取消”不能免除违约责任。

• 北京市海淀区人民法院虚构库存案与已激活手机退货案。前者说明“当天发货”的承诺若明知无法兑现即为欺诈，后者说明“已激活不退”须在购买流程中显著确认。

• 某电商平台新款手机首销批量取消订单事件（2025年9月）。用户付款后被自动退款，提示“账号或收货信息不符合系统要求，订单已取消”，平台解释为反欺诈算法所致，但未公开具体标准。据报道，有用户起诉，庭前以四百元和解。反欺诈目的的正当，并不能替代对个案用户的说明义务。

• 国补手机“双地址”劝退事件（2026年6月）。某平台商家销售国补手机，下单十日未发货，劝消费者取消订单，平台客服与商家口径不一。口径不一，本身是舆情的放大器。

八、支付、退款与国补

（一）概述

这一类事故包括：免息或分期异常（H1），退款延迟或卡单（H2），国补补贴或资格异常（H3）。

这一类事故涉及用户资金，加之《金融产品网络营销管理办法》自2026年9月30日起施行，收银台上的分期、“免息”标签都需要放到新规下重新审视，金融监管部门也可能介入，宜默认按Ⅱ级处理。

（二）法律分析

H1　免息或分期异常

“免息”“分期零手续费”是价格承诺。宣传免息而收取利息的，应当退息，此也属《明码标价和禁止价格欺诈规定》第十九条第（五）项“不履行价格承诺”。

《金融产品网络营销管理办法》对收银台的展示提出了新的要求：利率费率等关键信息应当与金融产品合同相关条款保持一致，并以清晰、醒目的方式展示，不得有重大遗漏、刻意隐瞒或误导（第八条），不得通过片面宣传首期费用优惠等方式诱导分期消费，不得使用“低利率”“无成本”等诱导性用语（第十条）。“免息”标签是否落入“无成本”之类，条文并未直接规定，宜作从严理解。年化利率的展示要求，另见中国人民银行公告〔二〇二一〕第三号。

商城显示的费率与支付方实际收取的费率不一致时，应按商城显示的较低标准处理：用户依据的是商城的页面，且新办法要求展示与合同一致。

H2　退款延迟

退款应按承诺时效完成。七日无理由退货的，经营者应自收到退回商品之日起七日内返还价款（《网络购买商品七日无理由退货暂行办法》第十三条）。资金账户属于代理主体或银联，对用户而言并非拖延的理由。故意拖延或无理拒绝退款的，依《消费者权益保护法》第五十六条可处违法所得一倍以上十倍以下罚款，无违法所得的处五十万元以下罚款。所谓“故意”，要看商城是否积极处理：主动告知、积极充值、给予补偿，都是“并非故意拖延”的证据。

H3　国补补贴与资格

对用户而言，应享而未享的补贴，须补差或恢复资格。对监管而言，国补另有一套合规要求：补贴按扣除各环节优惠后的最终售价计算，退货后已核销的补贴资格应及时恢复并解除绑定，不得无故锁定补贴资格，不得“先涨价后补贴”，不得强制捆绑销售，违规者将被约谈、暂停资格、限期整改，逾期未改者取消参与资格并追缴补贴资金。国家发展改革委也表示，对骗补套补、“先涨后补”等违法违规行为，“发现一起、查处一起、曝光一起”。

（三）处置要义

1. 恢复免息：免息失效的，先补配免息或追加贴息预算，使新订单恢复正常。

2. 退还利息：已产生利息的，可引导退货重拍并保留原订单权益，无法重拍的定制订单，按实际利息径行打款。

3. 手续费退差：手续费显示不一致的，按商城显示的标准退差。

4. 展示复核：对照新办法，将收银台的分期展示、默认选项、标签用语、费率展示过一遍，发现问题的，及时推动整改。

5. 退款卡单：退款卡单的，由财务与支付方核对资金、商户状态与可用通道，主动告知用户预计到账时间（留有余量），并给予补偿，催办记录留档。

6. 国补补救：国补被系统取消的已付款订单，引导重拍并保留原订单赠品与价格权益，资格无法返还的，签收无退货后补差。

（四）他山之石

• 以旧换新补贴违规被取消资格诸例。2024年10月，湖北某商贸公司等五家企业因“一机多卖”被取消以旧换新活动资格，被报道称为“全国首张罚单”，同年12月，安徽宿州某电子设备公司因“先涨价后打折”被取消当年参与资格。

• 审计发现的补贴资金问题（2025年）。据各省2024年度审计工作报告，六省被骗取或违规使用的补贴资金过亿元，手法包括虚构交易、提供虚假证明材料，部分地区发现“先涨价后补贴”。

• 上海松江消费券诈骗案（2025年）。行为人虚构订单核销消费券四百余张，骗取补贴十三万余元，以诈骗罪被判处有期徒刑三年、缓刑三年。

九、订单干预

（一）概述

这一类事故的共同点是：商城主动对用户已经成立的订单采取了行动，比如取消、拦截、锁单。它们往往并非事故的起因，而是处理其他事故时的“补救动作”。相当一部分二次客诉，恰恰由这些动作引起。

形态包括：单方取消已付款订单（I1），风控误拦截（I2），关闭未付款订单（I3）。

（二）法律分析

I1　单方取消已付款订单

法律上的起点仍是：已付款订单，合同已经成立。取消须有合同依据（用户协议、活动规则中关于恶意刷单、非生活消费、超限购的条款）与个案证据，无依据而取消者即为违约，未告知理由与申诉渠道的，还可能被认定为设定不公平、不合理的交易条件（《消费者权益保护法》第十六条第三款）。

“为用户着想”（如商品不适配，故代用户取消）也不能替代用户的同意。批量单方取消还有一种放大效应：它把一次普通的配置错误，变成“商城擅自取消订单”，而后者正是用户最易诉诸12315与投诉平台的话题。

I2　风控误拦截

对被误伤的正常用户，拦截即为违约，而“被当作黄牛”本身会令用户格外愤怒。风控规则也须经得起检验：标准不透明、无申诉渠道、误伤率高，可能被视为不公平的交易条件。反之，对于有证据的恶意行为，法律并不保护：北京互联网法院认定恶意利用技术错误的行为不受消费者权益保护。

I3　关闭未付款订单

依事先公示的付款时效关闭未付款订单，属正常的交易规则。临时口头宣布一个新时限并手动执行，则是单方变更交易规则，用户无合理预期，易生投诉。

（三）处置要义

1. 事前会商：运营与产品不得自行决定批量取消已付款订单，须先与客服团队、法务商议。

2. 已取消订单：尽快联系用户说明情况，提供恢复订单或重拍并保留原权益的选项，并予补偿。

3. 自动取消：修复逻辑，被取消用户按原订单权益重拍。

4. 取消依据：找到合同依据，逐单告知理由与申诉渠道。

5. 风控复核：风控拦截前，筛选规则须经风控复核，判定依据（账号关联、地址聚集、脚本请求等）留档，对拦截名单抽样与重点人工复核。

6. 误伤补救：恢复发货或重拍并保留全部原订单权益（含抽奖与中奖资格），给予补偿。

7. 付款时效：付款时效写入规则，并在下单页显示。

（四）他山之石

• 某电商平台新款手机首销批量取消订单事件。反欺诈算法的标准不公开，致使大量正常用户无从申诉，舆情由此发酵。

• 焦作市马村区人民法院进货式购买案。明显超出生活消费合理限度的购买者，不属于消费者。这为取消异常订单提供了实体法上的支点，但须有证据证明“明显超出”。

• 拼多多2019年券漏洞事件。对团伙化的恶意行为，报案与财产保全是比单方取消更有力、也更正当的路径。

十、客服、主播与达人

（一）概述

常见形态包括：政策未同步而客服答复有误（J1），自有直播间口误或贴片错误（J2），合作达人错误宣传或私自承诺（J3），达人爽约、刷单等合作方违约（J4）。

这一类事故最易被低估。业务方常认为“页面没写，是客服说错了”。然而对用户、对监管机关而言，这一区分几乎没有意义。近年直播电商的数起重大处罚，也多由主播的口播而起。

（二）法律分析

J1　客服的答复即商城的表示

客服答复用户，属于职务行为。用户依客服的答复下单，该答复即构成合同内容的一部分，或至少构成《民法典》第四百九十六条意义上的交易说明。中国消费者协会2026年上半年投诉分析将“AI客服承诺不认账”列为热点，并明确指出，以“AI不代表公司立场”为由拒绝履行，不能免除经营者的责任。人工客服与智能客服，在这一点上并无分别。

J2　自有直播间：职务行为与纠错义务

《直播电商监督管理办法》自2026年2月1日起施行。第六十三条规定，直播营销人员的违法行为属于职务行为的，由其所在单位承担行政责任。《最高人民法院关于审理网络消费纠纷案件适用法律若干问题的规定（一）》第十一条也规定，平台内经营者开设网络直播间，其工作人员在直播中作虚假宣传给消费者造成损害的，由该经营者承担赔偿责任。

该办法另设程序性义务：直播间运营者应当建立主播纠错机制，发现口误、表述不完整或不当的，应当现场纠正，并保存相关记录不少于三年（第三十一条）。商城自建的直播间也在适用之列。

口误当场纠正，是否即可免责？纠正之后下单的订单，一般不受影响，纠正之前听到错误信息而下单的，仍应按所言兑现。纠错义务是减轻责任的前提，而非免责条款。

J3　合作达人：先对用户负责，再向达人追偿

对消费者而言，达人在店铺链接下的讲解，就是店铺在宣传。商城作为经营者，首先承担责任，再依合作协议向达人或其机构追偿。

达人所作的额外承诺，效力如何？最高人民法院2026年8月发布的平台经济典型案例中，有一例主播在直播中承诺“假一罚四”并称由其“兜底”，法院认定该承诺有效，判令主播与经营者承担连带赔偿责任。同批案例中，另有一例主播临场发挥、贬损竞争对手商品，被认定为商业诋毁，判赔三十万元。可见，直播间里的“临场发挥”，既可能成为额外的赔偿义务，也可能构成不正当竞争。

参数类错误（如将4G手机说成5G）无从“兑现”，只能于发货前告知真实参数并给予退款选择。店铺设有“假一赔N”一类权益的，尤须在发货之前处理完毕。

J4　合作方违约与刷单

达人爽约，是合作方违约，对消费者影响不大，主要是商城自身的损失，依协议追偿即可。

刷单则不同。虚构交易、编造用户评价，为《反不正当竞争法》第九条与《网络交易监督管理办法》第十四条明令禁止，商城若知情不管，也可能被牵连。发现达人刷单，应当立即拦截，保留证据，书面告知对方，并考虑终止合作。

（三）处置要义

1. 核对原话：核对原始口径，比如政策表、客服知识库、直播脚本、卖点卡、直播回放。

2. 同步话术：修正知识库与话术，并同步至所有客服渠道。原话术已作出承诺的，按承诺兑现，不得以“客服说错了”否认。

3. 自有直播：当场纠正，导出纠正之前的订单，按所言补发或补差，纠正记录与回放保存三年以上。

4. 达人宣传：要求达人重新讲解，对待发货订单逐一告知真实信息，附重新讲解视频与参数表，接受者发货，不接受者退款。

5. 额外承诺：商城先对用户兑现，或与达人约定由其兑现、商城督促，不得将用户推给达人自行交涉。

6. 刷单处理：拦截、退款、保全证据，书面通知合作方，依协议追偿。

7. 协议完善：事后补齐合作协议条款：商品信息以商城提供的脚本为准，口误须当场纠正，不实宣传造成的损失由达人承担，禁止刷单与私自承诺。

（四）他山之石

• 某直播机构月饼产地宣传案（2024年）。直播间将外地生产的月饼宣传为“香港品牌”，合肥市市场监管部门对该机构罚没合计六千八百余万元，责令暂停经营、限期整改，次年3月通报，已按“退一赔三”累计赔付两千七百余万元，完成八十余项整改。

• 某网红红薯粉条案（2024年）。直播间宣称“纯红薯粉条”，检测不含红薯成分，当地市场监管局拟对销售方罚没一百六十余万元，对生产商罚没六百七十余万元。

• 某直播机构口播超出卖点卡案。主播口播内容超出品牌方提供的卖点卡，构成虚假宣传，被罚一百七十五万元，入选市场监管总局2025年发布的直播电商典型案例。此案对商城的启示是：卖点卡须写全、写准，且主播不得超出卖点卡讲解。

• 最高人民法院平台经济典型案例（2026年8月）。主播“兜底”承诺有效，判令连带赔偿，主播临场贬损竞品，构成商业诋毁。

十一、系统故障与个人信息

（一）概述

系统故障本身并不违法，它的法律问题都出在后果上：页面承诺未能兑现（归入前述对应各类），订单被错误取消（归入第二章第九节（订单干预）），用户所见与实际不一致（K2），用户信息被暴露（K3）。故这一类事故的第一步，是“看后果归类”。

例外是信息安全与内容安全。个人信息泄露、官方账号发布不当内容，一经出现即宜按Ⅰ级处理，且伴随法定的报告与通知义务，时限极紧。

形态包括：系统故障与熔断（K1），前端显示与实际不一致（K2），个人信息泄露或异常展示（K3），商业短信误发（K4），不当内容（K5）。

实践中，“系统异常”一词被大量使用，其中也包括人为配置错误。对用户不展开内部原因，并无不可，但面对市场监管部门调查时，应当如实说明是配置失误还是系统缺陷，不能以“系统异常”四字搪塞。

（二）法律分析

K1　故障期间的后果，分别归类

赠品未绑定的，依第二章第四节（赠品）处理。权益未发放的，依第二章第三节（积分与会员权益）处理。订单被取消的，依第二章第九节（订单干预）处理。显示错误的，依本节K2处理。客服系统故障一般不直接对用户产生法律后果，但会导致已承诺的响应时限、退款时限延误，应当跟进。

K2　前端显示是商城的表示

页面显示“领取成功”，用户据此主张兑现的，是有他们的道理的，不能以一句“系统异常”打发。单纯的信息显示错误（物流提示、面单名称），不涉及用户权益的，解释清楚即可，但若显示内容会使用户误以为自身权益受损（例如以为买到了翻新机），则须认真解释并提供核验方式。

K3　个人信息

《个人信息保护法》第五十七条规定，发生或者可能发生个人信息泄露、篡改、丢失的，个人信息处理者应当立即采取补救措施，并通知履行个人信息保护职责的部门和个人，采取措施能够有效避免危害的，可以不通知个人，但部门认为可能造成危害的，有权要求通知。

报告时限更为紧迫。《国家网络安全事件报告管理办法》自2025年11月1日起施行，规定较大以上网络安全事件应当于最迟四小时内报告属地省级网信部门，泄露一百万人以上个人信息的，属于“较大”事件。原因、影响一时无法判明的，可先报基本情况，其余及时补报，事件处置结束后三十日内，按原渠道报送总结。须注意，这一报告时钟与前述对个人的通知义务，是两项独立的义务，应分别核验。《网络数据安全管理条例》第十一条也要求启动应急预案、按规定报告，对造成危害的通知利害关系人。

民事责任上，个人信息侵权适用过错推定（《个人信息保护法》第六十九条），商城须自行证明没有过错。北京市第四中级人民法院审理的一起案件中，海外购平台的订单信息泄露后，消费者遭遇精准诈骗，法院适用过错推定，二审改判平台公开赔礼道歉。行政责任上，情节严重的，罚款最高可达五千万元或上一年度营业额百分之五（第六十六条）。

订单信息是诈骗分子最青睐的材料。2025年，公安部通报快递订单信息泄露系列案件，2026年，四川内江警方破获一起“订单解密”案，涉及个人信息二百余万条。用户接到冒充“商城客服”的退款诈骗电话，往往首先怀疑商城泄露了信息，此时商城的应对，同时关乎法律责任与品牌信任。

系统异常导致用户联系方式乱码、错显的，即便看似只是显示问题，也应立即通知隐私合规，确认数据是否被写入其他记录、是否对他人可见。确未外泄的，也应留存评估记录。

K4　商业短信

未经同意，不得发送商业性信息（《消费者权益保护法》第二十九条第三款、《消费者权益保护法实施条例》第二十四条、《广告法》第四十三条、《网络交易监督管理办法》第十六条）。2026年5月1日起施行的《通信短信息服务管理规定》要求，发送商业短信应有接收方同意的证明，并提供便捷的拒绝方式。内容错误而非营销性质的误发，主要是体验问题，解释即可。

K5　不当内容

官方账号发布辱骂用户、歧视性或侵权内容，首先是品牌与舆情问题，也可能涉及对特定人的名誉侵权、违反网络信息内容管理的规定。不过，一般不会出现这样的情况。

（三）处置要义

1. 止损：暂停出问题的功能、活动或发送任务。

2. 归类：逐一列出故障造成的后果，按前述各类分别处理。

3. 个人信息事件：启动数据安全事件流程，评估影响的人数、信息类别与可能危害，判断是否须在四小时内报告省级网信部门、是否须通知个人，通知内容包括：发生了什么、涉及哪些信息、商城已采取的措施、用户可以做什么、联系方式。

4. 防诈提示：订单信息可能外泄时，对受影响用户发出防诈提示，如商城不会以任何理由要求用户转账或提供验证码。

5. 显示错误：对受影响用户作出解释，设补偿梯度，保持口径一致。

6. 短信误发：停止发送，核对同意记录，营销短信误发给未同意者的，留存排查记录并整改。

7. 不当内容：删除，统一口径，公开致歉，内部复核审核流程。

8. 对监管如实说明原因：区分配置失误与系统缺陷。

（四）他山之石

• 某汽车企业数据泄露勒索事件（2022年12月）。企业收到勒索邮件，对方索要价值二百二十五万美元的比特币，企业公开回应称“不会与不法行为妥协”，并表示将承担相应责任，已报警。公开、承担、报警，是这一类回应的三个关键词。

• 北京市第四中级人民法院海外购订单信息泄露案（见前述）。过错推定之下，平台须自证已尽安全保障义务。

• 某企业会员信息未加密案。上海市网信部门查处某企业一点五亿条会员信息未加密存储、存在泄露风险的问题。网信部门近年持续发布执法典型案例，“未履行数据安全保护义务”是高频事由。

• 四川内江“订单解密”案（2026年）与公安部快递订单信息泄露系列案（2025年）。订单信息是黑灰产的重要来源。

第三章　补救与善后

一、用户协商与补偿

实务中，补偿多以积分、券或小礼品的形式给出，并按不便的程度分档。

与个别用户达成和解，应注意以下边界：

• 不得将依法应提供的退款、履约或补救，与删除真实评价、撤回投诉举报、放弃法定权利等条件捆绑。

• 对方主张的金额较高，或有重复投诉记录的，应回到具体事实与证据审查，不以身份论处。

• 和解协议写明所解决的范围，与同一事故其他用户的处理、与监管程序的推进，互不影响。

• 和解金额不宜对外公开，也不宜作为同类用户的“标准价”。

二、投诉

二〇二五年度，全国12315平台受理投诉两千零三十六万余件，网购投诉举报一千五百余万件，占比过半。同年，全国消协组织受理投诉二百零一万余件，同比增长百分之十四点四五，按投诉性质，售后服务问题占百分之二十七点六八，合同问题占百分之二十三点七九，虚假营销宣传占百分之七点八八，通讯产品位列商品类投诉的高频之列。

中国消费者协会的“双十一”消费维权舆情分析显示，二〇二四年“双十一”期间，直播带货类负面信息逾二十三万条，“优惠套路”类负面信息逾十万条。二〇二六年“618”之前，市场监管总局发布合规提示，重申严查虚假降价、误导促销等行为。

这些数字说明，电商事故的用户，诉诸外部渠道的门槛越来越低。

事故发生当天，应立即保留证据：

附录　用语小辞典

上文沿用了电商行业的若干说法，择要释之。

• 负卖　库存不足时仍允许下单，以待后续到货履约的销售方式。超卖、预售跳票，多与负卖配置有关。

• 卡单　订单因系统、资金、资格或主体等原因停滞于某一状态，无法继续流转。

• 货款两失　商品已送达用户，而用户又获退款，致商城货、款两空的情形。

• 权益包　随机器销售或于签收后发放的一组附随权益，如配件、会员服务、延保等。

• 积分膨胀　在一定条件下，积分抵扣比例或价值按倍数放大的营销玩法。与立减、券叠加时，是价格事故的常见来源。

• 绑赠　在后台将赠品与主商品绑定、随单发出的配置方式。漏绑、错绑，即指这一环节出错。

• 价保　价格保护。购买后一定期限内降价的，按规则补偿差价。

• 政策表　记录某一商品在某一时段全部价格与优惠政策的内部表格。

• 卖点卡　提供给主播、达人的商品信息与宣传要点，直播讲解不得超出其范围。

• 贴片　直播画面上叠加显示的文字或图片信息。

• 分货　新品上市阶段在各销售渠道之间分配货量。

• 黄牛单　以转售为目的、明显超出生活消费需要的订单。认定须有证据。

• 国补　国家对消费品以旧换新及数码产品购新给予的补贴。

• 代理主体　部分商家为承接国补等业务，以其他经营主体名义开展销售与收款的安排。对用户而言，其问题即商城的问题。

• 熔断　系统在流量过载时主动拒绝部分请求以自我保护的机制。

• 进线　用户通过客服渠道咨询。

• 外投　用户向商城以外的渠道（12315、消协、社交媒体等）投诉。

• 二线　处理升级工单、外呼补偿的客服团队。

• 首销　新品首次开售的时段，是事故与舆情最集中的时段。

• 退一赔三　《消费者权益保护法》第五十五条规定的欺诈惩罚性赔偿，即退还价款并赔偿价款三倍，不足五百元的为五百元。

• 重大误解　《民法典》第一百四十七条规定的可撤销事由。撤销须向法院或仲裁机构提出，且受九十日除斥期间限制。

• 不当得利　没有法律根据取得的利益，应当返还（《民法典》第九百八十五条）。积分多发、货款两失，均涉及此点。

The Imperial Family

• Emperor Jiajing: 12th emperor of the Ming dynasty
• Prince of Yu: son of Emperor Jiajing
• Princess Li: consort of the Prince of Yu

The Imperial Court

• Lu Fang: chief of the interior ministry, Emperor Jiajing’s most senior eunuch
• Yan Song: grand secretary of the Privy Council
• Yan Shifan: son of Yan Song
• Xu Jie: deputy grand secretary of the Privy Council and head of the Imperial Treasury
• Tan Lun: the Prince of Yu’s chief of staff
• Zhang Juzheng: head of the Ministry of Defence
• Gao Gong: deputy minister of the Imperial Treasury
• Mao Qing: deputy minister of justice
• Feng Bao: commander of the Imperial Secret Police
• Zhou Yunyi: imperial astronomer
• Luo Wenlong: director of the Imperial Post Office and Yan Song’s confidante

The Zhejiang Provincial Government

• Hu Zongxian: governor of Zhejiang Province
• Zheng Bichang: chief administrator and second in command of Zhejiang Province
• Ho Maocai: head of the Zhejiang Provincial Justice Department
• Ma Ningyuan: mayor of Hangzhou City
• Gao Hanwen: successor to Ma Ningyuan as mayor of Hangzhou City
• Wang Yongji: magistrate of Jiande County
• Hai Rui: magistrate of Chun’an County
• Tian Youlou: deputy magistrate of Chun’an County

Other Characters

• Yang Jinshui: head of the South China Textile Bureau and the Zhejiang Provincial Maritime Affairs Department
• Shen Yishi: silk mill owner and Zhejiang’s wealthiest businessman
• Chee Dazhu: leader of rebel farmers in Chun’an County
• General Qi Jiguang: regional military commissioner responsible for fighting Japanese pirates in southeast China
• Dr Li Shizhen: legendary doctor, considered to be the founder of Chinese medicine
• Zhao Zhenji: governor and imperial inspector of Nanjing
• Li Xuan: protégé of Yang Jinshui and manager of the Xin’an River Flood Control Commission
• Inoue Toushirou: Japanese pirate
• Warden Wang: warden of Chun’an County prison
• Officer Xu: squad leader of troops in Chun’an County
• Officer Jiang: police officer in Hangzhou City

Prologue

On the brink of Chinese New Year’s Eve in 1560, no one in the capital city of Beijing seemed to be in the mood to engage in their usual frenzy of preparations. Since the winter solstice, no snow or rain had graced the city and neighbouring provinces. It was widely feared that a dry, barren winter would lead to drought and spawn large-scale locust infestations. Famine would follow, and the heavenly god soon would descend to earth to conscript his lost people back into the fold.

The public shuddered at the dire situation, which had no parallel in the long history of the Ming dynasty. Ten emperors had ruled, and they had all received their expected annual precipitation. Crops routinely flourished, and business continued apace. Surely this bizarre long-lasting absence of snow and rain was the manifestation of heavenly condemnation. For a while, the rumour mill went wild. Who, exactly, had incurred the wrath of heaven?

That same year – the 39th under Emperor Jiajing’s reign – the state coffers suffered a similar dry spell, running so low that officials working for the imperial ministries in Beijing went months without pay. One could only imagine the predicament of ordinary folks who lived hand-to-mouth in the best of days. Eager for scapegoats, the public soon targeted Grand Secretary Yan Song, who had controlled the Privy Council for nearly two decades, and his son, Yan Shifan, nicknamed “Grand Secretary Junior”. To add insult to injury, a fire in November on the lunar calendar destroyed the Longevity Palace, Emperor Jiajing’s haven for meditation and other Taoist practices.

Gradually, the gossip and rumours reached Emperor Jiajing’s ears. The disturbing weather had induced a political power struggle.

The day before New Year’s Eve, pale winter sun shone on the capital city, and the latest batch of weather reports brought further distressing news when they arrived that morning: no snowfall in the provinces of Shandong and Shanxi, nor in districts under the direct jurisdiction of the capital!

Emperor Jiajing, who had presided over a series of Taoist worshipping ceremonies to pray for snowfalls, finally lost patience. A devout believer in the predictions of a Taoist priest, he seldom trusted the analyses of the imperial astronomer. But in late morning, he hastily summoned Zhou Yunyi, his weather official, to the Yuxi Palace in the west wing of the Forbidden City. Emperor Jiajing requested that Zhou research the weather conditions under the reigns of his three predecessors and produce an analysis that portrayed snowless winters as common occurrences even during times of prosperity. The current abnormal weather, then, would not be linked to the emperor’s rule.

The meeting was a disaster that bright, dry morning. Zhou refused to alter his analysis of the situation, which did not reflect well on the scruples of the Imperial Court. The emperor became so enraged at Zhou that he smashed a jade pestle into pieces and ordered the removal of all Zhou’s imperial titles. Staffed by court eunuchs, the Imperial Police escorted the stunned astronomer to the Meridian Gate, the southern entrance to the Forbidden City.

At noon sharp, the police tied Zhou to a stake on the central pathway. Looking up at the unusually bright sun, he waited calmly for his zhang, a brutal punishment that involved beatings with a large thick wooden stick on the back, buttocks or legs.

“On behalf of His Majesty, I want to question you one last time,” a voice bellowed from the Meridian Tower behind Zhou. “Why hasn’t it snowed this winter?”

“I’ve already stated to His Majesty – the Imperial Court spends with no restraint, and officials at all levels are corrupt. Consequently, the treasury is being emptied out, and ordinary folks are becoming destitute,” Zhou replied, his eyes blinking in the glare. “A snowless winter serves as a dire warning from heaven.”

“Aiya,” the eunuch who questioned Zhou uttered with a disappointed sigh, so soft that it was barely audible, but Zhou could detect the underlying terror in the tone. Before long, the four executioners standing around Zhou began the dreaded ritual: the first two straightened his upper body by inserting their wooden sticks under his armpits while the other two smacked him on the back of his kneecaps. Helpless, the astronomer dropped to his knees. As the police yanked the sticks from under his armpits, Zhou collapsed and fell spreadeagled on the dry brick pathway. The four executioners pinned him squarely down and proceeded to stamp their feet on his hands and ankles. Eventually, they looked up from their crumpled victim to the head eunuch for further instructions.

Feng Bao, the eunuch who commanded the Imperial Secret Police, did not issue his final order right away. Looking hesitant, he strolled over to the imperial astronomer and bent over. “It’s New Year’s Eve tomorrow, and your family members are waiting for you at home,” he whispered in a pitying voice. “Could you for heaven’s sake change your statement?”

Imploring Zhou “for heaven’s sake” felt cruelly ironic to an official known for his outspoken righteousness. Zhou could not respond. Closing his eyes, he pressed his wobbly forehead close to the ground. A few tears leaked from the corners of his eyes. Zhou’s muteness soon exasperated Feng, who sprang to his feet. “I want to ask you one more question,” he raised his voice. “Who instructed you to deliver the blasphemous statement to His Majesty?”

“I was an official of the Imperial Government, and my job was to observe the astronomical phenomena,” Zhou finally spoke, with his eyes closed. “I faithfully interpreted the heavenly signals, and with honesty I conveyed the messages to His Majesty, the son of heaven. Nobody could tell me what to do, except our heavenly father.”

The short but bulky Feng stepped back and turned his gaze away from the heretical astronomer. With his feet turning inward, he muttered through his teeth, “Start the zhang.”

The four executioners looked at each other knowingly – an inward turn of Feng’s feet signalled the death penalty. Moments later, four thick wooden sticks struck hard on Zhou’s lower back, just above his kidneys. Each horrific stroke landed silently. But the astronomer did not moan or show quick evidence of any external injuries, even as his internal organs shattered. Finally, blood spewed out of Zhou’s mouth and nose.

Twenty strokes later, two eunuchs lifted Zhou from the ground. Re-inserting their wooden sticks under his armpits, they propped him up. Zhou’s upper body wilted, his once-wise head now drooping onto his shoulder like an idiot doll’s. Feng walked over and cupped Zhou’s head in his hands like a scientific specimen. There was no sign of life. To certify Zhou’s death, Feng plucked off a long hair from the astronomer’s head and placed it under the dead man’s nose. The hair did not move.

With a long sigh, Feng stood up. “Notify his family,” he ordered. “Tell them to come and collect the body.”

The white sun hung stubbornly over the Forbidden City, bathing the empty palace with lukewarm light. With the day’s activity and quick crescendo to brutality, it was hard to believe that Emperor Jiajing had deserted this imperial complex for 21 years.

1

Considering the promise of its name, Longevity Palace should never have burned down, forcing Emperor Jiajing to relocate to the outlying Yuxi Palace. Disillusioned, he spent most of his waking moments sequestered in the Taoist Alchemy Room which he christened “Cultivation, Discipline and Prudence”. Once again, however, the emperor’s isolated existence and devout faith could not attain the heavenly blessings that his kingdom sorely needed. When a worrisome drought plagued the surrounding land, he felt obligated to reappear in public and address the crisis by issuing a rare edict of self-criticism:

Due to my negligence and insufficient reverence for the heavenly god, a nourishing snowfall has failed to bless us. If any of you in the myriad regions have committed offences, they must rest on me alone. In recompense, I hereby vow to fast and pray with all my heart for snowfall from the first to the fifteenth of January 1561. Hopefully, my sincerity and piousness at Yuxi Palace will draw the favour of the heavenly god to honour the Ming empire with an auspicious snowfall.

Emperor Jiajing would not remain alone for long in his self-imposed austerity. Other officials soon rushed to mimic his example; Privy Council members from Grand Secretary Yan Song on down. Lu Fang, the eunuch who headed the Interior Ministry, also expressed remorse and assumed blame for the bone-dry winter. A notice jointly issued by the Privy Council and the Interior Ministry appeared on the walls of the Meridian Gate: “In solidarity with His Majesty, all imperial officials in Beijing will eschew lavish cooking and refrain from eating meat or fish during the New Year holidays.”

Publicly, officials unanimously supported the austerity measures, going about their business with fear and sobriety, but in private many stealthily celebrated the holiday with contraband meat and intoxicating drinks in their deep courtyard mansions. Regardless of how the public chose to celebrate the New Year, if the Emperor’s prayers and fasting produced no snow by the fifteenth of January, the first full moon, the results could be calamitous for the entire empire. It was hard to predict who would incur the wrath of the famously capricious emperor and become the next scapegoat. Politics was becoming as unpredictable as the weather.

After two weeks of fervent prayers and sacrifice, snow still eluded the parched kingdom. Now the fifteenth of January, in the wee morning hours, dark heavy clouds gathered over the west wing and blotted out the stars, but there was still no sign of ice crystals. When daylight broke, Emperor Jiajing was to convene the much-dreaded annual treasury meeting at his residence. Exhausted and thin, the emperor was incredulous that he had not been able to generate a single six-sided flake. He wondered how he would face his subjects, much less his Privy Council members and the five eunuchs controlling the Interior Ministry. Fierce arguments over blame for the abnormally punishing weather promised to intensify the power struggle between the Yan clan and the “Clear Stream” faction led by the Prince of Yu. Countless lives could be lost.

Even without the life-giving snow, fireworks on New Year’s Eve went ahead as usual. For the Lantern Festival, which fell on the fifteenth of January on the lunar calendar, tradition dictated that the palace lit up red lanterns a day earlier than ordinary households. Before three o’clock that morning, the eunuchs and maids had arisen even earlier than usual. For a few hours, shadows of servants and officials reflected busy preparations according to custom. When the lanterns under the eaves lit up one after another, they formed streams of crimson in the vast expanse of darkness. The lanterns’ long beams silhouetted the intricate palace rooftops against the sky as if the buildings were floating in mid-air.

Two young eunuchs were tasked with finishing up the remaining lanterns. The tall, stronger one hoisted a shorter, thin colleague up in the air by his legs. “This damn weather,” whined the eunuch on the top as he tried repeatedly to ignite a tinder by striking a flint with his cold, numb hands. “Even without the snow, it sure feels cold as hell.”

“Shut your filthy mouth,” cursed the fellow beneath, who was hoisting him up by the legs. “If anyone hears you, our hides could be tanned for jinxing it, especially if we still don’t get any snow today.”

Muttering more epithets, the eunuch balanced on top finally procured the sparks he needed, and the lantern lit up. As he slowly pulled a red muslin cover over the lantern, his body suddenly froze. The eunuch’s hands stopped in mid-air, and his eyes gazed at the lantern cover.

A big feathery snowflake had landed on the left corner of the red cover. After one, he saw another.

The yeoman shut his tired eyes in disbelief and opened them again to see another snowflake followed by another.

“What’s taking you so long?” grumbled the eunuch beneath him. “Did you see the face of the Zhu Yuanzhang or something in the flame?”

“Snow!” he yelped in his high-pitched voice, shattering the quiet solitude of the dark empty palace.

The eunuch beneath him stiffened, and for a moment the screamer feared he had hallucinated the powdery boon.

Fortunately, white flurries danced silently in the air, glistening in the red light before merging into the darkness.

“It’s snowing!” the second eunuch affirmed and became so exuberant that he nearly lost his grip on the fellow lamplighter.

Soon, screams of shrill confirmation sounded in various corners. A high-pitched chorus penetrated the thick cold air.

“Who’s that screaming?” A stern voice put a brake on the excitement. The courtyard quietened down momentarily as Feng Bao emerged, along with several other members of the Imperial Police. The grim-faced officers paused under the eaves of a palace on the left side of the space rumoured to be the emperor’s residence.

Slowly, Feng inspected the early-morning sky. Reaching out his fingers as though expecting a bird to come and perch, he caught a few lacy flakes. Feng’s eyes sparkled for the first time in months, and he announced, “The heavenly god has finally answered our prayers and granted his blessings.” He blabbered, “I’m going to report the good tidings to His Majesty first and then run over to the Interior Ministry. Take those screaming boys to the House of Honours for punishment later. Before I bring the happy tidings to His Majesty, I want everyone to keep their mouths shut. Otherwise, I’m going to have the shrill ninnies beaten to death.” The director’s firm practical side quickly countered his uncharacteristic euphoria.

“Yes, sir!” His taller and stronger subordinates bowed to him before scattering to capture the disobedient eunuchs. Feng turned on his heel and hurried over to Yuxi Palace, walking with long strides.

Two bronze braziers warmed the Interior Ministry’s duty room. Filled to the brim with silver charcoals, the braziers glowed like two red eyes. But the warm air and red festival lights failed to lift the spirits of five senior eunuchs who were sitting on a row of fragrant rosewood chairs against the north wall. All looked sullen, and a few young eunuchs fussed around them. Some knelt in front of their feet, replacing their warm slippers with boots, while others stood behind their seats, trying to wrap their necks with white fox fur mufflers. The five patriarchal figures were preparing for that morning’s Privy Council meeting.

Suddenly, the thick curtain lifted, and a bitter cold wind gusted in. A eunuch on duty in the courtyard burst in, his face flushed. “Congratulations,” he exclaimed, dropping to his knees before the group. “Congratulations to all my papas here. The heavenly god has bestowed snow upon us, at last. It’s becoming quite heavy.”

Both the senior and junior eunuchs in the room rose simultaneously. Even though some were eager to step out and examine the brilliant phenomena for themselves, they resisted the urge. Instead, everyone turned to the eunuch sitting in the middle. Named Lu Fang, he was known to the outside world as the interior minister and within the imperial compound as “Daddy”. Excitement glimmered in Lu’s eyes, but he quickly composed himself. Rather than dashing out into the courtyard, he simply shot a casual glance at the curtain. It was as if he could see the snow through the big thick fabric with his deep sharp eyes.

“Kudos to His Majesty,” he praised. As chief of the Interior Ministry who commanded a staff of ten thousand strong, Lu supplied the right words for every occasion. “Let’s take a look,” he said before stepping towards the door.

Whiteness carpeted the ground, which glistened under the red lanterns. The snowfall had intensified. What an auspicious scene!

“His Majesty must be meditating at the moment,” Lu Fang told his deputy Huang Jin.

“I assume so,” Huang answered.

“Since it’s almost time for the treasury meeting, why don’t we walk over to His Majesty’s residence together,” Fang suggested to the rest of his deputies. “Then, we can report the good tidings in person and offer our congratulations.”

As the group was about to leave, the fellow who first reported sightings of the snowfall crept up to Lu. “I hear that Feng Gonggong^(1) forbids anyone from talking about the snow because he’s on his way to report the good news to His Majesty,” he whispered.

“Are you sure?” Lu asked, his long thick eyebrows quivering slightly. “Who told you this?”

“Feng Bao is quite fast on his feet,” quipped Chen Hong, Lu’s executive deputy, in his cold shrill voice. “His Majesty might be so pleased that he would invite Feng to join the Privy Council and send all the rest of us packing.”

“If Feng Bao has already done the reporting on our behalf, why don’t we wait for a few more moments,” Lu decided. “Once he’s done relaying the good tidings to His Majesty, I assume he should at least make an appearance here.”

Before Lu even finished his sentence, a junior eunuch carrying a lantern ushered Feng into the courtyard through a moon-shaped entrance.

“Oh, Daddy and my brothers, I’m glad you’ve seen the snow,” he said, kneeling on the snow-covered stairs in front of Lu. “Your son is here to offer his sincere congratulations! This heavy snowfall will put His Majesty in a good mood, making things easier for Daddy and my brothers.”

Lu did not meet his eyes. Feng kowtowed again before springing to his feet. Once more, he tried to ingratiate himself with Lu.

“So His Majesty is aware of the snowfall, I assume,” Lu finally spoke with a fake smile.

“Yes, Your Highness,” Feng replied. “Your humble son has already reported the amazing news to His Majesty on your behalf.”

“What did His Majesty say when he heard of the miracle?”

“Ah… well, I didn’t exactly get to see His Majesty,” Feng said. “I knelt outside the palace and relayed the news. I heard the bell chime once. So I assume His Majesty knew about it.”

“I thought the emperor would have been so pleased that he would grant you a promotion at the Interior Ministry,” Lu interrupted him with a sardonic laugh.

The four deputies glared at Feng. A startled look spread across his face.

“That’s true,” Cheng Hong, who had just badmouthed Feng a few minutes before, mocked in his icy tone. “It’s time for us to make room for you.”

Fear distorted Feng’s face. He quickly plopped to the slippery white ground, slapping both sides of his face fiercely. “I deserve to die, I deserve to die,” he pleaded. “All I did was to bring good tidings to His Majesty on Daddy’s behalf. Other than that, I harboured no selfish intentions.”

Lu ignored his pleading. “The other council members are probably there already,” he said to his deputies. “Let’s get going.”

The junior eunuchs put the cloaks on the patriarchs and handed them white fox fur hand muffs. Sedan carriers removed the tarpaulins over the parked two-wheeled vehicles in the courtyard, flinging off the snow. Lu and his deputies stepped down the stairs, and each climbed into his litter. Before departing, their porters handed each of them a leather blanket to cover their knees. Bundled up and fussed over like children, they were ready for the happy errand. A few minutes later, five sedans left the Interior Ministry’s courtyard in the accumulating snow.

Those employees who were supposed to stay and staff the night duty room also slipped out briefly to watch the stunning weather. Soon, the courtyard became deserted. Feng remained alone, a pitiful figure kneeling on cold, immaculate ground.

Daylight broke when the procession of sedans left the Interior Ministry complex. The ubiquitous red lanterns cast their faint and grey light on the snow. It was hard to believe that in merely half an hour, the ground had been completely transformed into an expanse of whiteness. The snowfall was supposedly a “heavenly” event worth celebrating, but Feng’s earlier ban dampened the enthusiasm. Except for the occasional snow shovelling, a dead silence reigned.

Seeing that the procession of sedans approached, the eunuchs who were busily shovelling the pathway, quickly dropped to their knees. Soon, palace maids and eunuchs who were running errands in the vicinity followed suit – the blanketed pathways, stairs and corridors were packed with Imperial Court staff on their knees and with their eyes cast downward as signs of respect.

Scanning the obsequious, quiet crowd, Lu had an idea. “Feng has really made these kids scared,” he said to an assistant who escorted his sedan. “The snow heralds auspice for our Ming empire. Let them stop shovelling. Ask them to rise and go to celebrate the good tidings. The louder they shout, the better.”

“Yes, sir,” the eunuch answered before commencing to scream at the top of his lungs. “I have words from Lu Gonggong. The snow heralds the auspices of our Ming empire. Stop shovelling. Get up and relay the good news – the louder the better.”

After a pregnant pause, one eunuch rose. Tossing his broom into the air, he released a pent-up holler. “Snowfall!”

“Snow is falling!” Others began to cheer. “The heavenly god is blessing us with snow. The heavenly god has bestowed auspicious snow on our Ming empire.”

As the sedan carriers moved forward through the ecstatic crowd, a benevolent smile illuminated Lu’s face.

Before approaching the Yuxi Palace, Lu suddenly halted his sedan and the others behind him quickly. In the distance, Lu could see several cloaked figures passing through a moon gate and coming towards them.

“They are arriving as well,” Lu said to his deputies as he disembarked from his sedan. “Why don’t we walk over to greet them?”

The four deputies complied, descending from their sedans and following Lu.

Despite the intense snowfall, the morning sky began to brighten up. A small entourage quickly came into clear view: they were members of the Privy Council, donning red robes and thick cloaks with white fur earmuffs, outfits specifically reserved for top-ranking imperial officials.

Grand Secretary Yan Song, who rested in a big sedan chair, led the group. Deputy Grand Secretary Xu Jie and council members Yan Shifan and Li Chunfang walked behind. The previous December, the emperor had specifically designated Gao Gong from the Ministry of Treasury and Zhang Juzheng from the Ministry of Defence as observers of council meetings. Both were known opponents of the notorious Yan clan. The emperor’s pointed invitation to the council’s most important finance meeting came at the height of public frustration over the government’s budget problems. Additionally, the ominous implications from the disobedient weather had added a sense of foreboding and unpredictability.

Yan Song assumed his poker face. In contrast, his son, Yan Shifan, projected confidence and preparation. As head of the Ministry of Construction and Personnel, he was responsible for most of the previous year’s budget deficit. Could it be that the emperor had invited these two provisional members to restrict him and his father? Or perhaps His Majesty had intended to determine if members of the Clear Stream faction instigated the latest round of criticism against him and the Imperial Government. Both possibilities were chilling.

Fortunately, the magnificent snowfall would ease much of the tension: if those two dared attack him, Yan Shifan would resort to a sabre that never failed him before – accusing Gao and Zhang of conspiring with the convicted imperial astronomer against the emperor. If things were to go Yan’s way, the charges could no doubt cost the newcomers their lives.

Yan Song’s sedan lurched to a stop. The ageing grand secretary, with his grey hair and long grey beard, realised that the man walking towards him was Lu Fang and hastily whispered to his son, “Quick, help me get out.”

Yan Shifan raised his arms to help his father alight from the sedan. The father-son duo walked over to greet Lu. Other council members, including Gao and Zhang, followed the Yans but kept their distance.

“Congratulations,” Lu offered the fist and palm salute while they were still a dozen feet apart.

“Likewise, likewise,” Yan Song returned the greetings, his smiling face blooming like a chrysanthemum.

“Grand Secretary,” Lu held Yan’s other arm and complimented the octogenarian with equally feigned enthusiasm. “The big snowfall is truly age-reversing. If you were eighty last year, you would turn seventy-nine this year.”

“Lu Gonggong, are you making fun of my old age?” Yan Song teased in his signature Jiangxi accent. “The snowfall is life-saving, but if it had rained silver dollars I would have been happier because I would no longer need to worry about our budget and could retire with ease.”

“We cannot allow you to retire,” Lu joked, tightening his grip over Yan’s right arm as they slowly climbed the stairs that led to the Yuxi Palace. “If His Majesty lives ten thousand years, you should live at least one hundred years. Don’t forget you have twenty more years to serve His Majesty.”

“Twenty more years?” blurted Yan Shifan in his usual acrimonious tone as he walked beside his father and Lu. “I’m sure that would make some people really upset.”

Yan Shifan was only in his early fifties. Having lived in the capital city for more than two decades, he had largely lost his accent and spoke like a local Beijinger.

“How could that be?” Lu said with an awkward laugh while glancing sideways at other council members behind them. Pretending that they hadn’t heard it, the other council members simply shifted their gazes elsewhere.

“We’re crossing the river in the same boat, and collaboration is key,” Lu said, still smiling.

As the group ascended the stairs, a plaque inscribed Yuxi Palace towered over them. Yan had personally written the calligraphy, which conveyed vigour and strength.

In front of the entrance, silence fell. The junior eunuchs guarding the palace stepped up to greet members of the emperor’s inner circle. They helped untie the guests’ cloaks and shook them vigorously to clear the snowflakes. Every single move was done briskly and quietly as if even a decibel of noise could disrupt the solemnity of the palace.

Once inside, Lu quickly took on a sombre expression. “I assume you are well aware of the incident involving Zhou Yunyi, the imperial astronomer, the day before New Year’s Eve.” He slowly scanned the faces of each colleague and reminded them. “His Majesty has been staying here to pray for snow since New Year’s Day. The heavenly god has manifested his mercy today, but, with the looming budget deficit, I’m not so certain if even the auspicious snow alone can truly buoy the spirit of His Majesty. I beseech each one of you to show some flexibility and, if possible, let certain items pass without making too much of an issue. We can figure out other ways to resolve it next year. I’m sticking with what I just said – we’re crossing a river in the same boat. Regardless of what happens, collaboration is key.”

Yan Song nodded in agreement, but Yan Shifan shot a few nasty glances at certain council members standing behind him. Once again, they simply ignored him by gazing at the ground.

Two junior eunuchs proceeded to open the gate to the emperor’s inner chamber – since pushing the iron gate could produce loud squeaks, the young eunuchs relied on their strong arms to give the heavy double doors a small, strategic lift before easing it inside slowly. Once the doors slid open, the group marched in like geese in a V-shaped formation – eunuchs from the Interior Ministry on the left and members of the Privy Council on the right.

The emperor’s new residence looked spacious, but nothing like a palace hall. At the centre sat a simple rosewood horseshoe chair with a round back, rather than the usual Sumeru platform. The customary design in other palaces symbolised Mount Sumeru as the centre of the earth and universe. An enormous three-legged incense burner with a lid, hollow-carved with the Taoist trigram symbol, stood behind the chair.

Light smoke swirled out of the hollow top of the burner, sending a faint fragrance of incense wafting in the air. Behind a wall on the north side hung a plain white scroll, on which appeared a few lines by Lao Tse, the founder of Taoism. The elegant calligraphy proclaimed, I have three precious things which I hold fast and prize. The first is gentleness; the second is frugality; the third is humility, which keeps me from putting myself before others.

Four square columns supported the soaring ceiling; two on each side and seven metres apart. Between each set of columns lay two long rosewood desks, piled up with stacks of documents, books, empty letterheads, writing brushes and ink boxes. Strangely, no chairs sat behind the long desks. A lone embroidered drum stool sat at the end of the table on the right side. Besides, the bronze ink box on the left desk contained red ink while its twins on the right desk held black ink.

In the corners, slightly behind the columns, rested four gigantic bronze heating stoves. Four puppet-like eunuchs closely monitored the burning silver charcoal inside. This simple but effective heating device, with bluish red flames flickering inside, warmed up the palace like a spring breeze – without a single wisp of smoke.

Lu and his four deputies lined up on the left while Yan Song and his fellow Privy Council members moved to the right. Simultaneously, they knelt and kowtowed three times to the empty throne in the middle of the palace. When the meeting commenced, the eunuchs moved over and stood behind the long desk on the left while Deputy Grand Secretary Xu Jie and four other council members stood behind the right desk. Grand Secretary Yan Song hobbled over to the front and sat on the embroidered drum stool next to the desk on the right.

Thus, the 1561 AD treasury meeting officially opened in front of the emperor’s empty throne.

Cabinet members held their breath as Lu turned his eyes towards the passageway curtained gracefully by white veils on the east side of the palace. Soon, everyone else looked in the same direction. The opening led to the palace’s outer wall on the south end, with paned windows that were left open. The emperor’s Alchemy Room, where he had lived in isolation for two weeks, stood on the north end. Now the emperor kept the inner chamber door wide open, allowing flurries of snowflakes to twirl into the room. The cold air did not seem to bother the emperor. In fact, the snowflakes obviously delighted him.

A few moments later, a chime sounded from a brass singing bowl. The bright sound, which signified that the emperor was ready, echoed in the hall.

“I call this meeting to order,” Lu declared.

The four puppet-like eunuchs who were tending the stoves quietly covered the heating devices with bronze lids. Duty done for now, the eunuchs silently scampered away, like cats.

As usual, Lu presided over the proceedings and moved directly to business. “We’ll follow our usual routine – the council will review last year’s actual expenditures from all the ministries, the north and south capitals, and the governments of thirteen provinces. Then, we will decide which items to settle and which ones to deny.” He paused but hardly glanced up before barrelling into his next item. “Regardless, every item needs a detailed explanation. At the same time, we will deliberate over next year’s budget. The Ministry of Revenue will compile a list of major spending items and come up with a total number. The council will review each item with comments. Let’s approve as many as possible. What do you think?”

Yan Song spoke in his usual measured tone to set the theme for the meeting. “Thanks to His Majesty’s heavenly virtue and everyone’s hard work, the most difficult days are finally behind us. Last year, two provinces suffered severe drought, three provinces were struck with extensive flooding, wars broke out in the north and southeast, and we also had that damaging fire inside the palace here. To tell you the truth, I didn’t know how we would get through these trying times. With His Majesty diligently tending state affairs, toiling away for our Ming empire was the least we could do. It just so happened that several provinces suffered snow deprivation this winter, and some people took advantage of the dire situation, attempting to attack our Imperial Court. If it hadn’t snowed today, we would have had to submit our resignation. Anyway, none of these dire prognostications matter. The most important thing is how well the crops will fare this year. Fortunately, we are having snow today, and it’s substantial. We also shouldn’t forget the fact that His Majesty has been fasting since New Year’s Day to pay homage to heaven. His prayers have secured this snow because the heavenly god has been deeply moved by His Majesty’s piety. We now have the continued blessings of the heavenly god. As long as we, the stewards of our empire, continue to work tirelessly, our country will be able to maintain its power and prosperity.”

Yan Song then paused for a few seconds – not for the applause or recognition of his peers, but rather to wait for the emperor next door to savour his words. Meanwhile, the Privy Council members standing behind the two tables looked on solemnly, seemingly oblivious to Yan’s obviously flattering remarks.

If one took the passageway and walked north into the emperor’s Alchemy Room, the first thing in sight was an altar, with the statues of Three Divine Taoist Masters. Underneath the altar stood a platform in the shape of the Taoist eight trigrams, with a yellow meditation cushion on top. Since no one was sitting on the platform, the brass singing bowl with brass mallet placed diagonally inside looked conspicuous on the rosewood shelf, reminding one of the crisp chiming that filled the hall before a meeting commenced.

A row of gigantic rosewood bookcases lined the wall adjacent to the palace hall. Zhu Houcong – Emperor Jiajing – a tall thin man with long hair tied into a bun on top, sauntered back and forth in front of the bookcases. Dressed in a light loose silk robe, he seemed to be in his early fifties. If this had been elsewhere, nobody would have guessed that he was the most powerful man in the Middle Kingdom.

Since moving into this mansion the previous November, Emperor Jiajing had converted it into an alchemy room, doubling it as his living quarters, where he reviewed Imperial Court documents and reports. A special place certainly deserved a special name. To illustrate the virtue of self-reflection, he christened it “Cultivation, Discipline and Prudence”. The emperor’s emphasis on “self- discipline” also served as a cautionary message and reminder for his council members sitting in the hall and for tens of thousands of officials governing the provinces.

The accumulating snow outside obviously pleased the emperor, and he appeared somewhat relaxed. Despite fifteen days of fasting and non-stop meditation, he showed no palpable sign of fatigue. Pausing in front of a bookcase marked with the label “Ministry of Revenue”, he pulled out a stack of ledgers. Instead of opening them, however, he tilted his head, staring at the gap in the bookcase where the ledgers used to sit – the back of the bookcase was not sealed, and standing in front of the bookcase accorded the emperor a more advantageous position than his usual seat on the eight-trigram platform. From here, he could privately observe the discussions more clearly. Having heard the first half of Grand Secretary Yan Song’s opening remarks, he was waiting for him to continue.

At the same time, Yan Song knew perfectly well how his words would be received. Having served His Majesty for twenty years, he felt smug about his special bond with his ruler. In fact, he knew exactly where the emperor was standing at that very moment. So he took a pause and measured his tone before continuing. “Over the past month, everyone has been working hard to itemise and review last year’s expenditure,” he stated. “At the same time, all of the council members have already attached their comments and suggestions. If the Interior Ministry signs off on them, we’ll be able to settle last year’s bills and move on to this year’s budget.”

Yan paused again and turned to his deputy, Xu Jie, who also headed the Ministry of Revenue. “You and Zhang Juzheng are in charge of the Ministry of Revenue, which reviews all of the treasury reports,” Yan Song continued. “I assume you have gathered the comments from other council members. Please give us a report before we submit them to Lu Gonggong’s Interior Ministry for approval.”

“The Ministry of Revenue did not receive the reports and council members’ comments from Yan Shifan until yesterday,” Xu said slowly – he was as calm and calculated as Yan Song but did not have the grand secretary’s overarching authoritative air. “My colleague Gao Gong and I spent the whole night perusing the reports. We have signed off on some but left some unsigned because we wouldn’t dare without further discussions with all of you.”

“What?” Yan Shifan, the son of the grand secretary, reacted first. “Do you mean to say that you didn’t sign off on some of my budgeted items? Which ones?”

Lu and his four deputies at the Interior Ministry were also taken aback by Xu’s statement. They looked to Xu for explanations.

“We approved the defence budget,” Xu continued, maintaining his composure. “But if we approve the budgets of the Ministry of Personnel and the Ministry of Public Works, we could incur a huge deficit in the coming year. So we did not sign off on them because we don’t have the authority to do so.”

Yan Shifan repeated his question. “Are you saying that you object to budgets prepared by the Ministry of Personnel and Ministry of Public Works?” Even though he had considered the possibility of opposition at the meeting, he did not anticipate that Xu, known for his prudence and acquiescence, would be the one to raise tough questions. Shocked, Yan Shifan’s eyes widened. In fact, other council members and eunuchs also looked on in disbelief. The air seemed to have frozen along with the weather outdoors.

Xu’s words also caught the attention of Emperor Jiajing. He raised his head abruptly and stared at the ceiling. Once again, the voice of his former astronomer, Zhou Yunyi, reverberated in his ear – it sounded so distant and yet so close. “The Imperial Court spends without restraint… the heavenly god is sending a warning… heaven’s warning.” The emperor’s dismal eyes focused on the cover of a treasury report he held in front of him.

Back in the hall, Deputy Grand Secretary Xu Jie closed his eyes as usual after his short remarks. Yan Shifan faced Gao Gong, the deputy minister of revenue. Despite his visible efforts to contain his anger, his rejoinders sounded like howling. “You were all there when the ministries presented their budgets, and now you authorise some while denying others. What in the name of the heavenly god is your Ministry of Revenue trying to do?”

His angry voice vibrated in the otherwise-quiet palace.

Gao pushed forward a pile of ledgers and reports on his desk and coughed slightly to clear his throat. “Your Highness, the Department of Revenue is part of our Imperial Government,” he said in a low voice that exuded arrogance. “Please do not refer to it as ours. The Ministry of Personnel and the Ministry of Public Works also belong to the Imperial Government, and they shouldn’t be called yours either. If the Ministry of Revenue must follow everything that the Ministry of Personnel and Ministry of Public Works dictate, why don’t you take it over? In this way, there is no need for us to discuss the issues here.”

The bold and blunt remarks made everyone nervous. The assembled council members looked from Gao Gong to Yan Shifan, who was slightly taken aback by what he had just heard. But he quickly recovered from his shock. “One of you is the minister of revenue and the other the deputy minister. What’s wrong with calling it ‘your Ministry of Revenue’? Of course, the Ministry of Personnel and the Ministry of Works are not my family business. The council has attached their support for the budgets of these two ministries. If you are unwilling or unable to handle these tasks, please feel free to let us know. But you threaten the Imperial Court by refusing to sign off on the budget. Do you know the consequences of delaying big government projects?”

“Yes, if you want to remove me from my post, please go ahead,” Gao Gong replied, refusing to budge. “After reviewing the budget report you submitted yesterday, both Minister Xu and I are prepared for this eventuality. If you don’t think we can handle the revenue, feel free to appoint anyone you see fit.”

“Gao Gong!” Yan Shifan raised his fist, but before it landed on the table, his father, Yan Song, stopped him with a stern warning.

“This is His Majesty’s council meeting,” he reminded.

Inside the Alchemy Room, Emperor Jiajing, who was flipping through the budget book, paused and glanced at the hall through the gap in the bookcase.

“Father,” Yan Shifan sounded wounded by the reprimand.

“Do not call me ‘Father’ here,” Yan Song could be heard saying to his son. “We’re at the council meeting, and you are addressing an official of the Ming. At meetings like this, everyone is entitled to his opinions. Gao Gong, why didn’t the Ministry of Revenue sign off on the budget approved by the council? If you have run into any problems, please share them with the council.”

Emperor Jiajing pricked his ears and listened.

“Just a reminder, everyone,” Lu’s voice said. “Let’s limit our discussions to issues only – there’s no need to throw around things like ‘dismiss me from my title’. It is up to His Majesty to decide who should and should not take on certain tasks. He has a steel yardstick in his hand, and I hope everyone understands that.”

The Emperor looked on silently.

“If that’s the case, let me focus on a few numbers in last year’s expenditure,” Gao Gong stated.

Emperor Jiajing flipped open the national treasury report and put one of his forefingers on page one.

Inside the hall, Gao Gong also held up a copy of the national treasury report, identical to the one Emperor Jiajing was reading, and began. “The revenue collected from the two capital cities and thirteen provinces totalled forty-five million, three hundred and sixty-seven thousand taels of silver dollars. At the beginning of last year, we budgeted thirty-nine million and eight hundred thousand taels, but when the expenditure reports came in yesterday, we noticed that total spending reached fifty-three million and eight hundred thousand taels. If we balance the spending against the revenue, the deficit climbed to more than eight million and four hundred and thirteen thousand.”

Inside the Alchemy Room, Emperor Jiajing appeared to be perusing the national treasury report but was actually listening to the debate outside.

“But when we carefully reviewed last year’s total spending against last year’s budget, we realised that the operating deficit has actually exceeded fourteen million taels,” Gao continued.

Emperor Jiajing closed the treasury report and tossed it on a rosewood desk in front of him. Then, he strolled over to a cushion near the incense burners and sat cross-legged, with his eyes closed.

Gao Gong’s presentation outside went on. “If we look at a breakdown of the figures, the Ministry of Defence outspent by three million, and the remaining eleven million taels of deficit came from the Ministry of Personnel and the Ministry of Public Works. Many are wondering why we refuse to authorise the defence spending. This is because the extra three million taels allocated for the Ministry of Defence were used by the Ministry of Works. In other words, all of the fourteen-million-tael deficit was incurred by the two ministries.”

To illustrate his point, Gao pulled out an invoice. “Let me show you the three-million deficit originally budgeted for the Ministry of War,” he said. “Since the Ministry of War never saw their money last year, how do you expect us to sign off on the spending?”

Upon hearing Gao Gong’s accusatory remarks, Emperor Jiajing’s eyebrows shook a bit, but his eyes remained closed.

In the hall, everyone now turned to Yan Shifan, who looked visibly exasperated. “When we presented the spending report, both of you were there and saw it, but none of you said anything,” Yan retorted. “Now you have shifted all the blame to the Ministry of Public Works.”

Nobody responded. Yan Shifan skipped Gao Gong and confronted Deputy Grand Secretary Xu Jie. “What on earth do you intend to do?” he asked.

“We did see it, but it didn’t mean that we reviewed it,” Deputy Xu replied calmly. “Last night, upon checking with officials at the Ministry of War, we noticed the discrepancy. I think Zhang Juzheng can better explain this.”

Zhang, the youngest provisional council member who headed the Ministry of Defence, stood at the far end of the table.

“Yes, sir,” he began. “We submitted the Department of Defence’s budget to the Ministry of Revenue for authorisation on the twenty-seventh of December last year. Our total spending fell well within the budget. But when the Ministry of Revenue invited me over to check a few items in our report yesterday, I was surprised to learn that we had a deficit of three million taels. When I examined the details, I noticed that the spending was related to thirty gunboats that the Ministry of War had ordered. According to the explanation, the gunboats were built at the requests of Generals Qi Jiguang and Yu Dayou to use in their fight against Japanese pirates in the southeast. But, as of now, we at the Ministry of Defence haven’t seen a single gunboat.”

Zhang finished his statement in one breath, and those who had not been briefed on the issue began looking at each other in confusion and hostility.

In the Alchemy Room, Emperor Jiajing sat motionless on top of his cushion, looking totally immersed in his meditation. It had been twenty years since he moved out of the Forbidden City, following an attempted coup by a group of palace maids who had conspired to strangle him during his sleep. Over the past two decades, he no longer held court, and neither did he summon or meet with his cabinet members for meetings. Instead, he spent his days meditating, and he ostentatiously described his way of governing as “ruling by doing nothing that is against nature” or “non-interference governing”.

However, few had realised that he had long grasped the Taoist truth of “great polarity” politics – a monarch could not monopolise power and make all the decisions by himself. One needed to delegate decision-making to one’s subordinates, allowing them to fight over it. If they did it right, he took credit. If something went wrong, his ministers and eunuchs would inevitably take the blame. As the saying goes, one moment of silence is more eloquent than ten thousand beautiful and appropriate remarks. For each remark, you are its master before you utter it. Once you let it out of your mouth, you become its slave. Let the council members speak. Let the interior ministers debate it. Let them speculate what was going through his mind. At meetings like this, he had to make it clear that he had the final say in every decision and that every decision would be implemented according to his will.

But he never showed his face. Instead, he would chime his singing bowl next door to approve or deny each item. If any errors occurred, he would hold the cabinet or the eunuchs accountable.

As the budget meeting was turning boisterous, the emperor felt calmer and more immersed. While they were arguing fiercely, he simply listened. Very soon, both sides were deadlocked. Without him to mediate in person, Lu took up the task on his behalf.

“Could anyone elaborate on that?” he asked, referring to Zhang’s allegation relating to the gunboats. While he launched his questioning, Lu fixed his eyes on the red ink boxes in front of him.

“You try to make my job difficult, and it doesn’t work,” Yan Shifan said, glaring at Gao Gong and Zhang before turning to Lu. “Allow me to explain. It is true that we ordered thirty gunboats which cost three million silver taels. They were built simultaneously at two shipyards – one in Zhejiang and the other in Fujian. It is true that those gunboats were initially commissioned for the navy to fight the pirates, but we had to temporarily allocate ten boats to the Department of Public Works, which used the boats to ship a large quantity of lumber when we were rebuilding several palace halls damaged by fire. The other twenty boats were leased to the Maritime Affairs Department, which should have reported this arrangement to the Privy Council.”

“Is that true?” Lu asked his deputies at the Interior Ministry. It was obvious that Lu knew the answer, but he deliberately deferred it to his deputies, who glanced at each other knowingly.

“Yes, we are aware of this,” responded Chen Hong, Lu’s executive deputy. “The Maritime Affairs Department employed those boats to export silk, tea and china to Persia and India. Since they were short of boats, they used those newly built gunboats. Subsequently, however, due to the rampant piracy along the coastal region, we couldn’t cobble together enough military personnel to escort the commercial boats. Eventually, they were transported back to the capital via the Hangzhou-Beijing canal.”

Lu uttered a dramatic sigh of relief.

“Now, we have a better idea,” he said. “Ten gunboats were used to transport lumber for the palace repair and the other twenty for Maritime Affairs. Even though the Ministry of Defence never saw the boats, the money that they budgeted has been put to good use. Several of the damaged halls have been restored to their previous splendour. There are still a few left, but they can wait. Minister Yan, the Ministry of Public Works should return the ten gunboats to the Ministry of Defence. I’ll notify Maritime Affairs, urging them to do the same. If they need extra boats, they could apply for funding – there is no need for them to take gunboats from the Ministry of Defence. Once the thirty gunboats go back to the Ministry of War, the three-million-tael deficit can be justified.”

Lu’s remarks met total silence. Gao Gong froze, holding the three-million-tael invoice. Everyone was waiting for the chime next door, which signified the emperor’s approval or denial.

Inside the Alchemy Room, Emperor Jiajing was sitting on the cushion with his eyes closed and his crossed fingers resting on his knees. He waited for quite some time before raising his hands to grab the pestle inside the singing bowl. Haltingly, he hit the brass bowl. The sound rang inside the hall.

“The Ministry of Revenue can authorise the three-million-tael spending,” Lu declared in his high-pitched voice.

Yan Shifan looked visibly relieved and peered at Gao smugly. It was obvious that Gao and his allies had lost this round. In frustration, Gao held the invoice in his hand and stood there sulking.

“Please sign it,” said Xu Jie, his superior at the Ministry of Revenue, who grabbed the invoice from Gao’s hand and carefully wrote his name on it. When he handed it back to Gao, Xu jerked his hand slightly in mid-air. Gao understood the signal. Even though he tried to control his emotions while signing his name, his hand shook slightly. As a result, his signature looked a bit rougher than usual.

Once again, Lu’s voice raised a few octaves. “Red ink authorisation,” he intoned. One of his deputies standing next to him left his desk, walked to Gao and took the invoice from him. When he returned, he handed it over to Lu reverentially, with both hands. Picking up a paintbrush, Lu soaked it in red ink and carefully wrote “Approved” on the invoice.

“Do we have any other invoices that the Ministry of Revenue has not signed?” Lu asked with a touch of iciness in his voice.

“Yes,” Gao growled. “We have several items budgeted for river repairs. One of them involves the repair of Xijiang River, which was initially budgeted one million taels but the actual spending ran up to two million.”

“The fact that Zhejiang Province is one of our key tax bases certainly justifies the extra money spent on river repairs,” Yan Shifan argued. “The Water Management yamen has kept each expense in detail, so feel free to check their books. Besides, the Water Management yamen is staffed by officials at the Interior Ministry. When you refuse to sign off on it, are you targeting anyone else, besides the Ministry of Public Works?”

“Let’s move on,” Lu said, his tone revealing a touch of impatience with Gao.

“The amount of loan that the palace had taken out for repairs after the fire,” Gao continued. “The Ministry of Public Works budgeted three million taels, but the actual invoice reached as high as seven million – four million over budget.”

“So, after you go around attacking everyone, you’re going to make His Majesty your target,” Yan Shifan accused, revealing his invisible sword.

As expected, Emperor Jiajing, who sat on his cushion with his eyes closed, tightened the grip on the pestle.

In the hall, Gao felt he had to defend himself and stand up to his opponent. “I’m merely talking about the four-million-tael deficit incurred by the Ministry of Public Works,” he said sternly. “I didn’t say we shouldn’t repair the palace. Grand Secretary Junior, if you want to kill me, why don’t you just do it now, rather than trumping up these arbitrary charges?”

“Please stop,” Xu Jie interrupted Gao’s tirade. “This is a public debate. Nobody here is trying to trump up charges against you. Neither is His Majesty. When the Ministry of Revenue raises a question, it is important for the Ministry of Public Works to respond to any queries. It shouldn’t be considered a criminal act, don’t you agree?”

Xu turned to Yan Shifan. “Grand Secretary Junior, when the invoices don’t match the budget, it is our job to question the discrepancy,” he said. “There is no need to be upset.”

Xu Jie’s impromptu remarks, irrefutable at best, subtly protected Gao while helping defuse Yan Shifan’s bloodthirsty anger. Unable to formulate the appropriate rebuttal, Yan Shifan swallowed his pride and looked to his father for cues.

Yan Song, who kept his eyes slightly shut, remained expressionless. Yan Shifan then turned to Lu, who ignored him and picked up where Xu left. “Deputy Grand Secretary Xu is absolutely right,” he said to Yan Shifan. “Why don’t you explain to us why your ministry exceeded the budget for this project?”

Yan Shifan looked reluctant. “There isn’t much to explain because everybody here already knows about it,” he mumbled. “The original budget for palace repair was based on the price of lumber in the southwestern provinces of Yunnan and Guizhou. However, when we sent people over there for site investigation, they reported that the mountains were too high and the forests were too dense. There were no decent roads for us to transport the lumber out. So we ended up purchasing lumber from Southeast Asia. We were given one year to complete the repair work, and the fact that domestic lumber was not available aggravated the challenges. Workers at the Ministry of Public Works had put in many extra hours, trying to find an alternative source. Several boats were capsized when transporting the lumber from Southeast Asia to Beijing. Despite the difficulties, we were able to finish most of the sections before year’s end. We don’t mind the troubles and the hard work because we are rewarded by serving His Majesty. But why are you picking over the bones? Why won’t you let everything go?”

“If that’s the case, I would recommend that the Ministry of Revenue authorise the expenditure,” Lu said in an apparent attempt to exculpate Yan Shifan. Once again, all eyes were on Xu and Gao, both of whom kept their thoughts to themselves.

Emperor Jiajing rose from his cushioned seat, pacing up and down impatiently. His long wide sleeves fluttered in the air. He enjoyed the heated arguments outside as much as their silence, which bred action. Thunder and rain were normally preceded by silence.

Zhang, who sat at the end of the long table, broke the silence. “While Minister Xu and Deputy Minister Gao might not feel a bit restrained, let me say a few words first.”

“Please go ahead,” Lu permitted.

“I’ll only focus on the Ministry of Defence,” Zhang enunciated each word slowly. “We spent most of our resources last year defending our northern borders. Due to the increase in troops and personnel, we were able to ward off several invasions by Altan Khan, ruler of the Tümed Mongols. We have just received intelligence from the border region that he is planning more large-scale attacks this year. While more troops are needed in the region, we also need to repair and reinforce the Great Wall that connected the northeast and northwestern regions. This item alone would require an increase of two million taels in our military budget this year. Besides, we also need to bolster our military along the coastal regions in the southeast. In Zhejiang and Fujian Provinces, we relied solely on the twenty thousand strong troops commanded by General Qi Jiguang and Yu Dayou to fight against the Japanese pirates whose frequent raids are preventing commercial boats from transporting silk, tea and china overseas. These losses alone amount to millions of taels. To guarantee the safe passage of commercial boats in the southeast region, it is imperative that we recruit more troops in Zhejiang, Fujian and Guangdong. The recruitment drive will no doubt add another two million taels to our budget. If we follow last year’s example and use up all the funds in the treasury in one year, the Imperial Government will have to raise taxes. Before this meeting, I heard that some provinces have started collecting advance taxes for 1566. If we allow the situation to continue, how are we supposed to sustain it? It is a tremendous challenge to run the Ministry of Revenue. I don’t think this is something for which Minister Xu Jie and Gao Gong should be held accountable.”

“Then who should be held accountable?” Yan Shifan questioned.

“I’m not in any position to assign blame now,” Zhang continued eloquently. “In all things, success lies in preparedness, and lack of preparation leads to failure. Forearmed is forewarned. If we follow last year’s example and outspend our budget, we’ll always end up borrowing money from next year’s. What will happen if next year’s money runs out? I don’t know how our empire can survive in its present form if we do not deal with these issues carefully.”

“Are you saying that repairing the palace and fixing the rivers have exhausted our government’s resources?” Yan Shifan interrogated.

“No, that’s not what I meant,” Zhang contended.

“What did you mean?” Yan Shifan began to press Gao aggressively.

“Given that you don’t agree with Zhang’s statement, are you saying that we should continue our deficit spending like last year?” Gao interjected.

“Lu Gonggong, the traitorous and the disloyal are clawing out of their dens,” Yan Shifan yelled, realising that the argument had escalated into a life-and-death battle. “Gao and Zhang are teaming up to attack us.”

The thunder finally rolled. Emperor Jiajing returned to his seat but was in no mood to sit down. He stood there quietly, watching for the rainstorm to arrive.

With his life hanging by a thread, Gao remained undeterred. His response showed both his grit and wisdom. “How do you write the character traitorous? This character happens to be made up of three components, each of which means ‘female’. Everyone here knows that I have only one humble wife. Grand Secretary Junior has just taken another woman as his concubine. Now that he has nine wives and concubines, it’s probably a bit far-fetched to use the word traitorous on me.”

“This is totally irrelevant,” Yan Shifan lost control and banged on the desk. “You and a handful of your cohorts are secret supporters of Zhou Yunyi, who defamed His Majesty on the twenty-ninth of December. Zhou was a mere astronomer, so how could he know so much about our spending report last year? It puzzled me for quite some time, and now I finally understand. Some people sitting in this room must have disclosed our spending details. Who is this snake? Why are you afraid to admit your role in this and take responsibility for what you have done?”

Gao Gong didn’t answer. Neither did Zhang. Once again, silence fell. Even Lu found it hard to intervene on behalf of His Majesty. Unconsciously, Lu cast a glance at the passageway that led to the Alchemy Room. Time seemed to have stalled.

Finally, a murmur sounded in the passage. Emperor Jiajing emerged in his flowing robe, reciting a Tang dynasty poem. “Cultivating the body, detached and free like a crane…”

Instead of hailing him “Wansui” or “Wish you live ten thousand years”, council members knelt on the floor silently, waiting for His Majesty to complete the poem.

“Under a pine tree inside a grove lay two sets of scriptures,” the emperor intoned. “I come to enquire about the Way, but the master simply stated, like the clouds in the blue sky and the water inside a bottle.”

The emperor moved towards the throne in the middle of the hall, and instead of taking the seat, he stood quietly. Resting an arm on the side of the platform, he looked with disdain at the people kneeling in front of him.

Realising that the emperor had finished his chant, Yan Song waited for a few seconds before offering his greetings. “We, the servants of our Ming empire, wish His Majesty…”

“A long life, a long long life,” the other council members chimed in unison and offered three kowtows in reverence.

“Grand Secretary Yan, your son just claimed that astronomer Zhou Yunyi had a few co-conspirators and they might be hiding in this council,” the emperor demanded. “Tell me who these traitors are.”

“Your Majesty, I do not believe that any of our council members are supporters of Zhou Yunyi,” Yan Song responded with his head down.

“Then how on earth did he manage to obtain so many intimate details of last year’s spending?”

“How could he not? Those figures are public knowledge and accessible to all ministries! For example, a directive distributed to all ministries itemised the money we allocated for riverbed repairs in Jiangsu and Zhejiang Provinces, and for drought relief in Henan and Shaanxi Provinces.”

Emperor Jiajing raised his voice and continued. “Then how did he know so much about the privately brokered fund that we had budgeted for the palace repair?”

“It merely shows that the Ministry of Public Works also publicised it as a measure of transparency,” Yan Song answered calmly.

Nobody expected Yan Song to offer such a conciliatory response in the face of a new wave of political power struggle. Regardless of whether the council members understood his intention, many looked visibly relaxed; a few glanced at Emperor Jiajing furtively to see his reaction.

Emperor Jiajing’s face loosened up. Seating himself on the throne, he ordered his cabinet members to rise from their kneeling positions. “Please continue with your fights,” he teased, with a smile.

His cabinet members kowtowed one more time before standing up.

Yan Shifan gaped at his father, looking a bit perplexed that the old man would fail to come to his defence.

“Don’t look at your father like that,” Emperor Jiajing chastised. “Learn something from him.”

“Yes, Your Majesty,” Yan Shifan answered quickly, with his eyes cast on the floor.

“The piece I chanted just now is called The Poem of Seeking the Way,” Emperor Jiajing said in a cheerful tone. “Maybe some of you know it – Li Ao of the Tang dynasty composed it. The last stanza was my favourite – ‘The clouds in the blue sky and water inside the bottle.’ There is nothing mystical about truth. It lies in things around you, in different forms – the clouds and the water,” he said, pointing around the tense room. “Everyone here is my cloud and water, and each person performs different duties. Regardless, you’re my loyal ministers, and no one is traitorous.”

Puckering up enough courage, Yan Shifan looked up at the emperor and repeated his allegation. “Your Majesty, I have to air my suspicions of Gao and Zhang because their tirades sounded similar to Zhou Yunyi’s incendiary remarks on the twenty-ninth of December.”

“It is not a bad thing if they do sound similar, is it?” Emperor Jiajing retorted. His unexpected reply held everyone in suspense.

“Looking back, I feel somewhat regretful about Zhou Yunyi’s death,” the emperor added with a sigh. “He harboured no ill or selfish intentions even though his words could cause disruptions to the Imperial Court. I merely ordered twenty strokes as a warning to him, but little did I know that he would have been killed… Lu Fang, it’s about time you instilled some discipline in the Imperial Police Force. Go and find out which viper took charge of Zhou Yunyi’s execution on the twenty-ninth of December.”

“Yes, sir,” Lu Fang replied nervously. “I’ll look into it right away.”

Emperor Jiajing then softened his icy tone. “I’m told that Zhou Yunyi left a large brood, with an ailing mother,” he said. “Let’s allocate some money to help take care of them. The money can come straight from the treasury.”

“Yes, sir, I’ll do accordingly,” Lu answered.

“Running a country is equally as hard as running a family,” the emperor began to wax sentimental. “They operate on similar principles.”

Many nodded, unsure if the leader’s sudden shift in tone would continue.

Then, Emperor Jiajing suddenly turned to Yan Shifan. “I just heard Gao Gong mentioning your taking in a new concubine. Wife Number Nine, yesterday?” he asked. “What is that about?”

Taken aback by the emperor’s question, Yan Shifan dropped to his knees. “When I get home today, I’ll have the marriage annulled and send her home,” he vowed.

“A true manly man can afford to have nine wives,” the emperor joked. “What would she do if you send her home? Just keep her and the other of your concubines. It’s OK with me as long as you focus more on your duties as an imperial official. Please rise.”

“Yes, Your Majesty,” Yan Shifan said in a barely audible voice.

After a few minutes of bantering, Emperor Jiajing brought up a serious topic. “We just had an extraordinarily difficult year, so what are we planning to do differently this year?” he asked Yan Song. “We need a strategy – to battle over the things that are worth battling for. As head of the Privy Council, you’re the housekeeper. What’s your plan?”

“Regardless of the situation, the well-being of a family’s finance always depends on either cutting costs or increasing profits,” Yan Song said with sincerity. “Even though every expense we incurred last year was justifiable, we must ask ourselves if we really needed to spend that much. Zhang Juzheng was right when he quoted the saying that success lies in preparedness, and lack of preparation leads to failure. Take the palace repair as an example. Why did the Ministry of Public Works purchase lumber from southeast Asia and ship it all the way to Beijing? Why couldn’t we take lumber from Yunnan and Guizhou Provinces? There’s a sad but simple reason – we couldn’t access them due to shoddy road conditions. I remember we discussed building roads in those two provinces a few years ago. Such improved roads would not only make it easier for the national government to manage the resources better inside the mountains but also benefit the locals, who could finally move their products out and sell them. All told, if this project had been implemented, we would have saved three million taels.”

Emperor Jiajing nodded with approval and directed a questioning gaze at Yan Shifan.

“The Ministry of Public Works was partially to blame, and I should take full responsibility,” Yan Shifan admitted reluctantly.

The emperor nodded again, his face brightening up.

“When we discuss this year’s spending, we need to focus more on savings,” Yan Song continued.

“Zhang Juzheng,” Emperor Jiajing interrupted Yan Song and directly addressed his young minister of defence “Did the grand secretary sum up your views correctly?” he asked.

“Yes, Your Majesty,” Zhang replied. “The grand secretary expanded it, making it more succinct.”

“You’re pretty good with figures,” the emperor said, looking at Zhang appreciatively. “While I was inside, I heard you talk eloquently about the benefits of protecting the sea routes. In this way, our country’s commercial fleets can ferry goods to India and Persia, bringing back more than ten million taels of silver a year. I want to hear more about this idea.”

“Yes, Your Majesty,” said Zhang, who looked visibly flustered but excited. “Actually, this is not my own idea. Back in 1405, Emperor Chengzu sent Zheng He, a fleet admiral on an expedition. Between 1405 to 1433, Zheng commanded several expeditionary voyages to Southeast Asia, South Asia, Western Asia and East Africa, dispensing and receiving goods along the way, promoting trade and spreading the influence of our Ming empire. Since then, the sea routes became crowded with commercial fleets. But about thirty years ago, Japanese pirates disrupted the passageway, deterring commercial fleets from trade missions. Given that I’m with the Ministry of War, however, I see things differently. My belief is that we should increase our military budget and bolster troops guarding the coastal regions in Zhejiang and Fujian Provinces. We should encourage Generals Qi Jiguang and Yu Dayou to recruit more soldiers and build more gunboats. In this way, we can hunt down the pirates, defeat them and reopen the trade routes.”

“Zhang Juzheng has discussed this idea with me,” Yan Song added.

Both Deputy Xu Jie and Gao Gong cast a subtle but quizzical glance at Zhang, who was apparently surprised by Yan Song’s assertion. Shaking his head slightly, he signalled to Deputy Xu and Gao Gong that Yan Song’s claim was false.

Growing bolder, Yan Song continued to hijack the idea and shamelessly took credit for it. “When our trade route reopens, we can decide what sorts of products to export,” he continued. “For example, we can increase the profit on silk produced in Zhejiang Province. A bolt of high-quality silk can sell for six taels of silver here, but if we can transport it to a foreign country, we can get at least ten taels per bolt. At present, we have about ten thousand weaving machines in the southern capital of Nanjing and eight thousand in Zhejiang Province. Do you think we can add more weaving machines to increase production?”

“Of course we can,” Emperor Jiajing jumped into the conversation. “The key is to expand mulberry farms and increase silk production.”

“Your Majesty’s wisdom will guide us,” Yan Song complimented. “Historically, farmers in Zhejiang provided raw silk for weavers in Nanjing because the climate conditions there are perfect for mulberry trees and silkworms. The council thinks it is feasible to convert half of the farmland in Zhejiang into mulberry fields. In this way, they can produce ten million taels of raw silk, which can translate into two million bolts of silk.”

“But if peasants convert all their farmland into mulberry fields, how are they going to feed themselves?” the emperor reasonably enquired.

“We can move grain there from other provinces,” Yan Song said. “In the past, Zhejiang has received about sixty million kilograms of grain in subsidies from other provinces per year. We just need to add to the quota after farmers convert their farmland.”

“But it is more expensive to buy grain from other provinces than to grow it. Will farmers be happy about increased costs?” the emperor asked.

“We have to take into account the fact that growing mulberry and producing raw silk is more profitable than standard crops,” Yan Song replied.

The emperor ceased his queries but, before ending the conversation, added a firm, personal mandate. “Farmers should pay the same amount of tax after they convert their farmland into mulberry fields,” he decreed. “No extra tax levy is allowed.”

“No living soul possesses such keen intelligence as Your Majesty,” Yan Shifan exclaimed obsequiously. “With your approval, farmers in Zhejiang will jump at the opportunity to grow mulberry trees,” he raved. “With an abundant source of raw silk, we shouldn’t have problems adding a few thousand weaving machines in Nanjing and Zhejiang Provinces.”

“Excellent,” Emperor Jiajing clapped his hands lightly and descended from his throne. “It doesn’t hurt to argue and fight over things,” he murmured while pacing around. “Unrestrained arguments produce sound ideas. Let’s assign this conversion plan to the Interior Department and the Ministry of Public Works to implement. Of course, we should involve the Ministry of Treasury too. All the proceeds should be collected at the Ministry of Revenue. I urge the council to formulate a detailed implementation plan and send it directly over to Hu Zongxian, governor of Zhejiang Province. Ultimately, we have to rely on him for full implementation.”

“Yes, Your Majesty,” Yan Song and Lu Fang promised in unison.

On the spur of the moment, the emperor strolled towards the front gate and was about to unlatch it himself. Two junior eunuchs quickly scurried over and opened it for him. A blast of snow-laden wind flew into the hall, sending the emperor’s long sleeves flying.

“Aiya… Your Majesty, be careful – you could catch a cold,” Lu dashed over to close the door.

“I’m not as fragile as you are,” the emperor waved his hand dismissively to stop Lu.

The snow continued to blanket the region. The red lanterns were glowing in the white snow, forming a promising scene. As the emperor was inhaling the fresh air, he noticed several eunuchs kneeling quietly on the steps outside, like a cluster of snowmen. The one at the front held a tray above his head. Despite the heavy snow, the emperor could see a big jade tablet on the tray.

“Could it be that the Prince of Yu’s wife has given birth?” Emperor Jiajing’s eyes lit up.

“Congratulations, Your Majesty,” the eunuch who held the tray announced loudly. “The heavenly god has blessed you and our Ming empire with a boy.”

Lu, who stood behind the emperor, quickly hurried over and received the tray. Then, he dashed back and knelt before the emperor, raising the tray above his head. “Your Majesty, congratulations!”

His four deputies at the Interior Ministry quickly dropped to their knees. Yan Song and the other Privy Council members followed suit.

“Congratulations, Your Majesty.”

Regardless of whether the Privy Council members were truly happy or merely feigning, it was the emperor’s first grandson, a blissful event for the Ming dynasty. Under normal circumstances, it was considered a taboo to look the son of heaven in the eye, but on that occasion all eyes were directed towards the emperor – such exception was called “welcoming happiness”. Jubilation flamed up on Emperor Jiajing’s face and eyes – he did not seem at all surprised. Instead, a hint of gleeful smugness appeared on his face, as if he had planned all along to have the news arrive along with the snow.

“Please raise the tray higher,” he instructed Lu.

“Yes, Your Majesty,” Lu said, duly hoisting up the tray. Reaching his right hand into his long left sleeve, he pulled out a winter jujube, as big as a baby’s fist, and placed it on the tray. Then, before the surprised crowd, the emperor mischievously reached into his right sleeve with his left hand and brought out a similar-sized chestnut.

“What do these two items symbolise?” he quizzed his ministers, who were still in shock.

With the tray over his head, Lu could not see what the emperor was showing. Lu’s deputy, Chen Hong, responded instead. “Your Majesty, together, these two signify that an heir will soon be crowned,” he stated.

Impressed by the “magic trick”, many wondered how the emperor would have known that it would be a day of bliss for the country.

All the Privy Council members knew that it was an opportune time to sing praises for the emperor, and at the same time they also realised that no words were enough to express their praises. Even though he was in his 80s and had decades of experience serving in the Imperial Court, Yan Song simply stood there, stunned and delighted like everyone else.

“One cannot afford to be ignorant of family matters,” Emperor Jiajing said with conceit. “He has to be on top of both national and family affairs.”

His ministers and eunuchs prostrated themselves on the floor. “His Majesty’s wisdom and talent are boundless.”

Having got a thrill out of his magic trick, the emperor’s jubilant face turned serious, and he said to Lu, who was still kneeling in front of him, “The winter jujube and chestnut were heaven’s gifts to me, and I will pass them on to my grandson. What is the traditional custom? What kinds of gifts should we endow on the new parents and the baby?”

“Your Majesty, given that this is your first royal grandson, we would assign twenty eunuchs and twenty maids, in addition to the usual congratulatory gifts,” replied Lu.

“OK, go and take care of it quickly,” the emperor demanded.

“Yes, Your Majesty,” Lu promised loudly.

Next, the emperor turned to Xu, Gao and Zhang. “For years, you have served as mentors and advisers for my son,” he said, his voice exuding tenderness. “I assume you’re eager to go and congratulate the Prince of Yu. I won’t keep you here tonight to eat yuanxiao^(2) and celebrate the lantern festival with me. Please go.”

The three council members kowtowed before dashing away.

Yan Song and his son were still kneeling in the hall. The emperor watched pensively as his other council members disappeared in the snow. “I don’t always know what is going on in the nation and my family,” he murmured, as if to himself. “Grand Secretary Yan, now that we are alone, could you tell me if any of our council members are secret supporters of Zhou Yunyi?”

Yan Shifan raised his head and was about to speak when his father stopped him with a stern glance. Emperor Jiajing slowly turned his head and signalled for the father and son to rise. “It’s the lantern festival – why don’t you two stay and keep me company? Let’s have yuanxiao together.”

“Please accept my humble thanks,” Yan Shifan replied. While his voice was filled with gratitude, it also conveyed a slight sense of grievance.

Lu Fang and his deputies stopped by the Interior Ministry’s office complex before heading over to the Prince of Yu’s mansion. When they approached the duty room, two junior eunuchs dropped to their knees to greet them. Near the stairs, Lu suddenly stopped because he caught sight of a kneeling “snowman”.

“Who is this?” Lu asked.

“Daddy, it is Feng Gonggong.”

Seeing that his protégé, Feng Bao, lay literally frozen in the snow, Lu looked conflicted. His four deputies exchanged quick knowing glances. “Why don’t you go and eat some yuanxiao to celebrate the Lantern Festival,” Lu told the group. Chen Hong, his senior deputy, felt a bit resentful knowing that Lu attempted to send them away so he could take care of Feng. Even though he wouldn’t dare challenge Lu, Chen wasn’t willing to let Feng Bao off the hook so easily.

“If we all go, who’ll be on duty then?” Chen asked.

“I’ll do it,” Lu insisted.

“But we can’t let you…” the other deputies, who had seen through Lu’s true intention, joined Chen in begging to stay.

Lu waved them away. “Just go and have a good time.” As the deputies reluctantly stepped away towards the Moon Gate, Lu dispersed the rest of the eunuchs in the courtyard. “I only need two people to help me here. The rest can leave and celebrate the Lantern Festival with friends,” he said in a moment of calculated generosity.

Once the small crowd exited the courtyard, Lu yelled at Feng Bao, “You can stand up.”

Feng did not respond.

“Stand up,” Lu repeated.

Realising that something had gone wrong, Lu instructed the two helpers to step over and check up on his protégé.

“Feng Gonggong, Daddy asks you to rise,” they bent over and whispered to Feng.

When Feng did not move, they tried to lift him, but couldn’t.

“Feng Gonggong is frozen stiff,” one helper screamed.

“Carry him inside,” Lu said, his face and voice betraying no emotion.

The two helpers strained to lift up Feng’s iced-over body and lug him into the night duty room. After sitting him on a chair, they removed his wet clothes. Soon, the big charcoal brazier, which heated up the room comfortably, brought Feng to life. Even though his eyes remained closed, his teeth began chattering. The guards bolted out and came back with two buckets of ice. Scooping out some with their hands, they rubbed the ice gently on Feng’s arms and legs. Lu sat on a chaise lounge next to a window, his eyes half-closed. Eventually, Feng began groaning.

Lu Fang slowly opened his eyes and glanced at Feng.

“Carry him to the bed, and feed him some ginger tea,” Lu told the two helpers.

The two junior eunuchs lifted Feng from the floor, placed him on a bed in the duty room and spoon-fed him ginger tea. After a few coughs, Feng regained consciousness. Even though he was still weak, he managed to get up, drop on his knees and kowtow to Lu.

“Daddy, it was my fault…” he sobbed.

Lu waved his hands, ordering the junior eunuchs to leave the room. Then, he ambled over and sat on the edge of the bed where Feng Bao sat. “After all these years working for me, you haven’t learned a thing,” he scolded. “Even a cow knows how to play a rope trick after I teach it three times. Look how arrogant you were, so desperate to climb the ladder. On the twenty-ninth of December, you had Zhou Yunyi killed without consulting with me. Today, you tried to show off and report the good news without notifying anyone else. I don’t hold grudges against you, but what about the others? Zhou Yunyi had many cohorts here. And the Prince of Yu is also one of them. If you wish to die, what you have done will certainly make your wish come true.”

“I’m sorry. It will never happen again,” Feng kept murmuring. “Your humble son will remember your words and start all over.”

Lu stopped talking and gazed at Feng tenderly, which made his protégé more nervous. Feng could sense that Lu had something else in mind.

“I promise I’ll turn over a new leaf,” Feng pleaded.

Lu paused for a few minutes. “From tomorrow on, you’ll be reassigned to the Prince of Yu’s mansion,” he said.

It took a while for the words to sink in. Shocked and stunned, Feng struggled to get up and stumbled off the bed. Kneeling in front of his mentor, he grabbed Lu’s leg. “Please don’t do it, Daddy,” he begged. “It’s probably better if you just have me killed on the spot. I’d rather die than work at the Prince of Yu’s mansion.”

“Get up,” Lu ordered with an icy tone that sent shivers down Feng’s spine.

“But Daddy,” Feng said, shuddering uncontrollably while leaning his body on the edge of the bed.

“Let me gift you a few words,” Lu said to Feng, who seemed to be in a stupor. “There is a popular saying among government officials: one needs to always ponder three things – think about danger, think about retreat and think about change. These three things are connected. If you sense danger, you need to plan your retreat right away and withdraw to a place where your enemies won’t spot you. Once you retreat to a safe corner, you bide your time, slowly reflect on your mistakes and plan your comeback. This is called ‘the contemplation of change’.”

“I’ll follow your teaching,” Feng replied with a trembling voice. “But sending me to the Prince of Yu’s mansion is like putting me on the road to ruin.”

“Listen carefully to what I’m about to tell you,” Lu interrupted Feng with a fierce look. “There is another popular saying among officers who serve in the Imperial Army. It’s called ‘allowing a person to confront the danger of death and he will fight to live’. In your particular case, many officials, including the Prince of Yu, know that you are responsible for Zhou Yunyi’s death. They despise you. How could you convince them that you didn’t actually kill Zhou Yunyi? You won’t have the opportunity to defend yourself if I keep you here. As you know, the Prince of Yu will take over and ascend the throne sooner or later. When the day comes, you’ll be doomed if you don’t redeem yourself right now. Listen to me. I’m going to send you over as part of His Majesty’s gifts. Your job is to babysit and look after the royal grandson. Once you’re there, you need to work hard and keep your head down, gaining confidence and trust from the prince and others around him. In this way, they’ll change their perception of you and treat you better. Someday, when the prince is crowned, I’ll have to rely on you for protection.”

Lu became emotional, his eyes glistening with tears. Feng lay prostrated on the floor and began wailing. Lu was not sure if his protégé had truly grasped his meticulous intent.

For the Prince of Yu, time seemed to have stalled since dawn. Gao Gong and Zhang Juzheng had briefed him on their possible confrontation with Yan Shifan at the Privy Council meeting the night before. Their plan made him nervous. But his wife, Princess Li, went into labour at three o’clock in the morning; it was a difficult birth, and the prince could hear her painful howling for two hours as he waited nervously in a chamber outside his living quarters.

With his chief of staff keeping him company, the prince paced up and down the room. As the hours went by, he became increasingly worried about both his child’s pending birth and, at the same time, the possible consequences of his mentors’ actions at the Privy Council meeting. Personal and political tensions pressed down on him.

Thank heavens, the birth went smoothly, and he was now the father of a baby boy. Gao Gong and Zhang Juzheng braved the snow and arrived to offer their congratulations. It was obvious that they had been sent by his father, the emperor. As the period of suspense and tension subsided, the prince found his body weakening. When his two mentors dropped to their knees and kowtowed, he couldn’t even summon enough strength to stand up and return the courtesy. He just moved slightly and waved his hand. “My teachers, please rise. I’m glad you’re back safe and sound.”

Several chairs in the room formed a circle around a big bronze brazier. The prince sat in the middle, Xu Jie and Gao Gong picked their seats on the right, while Zhang Juzheng and chief of staff Tan Lun were on the left. As the crown prince and his advisers clustered around the fire, they looked at each other quietly and became so emotional that they didn’t know where to begin.

“The three of you probably had no idea how His Royal Highness survived the past several harrowing hours,” Tan Lun started, his eyes moistened. “Princess Li had been in labour since dawn, and for two hours the midwives couldn’t deliver the baby,” he said. “Fortunately, someone remembered that Li Shizhen^(3) had left a few herbal pills that would help induce labour. Thank heavens, the pill worked, and both the mother and baby boy are well.”

Xu, Gao and Zhang glanced at the prince’s pale face sympathetically.

“Meanwhile, the prince was worried about you three,” Tan continued. “He went outside and stood in the snow several times to check if all of you were coming back. He feared that you could be taken away.”

“Confucius once advocated benevolence, and Mencius emphasised justice,” Gao interrupted Tan. “I’m not afraid of following Zhou Yunyi’s example and sacrificing my life for our Ming empire. Now that Your Royal Highness has a son and our empire has a successor, there is hope. If I die, I’m sure others will step in. As a Ming official, I have to do my job and fight for justice. Otherwise, I’d rather die.”

“There aren’t too many righteous officials left, and you all are pillars of our Ming empire,” the prince remarked.

He seemed to have recovered from the mental exhaustion, but his voice still sounded weak. Stoking the fire in the brazier, the prince remarked, “The Imperial Government cannot afford to lose any of you. Otherwise, I don’t know who will be able to help His Majesty to remedy the ills that beset our empire.”

“His Majesty is wise and capable,” Xu interjected. “With his leadership, I don’t think we are likely to end up like that.”

But Gao disagreed. “What happened at the council meeting today wasn’t too encouraging,” he complained. “Your Royal Highness, do you know that the council approved all of last year’s bad debts and wasteful spending?”

“At least, we have had a promising start to this year,” Xu argued. “Because of our efforts to control spending, we’re not going to increase taxes. I hope that the land-conversion plan in Zhejiang goes smoothly.”

“I doubt the conversion will work,” Zhang said bluntly. His words drew the attention of both the prince and his chief of staff.

“Why?” asked the crown prince.

“Grand Secretary Yan Song proposed at the meeting today that farmers convert half of their prime farmland into mulberry fields,” Zhang explained. “He claimed that the conversion would lead to an increase of 200,000 bolts of silk a year. Profits made from the silk would be able to bridge the deficit. Good as it sounds, it’s quite pernicious. This gives the Yan clan just another excuse to rob local farmers of their land. If wealthy merchants control half of the farmland in Zhejiang, farmers there would be forced into dire straits and rise up against local officials. Besides, Zhejiang is rife with pirates. It wouldn’t be long before we see chaos and uprisings there.”

“Why didn’t you state this at the council meeting?” the prince said impatiently.

“His Majesty approved the plan before Yan Song even finished it,” Zhang said. “He simply instructed Yan not to levy more taxes on farmers who agree to the land conversion. But did it ever occur to His Majesty that farmers wouldn’t be able to benefit from the land conversion and the no-tax provision? Yan’s wealthy cronies in Zhejiang would collude with big merchants to purchase land directly from peasants and grow mulberry trees.”

“I completely see your point,” Tan Lun, the prince’s chief of staff, nodded. “Theoretically, if the Imperial Court does not levy extra taxes on converted land, a farmer can earn up to fifty per cent more from growing mulberry trees and producing raw silk than he would from planting rice and other crops. But it doesn’t work that way. Local officials would collude with merchants and use all different administrative means to force farmers to sell their land. In this way, the merchants can monopolise the silk production. They can grow mulberry trees, raise silkworms and then manufacture silk. The profits could be unimaginable.”

“You’re right on target,” Zhang concurred. “When Grand Secretary Yan Song proposed the idea, his true intent might have been to make up for the rising deficit. But the fact that his son, Yan Shifan, has suddenly thrown his support behind it shows that they must have plotted beforehand.”

Gao stood up. “We have to stop this. Even though we were not able to shoot down the project at the council meeting, we have to strategise, figure out a way to salvage the situation, and prevent this bad policy from being implemented in Zhejiang.”

“How can we do it?” the prince asked Xu, who was unusually quiet during the discussion. “The Yan clan is quite influential, both at the Imperial Court and inside the Zhejiang government.”

Xu didn’t reply to the Prince of Yu. Shifting in his seat, he turned to Zhang. “Do you have a specific plan?”

Zhang considered it for a few minutes. “The Yan faction is not what many see as a monolithic whole,” he said. “I’m sure there are some honest and upright officials in Zhejiang. We need to look for cracks. There is one person who I think we can win over.”

“Who?” Gao asked sceptically.

“This person holds a powerful position there,” Zhang said.

“Are you talking about Hu Zongxian?” Gao probed.

“Yes,” Zhang affirmed. “He’s not only the governor of Zhejiang Province but also the imperial inspector, who has gained the trust of both Grand Secretary Yan Song and His Majesty. If only we could get someone to convince him of the policy’s deleterious effect, he could make a case to His Majesty and kill it before it is implemented.”

“I beg to differ,” Gao said. “Yan Song plucked the governor of Zhejiang from obscurity and then nurtured, promoted and planted him there. I don’t mean to say that we are not able to move any trees in Yan Song’s garden, but Hu Zongxian is deeply rooted, and I doubt we can move him over to our side.”

The prince fixed his gaze on Tan Lun, his chief of staff, seeking his opinions.

“We can certainly explore this idea,” Tan said. “As his Royal Highness is aware, Governor Hu and I used to be close friends. He’s smart and independent when it comes to state affairs. Ever since he’s taken over the Zhejiang governor’s post, he has stood his ground on many key issues, despite the fact that he seemed to obey Yan Song and his son in public.

“Even so, whom should we rely on to win him over?” Gao questioned. “As the saying goes, a mere acquaintance has no power over close friends. What makes you think he’ll listen to us?”

“We won’t talk to him directly, of course,” Zhang said. “But we can send over a friend of his who can explain our position to him.”

“Who should that person be?” asked the prince.

Zhang turned to Tan Lun, and the prince suddenly understood. So he shifted his head towards his chief of staff.

“Of course, I can go without question,” Tan said. “But I need to have a legitimate reason, such as securing an appointment as an official in Zhejiang, where I could work alongside him and use the opportunity to convert him.”

The prince and his confidants exchanged glances knowingly – everyone liked the idea.

“I think this is a good game plan, and we can certainly try it,” said Xu cautiously. “With Tan Lun planted next to Governor Hu Zongxian, I’m sure we can achieve something. It’s better than nothing.”

“If that’s the case, I’ll give my permission,” said the prince. Standing up, he rested his hands on the arms of his rosewood chair. “As long as we can awaken his conscience, the situation won’t get out of hand.”

Zhang became flustered and said to Tan, “It’s not enough to salvage a bad situation. Are you planning to come back after this assignment?”

Startled by this unexpected rhetorical question, Tan asked. “What do you mean?”

“If you want to come back in triumph, you should first start a fire in Zhejiang and then bring some sparks back to the Imperial Court, letting the flames destroy Yan Song and Yan Shifan. If you can’t achieve that, you probably shouldn’t even bother coming back to see his Royal Highness. There is also a possibility that you could lose your life there. You need to think it through before making a decision.”

Gao slapped his knee in excitement and stood up to voice his support for Zhang. “That’s an excellent point. If you really want to go, you should be prepared to do it in a grand fashion. It’s not worth it if you simply want to do a little bit, with the attitude that it’s better than nothing.”

The fiery exchange of words made the Prince of Yu nervous. He turned to Xu, who didn’t seem to mind that his younger colleagues challenged his attitude because he knew that as the prince’s mentor and pillar of the Clear Stream faction, he needed to balance both short and long-term considerations. “Please remember, silk production falls under the jurisdiction of the South China Textile Bureau, which is directly under the control of the Interior Department,” Xu pointed out.

“Sir, your concern is…” the prince asked politely, and then he suddenly understood. With his blank stare into the distance, he looked lost. “If the South China Textile Bureau is implicated in implementing the policy, many in the Imperial Court, including His Majesty, would be affected… Should I send Tan Lun or not?” he asked bluntly.

The prince’s remarks saddened Tan Lun. When Zhang and Gao, two younger officials known for their blunt heroism, triggered him to take action, he did not appear to be offended. He considered himself a warrior who was not afraid of devoting his life to a bigger cause, even though it might mean brutal death as his end. However, Tan Lu looked disappointed at the prince’s cowardly reaction to Xu’s concern. Obviously, the prince, fearful of the Interior Department and Emperor Jiajing, cared more about his own interest than that of Tan’s life.

This sense of bitter disappointment further strengthened his resolve. “Your Royal Highness, do not worry,” Tan pledged. “I will not do anything that jeopardises your position or that of my colleagues here. All I need is a letter from the Ministry of Personnel, appointing me as the military adviser in the Zhejiang governor’s yamen. I can leave tomorrow.”

The room fell into an awkward silence. There was no doubt that the prince – a sensitive person – and his other cohorts understood Tan’s sentiments.

“Your Royal Highness, it’s the Lantern Festival today.” Tan broke the silence and suggested that they enjoy a bowl of yuanxiao together. The way he said it echoed an ancient scene where the assassin Jing Ke bade farewell to Prince Yan before leaving on his mission to assassinate the tyrannical emperor of the Kingdom of Qin. Everyone, including the prince, became emotional. At that loaded moment, a palace maid walked in.

“Your Royal Highness, the princess just asked if we should invite everyone to eat yuanxiao since it’s already past noon.”

The prince suddenly came to his senses. “Yes, bring up the yuanxiao,” he ordered, with a slightly hoarse voice. “Don’t forget the liquor.”

“Let’s propose a toast to Tan Lun,” Gao said loudly, totally forgetting about the emperor’s grandson, whose birth they came to celebrate.

2

Despite a dry winter season, spring flooding replenished the Xin’an River in the southeastern province of Zhejiang. By April on the lunar calendar, incessant rainstorms had pushed the water level of the Xin’an to its peak. Clear and serene, it generously irrigated the vast expanse of green rice seedlings on both sides of the bank as it confidently meandered forward. Local peasants praised the Xin’an’s life-giving force, often citing a famous adage of Lao Tse, the founder of Taoism: The top virtue is like water, benefiting all, contending with none.

For the first time in ages, Master Lao Tse’s adage could no longer be applied to the Xin’an River. All the irrigation canals along the river stood blocked. Like an arrogant government who ignored the needs of its people, the vigorous river now ran roughshod without stopping, and the abundant water went wasted.

Zhang and his cohort of reformers had accurately foreseen the dreadful outcome. From the very beginning, the Yan-led initiative to convert rice paddies into mulberry fields set off a domino-toppling chain of disaster for the locals, government, and beyond. Still, the plan continued apace.

On that day, fully armed soldiers and government officials lined up along the embankment. Ma Ningyuan, the mayor of Hangzhou, along with two magistrates, Chang Boxi and Zhang Zhiliang, had travelled there to forcibly implement the new land-conversion policy. Thousands of local farmers had shown up as well, and they now dropped to their knees in despair.

Alongside the rice paddies near the embankment, two rows of armoured soldiers on horseback waited ominously for orders.

“Crush the seedlings,” bellowed Mayor Ma. Eager horses charged forward, sweeping across the rice paddies like waves of violent floodwater, transforming the rice paddies into a fierce battleground. Without guns or even enemy troops, the officials fought a brilliant battle. Muscular horses trampled on dry cracked farmland, killing the countless inch-tall seedlings. The deafening hoof beats failed to drown out the loud wailing by farmers who knelt along the embankment. Total destruction followed in the wake of the horses, who moved on like the unceasing deluge that lay ahead.

“Put up the markers,” two officials standing next to the mayor barked at the soldiers who carried wooden billboards that prominently bore the characters Mulberry Field. The soldiers rushed over to the trampled farmland and hammered the billboards deep into the ground. The wailing became louder as the horses moved on to other plots.

“Dad!” a young woman’s shrieks rose above the howling and crying.

Before the shocked onlookers, an old farmer ran as fast as he could and plunged into a rice paddy, thrusting himself to the ground. As he pressed his ancient face close to the soil, he stretched out his thin arms to encircle a patch of withering seedlings as if protecting his own children. As the horses approached, the old man remained flung across his trusted land.

“Let’s fight it,” a strong young man shouted to his fellow farmers. “They’re going to kill us anyway.” He leapt into the rice paddy and rushed through the swirling water towards the elderly man. Several other farmers joined them, and together they locked arms, forming a human wall in front of the prostrating old man. A local crowd nodded and murmured from where they knelt by the riverbanks.

Unprepared for the resistance, the soldiers on horseback became nervous and baffled. Such combativeness was rare in the countryside. Finally, they looked to their officer for direction.

The officer who led the raid instinctively pulled on his reins. As other soldiers moved to imitate him, their horses refused to obey and galloped towards the human wall. Sweat broke out on the officer’s face. Fortunately, the confused soldiers were able to halt their horses about twelve feet away from the protestors. Puffing and snorting, the agitated animals kicked and dug their hooves into the dirt.

“These unruly bastards!” cursed Zhang, the magistrate of Jiande. He stamped his feet.

“They’re plotting an uprising,” added Chang Boxi, the magistrate of Chun’an. “I just heard a young traitor calling for an uprising.”

“Which one? Point him out!” directed Ma, the mayor of Hangzhou.

“It’s that one there.” Chang pointed at the young man who started the resistance.

“Lock him up,” Mayor Ma howled.

A dozen yamen guards rushed over to the crowd with chains and wooden poles. Soon they shackled a dozen young farmers, including the so-called leader, and dragged them over. The arrests incensed the crowd so much that they rose from their supplicating postures. The formidable group began walking towards the soldiers and yamen guards; a riot appeared ready to start. In an attempt to stop the strapping farmers from advancing, the soldiers swiftly produced their weapons.

Meanwhile, the mayor and the two magistrates walked up to the shackled farmers.

“Who is the agitator?” asked the steely faced mayor. “Who gave the command, ‘Let’s fight it?’”

“I did,” the young man said, stepping calmly forward.

Startled by his peaceful demeanour, the two magistrates exchanged quizzical glances at each other.

Mayor Ma sized up the young man and said sarcastically, “Wonderful. I always appreciate it when insurrectionists are so earnest and straightforward. What’s your name?”

“Chee Dazhu,” the young man replied.

“What do you do for a living?”

“I’m a mulberry farmer. My family has farmed mulberries for generations.”

The mayor took a closer look at the young man and asked, “A mulberry farmer? Then why on earth are you making trouble here when we’re merely converting all the other rice paddies over?”

After pausing for a few seconds, the young man said, “Because I don’t think it is right to treat rice farmers like this. Without feelings of respect, what is there to distinguish men from beasts?”

“Confucius,” muttered the mayor under his breath. “You are a real man!” Then, the mayor changed his tone abruptly. “What position are you holding under Wang Zhi?”

“Wang Zhi? Who’s that?” the young man asked in complete confusion.

“As if you don’t know – he’s the leader of the pirates!”

Startled, the young man protested loudly, “I swear I don’t even know him!”

“Oh yeah? When the time comes, you will divulge your relationship with Wang Zhi!” Mayor Ma uttered in a low voice before turning to the large crowd gathered outside the rice paddies. “Converting rice fields into mulberry farms will benefit both our country and individual farmers. It’s a win-win policy for all of us and will lead to an even more prosperous future. Unbelievably, we are running into all sorts of stumbling blocks. Today, some people even gathered here to boycott the land-conversion policy. Now we understand why – the pirates are instigating a riot!”

The screaming and wailing suddenly stopped. Colluding with pirates constituted a capital offence, and the mayor’s threat worked. The crowd fell into a stunned silence.

“Let the horses run to kill the crops,” Mayor Ma ordered. “Anyone who dares to obstruct them this time will be arrested and sent to the prison in Hangzhou with this group!”

The two magistrates standing next to the mayor shouted simultaneously to the soldiers on horses. “Go!” The soldiers unleashed the horses, which ran rampant in the field, leaving thick trails of annihilated seedlings.

In the distance, a pack of five horses was dashing towards the embankment. At the sight of the advancing squad, the officer who directed the operation in the rice field immediately reined in his horse.

The squad came into clear view, led by a rider wearing a helmet adorned with a big red tassel. His black cloak flew in the air, making him look like a ferocious bat. “It’s the general,” the officer blurted out in surprise. He dismounted quickly.

General Qi Jiguang was the regional military commissioner. As he dismounted, the soldiers who had been tasked with maintaining order rapidly lined up in two neat rows to await their commander’s arrival.

Perching on the edge of a rice field, General Qi scanned the damages and glared at his horsemen, who had abandoned their destructive mission and were galloping over towards the embankment. Once they climbed out of the rice field, the horsemen dismounted and stood at attention, facing each other in two rows. Slowly, General Qi rode around his troops. First, he glanced at the swarms of dejected farmers on the embankment, and then he fixed his gaze on the trampled crops. Qi’s frosty expression sent chills down the spines of his soldiers, who stood there silently. Even their horses remained motionless.

The commotion on the edge of the rice field caught the attention of Mayor Ma and the magistrates.

“What’s he here for?” asked Chang, the magistrate from Jiande.

“Is he coming to pull out his troops?” Zhang, the magistrate from Chun’an, speculated.

“No, he can’t,” Mayor Ma explained. “The troops were assigned to me by the Ministry of War.”

The three officials strode towards General Qi.

“You were out when I went to summon your troops,” Mayor Ma raised his voice and shouted to the general. “I left a letter from the War Ministry on your desk.”

General Qi ignored him and glared down at the officer in charge.

“Did you command the soldiers to destroy the crops?” General Qi questioned.

“Yes… sir!”

Whop-eesh! General Qi cracked his bullwhip to lash the officer’s face like a bolt of lightning. Despite the long bloody welt, the officer straightened his body without flinching.

“Who else has damaged the crops?” General Qi yelled. “Step out.”

The cavalry moved a step forward simultaneously, without disrupting their formation. General Qi moved slowly between the two rows, waving his bullwhip. Each crack produced a welt on the face of his horsemen, who remained miraculously poised, at attention. The crowd watched in awe as the viperish bullwhip danced in the air.

The two magistrates, Chang and Zhang, stood there in a daze. The yamen looked baffled. Mayor Ma’s face turned uglier by the minute.

“You have cut off the water and trampled the crops,” General Qi stopped the whipping and reprimanded. “Do you know who supplies you with food every day?”

“Of course they do,” Mayor Ma spoke up and answered on behalf of the soldiers. “The Imperial Government. It’s quite obvious, isn’t it?”

General Qi was forced to face Mayor Ma. “Then where does the Imperial Government get its food?” he asked the mayor.

“Under the heaven, every inch is His Majesty’s land. And to the borders of the land, every individual is his subject,” the mayor responded confidently in a raised voice. “Therefore, His Majesty provides food for us.”

“Well deduced,” General Qi complimented him sarcastically, his eyes boring into the mayor’s. “If that’s the case then, why are you cutting off water to His Majesty’s rice field? The crops you have destroyed are His Majesty’s crops.”

Speechless, Mayor Ma had no answer as his face grew blue. General Qi straightened his back and turned to his soldiers again. “Do you know what offences you have committed by cutting off His Majesty’s water and trampling on His Majesty’s crops?”

“Yes, sir – death,” the soldiers answered unanimously, smart enough to know at whom the questions were directed.

“I’m glad you understand it,” General Qi said before ordering his troops to regroup and return to their barracks.

As the soldiers gathered to leave, the farmers began pleading. “General, don’t leave yet,” they shouted on their knees. “They have arrested our honest folks. Please release them.”

Soon, more shouts broke out in the crowd. “Release! Release!”

General Qi did not respond to the crowd’s plea. Instead, he turned to his soldiers as they prepared to depart.

“This is pure sabotage,” fumed Chang, the magistrate of Jiande County. “Are you trying to boycott an imperial order?”

“Your Highness, we can’t allow Qi Jiguang to withdraw the troops,” pleaded Zhang, the magistrate of Chun’an, as he approached Mayor Ma.

The mayor raced over to General Qi. “The Ministry of War has assigned the troops to me,” he yelled. “You have no right to take them away.”

“The troops have to go to fight the pirates now,” General Qi replied in a cold yet resolute tone.

“What? Do you have written orders from above?” the mayor questioned.

“Yes, of course!” said General Qi.

“From whom?” asked the incredulous mayor.

“I don’t have to show them to you,” General Qi replied haughtily. “If you really want to find out, go and ask those at the Imperial Palace in Beijing.”

“I know who’s behind this,” the mayor said in an accusatory tone. “Did you receive the order from Tan Lun?”

General Qi paused for a minute then continued about his business without answering. Mayor Ma marched a few steps forward and stopped in front of General Qi’s horse.

“Qi, you are a friend of governor Hu, and so am I,” he reminded him. “If you want to undermine my work, you’ll come to no good in the end.”

General Qi tilted his body towards the mayor. “Given that we’re the governor’s friends, let me offer you a piece of advice,” he whispered. “Release those farmers before my troops leave. Otherwise, the farmers may tear you to pieces and toss your remains in the river.”

Before the mayor had time to respond, General Qi spurred his horse into a gallop and shouted to the soldiers, “Let’s go!”

The army and their horses followed their general and marched past the mayor, who was left alone by the side of the road.

Farmers gathering on the embankment began to gather force again, storming towards the mayor’s entourage and wrestling with the yamen guards who held the shackled instigators. Someone thundered, “Release them,” and hundreds responded. Panicked, the two magistrates nudged closer to the mayor. “Your Honour, why don’t we release them first and figure out what to do when we get back to Hangzhou?” they begged.

“You coward! If you want to run, leave your official’s hats here and go,” reprimanded Mayor Ma with a fierce and disgusted look on his face.

As the two magistrates stood there, startled, the mayor turned to his apprehensive yamen guards who watched over the shackled farmers. “Without my order, nobody can release them,” he pointed out.

The crowd was moving towards the mayor. Undaunted, he marched calmly towards them.

Surprisingly, they stopped.

“I’m standing here alone as your mayor,” he taunted them with a stern voice. “If you want to start an uprising, come on over and get me. Throw me into the river – I dare you.”

Unexpectedly, his ferociousness effectively deterred the crowd. For a few minutes, the embankment stood silent. “Converting rice into mulberry is His Majesty’s new national policy,” he continued. “You either convert the farmland yourself or sell your land and let others do it. Nothing can change it, regardless of how many people have to die for this – be it one thousand or ten thousand. Even if the whole population of our province perishes, the conversion will still continue. General Qi might have left with his soldiers, but the Imperial Court will send reinforcements – thousands of them – to keep order. If you want to use violence to boycott the imperial policy, do it. I’m here for you to slaughter.”

The crowd stared in disbelief. “Take those pirates back to Hangzhou,” the mayor barked. By then, the two magistrates had quickly composed themselves. “Tie them up and go,” ordered Chang, the magistrate of Jiande.

The mayor turned around and marched at the front.

Submitting to the mayor’s threats, the farmers, who were timid and kind by nature, did not rise up and riot. But Mayor Ma’s threats failed to disperse the crowd. They simply followed the mayor as he was getting ready to return to Hangzhou.

Chang, the magistrate of Jiande walked up to the mayor and whispered, “If these people follow us all the way to Hangzhou, things could get out of control.” Sweat ran down his cheeks.

“It’s already getting out of control,” the mayor said, striding forward. “Let’s return to Hangzhou first and see what the governor has to say.”

The crowd wriggled forward quietly behind the mayor’s entourage, like the flowing water in the Xin’an River.

The governor in Zhejiang was Hu Zongxian, who simultaneously held the position of imperial inspector. On that afternoon, Governor Hu was entertaining a group of western merchants at the South China Textile Bureau’s product exhibit hall. Yang Jinshui, a eunuch who headed both the South China Textile Bureau and the Zhejiang Provincial Maritime Affairs Department, had organised a show to illustrate the marvels of Chinese silk. Despite his reluctance, Governor Hu felt that he should be there to offer support.

Boom, boom, boom! The pulsating sound of the drums not only assaulted one’s eardrums but also tugged at one’s heartstrings. Drumbeats had only recently become a form of entertainment under Emperor Jiajing, rather than the traditional call for action in the bloody battlefield. As the drums faded out, the sound of flutes filled the cavernous hall – another recent addition to the established music repertoire. Even though the tender and melancholy melody came from the flautist sitting on the stage nearby, one felt as if it had flown down straight from the remote heaven.

Shimmering silk draped the handrails of a long spiral staircase that stood in the middle of the exhibit hall and led to the second floor. From the handrails, the gorgeous fabric extended upward and ended on the shoulder of a tall and beautiful young woman. She, in turn, had elegantly wrapped the tip around her neck.

Appearing both translucent and colourful at the same time, the silk looked magical. Similarly, from a distance it appeared to have rich patterns but grew smooth and blank when one moved closer. The flowing silk melded seamlessly with the soft, siren-like melody of the flute, another once-forbidden aesthetic pleasure recently allowed again as official entertainment. When the stirring tune ended, the silk-bedecked lady moved, turned her back and smiled at the guests who were sitting on a row of chairs across the hallway. When she walked, catlike, towards the end of the second-floor corridor, her elegant figure pulled the bustling silk like a bridal train. Captivated both by the model and material, the guests stood up and applauded vigorously.

Governor Hu sat in the middle of the row. On his left was Yang, who had orchestrated the performance. A few local officials and five opulently decked-out merchants flanked him on either side. The merchants stood out because of their foreign looks – they had unusual aquiline noses, deep-set eyes and dark skin. The entertainment obviously bedazzled them.

“Light the candles,” Yang ordered with his high-pitched voice as he clapped his hands. Dozens of his assistants, each carrying a lit candle, emerged from the hall’s dual entrances. They approached the audience and handed each member a gleaming candle. When Hu declined his, Yang looked puzzled. “You and other officials should go ahead and show them the product,” said Hu, with an exhausted look.

“I understand that you’ve been really swamped lately,” Yang said. “But I’m afraid that we can’t let you go yet. We’re going to start negotiating with our clients. Once we figure out how much silk they will order and how many gunboats we require to escort the commercial ships, we need your approval to seal the deals. Why don’t you sit here and take a rest first?”

Holding a candle, Yang stepped away with his guests. As he paused before the staircase, he shouted once again, “Lights off.” The red silk lanterns that decorated the second-floor corridor went off, and the exhibit hall darkened. The candles flickered, forming an aura of light in the middle of the hall.

By the candlelight, Yang’s pale, beardless and pudgy face, typical among eunuchs, became clearer. He led the group forward, and slowly they approached the spiralling stair to examine the silk that draped around the handrail. Seated nearby, Governor Hu closed his eyes. Then, a guard appeared at the entrance, carrying a thick wool cloak on his arm. He tiptoed over to Governor Hu and quietly placed it over his body before retreating into a corner.

When Yang and his guests were halfway up the stairs, they paused as two of Yang’s assistants gently lifted the silk and held it aloft. “Please proceed to examine the fabric,” Yang said, moving his candle closer to the silk. Butterflies and bees on the fabric came alive. They flew around clusters of flower buds; their wings appeared so transparent that one could see both sides. Each butterfly and each bee carried a different colour and pattern, and when they flapped their wings they took on different angles. The foreign merchants smiled but remained unimpressed.

“Let’s go up,” Yang said.

When they reached the landing on the second floor, Yang’s two assistants took a few steps back and carefully held up the second stretch of the silk for the guests to examine. Several candles converged to shed light on the fabric – similar patterns of butterflies, bees and flower buds.

The guests merely smiled politely without showing much interest. Seeing their diffidence, Yang pointed his soft and slender finger at a flower bud on the fabric and declared in his feminine voice, “Look at this flower, watch it very carefully.”

The guests bent over. Yang tapped one of his fingers on a flower bud. At Yang’s touch, that flower bud began to move – it was slowly blooming.

“Kai Le,” one of the merchants blurted out in Chinese, which meant “It’s blooming”. His fluent Chinese, with an awkward Zhejiang accent, suggested that he had taken many business trips to the region.

“You have a sharp eye,” Yang complimented the Chinese-speaking merchant. “Based on the western time device, this part of the fabric can be made into a dress that is suitable to wear at seven o’clock in the morning. Since the flowers are still budding, the butterflies and bees simply fly around them.”

The Chinese-speaking merchant translated Yang’s words for his colleagues, who nodded vigorously.

“This other section of the fabric can be tailored into a dress for a woman to wear at ten o’clock in the morning when the flowers are blooming, and bees and butterflies are beginning to collect nectar and pollen,” explained Yang.

After hearing his words translated, the guests abandoned their former restraint and uttered sounds of admiration. Their positive reaction pleased Yang and the other officials, who looked at each other proudly.

“Please allow me to continue,” Yang said with a cautious grin. The group held their candles and climbed another flight of stairs. Their shoes stepped soundlessly into the thick carpet. The hallway was so quiet that one could hear Governor Hu’s light snoring.

Outside the exhibit hall, the sounds of clicking hooves caught the guards’ attention. The South China Textile Bureau was located inside the imperial provincial government office complex. Under normal circumstances, it was closely guarded, but on that day all the senior officials in the province who were invited to the show had brought their own guards. So a heavy presence of uniformed security personnel made the exhibit hall look more intimidating than usual. Therefore, it came as a shock to the guards that horses were even allowed to burst into the complex. Looking alarmed, the guards rushed out to the Textile Bureau’s main entrance, and in came an angry-faced individual they recognised as Mayor Ma. While they were deciding whether to stop Mayor Ma’s horse, he had already barged in and stopped right in front of them. The governor’s personal aide knew the mayor well, and he went up to greet him.

“Is the governor here?” The mayor dismounted before tossing his bullwhip to a startled guard behind him.

“Yes, Your Highness,” replied the aide. “What’s the rush? An emergency?”

“There’s an uprising,” said the mayor, who strode towards the main entrance to the exhibit hall. “Some pirates have instigated it, and about a thousand unruly scoundrels are gathered outside as we speak.”

Shocked at the news, the aide led Mayor Ma into the Textile Bureau’s courtyard, a labyrinth of chambers and halls. After passing through multiple heavily guarded gates, Mayor Ma finally saw the exhibit hall, which, to his surprise, had no armed soldiers at the entrance. Only two eunuchs stood outside. The determined mayor made a beeline for the entrance, leaving the governor’s aide scrambling behind. “Your Highness, we can’t allow you to go in at this moment,” two eunuchs said in a firm tone as they stopped him. “It’s not the right time.”

The mayor, who had acted arrogantly in front of the farmers, finally met his match here. Faking a smile, he whispered in a humble tone, “I have something urgent to report to the governor. Please, I really need to see the governor and the others now.”

One of the eunuchs pointed a finger at the hall and whispered, “All urgent matters have to wait. As you can see, they’re in the middle of…”

The mayor peeked in and saw shadows flickering on the walls. Yang and a few provincial officials were watching a silk product display in a room partially illuminated by candlelight.

Confused and out of his element, the mayor took a gulp of air and said in a hushed voice, “There’s an uprising that I have to report.”

“An uprising?” the eunuchs uttered, looking shocked and nervous. “Where? How many troops are involved?”

“At this stage, we haven’t mobilised the troops yet,” the mayor explained. “Only a thousand or so farmers are gathered outside the complex.”

The two eunuchs, who had their hearts in their mouth, uttered a sigh of relief. “For a moment, I thought the pirates had attacked us,” said one of them. “Why don’t you just wait for a few minutes? It won’t be long.”

Just then, the governor’s aide caught up with them. “Since Governor Hu is resting, would it be possible for me to take him inside and talk with him?”

“That’s right,” the mayor nodded ingratiatingly. “I promise I won’t interrupt the show. All I need is to talk with the governor quietly and report the incident.”

The two eunuchs looked at each other hesitantly. Obviously, it was not wise to stop the governor’s aide from seeking out his boss. “Well, if anything happens, I’m afraid you have to take the blame,” a eunuch said to the aide.

“I swear that we won’t cause any problems,” the aide promised.

“All right then, please go in quietly,” one of the eunuchs acquiesced reluctantly. “You know how upset Yang Gonggong can get when interruptions occur.”

“Of course,” the mayor added.

“Please go this way,” one of the eunuchs said while stepping aside to let them in.

The mayor followed the governor’s aide and tiptoed inside. Before they approached the governor, the aide signalled the mayor to halt. In the faint candlelight, they saw Governor Hu sitting there with his cloak covering his back. Even though the governor kept his upper body upright, the mayor could hear his light snoring.

The governor’s thinning face betrayed stress and exhaustion. Realising his state, the aide became reluctant to wake him. He shot a glance at the mayor, who shook his head sympathetically, indicating for the aide to wait. They simply stood there, unmoving, so they wouldn’t disturb their governor’s nap.

The unusual activities on the second floor caught their attention. Mayor Ma and the governor’s aide turned their gazes towards the stairs, where Yang, the eunuch who directed the South China Textile Bureau, was attempting to impress his guests with the elaborately designed silk samples. Yang and his guests moved closer towards the top of the stairs, where the young model was holding the tip of the beguiling silk sample. Two of Yang’s assistants went ahead of everyone to straighten out the surface, which seemed to have retained the same pattern – butterflies and bees. But a closer look by the candlelight revealed a different picture: the butterflies and bees were actually falling flower buds.

“This part of the silk can be tailored into a dress that ladies wear in the evening,” said Yang. “Based on your western custom, the material is good for a nightgown.”

All the guests nodded with admiration and appreciation. One muttered something in his native tongue, and the Chinese-speaking merchant immediately turned to Yang and explained, “My friend is curious to find out why you want to embed these subtle changes in this pattern?”

Yang gave out a mysterious smile. “As you probably know, a true aristocrat seldom shows off,” he said. “They’re reluctant to bring attention to themselves. So they wouldn’t want people to see right away that they have changed outfits. One has to be observant to notice that they have actually changed four times during the day. That’s what we call a true aristocrat.”

Yang’s explanation triggered a round of lively discussions among the guests. When they finally dwindled, the Chinese-speaking merchant spoke up on their behalf. “They think this type of silk will sell well among the wealthy in their countries,” he briefed Yang. “Of course, when I say ‘they’, it includes me as well. We’ll each order a hundred thousand bolts. Do you have enough in stock? That’s what we want to know.”

Yang paused for a second. “Of… Of course, we do,” he answered. “We’ll have enough to meet everyone’s need.”

Once the orders were confirmed, Yang declared in a high-pitched triumphant voice, “Open the windows!” The curtains on the second-floor windows were lifted and daylight filtered in, carrying different colours – the windows were draped with a variety of colours and patterns of silk.

Music rose. Governor Hu opened his eyes and saw Yang descending the stairs, beaming with self-congratulatory delight. As Governor Hu stood up to greet Yang, his aide approached to remove the cloak from his back. From the corner of his eye, he was surprised to see Mayor Ma, who was too preoccupied to follow the usual etiquette of bowing. But he and the governor were close enough, and an occasional omission wouldn’t do him much harm. The mayor cupped his hands, whispering in the governor’s ear what had happened along the Xin’an River bank. Hu showed no emotions. Having secured this high ranking within the government, Hu might have cultivated and attained his state of serenity at a time of crisis. Or perhaps he had long anticipated that such riots would happen sooner or later.

As Yang and his guests came up to him, he greeted them with a calm yet weary smile.

“Our guests have ordered half a million bolts of silk,” Yang reported to the governor, grinning from ear to ear. “That will translate into seven and a half million taels of silver. Your Highness, it is now up to you to make it happen.”

Governor Hu did not respond and wore only a contrived smile on his tired face.

Noting his response, the other officials refrained from expressing too much enthusiasm about the deal.

Meanwhile, the foreign merchants began chit-chatting in their native tongues. The Chinese speaker stopped his own chatter and translated their conversation to Yang. “Mr Sahari and his friends really like the model who was holding the silk there. Can you find some other young women like her and sell them to my friends?”

Yang sniggered. “That does not fall under my jurisdiction. Go and ask them,” he said, pointing at Governor Hu.

Hu’s smile vanished. “Our Ming empire sells silk, tea and china, but not humans,” he said, sternly.

Even without the translator’s assistance, the foreign guests understood what Hu had said from his facial expression. They stopped their jokes, their faces turning sullen.

“Please send our guests to the hotel for food and rest,” Hu told Yang, who, by then, had noticed the anxious-looking Mayor Ma. His unannounced presence could only indicate one thing – there was an emergency that needed the governor’s urgent attention. A flicker of annoyance flashed across Yang’s face. He turned around and faced his guests with a chortle. “You have probably heard the Chinese phrase Paradise in heaven, the cities of Suzhou and Hangzhou on earth,” he said. “We specifically invited these musicians from Suzhou to perform for you today. This evening, we have arranged a boat tour for you on the legendary West Lake in Hangzhou. Let’s talk business tomorrow.”

After hearing the translation of their host’s words, the guests looked pleased and eager. Yang clapped his hands, and several young eunuchs appeared. They led the guests out of the exhibit hall.

“Let’s go and have a meeting at my office,” Governor Hu told Mayor Ma before marching to the door in big strides. Mayor Ma and the other officials followed.

The public space outside the governor’s office complex covered four mu of land, symbolising that the earth was a flat square and the Imperial Palace commands all four corners of the earth.

In the middle of the square stood a thirty-three-metre-tall flagpole, which remotely faced the office entrance. The flagpole lay flanked on both sides by two gigantic stone lions. At other times, the empty square exuded authority through its spaciousness, but today the atmosphere was different. Farmers from Chun’an, a rural county outside the city of Hangzhou, swarmed the space. Even the stone pathway to the entrance, specifically reserved for officials visiting the governor’s office, was packed with petitioners, all of whom fell to their knees soundlessly. The fluttering sounds of flags billowing in the wind accentuated the silence.

Armed with sabres, the governor’s security guards lined up on both sides of the front entrance, with the stone lions towering over them. Tan Lun, former aide to the Prince of Yu, donned his military uniform and waited quietly on the steps. As the crowd knelt silently, the armed guards watched them nervously and vigilantly.

Soon, Governor Hu’s entourage appeared in the distance. But given that the pathway was fully occupied by petitioners, the governor’s sedan and the guards’ horses could not pass through. Flummoxed, they stopped on the outer edge of the square. When Governor Hu and other provincial officials stepped out of their sedans, the petitioners cast their gloomy glances at the governor and then at the yamen entrance where Tan Lun waited, his eyes fixed on one person: Governor Hu.

Their eyes met. People noticed that the governor looked despondent, but Tan’s eyes showed flickers of hope and expectation. Avoiding Tan’s searching stare, Governor Hu quickly turned his face to the sky, towards the graceful and overhanging roof of the yamen building.

“Your Highness, take a good look at that person there.” Mayor Ma stepped forward and pointed at Tan Lun. “He’s the one who has colluded with General Qi and created this mess.”

“Let’s settle things with those two later,” suggested Ho Maocai, who headed the Provincial Justice Department. “I think we should make arrests first. Once we capture the ingrates, we can interrogate and investigate them one by one. Those who are guilty will be punished accordingly. If necessary, we should report this to Beijing.”

The crowd turned to Governor Hu, waiting to see where he stood on the protest.

“There are so many over here – how can you arrest them all?” Governor Hu spoke up.

“But this is the governor’s yamen and they can’t…” Ho stammered.

“Don’t worry,” Governor Hu interrupted him. “They won’t dismantle this place. Even if they do, I’ll take the blame. When the Imperial Palace removes me from my position, I’ll just go back to my native village. Why don’t we use the back door to get in?”

Instead of returning to his sedan, Governor Hu took a detour and walked towards a side street, where the back entrance stood. The other officials also abandoned their sedans and followed him. Yang Jinshui, the eunuch in charge of the South China Textile Bureau, began throwing a tantrum. With a sullen face, he scurried towards his sedan. A junior eunuch lifted the sedan curtain, and Yang clambered in.

Soon, Mayor Ma stood there as if in reverie, and it took a while for him to realise that he was the only official left in the square. Before hurrying away, he threw a few hateful glances at Tan Lun, who waited at the entrance with the stony expression of a statue.

Through the back entrance, Governor Hu’s entourage entered the expansive Zhejiang provincial governor’s yamen and gathered inside a conference hall. After they took their seats, an aide went out to summon Tan Lun, who was then serving as a military adviser to Governor Hu.

A few minutes later, Tan Lun appeared. Without greeting anyone, he walked over to an empty seat next to a long table on the right side of the hall. Barely had he sat down when Mayor Ma removed his official hat and tossed it on the desk in front of him. “We are risking our lives on the front line, but some people here are sabotaging us,” he fulminated. “Converting land and growing mulberry is a national policy. What I want to ask is, shouldn’t we go all out to implement it? But if we don’t have everyone’s support, I seriously doubt that I can do it.”

All eyes turned to Governor Hu, who stared into the courtyard with a pensive look before drifting to Zheng Bichang, the chief administrator, who was the second most powerful person in the province of Zhejiang.

Zheng felt obligated to speak up. “I have to agree with Mayor Ma. It’s been four months since the Imperial Court issued the policy. So far, we’ve only met ten per cent of the quotas. We’ve been receiving letters from the Privy Council every few days. Beijing is requesting progress reports. That’s the reason I sent Mayor Ma over to check up on those who were implementing the land-conversion programme. Many of you who are sitting here attended the trade negotiation at the South China Textile Bureau early today. We all saw that the foreign merchants have ordered half a million bolts of silk and that the orders have to be fulfilled by the end of the year. Without the land-conversion initiative, we wouldn’t be able to produce that much raw silk here in Zhejiang. If we allow this chaos to continue, the Privy Council will definitively call us to account. If Yang Gonggong and the South China Textile Bureau fail to generate enough silk for export, Lu Gonggong will be censured by His Majesty. Who’s going to take the blame? By then, I doubt anyone can get away with it by simply quitting.”

When Yang Jinshui’s name was mentioned, he sat there with his eyes closed, as if he had been a mere outsider. Zheng was accustomed to Yang’s shrewd calculated reticence – each time a sensitive topic came up, Yang would only put on his listening ear but seldom opine. On the contrary, Ho Maocai, director of the Provincial Justice Department, exerted no self-control at public meetings.

“I think some people are conspiring against the Imperial Palace,” accused Ho, who banged a fist on the desk to strike home his point. “The provincial government has sent troops to assist with Mayor Ma’s work and control those dangerous mobs. But now, those scoundrels are bold enough to stage a riot in front of the governor’s office. Do we know who in the world ordered General Qi to withdraw his troops? Please stand up and explain it to Governor Hu and Yang Gonggong?”

It was obvious that Ho’s remarks were intended for Tan Lun, especially after he and a few others glowered suspiciously in Tan’s direction.

To the surprise of those in attendance, Governor Hu spoke up and claimed to be the alleged culprit. “I was the one who instructed General Qi to pull the soldiers,” he said in his usual deep calm voice, which struck Ho and the other officials like claps of thunder. Even Yang was jolted awake before drifting into his feigned nap again.

Tan Lun had not expected that Hu would readily accept responsibility on his behalf. Feeling grateful, he was tempted to thank Governor Hu in front of everyone but resisted the urge. Instead, he remained still, with arms folded and eyes downcast.

“The government has planned to borrow sixty thousand tonnes of rice from private suppliers to make up for the loss of rice output during the land conversion. Any progress on that?” Governor Hu asked Zheng, his deputy.

“We haven’t had much luck yet,” Zheng answered, looking surprised that Governor Hu would suddenly change the subject. “We’ve approached several large rice suppliers, and they all claim they don’t have much to spare.”

“What about securing some loans from other provinces?” Governor Hu continued.

“We sent a representative to the neighbouring province of Jiangsu last week, and officials there sounded reluctant,” Zheng replied.

“Your answers have helped explain my current position on the land-conversion programme,” said Governor Hu, who peered at Ho Maocai, signalled for him to sit down.

“As the governor and imperial inspector of Zhejiang Province, I’m willing to take the criticism and punishment from the Privy Council. If folks in the field curse us, they can swear at me. I understand that growing mulberry is a national policy and we have no choice but to implement it. But aren’t they aware of the fact that if we propagate those mulberry seedlings now, we won’t start seeing new leaves until the autumn? This means that farmers can only harvest two rounds of silkworms this year – one in early autumn and the other in late autumn. Within such a short window, we wouldn’t be able to generate enough raw silk. In other words, if our government simply urges rice farmers to give up their grain production and grow mulberry trees, they wouldn’t be able to earn enough to support themselves. Without any government loans to tide them over, people will be starving in the winter. Hunger breeds rebels. I understand that we are required to produce an additional three hundred thousand bolts of silk every year. But if these three hundred thousand bolts of silk could lead to insurrections and produce three hundred thousand rebels, I don’t think I’ll be the only one who will end up having his head cut off.”

When Governor Hu stopped, the conference hall fell into total silence.

Hu turned to Mayor Ma and ordered, “I want you to go out there and release those folks immediately. Open up the irrigation channels along the Xin’an River and allow farmers to water their crops.”

Mayor Ma stood up, trying to defend his actions, but Governor Hu shot him down. “I don’t need to hear your explanation,” he said with a look of impatience. “Please go and take care of it now.”

“Yes, Your Highness,” the mayor responded in a husky voice. Picking up his official hat, he dashed out.

“Your Highness, I know I have no right to stick my nose in your affairs here in Zhejiang,” said Yang Jinshui, who had strategically kept his eyes closed most of this time. “But I have been assigned to run the South China Textile Bureau on behalf of the Imperial Palace. His Majesty should be cognisant of the transactions we completed today. So it’s really important that we fulfil those orders. As you probably know, the textile bureau has only about one hundred thousand bolts of silk in stock. The silk mills in Hangzhou and the nearby cities of Nanjing and Suzhou have to produce an extra four hundred thousand bolts. But, at present, we just don’t have enough raw silk. Based on our assessment, the current amount of raw silk provided by mulberry farmers in the area is only good for two hundred thousand bolts. So we’ll be at least two hundred thousand bolts short. If we can’t meet the quotas, we could be in big trouble. The Privy Council might let you off the hook, but I can’t get away with it because I’m a staff member of the Imperial Palace. I have to fulfil my promise for Lu Gonggong and His Majesty.”

“I’ll write up a report about today’s events to His Majesty,” Governor Hu countered. “If the Privy Council wants to implement the land-conversion programme, it has to urge our neighbours to loan more rice to us. The Ministry of Treasury needs to reach out to them directly. At the same time, we also have to persuade private rice suppliers to lend us rice or pressure them if necessary. I know many suppliers are concerned that the government might renege on its promises to pay back the loans. To boost their trust, I’ll put the governor and the imperial inspector’s stamps on all of the IOUs. Every day, I can see suppliers’ junks loaded with grain travelling on the Grand Canal. Why can’t they lend us some? Anyone who blatantly lies about their inventory and refuses to help out will be charged with hoarding. Extorting the rice suppliers is a better option than driving ordinary folks to rebellion, don’t you think?”

Yang didn’t answer. Instead, he closed his eyes again. Nobody around him openly objected to Governor Hu’s proposal.

Governor Hu’s report reached the capital city in seven days via the Imperial Express service. Instead of following the usual route and delivering it to the postal department, the courier ferried it directly to the Privy Council’s reception room inside the Western Palace. Xu Jie, the deputy grand secretary, happened to be on duty. From a mere glance at the envelope, he could tell that the letter was no ordinary report and could cause huge ripples. Holding his cards close to his chest, he ordered an assistant to personally deliver the letter directly to Yan Song’s home without opening it.

Local rumours long held that the nation’s major decisions were made inside the Yan family mansion, rather than the Forbidden City. The sly supposition had some truth to it. Yan Song had turned seventy-five in 1556, and except for his daily thirty-minute private meeting with Emperor Jiajing in the Yuxi Palace early in the morning, he seldom showed up at the Privy Council’s office. All the important government reports and documents were sent directly to his home. For urgent matters relating to national defence, Yan Song would summon council members to his mansion for discussions. Once he and his council members formed a consensus, he would draft an official response and submit it to the emperor through Lu Fang, who headed the Interior Ministry.

Under normal circumstances, Yan Shifan sifted and reviewed all major documents pertaining to the Privy Council before sharing them with his father. Governor Hu’s report on that day was no exception. Yan Shifan tore off the envelope, and after skimming through the document’s contents he exploded with anger and quickly sent a messenger to summon Luo Wenlong, his father’s confidant as well as his most trusted friend.

Luo headed the postal department that handled key reports and letters submitted by officials from around the country. When Luo arrived, Yan Shifan brought him along to consult with Yan Song in his study.

Even though Yan Song did not show much emotion upon reading the letter, Yan Shifan knew that his father was equally upset. “Governor Hu claims that we’ll lose the support from farmers if we grab their land, and landless farmers could pose a threat to the security of our country,” Yan Shifan said contemptuously as he held up Governor Hu’s report. “What does that mean? He’s such an alarmist. These statements are so pompous. I think he is boycotting our plan because he’s concerned about his own political future.”

“I cannot agree with you more,” said the scholarly-looking Luo. “I alerted and cautioned everyone here when the Prince of Yu decided to transfer his chief of staff, Tan Lun, to the Zhejiang governor’s office last month. As you’re probably aware, Tan Lun and Governor Hu have been friends for years. Governor Hu knows very well that Tan Lun is a confidant of the crown prince. Given that Your Highness is considering retirement and the crown prince might take over the country someday, it’s natural that Hu would look for a fallback plan to hedge his bets. The fact that Governor Hu bypassed the postal department and had his report delivered directly to the Privy Council shows that he intends to curry favour with Xu Jie and other friends of the crown prince.”

Yan Song, who had remained inert on his couch until then, interrupted. “But Xu Jie didn’t open the letter. I think Governor Hu simply wanted to bypass you two so he can get his message to His Majesty and me directly. I can’t vouch for anyone else, but I know for sure that Governor Hu is a loyal student of mine. I doubt he intends to betray me and undermine my authority. He simply has a different perspective on the land-conversion programme than yours, that’s all. When judging others, one should put oneself in their shoes. What would you do if you were Governor Hu?”

Yan Song’s reprimand disappointed Yan Shifan and Luo, both of whom had intended to drive a wedge between Yan Song and his protégé, Governor Hu. Little did they know that their seasoned elder would have dismissed their attempts so quickly. They looked at each other, speechless. Through their eyes, they seemed to be saying to each other: this man was eighty-one years old, but old age has not addled his brain.

“If you were in his position, you would have done the same thing,” Yan Song continued slowly, ignoring Yan Shifan and Luo Wenlong’s apparent disapproval. “It might not be a bad thing to have Tan Lung at his side. Tan has the backing of the crown prince, and the prince has the backing of His Majesty. It simply means that Governor Hu can’t be too reckless with his decisions.”

The old man certainly knew when to appear dull-witted, thought Luo.

“But the plan to convert rice fields to mulberry farms was also His Majesty’s idea,” Yan Shifan raged, angry at his father’s prejudice in favour of outsiders, rather than his own kin.

“Governor Hu is not saying that he won’t implement the policy,” Yan Song insisted. “Tan Lun’s presence is making him more prudent. The situation is pretty dire over there. If Governor Hu follows your plan without consulting with the Privy Council, he could give others an excuse to depose him.”

“Dad!” Yan Shifan walked up to his father and tossed Governor Hu’s report on a tea table next to the couch. “It’s so obvious that Governor Hu has written this report to curry favour with the crown prince,” he accused. “Anybody can see that, except you. Why are you always defending him? How could you claim that he’s merely trying to bypass me because he doesn’t like me? Who am I? I’m your son. You’re eighty-one years old. Have you ever thought that someday, when you retire or die, all of your political enemies would take me out? I won’t have any fallback.”

“Oh, stop it,” Yan Song interrupted his son. “Let me ask you, who is the crown prince’s father?”

Once again, Yan Shifan felt blindsided by his father’s question.

“Do you know who His Majesty is visiting this afternoon?” asked Yan Song, who gazed at the courtyard outside.

Yan Shifan and Luo Wenlong shook their heads.

Yan Song sat up in his couch and enlightened them. “He’s going to the crown prince’s mansion to meet his new grandson.”

Yan Shifan and Luo now understood what the old man was trying to imply – the Prince of Yu’s stock had just risen with the birth of his son.

“You’re always so impatient.” Yan Song shot his son a reproachable look before lying down on his recliner. “Why don’t you two sit down? You make me dizzy.”

“Now that Tan Lun has been transferred to Zhejiang Province, the Prince of Yu has been keeping a close watch on what is happening there,” Yan Song said. “In other words, even if the postal department intercepted Governor Hu’s letter, the Privy Council, the Interior Ministry and His Majesty would find out sooner or later. So stop fussing over protocols, and let’s focus on the content of the letter. How will His Majesty react after he reads Governor Hu’s report? To me, his arguments and suggestions are quite mature and wise. The conversion policy involves the conversion of many acres of farmland, and it directly affects the lives of thousands of farmers. Zhejiang has been rife with pirate attacks. If our policy triggers large-scale insurrection, it wouldn’t be good for our country. What if His Majesty shares similar concerns but still insists that we increase the production of silk by four hundred thousand bolts at all costs? How should we respond to this? I would suggest you peruse Governor Hu’s report. I understand that you support the idea of allowing large silk mill owners to acquire land from farmers and convert it into mulberry plots. But is there an alternative option that can accommodate both needs – boosting silk production while benefiting farmers?”

“I’m not aware of any other option that is better,” said Luo.

“Like you just mentioned, our land-conversion policy aims to boost the supply of raw silk for export production,” Yan Shifan responded in a testy tone. “Increases in silk exports can earn us more silver taels. But, if the quality of the silk is inferior, foreign merchants wouldn’t buy it. So the silk has to be made at large facilities. If we allow farmers to grow mulberry and raise raw silkworms, they would inevitably sell the raw silk to smaller mills. Their cheap low-quality products will never meet the export standards. That’s why we encourage farmers to sell their land to big mill owners. Dad, that’s what our land-conversion plan is all about. Our ultimate goal is to reduce the national budget deficit. But, if we don’t grit our teeth and stick with it, our national treasury will be depleted. Pretty soon, we won’t need others to topple us. We’ll collapse on our own.”

Yan Song remained unconvinced. To win the old man over, Luo realised that they had to follow his logic by temporarily leaving Governor Hu out of the conversation and making Yan Song aware that they were on his side all along. “We don’t have to speculate about Governor Hu’s motive,” Luo interrupted. “But your son is well-intentioned, and his analysis is right on target. As the saying goes, a desperate illness needs a desperate cure. The land-conversion policy was initially made to alleviate a perilous situation. We have to rely on large silk mill owners, who have the capacity to rake in several million taels of silver each year and help ease our deficit. If we’re lucky, we can probably cover some of this year’s expenses as well. As for those targeted farmlands, farmers have to sell them whether they like it or not. Otherwise, the export orders secured by the South China Textile Bureau will fall through. If we fail,” he added, looking Yan Song directly in the eye, “the Privy Council and Your Highness would be held responsible. I doubt that Lu Gonggong and the Interior Ministry would want to have anything to do with it.”

Luo’s words touched a sore spot. Yan Song sank into silence and stared blankly at the garden outside while Luo and his son, Yan Shifan, were waiting for him to speak. A few minutes later, Yan Song picked up Governor Hu’s letter from the tea table. “I guess we cannot always shoulder everyone else’s problems,” he sighed, waving it in his hand. “Take this letter to the Interior Ministry and try to talk with Lu Gonggong before His Majesty visits the Prince of Yu today. Tell Lu Gonggong to present the letter to His Majesty upon his arrival at the prince’s mansion. If possible, request that His Majesty offer his feedback right in front of the prince.”

Yan Shifan looked befuddled – he hadn’t fully grasped the old man’s true intentions.

“That is a very wise idea,” Luo complimented Yan Song while trying to explain it to the grand secretary’s son. “If His Majesty reads Governor Hu’s report, he’s likely to support the land-conversion policy, insisting that we meet the export quotas. Whatever suggestions or comments he makes in front of the prince would be known to everyone and exempt us from future liabilities. That’s your father’s first intention. Secondly, if the Prince of Yu opposes the policy, he wouldn’t dare challenge His Majesty in front of everyone. On the other hand, if the prince fails to speak up, it would be political suicide for him. In the future, we can easily claim that he conspires with his allies inside the Privy Council to sabotage His Majesty’s authority. Your Highness, have I interpreted this all correctly?”

Yan Song nodded appreciatively. “Thou hast certainly read my mind,” he praised. “Nobody is as perceptive and insightful as you are!”

Yan Shifan did not seem to mind that his father favoured Luo over him – at least not in this instance. “Ah, I see,” he blurted out loudly. “I’ll take the document to the Interior Ministry immediately.”

As Yan Song had correctly predicted, the news about Governor Hu’s urgent report had reached the Prince of Yu. Since Tan Lun’s secret letter to him arrived in Beijing simultaneously, the prince and his advisers were briefed on what Governor Hu had written.

Zhang Juzheng, the head of the Ministry of Defence, clapped his hands after reading Tan’s letter. “Tan Lun is a true hero,” he remarked excitedly. “It is quite a feat to persuade Governor Hu, a key member of the Yan faction, to submit this report. There is hope.”

“I beg to differ,” said Gao Gong. The deputy minister of the treasury, who was known for being easily excitable, was uncharacteristically calm. “Governor Hu must have proposed quite a few items in his report, but, except for Yan Song and his son, nobody knows exactly what has been included. There is a possibility that Yan Song could omit some items and present those less important ones to His Majesty. Then, Yan can write to Governor Hu, asking him in private not to mention those omitted items. I doubt Governor Hu would speak up to embarrass Yan, his mentor.”

Gao’s words dampened the enthusiasm in the room like a bucket of icy water. An uncomfortable silence ensued. The Prince of Yu shot a sidelong glance at Xu Jie, the deputy grand secretary.

“Governor Hu’s report was first delivered to the Privy Council’s duty room, and you happened to be there to receive it,” Gao groused. “I wish you had gone over to Yan Song’s house to hand-deliver the report. In this way, Yan Song would have felt obligated to share the report with you. That would have prevented them from rigging it. Please don’t take offence – I know prudence is a virtue – but often, too much prudence can ruin things.”

Xu’s face flushed red with anger. The Prince of Yu and Zhang, who were too flustered to respond, sat there quietly. An infant’s loud screaming from the inner chamber broke the awkward silence.

“What happened?” the prince shouted to the people inside. “We have so many adults in there, and nobody knows how to take care of a baby!”

“His Majesty is visiting this afternoon, and we’re trying a new hat on him,” a maid dashed out and explained, with her head lowered. “The boy doesn’t want it.”

“If he still cries, don’t put it on him,” complained the prince. “His Majesty will be here in an hour. Go and tell the princess that our son needs to wear the ceremonial robe. It’s frustrating that nobody here is helping.”

“Yes, Your Highness,” the maid said before retreating hurriedly.

The guests, all of whom were mentors of the prince, knew what he was insinuating. Deputy Grand Secretary Xu wondered if the prince was venting because of Gao’s previous remarks about him being overly prudent. So he stood up and dutifully offered his self-criticism. “Gao might be right in blaming me,” he offered. “If you also agree with what Gao has just said, I can make up for it by going to Yan Song’s residence right now and finding out exactly what Hu has submitted.”

Realising that he had probably overreacted, the prince quickly corrected himself. “I didn’t mean to blame or reprimand anyone,” he explained. “I was just in a bad mood. It’s kind of pathetic. Even though I’m His Majesty’s son, you people are treated better than I am. The last time I saw His Majesty was two years ago. If it hadn’t been for his grandson, he wouldn’t have come this afternoon. It’s a hopeless situation. I don’t even have the opportunity to shoulder some of my father’s responsibilities. What gives me the right to blame you? Oh well, His Majesty will be here shortly. Why don’t you all go home. Let’s discuss the affairs in Zhejiang some other day.”

Seeing that the prince had stood up, the guests reluctantly rose as well. They had hoped to meet and strategise with the prince about speaking with His Majesty during his visit. But now, the group parted on bad terms – Gao’s blunt criticism had soured the prince and left Xu in a dark mood.

“I’m sorry to be such a wet blanket,” Gao apologised to the prince before turning to Xu. “Please don’t take offence. I was just worried that Yan Song and his son could distort the messages in Governor Hu’s report. Oh well, we might get a better idea during His Majesty’s visit.”

As the Prince of Yu walked his three guests to the gate to bid them goodbye, the royal grandson’s loud wailing sounded again. He turned around and saw Princess Li stepping out of the inner chamber with their crying child in her arms. A maid followed, cupping with her hands a small crown embedded with tiny pearls. The delicate task had made her sweat profusely. An additional childcare cadre followed with the child’s nanny and three other maids. Perspiration shone on their faces, as well.

The prince glanced at his infant and then shook his head. “His Majesty could be here any minute, and you people can’t even get him to put on his royal hat,” he scolded, looking crestfallen. “Don’t you know how to take care of a child?”

The women visibly quaked, while the princess rocked the child gently and slowly in her arms. His crying diminished but started again as a maid hastily put the baby’s hat on with her trembling hands. Distressed, the maid quickly pulled her hand back.

“Feng Bao is the only person who can stop this,” Princess Li said to her husband. “I think we should get him here.”

The mere mention of Feng’s name disgusted the prince. He paused for a second then waved his hands in defeat. “Go and get him. His presence is required at the ceremony anyway.”

A few moments later, the maid rushed in with Feng, who, in a matter of months, had transformed into a different person. Donning a grey coarse linen robe with a wide blue belt, Feng had the new look of a low-level servant, complete with a modest smile on his dusty face. Before stepping inside, Feng dropped to his knees outside the entrance, his forehead touching the ground. “Your humble servant, Feng Bao, is kowtowing to the prince and princess.”

The prince, who was perusing a book at his desk, ignored Feng’s obsequious greeting, but Princess Li quickly invited him in. “Go and play with his Royal Highness, and see if you can get him to wear his crown,” she said, handing over her child to the nanny.

“Yes, Your Highness,” Feng kowtowed again before sidling in. The nanny walked over to Feng with the boy. Feng lowered his head and murmured to Princess Li. “Your… your humble servant had no time to change before he came in… I’m afraid that my grubby outfit might…”

“There’s no time to worry about that,” Princess Li said impatiently. “Take His Royal Highness now.”

The nanny placed the little prince in Feng’s arms. Feng tilted the boy’s face towards his. “Your Royal Highness, can you recognise me?” he whispered mischievously. “Your humble servant and playmate is here with you.”

Astonishingly, the boy immediately stopped crying when he saw Feng’s grinning face. He stared at him, with his eyes wide open. The nanny and maids uttered a long sigh of relief, and hard-earned smiles appeared on their tired faces. Princess Li, looking visibly relieved, turned to her husband, whose head was still buried in the book. “Now, figure out a way to get him to wear the crown,” Princess Li told Feng.

“Yes, Your Highness,” Feng answered. When one of the maids handed the delicate valuable crown to Feng, the boy became scared and burst out crying again. The prince closed his book and rose from his desk with an irritated look. Before he had the chance to reprimand the servants, a eunuch appeared at the entrance and kowtowed. “A message for the prince and princess,” the eunuch announced. “His Majesty has left the palace. His guards of honour are approaching the main gate.”

The boy was still crying, and people in the room began to panic. The prince waved his long sleeves in agitation and strode out.

“Act fast!” Princess Li ordered anxiously. “We have to find a way to get the boy to wear his crown.”

“If only you allow me to break the rules a bit,” Feng asked. With the princess’s permission, Feng slowly squatted down with the little prince in his arms, until his knees touched the ground. “Meow, meow,” he began imitating the sound of a cat while moving about on his knees.

The boy began to giggle.

“Little Sister, could you bring the crown over and put it on my head first?” Feng asked the maid, who hesitated and looked to the princess for permission.

“Please go ahead,” Princess Li said, her voice trembling with helplessness.

The maid walked over, leaned down a bit and carefully placed the crown on the top of Feng’s head. It was too small to fit, but fortunately the maid was able to use a long attached string to tie the crown firmly around Feng’s chin. As the benighted eunuch bobbed his head, meowing like a cat and barking like a dog, the accessories started to clank, which aroused the little prince’s curiosity. He stopped giggling and kept his eyes fixed on the glittery and clinking accessories on Feng’s head.

“I think you can put it on him now,” Feng said in a low tone to the nanny. She bent over, removed the crown from Feng’s head and cautiously moved to place it on the little prince. To distract the child, Feng rocked him back and forth, serenading him with long drawn-out sounds of cats and dogs while the nanny tied the string around his chubby, baby chin. The procedure worked as seamlessly as an experienced doctor feeding a bowl of bitter herbal water to a difficult child.

“Whew,” Princess Li exhaled long and slow before slumping into a chair behind her. “Let’s get ready to greet His Majesty.”

The prince’s mansion consisted of six layered courtyards, and from the front entrance to the reception hall there were twelve gates, all of which were kept wide open prior to the emperor’s arrival. The compound was packed with guards of honour, who lined up on both sides of the gates.

Emperor Jiajing was his normal self. In contrast to the finery worn by the prince and his family, a casual loose-fitting robe covered the Ming ruler, along with a yellow Taoist headband. Now, as he perched comfortably on a chair in the middle of the prince’s reception hall, a rare benevolent smile spread across his face. Lu Fang, standing behind the emperor on the left, also appeared gleeful.

The prince dutifully kowtowed to his royal father nine times then retreated to the left side, while Princess Li moved to a similar position on the right. Both the prince and princess kept their heads down, as dictated by custom. Feng knelt in the middle of the room, holding the wriggly little prince in his arms, with him facing the grandfather.

As the saying went, when a person is favoured by fortune, even his mind becomes keener. The royal infant was only a few months old, but he was not the least intimidated by the stranger in front of him. Instead of staging another tantrum, however, the infant gazed upon the old man’s face, grinning and giggling. Charmed by his grandson’s smile, the emperor clapped his hands before opening his arms. The prince quickly grabbed his son from Feng and offered him to his grandfather. Feng rose from the floor and bowed his way out.

Emperor Jiajing beamed with pleasure as he examined his grandson’s face. The child beamed back. Jiajing’s paternal instincts were rekindled after years of strict Taoist meditation and isolation.

As the two generations delighted in each other, Princess Li observed the protocol by keeping her head down. Without knowing how her son was reacting to the emperor’s grand gesture, however, she became anxious. Sweat gathered in beads on her smooth forehead.

“You have rendered a great service for our empire,” Emperor Jiajing said, placing the child on his lap and addressing Princess Li. “I will reward you handsomely.”

Princess Li had no idea that the emperor was addressing her. Her husband quickly reminded her, “Princess, the Royal Father is speaking to you.”

Princess Li quickly dropped to her knees. “The birth of the royal prince testifies to the virtues of our ancestors,” she intoned. “His Majesty’s veneration for heaven and his love of his subjects have produced karmic reward. As the humble wife of your son, I dare not claim and do not deserve any credit.”

Emperor Jiajing’s face brightened even more. “I must give credit where credit is due,” said the emperor. “Since you come from a humble family, I will bestow a knighthood upon your father.”

Dumbfounded by the news, Princess Li froze like a statue. The prince quickly knelt next to her. “On behalf of my wife, I want to thank my royal father for this heavenly gift,” he said, followed by three kowtows.

Princess Li recovered from her shock and prostrated herself on the floor. As the prince helped her up, Emperor Jiajing noticed that her face was streaked with tears. “It’s a happy occasion, and there is no need to cry,” the emperor consoled.

“Please forgive me for the breach of etiquette,” Princess Li apologised, holding back her tears.

In a moment of generosity, Emperor Jiajing tilted his head to his most senior eunuch, Lu Fang, and said, “If Jiangsu and Zhejiang Provinces produce an abundance of silk this year, please gift one hundred thousand bolts to Princess Li’s family.”

“Yes, Your Majesty,” Lu Fang responded. “I will pass on the message to the South China Textile Bureau.”

Princess Li was about to kowtow again to express her gratitude when Emperor Jiajing interrupted her. “There is no need to thank me,” he said while picking up the boy from his lap. “Take good care of my grandson.”

The prince hurried over, retrieved the boy from the emperor and handed him to Princess Li.

“On this auspicious occasion, your humble servant wants to report another small piece of good news,” Lu Fang whispered to Emperor Jiajing. “The South China Textile Bureau has just secured orders of five hundred thousand bolts of silk from foreign merchants.”

“How much will the transaction bring us?” Emperor Jiajing asked, looking visibly energised at the news.

“The domestic price for silk is about six silver taels per bolt, but, if we ship it overseas, each bolt can sell for up to fifteen silver taels. So five hundred thousand bolts can translate into four and a half million silver taels.”

“This is excellent news,” remarked the emperor. “Do you think there is enough raw silk in Zhejiang for us to fulfil those big orders?”

“Hmm…” Lu Fang paused deliberately.

“What is it?”

“We have received a report from Hu Zongxian, the governor of Zhejiang,” Lu Fang said. “The report is related to the land-conversion programme. Yan Song delivered it to me before we left the palace. I was planning to show it to you.”

Emperor Jiajing, a shrewd and perceptive ruler, detected the overtone in Lu’s words. “Has he run into problems?” he asked. “Is he trying to complain to me about the policy?”

“Nothing escapes your sharp eyes,” Lu said ingratiatingly.

“I don’t want to read about complaints,” the emperor said dismissively. “Tell him to take his complaints to the Privy Council and talk to Yan Song.”

“Yes, Your Majesty,” Lu answered loudly while shooting a sidelong glance at the Prince of Yu, who stood with his head down. Lu thought he had detected a slight twitch on the prince’s face.

“Tell the palace not to prepare supper for me,” Emperor Jiajing stood up and announced. “I’m going to eat here.”

The prince bowed to his father. “Thank you for the honour, Father,” he said.

Emperor Jiajing foiled Yan Song’s plan by sending back Governor Hu’s report without even offering any comments. But Yan Song took comfort in the fact that the emperor had at least become aware of Governor Hu’s report. Since His Majesty specifically delegated the task to the Privy Council, Yan Song felt obligated to obey and entrusted it to his son, urging him to handle it with caution.

The emperor’s lack of interest emboldened Yan Shifan, who ignored his father’s advice to proceed cautiously. Even though it was late at night, he summoned Luo Wenlong to the Yan family mansion. When Luo arrived, Yan Shifan paced up and down in the room, too absorbed to speak. Curious to find out about the emperor’s reaction to Governor Hu’s report, Luo picked a seat near a desk and looked at Yan expectantly.

“Draft a letter to our folks in Zhejiang,” Yan Shifan dictated. “Tell them to ignore Governor Hu’s interference and go all out with our original plan. The rainy season in May is a critical time, and we have to seize the opportunity. Destroy the sluice gates along the Xin’an River, and flood the nine counties in the region. Once the rice paddies are submerged in water, we will send out leading silk producers in the region to seize the land by bartering for it with grain. Once the land is secured, we’ll plant mulberry right away. I want to see silk this year!”

“Understood,” said Luo. “What did His Majesty say?”

“His Majesty didn’t even bother to read it,” Yan Shifan replied. “Governor Hu’s report is coming back unopened – untouched. This provides us with a perfect opportunity. I’ll personally draft a rebuttal on behalf of the Privy Council. Damn it. I’m going to let Hu understand that the Yan family owns the halo over his head.”

With that, Yan Shifan stopped pacing. After a few strenuous coughs, he spat out a ball of thick phlegm.

3

Governor Hu’s face looked gaunt and tired, more so than two weeks ago. Sitting at a gigantic desk specifically reserved for reviewing and signing confidential documents, he stared at his report that had been returned after the Privy Council’s rejection. Next to the report sat Yan Shifan’s accompanying rebuttal letter.

“I’ve heard your report was rejected,” Tan Lun stepped in, speaking with his usual strident voice.

“Take a seat,” Governor Hu said, raising his grim eyes.

Tan Lun paused for a second. Instead of sitting down, he stepped around the desk and right up to Governor Hu. “I’ve received a letter from the Imperial Palace,” he whispered. “I know what’s happening. The whole thing sounds so turbulent! Listen – my source wants me to share some details with you. Are you interested?”

“No, I’m not,” Governor Hu replied, closing his eyes.

Tan Lun stood there awkwardly. Governor Hu opened his eyes but did not turn his gaze to the young schemer. “I don’t think it is a good idea for you to stay here,” Hu said in his deep voice. “Go and pack, and get ready to leave.”

“Are you worried about incriminating me, or are you just concerned that my being here could harm your career?” Tan Lun questioned, looking Governor Hu in the eye.

Governor Hu fixed his gaze on his desk and did not answer. His grave expression revealed displeasure at Tan Lun’s words.

Realising that he had been too blunt, Tan Lun apologised.

“I didn’t mean to be rude,” he explained. “What I want to say is that, if the Imperial Palace puts the blame on you someday, my presence here might help absolve you.”

“You have not learned a thing since I last saw you ten years ago,” Hu said with a sigh. “I have no idea what the Prince of Yu sees in you.”

In a fit of pique, Tan Lun retorted, “Are you saying that I have not grasped the so-called ‘Three ponderings for government leaders’?”

Governor Hu looked Tan in the eye. “I don’t know what you are talking about,” he said slowly. “Are you referring to the saying about an official’s ability to always ‘ponder risk, ponder retreat and ponder change’?”

Tan Lun didn’t respond.

“If that’s what you were referring to, I want to tell you now that I’m not pondering any form of exit, and you shouldn’t expect to change me either,” Governor Hu continued.

“So I shouldn’t have come over here,” Tan lamented.

“No, you shouldn’t have,” Governor Hu said, pronouncing each word separately and clearly.

“Apparently, the people around me know you better than I do,” said Tan Lun, who looked somewhat lost.

“You’re talking about those who are mentoring and advising the Prince of Yu, aren’t you?” Governor Hu asked. “Let me be honest with you. They are a bunch of big talkers – way too pedantic for my taste.”

The comment irritated Tan Lun, and before he had the chance to defend his posse, Hu Zongxian cut him off.

“Let me finish,” Governor Hu said. “I act the same way no matter who is around. Isn’t that the definition of an ethical leader? If you hadn’t come, I would have acted the same way I am now. Tomorrow, when you leave, I will continue walking the same path. Therefore, there’s really no point in advising me what to do or volunteering to be my scapegoat.”

Tan Lun, stunned by the old governor’s candour, gave him a quizzical look. But Hu was having none of it. “The whole Imperial Court probably knows that I’m Grand Secretary Yan’s protégé,” Hu kept on, as if talking to himself. “In one thousand years, I’ll still be written up in the history books as someone who was affiliated with Grand Secretary Yan’s faction. Even so, why do people like you and members of the so-called “Clear Stream” faction still find some value in me?” He waved a thin hand. “I think it is because I’ve never allowed harm to come to our country and people. In my home town, villagers have built three memorial arches for me. Three! I’m over fifty now – if I can live up to seventy, I have about a dozen or more years to live. I will use everything I’ve got to keep my integrity so my fellow villagers won’t dismantle those memorial arches.”

Tan Lun sat there, listening intently.

“You and your scheming friends are under the illusion that you understand people and are well versed in what is happening locally,” Governor Hu said, with more than a hint of sarcasm. “But how many of you truly know me and understand the situation here? Take the land-conversion policy as an example. This unwise new national policy will bring about a sea change in local politics. Many big silk mill owners want to take advantage of the policy and monopolise the land. As you know, seventy per cent of my province here is covered by mountains, twenty per cent by water and only ten per cent is farmland. If we allow the big landowners to acquire more land, nearly half of the farmers would immediately end up without any property! With such a large number of landless people hovering around, our province would be a breeding ground for turmoil and insurrection. If those farmers don’t rise up this year, they will do it next year or the year after. History and human nature dictate that it will happen sooner or later. And when that happens, we’ll be facing both external threats from the pirates and internal chaos caused by discontented farmers. There’s no doubt that His Majesty would make me the number-one culprit, and my failure in Zhejiang would be printed in the history books. I have no interest in doing my people wrong like this and going down thus. So, for these reasons only, I won’t allow this policy to destroy Zhejiang, regardless of whether you had come or not. You might have arrived to assist me, or to proselytise to me. No matter what your motives are, the consequence is the same – you would mess things up for me.”

“What do you mean?” Tan Lun said, looking a bit befuddled.

“Before you came over here, I had easy access to Grand Secretary Yan, and sometimes sought advice on things that I didn’t agree with,” Hu said. “Occasionally, I would even submit a report to His Majesty and explain why I chose to do things in a certain way. Truly wise governing requires diplomacy and dialogue. So when it came to implementing the land-conversion policy, such access to Beijing would have allowed me to buy some time and change things slowly in the direction that I wanted. For example, the original plan was to convert half the farmland into mulberry fields, but I could have submitted a request to try and do it over three years. Using such a method would have given me more room to alleviate the situation and probably even reverse the outcome.”

Waving the rejected report in front of Tan Lun, Governor Hu continued, “After your arrival here, however, this is what I received from Grand Secretary Yan and His Majesty. Do you know why? Now they all see me as a raging partisan. If everyone perceives me as a partisan, I won’t be able to accomplish the things that you and others want me to, will I? The Privy Council discussed this policy early in the year. If your friends truly had the ability to stop it, they shouldn’t have allowed it to end up here in Zhejiang Province.”

Tan Lun cast his eyes down on the floor.

“Now that you’re here, the Privy Council no longer wants to hear what I have to say,” said Governor Hu. “I bet they’re conspiring to relieve me of my duties here in Zhejiang. Since you’re such an avant-garde genius of strategy, why don’t you sit down and read this letter yourself, then tell me how you interpret it?”

Picking up Yan’s rebuttal letter, Governor Hu handed it over to Tan Lun. He meekly took it, picked a seat near a window and started reading. Meanwhile, Governor Hu rose and walked over to his filing cabinets that stood against the wall, where he pulled out a stack of documents and letters. Seeing that Tan Lun had already finished reading the short missive, he handed over the documents. “These are letters from Grand Secretary Yan and his son, and these are official documents that detail the land-conversion plan,” said Governor Hu. “Don’t you want to read them?”

“No, I don’t need to,” Tan Lun said, shaking his head. His face showed a mixture of contrition and understanding.

“Why not?” Governor Hu asked.

“The more I know, the more difficult your job will be,” Tan Lun replied.

Governor Hu turned around, with his back facing Tan Lun. “In the book Commentaries of Zuo, there is a saying – ‘That which creates can also destroy’,” he said, growing misty-eyed. “Grand Secretary Yan promoted me, and any day now he’ll be the one who demotes me as well. But now I have this – When the big tree falls someday, I can take comfort in the fact that a person named Tan Lun will speak in my favour and judge me fairly.”

Tan Lun rose from his chair and became emotional as well.

“I’ve said everything that needs to be said,” Governor Hu continued. “I don’t think you should return to Beijing. At this critical moment, your presence here might make them more scrupulous. Since the Prince of Yu sent you here as a military adviser, I think it’s better if you report to General Qi Jiguang and join his army. There’s already chaos here inside the government. We have to make sure that the military is in good order.”

“I’ll take my leave now,” Tan Lun said. Wiping the tears from his face with the back of his hand, he strode out without speaking another word.

Meanwhile, in what was probably the largest silk mill in the whole country, the owner was giving a tour to three special guests. Twenty rows of three-metre-wide silk-weaving looms stood in front of them, with six lining up on each row. A passageway, wide enough for two people to walk side by side, ran through the middle of the workshop. Each machine was weaving a different type and colour of silk fabric. The cacophony of weaving machines rose and fell rhythmically. The hectic pace at the workshop put Yang Jinshui, who directed the South China Textile Bureau, in a cheerful mood. He invited Zheng Bichang, the deputy governor and chief administrator, and Ho Maocai, the director of the Provincial Justice Department, to join in the inspection. The bigwigs beamed with delight. The owner, a scholarly-looking young man who wore a long blue cloth robe and black cloth shoes, showed the three officials around the bustling workshop.

“Mr Shen, how many bolts of silk can the workers here weave every day?” Yang asked. Due to the loud noises, he was literally screaming, making his otherwise high-pitched voice more piercing.

“We’re now running two twelve-hour shifts every day,” shouted Shen Yishi, Zhejiang’s wealthiest businessman and a designated contractor for the South China Textile Bureau. “Even so, each weaver loom can only produce about eight inches of silk fabric per day.”

“So you’re saying that each workshop can produce a maximum eight thousand bolts of silk every year,” Yang continued in his shrill voice.

“Yes,” Shen replied. “I have twenty-five silk mills, which can probably produce two hundred bolts of silk per year. Why don’t we discuss business in our visitors’ room?”

When the three officials followed Shen into a spacious room, Shen clapped his hands, and numerous servants emerged from the side doors. They went about quietly, setting tables for tea. The visitors’ salon was more like a huge hall; Yang had never seen such a classy place in the Hangzhou and Suzhou region. Against the north wall stood a large rosewood tea table with a marble top, flanked on each side by rosewood round-backed armchairs. Similar rosewood armchairs with matching tea tables lined the east wall and the west wall. The mono-coloured marble floor, each piece embedded with marbled starbursts, struck Yang as the most precious and impressive.

“Please take the top seat next to Yang Gonggong,” Shen bowed slightly to Zheng, the chief administrator.

“You go ahead and take that one because it makes it easier for you two to talk,” Zheng politely declined before taking a seat on the far left.

Ho took a seat on the right. Yang, who was seated in the middle, invited Shen to sit near him. Four young men, brisk and business-like, appeared, each bearing a shiny bronze teapot. They tiptoed to the tea table and, with impressive dexterity, removed the lids of the teacups with one hand and slightly tilted the teapots in the other. Clouds of steam rose as water flew out of the teapots into the cups. Green sprouts expanded, floating on the water surface in the cup. Yang held his cup under his nostrils and inhaled deeply. “Nice tea,” he complimented, putting the cup down and waiting for the fragrant liquid to cool off.

“This is Lions’ Peak Dragon Well tea, from the first harvest of the year,” Shen explained. “Farmers collected the tea leaves at night, when the tea plants start to bud.”

Both Zheng and Ho sipped their tea, smacked their lips and nodded approvingly.

“This is the best of the best,” Zheng commented.

“We haven’t harvested a lot this year,” Shen said, somewhat apologetically. “I have prepared two pounds each for Lu Gonggong and Grand Secretary Yan. Sorry that I won’t be able to do the same for everyone, but each one of you will get one pound.”

As Yang reached for his teacup, he noticed that Shen himself was drinking plain boiled water. “Why don’t you drink tea yourself?” he asked, curiously.

“This is an old habit,” Shen said. “I like to retain my simple ways – it keeps me earnest and unadulterated.”

“Look at you,” Yang teased. “You’re too hard on yourself. You have twenty-five silk mills, three thousand weaving looms and more than one hundred thousand mu of mulberry land, plus several hundred silk, tea and china stores. But you drink plain water, eat plain food and wear plain cotton clothes. Are you trying to make some sort of a statement?”

“Well, as the saying goes, a pomade vendor uses water for her own hair,” Shen replied. “I’m setting up these silk-weaving shops for the South China Textile Bureau. I live frugally because, someday, when you can no longer bear the sight of me and kick me out of the door, I’ll still be able to survive.”

“Oh stop it,” Yang said, raising his voice. “I wouldn’t dare! If I kicked you out, Grand Secretary Yan and Lu Gonggong would have me killed.”

“Sorry, I meant it as a joke,” Shen said with a solemn look.

“I know,” Yang replied cheerfully before his tone also turned serious. “Let’s get down to business. We need to increase production by three hundred thousand bolts. Based on instructions from the Imperial Palace, the mills in Yingtian will handle one hundred thousand, and, of course, you’ll handle the rest of the two hundred thousand bolts here in Zhejiang. Based on our calculation, you need to add three thousand weaver looms and build new mills. All these take time. Have you worked out a plan yet?”

“The order comes directly from the Imperial Palace, and I wouldn’t dare procrastinate, no matter how arduous it can be,” replied Shen. “But the challenge is to secure land to grow mulberry. No matter how many machines we add, we still can’t silk merchandise without raw silk.”

Yang glanced at Zheng and Ho, signalling for them to address Shen’s concerns.

“We can get you the land to grow mulberry in a month or so,” Zheng cleared his throat and promised. “The important thing is to gather enough grain to barter the land. Do you have the grain ready?”

“How many mu of land can you get me?” Shen asked.

“Based on our projected production quotas, how many mu do you need?”

“If the land has already been converted and mulberry trees mature, we only need two hundred thousand mu. But, if it’s farmland and we have to convert it ourselves, we’ll need at least five hundred thousand mu. This is because the mulberry trees we plant in the spring are still seedlings in the autumn and there wouldn’t be enough to breed silk moths. Plus, the silkworms do not produce as much raw silk in mid or late autumn as they do in the spring.”

“You’re greedy, aren’t you?” Ho couldn’t help remarking. “You are now requesting an extra three hundred thousand mu of land. If you plant mulberry trees this year, they’ll mature in two years. They can breed much more raw silk than we need for this order.”

“As I said, the land I have purchased, the machines I have acquired and the mills I have built are for the South China Textile Bureau and the Imperial Government,” Shen said, laughing off at Ho’s bluntness. “I don’t have the guts or appetite to swallow it all and keep the profits for myself.”

Zheng and Ho uttered an awkward chortle, while Yang gazed at the entrance distractedly.

“Where is Mayor Ma?” Yang asked. “When is he arriving?”

“I had an invitation delivered to him two days ago,” Ho said. “He’s supposed to come and join us from Chun’an County today. He should be here any minute. I’ve already told the guards outside to bring him here directly after he arrives.”

“What’s the rush?” a loud boisterous voice sounded outside. Speaking of the devil, here he came. Mayor Ma strode in. Before he had the chance to greet everyone, Ho jumped from his seat and pulled him aside to the corner of the room. They whispered something to each other before returning to join the conversation. By then, the mayor’s face fell. He stood there, looking distracted and sceptical. Ho eyed Zheng and Yang, urging them to continue pressuring the mayor.

“So what do you think of the plan?” Yang asked the mayor.

“I haven’t thought it through yet,” the mayor growled. “This is a big decision. Why are we hiding it from the governor?”

“We’re not trying to hide it from Governor Hu,” Ho explained. “The grand secretary and his son specifically told us not to loop him in.”

Taken aback by Ho’s remark, the mayor barked, “So now the grand secretary and his son no longer trust the governor?”

“I don’t think it’s a matter of trust,” Zheng added. “With Tan Lun by his side, we just want to be cautious so the news doesn’t get out and reach those folks in Beijing.”

“So, in other words, it shows that Grand Secretary Yan has lost confidence in the governor,” Mayor Ma repeated.

“Why are you so stubborn?” Ho said with a tint of impatience. “What does it take for us to turn you around and point you in the right direction?”

Yang glared at Ho, signalling him to stop the badgering.

“I understand that you report to the governor and you want to remain loyal to him,” Yang said to Mayor Ma gently. “But who is Governor Hu’s mentor? Have you thought about that?”

“The grand secretary,” the mayor said hesitantly.

“So the answer to your previous question is quite obvious, isn’t it?” Yang said. “You’re dedicated and loyal to Governor Hu. That’s your strength. But you can’t just blindly follow orders. I understand you only take orders from Governor Hu. But your boss reports directly to the grand secretary. You won’t risk a mistake if you follow what the grand secretary tells you. Besides, by not telling Governor Hu, the grand secretary might intend to shield him from harm. Otherwise, if Tan Lun gets wind of it, he might rat on him and tell the Prince of Yu. If that happens, the first one they attack would be your friend, Governor Hu.”

The mayor stood there, obviously struggling to make a decision as the others looked on.

“OK, I’ll do it,” he finally said, looking resolute as if he was ready to risk everything. “I just want to make sure that nobody will starve after the counties are flooded. Otherwise, the governor will be stuck with a huge problem.”

Despite Mayor Ma’s mention of such a dire outcome, Yang looked pleased. So did Zheng and Ho.

“The grain we currently have in the state granary won’t be enough, of course,” Zheng replied to Mayor Ma. “Mr Shen will prepare enough grain for the land purchase.”

“There is no need to worry,” Shen pledged. “When the purchase starts, I won’t be short of even a single grain of rice.”

Yang stood up and reminded everyone, “We’re about two weeks away from the May rainy season. Troops need to be dispatched to guard all the weirs along the Xin’an River. Before we flood the area, nobody should be allowed to approach them. For security’s sake, let’s keep this plan a secret. If it leaks out, nobody will be spared.”

The air thickened with tension. Zheng and Ho turned to Mayor Ma, seeking his pledge to keep things confidential. Instead of responding to their unspoken requests, however, Mayor Ma suddenly asked Shen, “Do you have any old ginseng roots?”

The request confounded the group.

“I only have two left,” Shen replied.

“Do you mind gifting them to me?” the mayor asked solemnly, like a warrior who was making his last request before departing for the battlefield.

“What happened?” Zheng asked sympathetically. “Is your mother sick?”

“No, I just want to give them to the governor,” Mayor Ma answered as he gazed at the courtyard.

“Could you promise not to be stupid enough and leak our plan to the governor?” Ho asked, with trepidation in his voice.

The remarks incensed Mayor Ma. “If you don’t trust me, why don’t you ask someone else to do it?” he retorted.

Ho appeared speechless.

“Even though we are hiding this plan from him, he’ll still have to shoulder the blame if anything goes wrong,” Mayor Ma continued. “He looks quite exhausted lately. What’s wrong with gifting him two ginseng roots? It shouldn’t warrant your suspicion, should it?”

“All right then,” Yang interrupted, trying to smooth things over. “I admire Mayor Ma’s loyalty and his strong sense of justice. You’re bound for big things, Ma. Let’s wait for Mr Shen to get the ginseng roots.”

Shen nodded ingratiatingly before disappearing into a side room.

Carrying a red box smelling of ginseng, Mayor Ma showed up at Governor Hu’s office. The governor sat reviewing files and reports.

“Have you sent people to open up the irrigation channel so farmers can water their land?” he asked without taking his eyes off a document.

The mayor was mute, and after a few minutes Governor Hu looked up. Mayor Ma seemed to be in a daze, with his hands behind his back.

“Did you hear what I just said?” Governor Hu asked again.

“Oh…” the mayor recovered from his reverie and stammered. “Yes, yes, I’ve taken care of it.”

“What are you holding in your hands?” Governor Hu probed.

The mayor presented the red box haltingly. “Your Highness, these two ginseng roots…” he said, choking up. “I know you forbade us from giving you gifts. It’s not a bribe… I just think you probably need it because you look quite exhausted lately… I…”

Governor Hu stared at him for a moment before resuming his reading. “Your stellar efforts at work will be better than any gifts,” he said.

Still holding the red box, the mayor stood there without moving.

“OK, leave the box there and go to check the weirs,” he ordered.

“Yes, Your Highness,” the mayor said. Before stepping out, he took one last look at the governor.

The annual rainy season arrived in early May. In 1561, forty years into Emperor Jiajing’s reign, a natural catastrophe triggered by a human conspiracy was about to strike unsuspecting farmers living along Xin’an River in Zhejiang Province…

Darkness descended but the rain continued. Soldiers packed the public square in front of the governor’s office complex, each pulling a horse. Flickering lanterns hanging under the eaves swayed in the wind. In the dim light, the soldiers who were waiting for orders moved about like apparitions.

The heavy wooden gate suddenly flung open, and the soldiers saw Governor Hu striding out without a raincoat. Before he reached his sedan chair, bolts of lightning struck directly at the wooden gate – Governor Hu’s elongated shadow from the dim lights was slashed into two equal parts, from his head to his feet. A rapid succession of lightning bolts, followed by deafening claps of thunder, illuminated the ghostly faces of soldiers and their horses gathering in the public square. Hu’s top aide approached him from behind and held an umbrella over his head.

“Where is the river surveillance director?” Hu shouted to the top aide.

“He’s gone to brief different agencies on the disaster situation,” the aide replied in an equally loud voice, to be heard above the downpour.

“What did he say about the flooding?”

“Leaks have been spotted in all the weirs in the nine counties along the river,” the aide reported. “All the sandbags we have placed down there to stop the leaks have been swept away. It’s impossible to stem the flood.”

“Benevolent heaven, why are you so heartless?” Hu uttered, but his words were drowned out by more thunder and lightning. His body shivered with emotion, and his face grew paler in the jagged flashes.

“Your Highness, what did you say?” his aide asked.

“Let’s go to Chun’an County now,” Governor Hu decided.

The aide turned to the soldiers waiting in the rain and shouted, “Bring the sedan over!”

“No, get my horse,” Governor Hu interrupted before dashing down the stone stairs. As he stepped into the rain, the aide followed closely, holding his umbrellas and trying to keep pace with the governor.

“The horse!” his aide shouted. “Bring the horse over!”

A big black horse, powerfully muscled with thick mane and tail, stopped in front of the governor. Before he mounted, his aide opened up a raincoat. Governor Hu stretched both arms downward to allow the assistant to slip on the raincoat from behind him. As the aide was securing the hood and tying the strings in the front, another round of lightning struck. The rain poured down even more forcefully than before. But the black horse remained unfazed, planting its hooves firmly on the ground. A guard tossed his umbrellas to the side and held one of Hu’s hands to help him mount the horse.

“Why don’t you get two of our men and go to meet with General Qi and his military adviser Tan Lun?” Governor Hu ordered his aide. “Tell them to send one thousand troops to different weirs and help with flood rescue efforts. Then, ask the two of them to come and see me at Chun’an County.”

“Yes, sir,” shouted the aide. He and two soldiers leapt onto their horses and disappeared into the dark rain. Governor Hu kicked his black horse into motion and led the rest of the soldiers towards Chun’an County.

“Daddy, Daddy,” a feminine voice pierced the darkness, awakening Yang with a start. He climbed out of bed, put on a dark maroon silk jacket over his white silk pyjamas which featured subtle patterns of cicada wings. Sitting on the edge of his bed, he was poised to receive the unexpected guest.

A man burst into his room inside the South China Textile Bureau compound and stumbled his way to the bed. Plopping down on the floor near his feet, the man whimpered, his voice filled with panic. “Daddy, the weirs… have cracked… nine counties… are flooded.”

Yang looked at him dismissively. The man was his protégé, Li Xuan, who managed the Xin’an River Flood Control Commission.

Li caught his breath. “Someone… someone is trying to sabotage the weirs… and harm my career… and ruin yours…” he continued in a somewhat more coherent but nervous tone.

“What are you talking about?” Yang Jinshui asked. “Who is trying to harm us?”

Yang’s unusually calm response surprised Li. “All the weirs were repaired and fortified last year under my supervision,” Li said. “They should be standing solid as iron. Leaks were impossible… just impossible… but now every single weir is damaged…”

“No weir can be as solid as iron, and there’s no such thing as an impregnable dam,” rebuked Yang.

Stunned by Yang’s dismissive response, Li stood there, staring at his master silently.

Yang turned around and said to a woman in his bed, his harsh tone softening, “Madam Yun, could you get up and find an outfit for him to change into?”

A tall slender woman reluctantly rose from the bed behind Yang. She was the model at the textile bureau’s silk exhibition. Wearing thin transparent silk pyjamas with pretty patterns of cicada wings, Madam Yun flew out of bed and made a beeline for one of the dressers. She opened a drawer, picked an outfit and tossed it on a chair. Without saying a word, she slowly climbed back into bed.

Kneeling before Yang, Li straightened his back and focused his gaze at the floor.

“Get up,” Yang demanded. “Remove that wet outfit and change.”

“Daddy, nine counties… if they are all flooded, they’ll have me beheaded…” Li Xuan sobbed, without moving.

“Oh come on, you’ll live,” Yang said impatiently. “Get up! After you change, stay inside the Textile Bureau compound. Don’t go anywhere.”

Li stood up, looking sceptical. Then, an epiphany seemed to hit him. “Daddy, did you already know about this?”

“What do I know?” Yang asked. His eyes hardened.

“I… I don’t know what you know…” Li shuddered with fear.

“Ignorance is bliss,” he advised. “Let me tell you – some things can be simple if you choose to resolve them behind the scenes, but once you bring them out into the open they become complicated and can turn into huge scandals. We are part of the palace staff and our job is to handle tasks given to us by Lu Gonggong. Whatever happens locally is none of our business, regardless of how threatening it is. Let the local folks fight among themselves. In the next few days, there is no need for you to show up at work. It doesn’t matter if the land is flooded or people are killed. Just stay right here.”

Li Xuan seemed to have only half-understood. “Would it be possible for Daddy to switch jobs for me?” Li begged.

“I’ve already reported this to Lu Gonggong,” Yang replied. “Let’s wait patiently for him to make the arrangement.”

“Understood!” Li said with restored confidence. He managed to get to his feet and walked over to the chair. Cradling Yang’s clothes in his arms, Li swallowed his spit, inhaled deeply and began untying his clothes.

“Is this your place to change?” Yang’s cold harsh voice stopped him.

Li quickly picked up the clothes. At the door, he turned around and glanced at Yang and the woman behind him. “Thank you, Daddy and Mommy,” he said.

“You can leave now,” Yang ordered. Li stepped out and closed the door behind him.

There’s a popular saying among farmers: “Fierce wind never lasts a whole morning, and a rainstorm always ends in a day.” Even though rainstorms are quick and short, they often trigger flooding. This is what happened in parts of Zhejiang Province during the rainy season in 1561.

A rainstorm that ravaged the region for a whole day finally stopped around midnight. In the ensuing days, torrential floodwater from the mountains poured into Xin’an River, rapidly raising the water levels. Even though the rain had stopped, the water rose by the minute. In Chun’an County, thousands of torches flickered on the big dam on Xin’an River, but in the vast darkness and against the roaring sounds of the river, those flickering lights seemed so tiny and feeble.

Countless soldiers and farmers raced towards the gigantic sluice gate, where two widening cracks appeared, one on each side. The roaring water in the river was bursting through a crack, forming two ferocious waterways ready to swallow the farmland along the Xin’an River. People carried sandbags with both hands, and some on their shoulders. Soon, the sandbags piled up on the weir like a wall. Several soldiers and young farmers stood in a row, next to the sandbags, waiting for orders from General Qi and his adviser, Tan Lun, both of whom stood perched on the edge of the cracks. With the help of the torchlight, they attempted to survey the situation below.

“Get ready to push the sandbags down,” General Qi shouted out his order.

Soldiers and farmers stuck long wooden poles or the butts of their long firearms underneath the pile of sandbags and then pushed them hard with their shoulders.

“One, two, three. Go!” General Qi ordered. With minutes, a huge wall of sandbags was toppled into the cavity in the weir, in the hope of blocking the water. Hundreds of eyes gazed down. Unfortunately, like pinches of salt tossed into a large boiling pot, none of the sandbags stayed. They were swept away without a trace.

The crowd froze. Frustration and disappointment set in. But General Qi refused to give up. “More sandbags,” he ordered, with steely determination in his eyes. Soldiers and farmers began moving again, rushing to secure more sandbags.

On the far end of the weir, Governor Hu was standing alone on the edge of the river, his eyes gazing into the roaring waves. Guards holding burning torches stood a few feet from him. Tan Lun passed through the guards and quietly approached Governor Hu. He could feel Tan Lun’s presence behind his back.

“Any success?” Governor Hu asked in his deep voice, without turning his gaze from the river.

“I’m afraid not,” Tan Lun replied, his tone getting agitated. “This outcome shouldn’t surprise us because we simply had no time to prepare. This is now happening in nine counties. If we can’t block the leak here, the other eight weirs will meet a similar fate and burst. That’s exactly what those people are expecting to see.”

“When Mayor Ma came in to give me some ginseng roots last week, I should have thought of it and questioned him,” Governor Hu mused. “This could endanger the lives of several million people… a crime for all eternity!”

“Such a ruthless act… Unprecedented in history… It’s beyond anyone’s imagination,” Tan Lun ranted. “It looks like we have no other choice but to find a way to divert the floodwater.”

Governor Hu did not respond.

“Rather than exposing all nine countries to such disaster, we can divert the water,” Tan Lun proposed. “It’s a much better option to have one or two counties flooded and save the rest. Besides, it will be easier to organise rescue efforts, and we’ll have enough grain to cover the victims if we concentrate the distribution in one or two counties.”

“Is this General Qi’s idea as well?” Hu asked.

“Yes. But you have to make the final call.”

Governor Hu sank into silence for a few minutes before he sighed, “How am I going to tell the people in Chun’an and Jiande Counties if we divert the floodwater there?”

“Before making the decision, we’re going to give one more try to block the leak,” Tan Lun added. “As a last resort, General Qi is prepared to allow soldiers to plunge into the water and form a human wall near the crack. If it works, we’ll do the same in other places. If we still fail after having made this sacrifice, people will understand it better.”

Governor Hu turned around slowly. The torches lit up his gaunt face. “We need to help people evacuate their villages quickly,” he demanded.

“We have already sent people to the villages,” Tan Lun replied. “Fortunately, the region is surrounded by mountains and evacuation can be done quickly.”

Governor Hu looked in the direction of the weir. Even from where he was, he could hear General Qi’s desperate shouting. “I need volunteers… We need a human wall down there first before we push the sandbags down.”

Governor Hu shuddered at the idea of sending hapless soldiers into the treacherous water. He strode over to the general, followed by Tan Lun and his guards. Volunteers lined up, arm in arm, on top of a large pile of sandbags, waiting for orders.

General Qi did not issue his order of action. Instead, he waited for the governor, who was walking up to him. His set eyes were filled with grief and determination.

“Do we have names for our brothers here?” Governor Hu asked.

The general nodded solemnly.

“If anything happens to them, we will make sure to compensate and take care of their families,” Governor Hu pledged.

With a heavy heart, the general nodded again.

Governor Hu turned to the volunteer soldiers, offering his fist and palm salute.

“Thank YOU,” he shouted.

“Yes, sir,” the soldiers shouted back unanimously before turning around to face the fast-flowing river.

General Qi raised his right arm and shouted, “Go!” In unison, the soldiers howled at the top of their lungs before plunging into the turbulent water down below. Burning torches moved closer to the edge. While some people widened their eyes, trying to monitor the situation, many others closed theirs. Knowing the grim prospect of this mission, Governor Hu also closed his eyes.

General Qi kept his eyes fixed on his soldiers struggling in the ferocious water. They were supposed to steady themselves in the water, waiting for the sandbags to drop so they could manually fill the crack. General Qi’s heart sank when he saw that his soldiers became immediately submerged in the water. Then, his eyes brightened when they reappeared, still arm in arm. Their heads bobbed in and out of the water. “Drop the sandbags!” the soldiers in the water seemed to be shouting, but their voices were drowned out by the roaring waves. Fearing that the fierce waves could swallow his soldiers at any moment, General Qi resisted calls from his troops on the weir behind him to drop the sandbags. Instead, he began to regret his decision. Balling both of his fists, he yelled at the soldiers on the bank, “Drop down the ropes and save our brothers first!”

A dozen rescuers quickly untangled a pile of thick ropes and threw them down into the water. But by then, those soldiers had all disappeared. On the dam, an eerie silence fell.

The waves in the river rumbled.

All of a sudden, some farmers fell to their knees, and many others on the weir followed. In the torchlight, General Qi shut his eyes as tears oozed from their corners.

“We can go down,” a young farmer stood up and shouted. General Qi opened his eyes and recognised Chee Dazhu, the farmer who had been arrested by Mayor Ma earlier for allegedly “sabotaging” the land-conversion efforts. Chee Dazhu turned to his fellow villagers. “It is our turn to serve now,” he howled. “If you’re a real man, follow me.”

Several strong young men got to their feet and followed Chee Dazhu as he walked towards a pile of sandbags. Governor Hu looked at General Qi and shook his head in disapproval. The general immediately caught up with Chee Dazhu and stopped the farmers from advancing.

Chee Dazhu got on one knee, and his followers did the same.

“General Qi, let me pledge in front of my parents, my wife and children who are over there,” he said. “We will do as you tell us. If anyone should jump down there, it should be us. The other day, you came and stopped the troops from destroying the rice seedlings. We’re greatly indebted to you. We are willing to serve you. Please accept our service.”

“Were you the one who was accused of leading a riot?” General Qi asked.

“Yes, sir,” Chee Dazhu replied.

“Do you know who ordered your release that day?”

“Yes. It was the governor.”

“That’s right,” General Qi said. “Then we should all listen to him today. Please rise. Tell all of your folks to stand up. The governor wants to talk to you.”

Meanwhile, Governor Hu, surrounded by torchlight, moved towards the pile of sandbags. Grabbing a hand that General Qi offered him, he steadied himself and climbed on top of the sandbags. Peering down at the sweaty mud-smeared faces and the flickering torches, he opened his mouth, but nothing came out of it. It was as if something was stuck in his throat…

In his spartan living room, Shen Yishi, the silk contractor, was entertaining guests. Even though the servants had laid out food and liquor on the big round table in the middle of the room, none of the guests took their seats. Instead, they sat on chairs against the wall, waiting.

An aide rushed into the room and whispered something to Zheng, the deputy governor and chief administrator. Zheng’s eyes flashed with displeasure, then he stood up and declared, “Yang Gonggong is not coming. Let’s toast Mayor Ma and his colleagues without him.”

“He is supposed to be the mastermind of this plan, but when it comes to decisions he’s conveniently absent,” grumbled Ho, who headed the Justice Department. “How could he do this to us?”

His remarks rattled Mayor Ma and two of his magistrates. They stood there, looking gloomy. Even Shen, who was hosting the dinner, appeared a bit uneasy about Yang’s absence. But he quickly regained composure. “What do you want to do?” he asked Zheng.

Realising that he had to take control of the situation quickly, Zheng motioned for Ho to shift everyone to the table. “Let’s start the meal and discussion without him,” he suggested. “Once we come up with a plan, we’ll send it to Yang for approval.”

Ho invited Mayor Ma to the place of honour at the table. “You’re our hero today and deserve to be in the centre,” he said.

“Hero? I feel more like the world’s number-one criminal,” Mayor Ma grumbled in a hoarse voice. “Someday, when I receive the capital punishment and my family gets raided, I just hope all of you here can show some mercy and take care of my surviving family members.”

The mayor’s wry remarks made the two magistrates uneasy. Seeing that Mayor Ma had declined the place of honour and picked a seat on the side, they decided to sit next to him on the far end of the table, leaving Zheng and Ho with no choice but to take the chief’s seats. Zheng raised his cup to present the first toast of the evening. “We all work for the Imperial Court,” he said. “It is not the job of ordinary folks like us to judge the merits and faults of our deeds. If we do a good job implementing the conversion policy, we’ll bring honour to the country and long-term benefits to the people. It’s not a major problem if the farmland is flooded. The important thing is to make sure that farmers are properly fed. Therefore, I urge Mr Shen to get the grain ready quickly. We’ll be committing a cardinal crime if a deadly famine occurs.”

“There is no need to worry,” vowed Shen as he raised a glass and then emptied it. “It’ll be a fair swap, and I’ll compensate the farmers handsomely. If starvation occurs because of me, I’m willing to pay with my own life.”

“I hope Mr Shen’s words help put your mind at ease.” Zheng raised his glass again to console Mayor Ma.

“This is not a matter of whether my mind is at ease,” the mayor stood up and drained his liquor glass with one gulp. “I have no control over what will happen to me in the future. But I’ve been told that Governor Hu has gone to the weir to investigate the situation there. It would be heartless and unconscionable for us to drink here while he is there working. I need to go.”

Before the host and guests had a chance to respond, the mayor put the glass down on the table and marched out. A few minutes later, a messenger crept in with news about the governor’s decision to divert floodwater away into Chun’an and Jiande Counties to protect the other regions. The report unnerved Zheng, Ho and Shen, leaving them speechless. They quickly left the dinner and showed up at Yang’s office.

“Are you aware of the flood-diversion plan?” Ho cried out nervously when he saw Yang emerging from a side door in his office. “I heard that only two counties will be affected by the flood.”

Yang paused for a moment, pondering something before resuming his steps slowly. Then, under the glare of his three guests, he plopped into a chair.

“The diversion will make it hard for Mr Shen to buy up the five hundred thousand mu of farmland that we have promised,” Ho said.

“Well, I can still purchase the land in the non-flooded counties, but I’m afraid there won’t be enough grain to barter,” Shen said. “It costs me five hundred kilograms of rice to buy a mu of flooded farmland. But for the non-flooded farmland, where the rice seedlings are already knee deep, the price for each mu could jump five to six times.”

Yang listened silently. At one point, he shot a sidelong glance at Zheng and muttered, “It’s a mess now.”

“I heard that when the governor announced his diversion plan, Tan Lun was present,” said Zheng; a worried frown crossed his face.

Yang’s face twitched involuntarily.

Zheng continued, “We did this without the governor’s knowledge because the grand secretary’s son had instructed us to do so. Governor Hu should understand this. I can’t figure out why he’s decided to divert the flood. I truly have no idea what he is trying to do.”

“When is the governor returning to the city of Hangzhou?” Yang finally spoke up.

“I think he’s already back in his office,” said Zheng.

“What?” Yang sprung to his feet. “If he’s back, why hasn’t he sent anyone to contact you?”

“We’re just wondering about the same thing because my department should be handling the disaster relief efforts…”

Yang’s mind was racing, his eyes rolling.

“What’s to be afraid of?” Ho broke the silence. “The rice-to-mulberry conversion policy was issued by the Imperial Palace. If we fail, we could be all dead. Instead of supporting us, the governor is trying to defect to the other faction. Fortunately, our grand secretary is still alive, and the Interior Ministry is still in the hands of Lu Gonggong.”

“You certainly have more guts than I do,” Zheng grumbled. “I haven’t been able to find Mayor Ma. He’s nowhere in sight at the moment. If he leaks our plan and people know that we damaged the weirs deliberately, I don’t think any of us can be spared capital punishment.”

“You can’t find the mayor?” Yang asked in earnest.

“Correct,” Zheng replied. “I have sent several guards to search for him. He’s not at the city yamen. People at the Flood Control Commission have no idea where he is.”

“Then he must have been summoned by the governor,” Yang pointed out.

“I should think so,” Zheng agreed.

“If Governor Hu doesn’t want to talk with you, you should go and see him,” Yang suggested.

“What should we say to him?” Ho asked.

“It’s not a matter of what you’ll say to him,” Yang corrected him. “It’s what he’s going to tell or ask you.”

“Let’s go then,” Zheng urged.

Just as Yang had guessed, Mayor Ma was at the governor’s office. Donning a blue cloth robe, he sat quietly on a chair in front of the governor’s big rosewood desk. His face, covered with several nights’ unshaven stubble, had slimmed down significantly. His deep-set eyes appear bigger. He had just placed a big bundle wrapped up in cloth on the governor’s desk.

Governor Hu sat behind the desk with his eyes closed. Neither of them spoke. The silence accentuated the size of the bulging bundle on the desk.

“I want to apologise to Your Highness,” Mayor Ma muttered in his hoarse voice. “But my loyalty and devotion to you never wavered.”

Governor Hu did not respond; his face was expressionless, and his eyes remained closed.

“I was a certified scholar in my village, trying for years without success to enter the Imperial College,” Ma stated. “If you hadn’t discovered and promoted me, I would probably have been, at most, an assistant county magistrate. Neither I nor my family had dreamed that I would become the mayor of Hangzhou. The day when you plucked me from obscurity, I made up my mind that I would devote my whole life to you and that after I die I will continue to serve you as a ghost. I’m glad that I finally have the opportunity to pay you back.”

Mayor Ma rose to his feet and reached over to the desk to untie the big bundle. From inside the bundle, he pulled out his mayor’s official hat and robe. “Your Highness has changed my life by granting me this position, and I’m now returning it to you,” he said, holding it reverentially with both hands. “Whatever punishment the Imperial Court deals out, I’m willing to take it on your behalf. I just hope that the grand secretary, his son and the people who are friends with the Prince of Yu will give you a pardon.”

Governor Hu opened his eyes and slowly rose from his seat. Stepping out from behind his desk, he strolled over to the centre of the room, silently gazing at the courtyard through a large window. Mayor Ma slowly turned around. Holding the bundle that contained his official hat and robe, he stepped up and presented it to Governor Hu.

“Wham!” Governor Hu smacked him in the face. The mayor straightened his body, his hands clutching tightly at the bundle.

“You idiot!” Governor Hu scolded in his deep voice that was filled with anger and pain. “You think you know it all, huh? You think you’re helping me get a pardon from the grand secretary and the Prince of Yu… Do you know how deep the water is down there? The land-conversion policy and flood control are such big complicated undertakings, but you schemed with those people and kept me in the dark. Do you consider that an act of loyalty?”

“I didn’t mean to hide it from Your Highness,” the mayor explained. “I would never collude with anyone and harm you… Like Confucius advises us, there are many things in this world to which one is committed even though he knows they cannot possibly succeed.”

Governor Hu glared at Mayor Ma and shook his head in frustration. Slowly, disappointment turned into twangs of pain. Governor Hu had put so much trust in the young man facing him, but now the mayor felt like a stranger to him.

“I advised you time and again to read more history books, but you never took my advice seriously. When I urged you to read books by Wang Yangming,^(1) a fellow countryman of yours, you snubbed him, claiming some nonsense like reading ‘half of what Confucius wrote’ would be enough to help you handle your job. Let me ask you, what did Confucius really mean when he said, ‘There are many things in this world to which one is committed even though he knows they cannot possibly succeed’?”

The mayor did not answer.

“The true essence of Confucius is reflected in this quote – ‘Before committing oneself to a task, one first asks if he should, rather than if he can.’ Sabotaging the dam with the sole intent of flooding farmland is a heinous criminal act. You harmed the interests of our country and the people. How could you justify this criminal act with a Confucius saying?”

“I thought I was merely trying to help out by sharing your burden,” Mayor Ma defended.

Governor Hu responded by stamping his feet in fury. “You were trying to ruin several million lives in nine counties. Such brutality is unheard of in history. How could you say you were merely helping me share my burden? For this crime, I wouldn’t even consider it an excessive punishment to have you executed and eliminate nine generations of your family.”

The mayor stood there in a daze. Governor Hu raised his head towards the ceiling. “Everyone says that I have hired the best people to work in the Imperial Government,” he sighed. “How did I make this terrible mistake of appointing you as the mayor of Hangzhou and the regional commissioner of river flood control?”

The mayor dropped to his knees and uttered in total despair, “I shouldn’t have entered government services in the first place. I have an elderly mother, a wife and a young son in the village. Your Highness is aware that they’re honest country folks. Please spare their lives.”

When Governor Hu didn’t answer, he choked up and plopped down to the floor.

“Let me ask you one more time, who else is behind this scheme?”

Mayor Ma raised his head and pled, “Please do not question me on this. If you probe deeper, you could bring chaos to the Ming empire. I don’t think this is something that Your Highness can stomach. Even the grand secretary could be implicated. Why don’t you stick with the official line that nobody attempted to destroy the dam? Blame the Flood Control Commission, which obviously did a shoddy repair job that has triggered this catastrophe. But on the other hand, the massive flood would make it easier for the Imperial Court to implement the land-conversion policy. I just wanted to get you out of this so you wouldn’t be stuck in the middle. That was why I did it. Even if I had to pay with my own life, it would have been worth it.”

The mayor’s words had touched upon a sore point – an issue that worried Governor Hu the most. His face darkened. “You are among us, and we’re among you. You help me, and I help you,” he sighed. “This is the source of all evil… They’re gambling away your life and career for money. They’re destroying the livelihood of so many farmers in exchange for money… Even so, you’re still protecting them, all in the name of protecting the Imperial Court and a national policy. What kind of national policy is it? When the mulberry trees are taking over crops and start to yield profits, how much of the money goes to the Imperial Treasury? You’re not the only one they are trying to take advantage of. I’m not the only one they are trying to deceive. They’re going to hurt more people, including the grand secretary, who is surrounded by these evil and greedy people. He’s 81 years old. I hate to see him fall into disgrace.”

The mayor, stunned and regretful, stared at Governor Hu.

“Your Highness…” an aide came in and interrupted the conversation.

“Are Mr Zheng and Mr Ho here? Bring them in,” said Governor Hu. Before he got ready, he turned to Mayor Ma. “I doubt you can be spared capital punishment this time,” he warned. “After you die, I’ll see to it that your family is well taken care of. Go and wait inside the room there. I want you to listen carefully and learn the true nature of the so-called friends you’re trying to protect. At least, you can die with the comfort that you got to know the truth.”

Mayor Ma kowtowed hard on the floor, collected the bundle in his hands and tottered into a side room.

By the time Zheng and Ho were ushered in, Governor Hu had slouched back in his seat with his eyes closed. The two guests paused, looking at each other hesitantly.

“Your Highness,” Zheng tiptoed to the governor’s desk.

“Please have a seat,” Governor Hu invited him without opening his eyes.

Zheng and Ho sat down as told, waiting for the governor to begin. But, for nearly five minutes, Governor Hu seemed to ignore their presence. An awkward silence ensued. Zheng motioned with his head to Ho, who cleared his throat loudly. “It’s hard to believe that such a catastrophe could have occurred,” he said.

Governor Hu still did not move. Nor did he respond.

“After I heard the news, I visited some grain warehouses and did a quick calculation,” Zheng added. “We have about one hundred and fifty thousand kilograms of rice in storage. At the moment, more than four hundred thousand families are affected by the flood. Even if we distribute everything we have saved, we wouldn’t have enough. The food will only last them ten days or so. So the priority now is to buy rice from private suppliers. Unfortunately, we are short of funds. So we need to file a disaster report to the Imperial Court immediately and request substantial disaster relief funds.”

“What type of disaster are we going to report?” Governor Hu’s mouth awakened below his still-dormant eyes. “What type of relief funds are we requesting?”

“Of course, we’re going to report it as a natural disaster,” Ho mumbled.

“Is it really a natural disaster?” Governor Hu opened his eyes and confronted Zheng and Ho, both of whom were startled by the governor’s unexpected reaction.

“This is the flood season, and a terrible rainstorm battered the region for two consecutive days,” said Zheng. “The water level has risen rapidly. Things happened so fast that we didn’t have…”

Seeing how unabashedly Zheng was covering up the scheme, Governor Hu could no longer hide his contempt.

“If that’s how you want to describe it, you should be the one to draft the report,” he said.

“I can certainly draft it on your behalf, but Your Highness has to lead the effort, sign the report and submit it,” Zheng proposed quickly.

“Since you’re drafting the report, you will have to sign it and submit it yourself,” Governor Hu retorted. “But in case you have forgotten, I just want to remind you that our climate condition is similar to that in the neighbouring province of Jiangsu. The rain hit them hard as well. They have two rivers flowing through their province, Baimao and Wusong. Just like us, they repaired and enhanced the weirs on the two rivers last year. In fact, we budgeted more funds for repairs and maintenance than they did, despite the fact that we only have one river in our province. Guess what, the weirs in Jiangsu Province remain solid and intact, and people are safe, whereas we’re encountering an unprecedented disaster. How do you manage to explain away this so-called natural disaster and cover up your lie?”

Colour drained from Zheng’s face. He eyed Ho, and they both realised that it was time to show their cards.

“Now that Your Highness already knows about it, we feel obligated to tell you what truly happened from our vantage point,” Ho said. “As you know, the grand secretary’s son wrote us a letter. You must have received a similar letter from him. So if the Privy Council’s investigation implicates us, shall we show the letter to the investigators? Should we hold the grand secretary junior accountable? Is it necessary for us to urge His Majesty to rescind the land-conversion policy? Please advise.”

Governor Hu suddenly turned around and asked, “Are you saying that the whole flooding scheme was hatched by the grand secretary’s son?”

The question flew like a sharp dagger at Ho’s face. “I, I… That’s not what I meant…” Ho winced and stammered.

“Then what did you mean when you said that the grand secretary’s son had written to you and that we should hold him accountable?”

“What I… I was trying to say is that… I was just talking about the land-conversion policy…” he mumbled nervously.

“What does the land-conversion policy have to do with the damaged weirs along the Xin’an River?” Governor Hu interrogated. “What does this have to do with the widespread flooding? If there is a connection, you should state it clearly in the report.”

Ho was too stunned to speak, and Zheng pitched in. “The land-conversion policy has nothing to do with the flooding here…” he reassured Governor Hu. “But, at the same time, we can’t really blame the extremely heavy rains for causing this widespread flooding… The culprit seems to be the River Flood Control Commission. Last year, they received a huge amount of funds to fix and fortify all of the dams along the Xin’an River, but apparently, they performed a shoddy job. In the past, several commissioners were indicted for embezzling public funds, neglecting repair work and causing severe flooding during rainy seasons. You probably remember a recent indictment that occurred in the thirty-first year under Emperor Jiajing’s rule…”

“That makes a lot of sense,” Ho jumped in.

Instead of confronting Zheng about his deception, Governor Hu kept his silence and glanced cynically at Ho, waiting to hear his response.

Zheng signalled to Ho with his eyes, encouraging him to continue.

“We should draft our report as Mr Zheng has suggested and attribute the flooding to the leaking dams, rather than to the unusually heavy rains, like we previously proposed. As for whether officials serving on the River Flood Control Commission have embezzled public funds or not, we’ll launch a separate investigation at a future date. Causing the dams to leak in itself is a capital offence. Since Your Highness is authorised to impose the death penalty without obtaining permission from His Majesty, we should carry out summary executions of those who are connected with the case. Such tough measures will enable us to explain it and straighten things out with the Imperial Palace.”

“Those who are connected with the case?” Governor Hu questioned. “Who are you referring to?”

“Some of the officials who are serving on the River Flood Control commission, of course,” Ho replied.

“Which ones?”

Ho turned to Zheng for an answer.

“Naturally, the mayor of Hangzhou, who is the chief commissioner, should be held accountable,” Zheng alleged. “The two magistrates who are commission members shouldn’t be spared either.”

“So you are saying Mayor Ma, along with Chang and Zhang, the magistrates of Chun’an and Jiande Counties?” Governor Hu asked.

“Yes,” Zheng sheepishly lowered his voice.

“Who else?” Governor Hu demanded.

“It’s probably not a good idea to implicate too many people,” Zheng mumbled.

“What about the River Flood Control Supervisor appointed by Lu Gonggong at the Imperial Palace?” Governor Hu challenged. “Li Xuan is supposed to inspect every spending item and check the repair and maintenance on every weir. Do you really think we can absolve him of any blame?”

Zheng and Ho found themselves in a dilemma. “Your Highness, Li is a palace appointee,” Zheng maintained. “If we want to take any measures against him, we should first consult with Yang Gonggong, who has to report it to the Interior Ministry under Lu Gonggong.”

“If that’s the case, our credibility would be challenged if we submit the report to the palace,” Governor Hu pointed out.

Nobody answered – Zheng and Ho looked lost.

With a derisive smile, Governor Hu gestured to his aide who was standing at the door.

“Bring out Mayor Ma,” he ordered. “Arrest him and take him into custody.”

“Yes, sir!” the aide bowed before disappearing in the side room. Before Zheng and Ho had the chance to figure out what was happening, the mayor appeared, escorted by two of the governor’s guards. By then, the two Mandarins realised that they had foolishly fallen into Governor Hu’s trap.

Mayor Ma, with his bloodshot eyes, marched through the room. He paused in front of Zheng and Ho, who quickly cast their eyes down to avoid the mayor’s scornful stare.

“Take him away,” Governor Hu muttered. Under his command, the guards paraded the mayor to the door. Zheng and Ho kept their heads down until the sound of the mayor’s heavy footsteps faded. They looked up and saw that Governor Hu was back at his seat, with his eyes closed again.

Zheng clenched his teeth and mumbled to Ho, “Let’s go and talk with Yang Gonggong and see what he has to say.”

“I guess so,” Ho acquiesced. “His Highness might be correct. If we decide to attribute the flooding to the shoddy repair and maintenance, it wouldn’t be fair to simply punish our people and let a palace appointee get away with it.”

Governor Hu opened his eyes and got up from his chair. “If you agree with me, go and take your case to Yang Gonggong. Let’s move fast on the rescue efforts and distribute food to flood victims in Chun’an and Jiande Counties. Also, please state clearly in our report that such catastrophic flooding has made it hard to implement the rice-to-mulberry conversion policy. We need more time. After you finish the report, make sure to get Yang Gonggong to sign it. You two should also put your names on the report. Then, I’ll take over and submit it.”

After Governor Hu stepped out, Zheng and Ho stood there motionless. They had no inkling of how they would persuade Yang – notorious for being maliciously difficult – to give up and hand over his protégé. The situation could turn ugly. If they did not tread cautiously, they could upset the whole coterie of powerful eunuchs in Beijing. Of course, before leaving the governor’s office, Zheng and Ho had no time to ponder these echoing questions.

4

“Daddy,” Li Xuan called when he entered Yang Jinshui’s residential quarters inside the South China Textile Bureau’s compound. The new décor in the room dazzled him. The whole place was blushing red – red lanterns, red candles, a red silk mosquito net, red bed sheets and quilts, and red cushions on the chairs. Surrounded by the ocean of unrelenting red, Li felt a bit light-headed.

But Li was most shocked to see a table covered with food and liquor in the middle of the room. Yang sat at the table, waiting for him. So did Madam Yun, who sported a red bridal cloak. Baffled by the beguiling festive scene, Li froze.

“Come over and have a seat here,” Yang said to him, his face radiant with hospitality.

Li took a few halting steps forward and picked a seat on the far side of the table. “Go and sit over there,” Yang said, pointing at a vacant seat next to Madam Yun. “You’re the guest of honour tonight.”

Li was more confused than ever. “Daddy, are you playing a practical joke on me?” he said, forcing out a smile. “You know I’m a shy and timid person. Please don’t scare me.”

“You think way too much,” Yang said calmly. “Do as I say and sit down.”

“It’s very kind and generous of you, but I wouldn’t dare break the rules,” said Li, who insisted on taking a side seat. He could hear his own heart thumping. Yang gave in but urged Madam Yun to move over and sit next to Li. Holding her wine glass, the slender young woman snuggled against the junior eunuch. Springing to his feet like a startled monkey, Li asked in panic, “Daddy, please tell me what is going on. What do you really want me to do?”

“You are truly a smart boy,” Yang conceded. “All the training and favours I have bestowed on you are not completely wasted.”

The remarks sent Li reeling with fear. He fixed his gaze on Yang’s well-groomed face.

“Bring that cup of globefish soup for my boy,” Yang said to Madam Yun, who picked up a blue porcelain soup bowl from the table and placed it in front of Li. After she lifted the lid, Li involuntarily stared into the soup with a look of horror, as if the liquid had been laced with poison.

“What’s the matter?” Yang reassured him gently. “I’m not going to poison you.”

But Li simply sat there, refusing to touch the spoon. Shaking his head, Yang removed the lid from his own soup bowl and scooped up a spoonful of broth into his mouth.

“Of all the boys I have mentored, you’re the most thoughtful and loyal,” Yang complimented. “You brought me this globefish last year. I raised it in my pond, hoping that someday we could enjoy it together. I finally have the chance today. Earlier on, I asked a chef from Yangzhou to cook it for us. But you don’t seem to like it.”

“I’m sorry for being such an idiot,” Li said, literally slapping himself in the face. “I’m going to eat it.”

He removed the lid, cupped the bowl with both hands and took a big gulp directly from the bowl.

“It’s hot,” Yang yelled. “Pace yourself.”

The soup had burned his tongue. Li put the bowl down, opened his mouth wide and grimaced with pain. Madam Yun picked up a pot of liquor, filled up a large mug and offered it to Li.

“This, this mug is too big…” Li stuttered nervously.

“You’re truly perceptive,” Yang repeated. “Daddy does want to tell you something today. Actually, my message boils down to three sentences. I’ll broach a sentence each time you empty your cup. Now, drink up this one.”

Li finished it at a single gulp and waited for Yang to utter his first sentence.

“Well, you mentioned several times behind my back that you would die a happy man if you could sleep with Madam Yun,” Yang said nonchalantly. “Didn’t you say that?”

Li leapt from his seat, pushed away his chair and dropped to his knees. Yang stood up and held out a hand, trying to pull him up from the floor. Li refused to get up.

“Look at you,” Yang teased. “I’ve only uttered one sentence. If you keep acting like this, I won’t be able to broach the other two with you.”

Too scared to speak, Li kept kowtowing. Madam Yun, taking her cue from Yang, tried to help him, but Li sidestepped her as though she were a ghost.

“Get up,” Yang finally hardened his tone. Li quickly obeyed. When he rose to his feet, his legs quivered uncontrollably. Madam Yun held his arm and sat him down. Then, she filled up a second glass.

“Drink it up,” Yang demanded. Li could hardly hold the cup with his trembling hands. It took him a while to gulp it all down.

“My second sentence – how has Daddy treated you so far?”

Li was about to rise again, but Madam Yun pressed him down.

“Daddy treated me like his own son, and I’m forever indebted to you…” he mumbled.

“You are a good man,” Yang nodded. “Give him more liquor.”

Madam Yun filled up the cup again. Before Yang spoke, Li raised the cup and held it to his lips. Yang stopped him.

“Wait until after I finish my last sentence,” he said. “Then, drink as much as you want.”

Emboldened by the alcohol, Li responded loudly, “Daddy, you own my life, and you make every decision for me. Please finish what you need to say.”

“Fine,” Yang said. “My last sentence is – I want you to spend the night here and sleep with Madam Yun.”

Yang’s words dumbfounded Li. He stood there, stiff as a wooden board.

Yang rose and said, “I’m done with my three sentences. Now that you have heard what I have to say, I’ll leave it to you to decide whether you want to empty the cup or not.”

Then, Yang walked out and closed the door behind him.

By then, Li had finally seen through the charade. Turning around abruptly, he howled at Madam Yun, “Come over here and serve your man another drink.”

At the crack of dawn, the public square outside the governor’s yamen suddenly teemed with fully armed soldiers. Holding burning torches, they encircled the square, which appeared from the sky like nails spreading around evenly. The front gate stood wide open. Guards carrying swords and torches stood on both sides. The entrance pathway that led guests into the governor’s inner courtyard was also flanked by soldiers with torches, which lit up the compound like daylight.

A suffocating silence spread across the square. There was no wind, not even a gentle breeze. Flags hung limply on tall poles. Two men stood tied to thick wooden stakes nearby, their heads slumping lowly over their chests. Chang Boxi and Zhang Zhiliang, two former county chiefs, would be executed on charges of “negligence of duty”. Opposite them stood two more vacant stakes.

“Who is it?” a loud voice pierced the silence – a few lanterns coming towards the square. Several soldiers stirred, dashing over to intercept and question the newcomers.

“We’re with the South China Textile Bureau,” a person in the group replied. They explained that they had escorted Li over for execution. Two eunuchs took Li by the arm, and four soldiers carrying lanterns followed them. Li was too drunk to walk steadily.

“Is that Li Xuan, the River Flood Control Commission supervisor?” an aide to Governor Hu asked.

“Ye-yes… it is me, your Daddy,” Li garbled. “I’m… I’m ready…”

The governor’s aide pointed at a wooden stake and ordered, “Take him over there.” By then, Li had noticed the two magistrates who once served on the River Flood Control Commission with him. “Ah, I didn’t realise that you two were here before me,” he greeted them.

One of them shunned him by closing his eyes, but the other one, the former head of Jiande County, pleaded with him, like a drowning person grabbing a rope. “This is so wrong,” he cried. “Please, go and petition Yang Jinshui to save us.”

“Pe-petitioning… what?” Li reproached him. “You… you’re a damn coward. Come on, tie me up there.”

Out of despair, the Jiande County chief burst into sobs, but Li giggled. “At the crack of dawn, the tears of the departed have turned the maple leaves red…” he began humming an opera tune.

The two eunuchs tried to stop him, but he resisted them. “I regret that we hadn’t met each other earlier, and it is a pity that you’re leaving too soon,” he crooned, waving his hands like a soprano. “The willow leaves are long, but cannot restrain your white horses from galloping away…”

As he was trying to strike a pose, Li fell headlong to the ground. The two eunuchs quickly helped Li to his feet. Mortified by Li’s drunken outbursts, the guards looked at each other in frustration, not knowing how to handle him.

“Hurry… up… put me up… there,” Li shouted.

“No, no, we have received instructions that Mr Li is a member of the Interior Ministry,” shouted the governor’s aide. “We can’t apply an instrument of torture to him. Take him to the guard’s room first.”

Li Xuan, assisted by two eunuchs and four guards, marched into the governor’s yamen.

Inside the governor’s office, the dour-looking Yang Jinshui, Zheng Bichang and Ho Maocai sat quietly, waiting anxiously for Governor Hu to review the report they had just drafted. Since there was no breeze, the room felt stuffy. The loud sounds of insects outside increased their irritation.

“I mentioned to you earlier that we need to request more time in implementing the land-conversion policy,” groused Governor Hu, who placed the report down on his desk. “I don’t see it here. Why is that?”

Zheng turned towards Yang, but the latter sat there with his eyes closed.

“We’ve had many discussions with Yang Gonggong over this,” Zheng explained. “We just don’t feel that we are in any position to request a delay because the rice-to-mulberry conversion initiative is part of a national policy. It is up to the Imperial Palace to decide whether we should postpone it or not. If His Majesty is concerned about the large-scale flooding we are experiencing now, he can certainly issue a new decree, putting a moratorium on the implementation this year. Then, we’ll follow his decree accordingly.”

“What if the Imperial Palace refuses to issue a moratorium?” Governor Hu asked.

“Then, we just have to bite the bullet and try to overcome whatever difficulties and barriers stand in the way,” Zheng insisted.

Governor Hu jumped to his feet.

“Overcoming barriers that stand in your way? What kinds of barriers?” he vociferated. “Several hundred thousand people have lost their crops to flooding. They’ve been left with nothing to eat. These people will have nothing to harvest in the autumn, and no grain supplier is willing to loan them rice to help tide them over. Even so, you still want them to grow mulberry trees. They can’t eat mulberry leaves, can they?”

“Even if we don’t convert their land, they still won’t have rice or money,” Ho argued. “Their land has been flooded, and they have already lost their crops.”

“We can urge the Imperial Palace to loan us money or to allocate grain from elsewhere to help us,” Governor Hu suggested. “Besides, if farmers can replant some seedlings after the floods recede, they’ll still be able to harvest something in the autumn. They might not be able to pay back the loans this year, but they should be able to in three years. Therefore, it is imperative that we postpone the implementation for three years. Please put this in the report.”

When Governor Hu tossed the draft on the desk, Zheng and Ho sat there without stirring.

“If you want to include that request in the report, I’m not going to sign it,” Yang protested, without bothering to open his eyes.

“So what are you suggesting?” Governor Hu asked, refusing to back down.

“I’m in charge of the Textile Bureau, and my job is to produce silk and generate revenue for the Imperial Palace,” said Yang. “What else can I suggest?”

“I understand the importance of silk production. What if starvation occurs and people rise up against the Imperial Palace? Would you feel responsible?”

“That’s your business, not mine.” Yang opened his eyes in defiance.

An awkward silence followed. The loud churning of insects in the courtyard filled the room. Governor Hu stared at Yang, and his eyes sparkled with intensity. “Do you think it should be my business to cover up the scheme of breaking the dams to flood the farmland?” Governor Hu yelled suddenly, thumping the rosewood desk with his fist.

Yang looked startled but quickly regained composure. Banging on a tea table next to his chair, he rose to his feet. “What scheme?” he countered. “What are you implying? When you learned about the leaking dams, you were bent on looking for scapegoats. So I offered Li Xuan as a sacrifice. What else do you want? For regional officials like you, the grass is always greener on the other side of the fence. You can always jump over the fence when needed. I’m not as fortunate. I only have one lucky star, and he resides in the palace in Beijing. You don’t have to follow the grand secretary’s order. But I have to obey Lu Gonggong because I’m a member of the Imperial Palace staff. If there’s any fallout, my boss, Lu Gonggong, can report it directly to His Majesty.”

Even though he was burning with fury, Governor Hu decided to control his temper. “I don’t need Lu Gonggong to tell His Majesty,” he said. “As the Governor of Zhejiang, I can travel to Beijing and see His Majesty myself. But, first, let me show you something.”

To everyone’s surprise, Governor Hu summoned Mayor Ma into the room. The mere mention of Ma’s name startled Zheng and Ho. Yang’s arrogance and hostility seemed to have dissipated. They all looked towards the entrance.

Dressed in a blue cloth robe, the mayor stepped in, looking serene. He made a beeline for Hu, without taking notice of three of his former peers. Reaching into his breast pocket, he pulled out a stack of papers and handed them over to the governor. “Here is my confession,” he said. “It has all the information you need, including the names of my collaborators and details of how we sabotaged the weirs. I have asked both of my county chiefs to sign their names in here as well.”

“Please put it on the desk,” Governor Hu said softly as he looked Ma in the eye.

Ma cupped his confession with both hands and carefully placed it on the desk. Then, taking a step back, he dropped on his knees.

“At daylight, I’ll be gone…” he said. “You’ve treated me well, and I’ll pay back your kindness in my next life.”

After he finished, he kowtowed to Governor Hu three times before getting on his feet and marching out. The three mandarins stood there in a daze.

“Do you want to review the confession?” Hu asked his guests.

Nobody responded.

“If you don’t want to read it now, that’s fine,” Governor Hu continued. “I hope I don’t ever have to show this confession to another person. But, if the floods and the land- conversion policy turn local farmers into rebels, allowing the pirates to take advantage of the chaos and launch an attack on us, I’m afraid that I would not only lose my life over this but also earn myself eternal infamy. Therefore, I won’t permit anyone to create chaos in Zhejiang in the name of implementing His Majesty’s land-conversion programme. I won’t tolerate any attempts by others, whether intentional or inadvertent, to cause instability in our nation. There’s no backing out for me. There’s no way out for you either. Let me ask you one more time, are you willing to rewrite and modify the report?”

The three guests sat still in their chairs, gazing downward.

Yang broke the silence. “Now that Your Highness has said it, I guess we’ll just have to do it. After all, it’s for the betterment of our empire. What else can we say?”

Zheng complied as well. “All right then,” he said. Before leaving, Zheng moved over to the desk and picked up the draft report.

The flood report, along with a letter jointly signed by Zheng Bichang and Ho Maocai, reached Yan Shifan a few days later. After giving it a quick read, he forwarded the report to his father, Grand Secretary Yan Song.

“That’s great, that’s great,” Yan Song said sarcastically, his lips quivering with anger. Soon, his head and his thick white beard started trembling as well. In fact, he looked like someone who had just suffered a stroke. Panicked over the grand secretary’s strong reaction, Luo Wenlong, his confidant and director of the Imperial Post Office, and Mao Qing, the deputy minister of justice, rushed to his side. They held his arms and massaged his back.

“Your Highness, please don’t take it too hard,” Luo consoled.

The flurry of activities at the other end of the room jolted Yan Shifan, who had been lost in thought while pacing the room like a cornered lion. When he saw Luo and Mao fussing over his father, he quickly walked over. Slowly, Yan Song’s trembling had stopped, but he was still too upset to speak. Holding the report in his hand, he simply stared at it blankly.

“Human hearts are as unfathomable as deep water,” Mao observed while rubbing Yan Song’s shoulder. “How could one have guessed that Governor Hu would do this to the grand secretary.”

Yan Shifan clenched his teeth and said with a determined look, “Well, we raised him high, but we can also bring him down and crush him to death. Let’s draft a report and initiate the impeachment process right away.”

“Stop it,” Yan Song said. The old man had recovered from his initial shock. Banging on the arm of his chair with his old bony hand, he asked, “Tell me, who came up with the plan of damaging the weirs to flood the farmland? What was that about?”

None of them responded. Yan Shifan was glaring at the floor.

“Tell me!’ the grand secretary demanded.

“All right then,” Yan Shifan replied. “To cut a long story short, we encountered tremendous challenges when pushing the land-conversion policy because Governor Hu couldn’t make up his mind and resisted it from the very beginning. The rice-to-mulberry conversion wouldn’t be possible without the help of big silk mill owners. We have to offer them land at cheaper prices. So we decided that flooding was necessary. That’s the whole story.”

Yan Song wanted to say something but failed to summon enough strength to utter the words. He paused and closed his eyes. Luo eyed Yan Shifan reproachfully, signalling him to calm down. Taking his cue, Yan Shifan plopped down on a chair.

“We apologise for not consulting with you about this,” Luo whispered to Yan Song. “We just didn’t want you to be worried. We had planned to give you a detailed report afterwards. The farmland in Zhejiang’s nine counties is critical to the success of our land-conversion policy. It is imperative that rice seedlings are out this year and mulberry trees are in. We have to make it happen regardless of whether the land is flooded or not. Confucius admonishes us – the people may be made to follow a path of action, but they may not be made to understand it. Ordinary folks will never understand the difficulties we are facing. We have no other alternatives. Governor Hu could have easily cooperated with his colleagues there and submitted a report, claiming that the flooding was a natural disaster. Nobody here would have questioned the conclusion. But who would have known that Governor Hu could be so inscrutable? Fortunately, he has scrupulously blamed the flooding on shoddy repair and maintenance work on the weirs. I personally think that he’s merely attempting to stop us from implementing the conversion policy. The whole thing is still manageable.”

“The conversion policy is irrevocable,” Yan Shifan interrupted impatiently. “Hu’s now forcing others to sign on this report and has requested that His Majesty put aside this policy for three years. With the current dire fiscal situation, can we afford to wait for three years?”

“He can request three years, but it doesn’t mean that we are granting it,” Mao added.

“Well, it’s not up to him to decide, but, if the Prince of Yu gets wind of our plan, he and his friends can use this to attack us,” Luo warned. “That would make things more difficult. What I’m also worried about is that Governor Hu might use Mayor Ma’s confession as leverage. If Lu Gonggong knows that Governor Hu has solid evidence against us, he might withdraw his support and stop pushing for our agenda in front of His Majesty. An urgent task is to go and talk with Lu Gonggong and persuade him to see His Majesty together. As long as His Majesty remains resolute in his support, the rest should be easy.”

Yan Shifan, whose anxiety and anger had receded, gave his stamp of approval to Luo’s suggestion.

“I’m already eighty-one years old,” Yan Song sighed. “It’s about time you killed me.”

Seeing that Luo and Mao had dropped to their knees to apologise, Yan Shifan, visibly annoyed at his father’s reprimand, felt obligated to do the same. Putting one hand on the edge of his desk, Yan Song slowly got up.

Yan Song held the report in his hand and said helplessly, “I’ll follow your order and go to see His Majesty.”

Inside the Yuxi Palace, Lu Fang, the interior minister and chief eunuch, was reading aloud Governor Hu’s report to Emperor Jiajing, who listened quietly and intently. Grand Secretary Yan Song sat on a small stool. When the emperor stepped down from his cushioned throne and started pacing around anxiously, Yan Song laboriously got up from his chair as a gesture of respect.

“In Chapter 58 of Tao Te Ching, there is a passage that reads, When the country is ruled with a light hand, the people are simple. When the country is ruled with severity, the people are cunning,” Emperor Jiajing chanted. “People have been feeling lost for a long time. Tolerance can be a fault. So is repression. No wonder the people are feeling lost. I’m also lost. Aren’t you lost?”

Yan Song pressed his hand on the drum-shaped stool and dropped to his knees. So did Lu Fang.

“Be it tolerance or repression, it’s all my fault,” Yan Song stated. “Governor Hu knows the situation better than anyone else. I recommend that you summon him to Beijing. We can have a discussion and try to figure out if it is possible to accommodate both needs – disaster relief and land conversion. I’m sure we can work out a solution.”

Emperor Jiajing sauntered towards his bookcase and paused in front of a section labelled “Zhejiang Province”. Then, he mused aloud, “God descended from heaven to enquire about the happenings on earth. Let’s invite the earth lord over.”

“Yes, Your Majesty,” Yan Song replied.

“We should also invite two more people,” Emperor Jiajing added. “The first person’s surname is Yang, and his given name is Jinshui. He’s Lu Gonggong’s protégé. The second one is Tan Lun, a trusted ally of the Prince of Yu. Of course, Governor Hu is the grand secretary’s student. Bring these local lords and deities over. In this way, all factions will be represented.”

Emperor’s Jiajing’s suggestion and sardonic comments shocked Yan Song. He shot a sidelong glance at Lu, hoping that he could help him push back on the emperor’s suggestion. But Lu simply knelt there quietly, ignoring Yan Song’s silent signal.

“Yes, Your Majesty,” Yan Song reluctantly consented.

In May on the lunar calendar, the late afternoon sun still hung high in the sky. The slanting rays of the sun shone on the lofty and magnificent Qianmen Tower, and its glitter dazzled the eye. Even though the nine city gates were heavily guarded during the day, residents still could enter or exit freely. On days when the emperor held a special ceremony or summoned a senior official to the palace, all the city gates would be closed to the public until the royal guards of honour or the horse-drawn sedans of senior officials galloped through.

On the early afternoon of the twenty-first of May 1561 the Imperial Guards shut the Qianmen Gate and began clearing the area. Soon, a transportation official in the palace showed up and waited eagerly with four carriers who stood next to a green curtained sedan. From the colour and shape of the sedan, those who were familiar with the palace rituals knew immediately that a provincial governor would be visiting. Apparently, the governor was not the only guest. A senior eunuch was also standing in the vicinity with four carriers. The colour of the second sedan was blue.

Very soon, a string of horses sprinted towards the Qianmen City Gate, leaving behind them a trail of dust. Governor Hu’s top aide led the entourage, and four bodyguards followed the governor. Shrewd observers spotted Tan Lun with the group. Yang Jinshui also arrived, escorted by four junior eunuchs.

At the Qianmen Gate, the coterie stopped and briskly dismounted from their horses. Governor Hu and Tan Lun tossed their whips to the aides and walked towards the official greeters. After exchanging pleasantries, the greeter lifted and held the curtain on the side of the sedan. Governor Xu bent his head and climbed in. The carriers lifted the sedan and sped right through the city gate. Tan Lun and the governor’s aides marched in with their horses. Meanwhile, Yang remained on the horse, trying to catch his breath. It took two eunuchs to help him alight. His legs appeared so sore that he could hardly walk. In the end, he wobbled forward, with the eunuchs holding his arms.

When a greeter led Yang to his sedan and lifted the green curtain, he didn’t hop in. Instead, Yang grabbed the greeter’s wrist, pulling him closer. “Do you know why His Majesty has summoned me to the capital?” he asked in earnest. “Has Lu Gonggong mentioned anything?”

The greeter shook his head and said, “You know how Lu Gonggong is. His mouth is as tight as that of a Buddha statue. Nobody, not even his deputies at the Interior Ministry, can get him to leak anything.”

Yang stood there with an abstract expression. “Lu Gonggong is waiting for you at the Interior Ministry,” the greeter nudged him, snapping him out of his reverie. Yang dutifully grabbed the greeter’s arm and clambered in slowly.

Close to a quarter of an hour later, Yang’s sedan stopped in front of the duty room at the Interior Ministry. “Daddy!” Yang addressed Lu endearingly. The pain that had stunted his movement a few minutes before seemed to have vaporised. He jumped out of his sedan and made a beeline for Lu Fang, who sat inside the Interior Ministry’s duty room. Falling to his knees, Yang kowtowed three times.

“Please rise,” Lu said calmly.

Yang sprang to his feet. With both hands, Yang carefully picked up Lu’s teacup from a small table nearby and ingratiatingly offered it to his Daddy. Like an accused criminal who was waiting for his verdict at his trial, Yang looked nervous but expectant. Seeing that Lu sat on his chair quietly, Yang began to feel the tremors inside his body.

“Why don’t YOU drink it?” Lu finally spoke.

The patriarch’s words, imbued with symbols and meanings, were treated like an emperor’s edict. This was a routine that every regional appointee of the Interior Ministry would have to follow upon his return to the capital city. Before his meeting with his patriarch, the eunuch appointee would need to pick up Lu’s cup and offer him tea. If Lu ignored the person or refused to take the tea, it meant that the Imperial Palace or Lu himself was not happy with the person’s job performance. The appointee could face demotion, imprisonment or even death. But, if Lu drank up the tea, the appointee could utter a sigh of relief because it indicated “smooth sailing”. On the rare occasion when Lu invited the person to drink the tea from his cup, as he did with Yang, it showed that he was treated like family.

As expected, Yang’s eyes sparkled with gratitude. He removed the lid with his trembling hands and swallowed the leftover tea with one gulp. Then, he squatted down near Lu, and began patting and massaging Lu’s legs.

“Daddy, it’s been four years since I left here,” he said nostalgically, with his face raising towards the patriarch. “You have aged.”

Seeing that Yang was choking up, Lu sighed. “I live from day to day,” he said. “But let’s not dwell on me. Go and wash your face and change. I’m going to take you to see His Majesty.”

“You mean now?” Yang said – he couldn’t believe his ears.

“Since you have nothing to hide from me and told me the whole truth, I do the same for His Majesty,” Lu pointed out. “He’s aware of the flooding scheme. You just need to go and tell His Majesty in more detail.”

“But what if he asks about my role? Am I going to be blamed?” Yang said distractedly.

“You did it for the sake of the Imperial Palace. Fortunately, you didn’t lie about it. His Majesty appreciates your loyalty. Right now, only two counties are affected. His Majesty can stomach that. He has the whole country to rule.”

“But Daddy, I…” Yang remained unconvinced.

“There’s no need to say more,” Yang interrupted him with a stern tone. “Go and get yourself ready.”

For junior eunuchs like Yang, the honour of meeting with the emperor existed in name only. There was seldom any face-to-face meeting. Now that such an opportunity arose, Yang was required to wait on his knees at a spot near the gigantic silk curtains that separated the big hall from the emperor’s meditation room.

Having washed and changed, Yang felt refreshed. More importantly, Lu’s reassurance prior to the meeting calmed his nerves slightly, enabling him to keep a solemn and confident posture.

“Did you actually see the letter drafted by Yan Shifan?” the emperor’s voice reached him from the meditation room.

“Yes, Your Majesty. Your humble servant saw it with his own eyes,” Yang replied with his head down. “Yan Shifan’s letter was delivered to Zheng Bichang and Ho Maocai, urging them to flood the farmland. In this way, it would be easier to implement the land- conversion plan.”

“Have you seen Mayor Ma Ningyuan’s confession?” the emperor asked.

“Your Majesty, I didn’t. Governor Hu did invite Zheng Bichang, Ho Maocai and your humble servant to read it, but none of us actually saw it.”

“Why would Governor Hu do that? What could be his motive?” Emperor Jiajing raised his voice.

Yang hesitated. He looked to Lu, who was standing next to him, for advice.

“Answer it honestly,” Lu advised.

“Your Majesty, your humble servant personally thinks that Governor Hu has three considerations,” Yang raised his voice slightly.

“Three considerations? What are they?”

“First, as the governor of Zhejiang, Hu Zongxian is facing a lot of pressure. The pirates run rampant, posing a serious security threat to the coastal region. Plus, if peasants lose their farmland and their livelihood, they could rise up against the government. When external threats mix with domestic chaos, the government could lose control. This is probably what Governor Hu is concerned about. Secondly, Tan Lun, who worked for the Prince of Yu for years, might have some influence over him. Thirdly, Governor Hu feels indebted to the grand secretary, but he doesn’t always see eye-to-eye with the grand secretary’s son.”

After Yang finished, Emperor Jiajing summoned Lu into the meditation room. Yang pricked his ears. “You’ve done a good job training and promoting Yang,” Emperor Jiajing was heard saying. “He’s quite capable. Award him something, but do it quietly.”

Yang Jinshui knelt on the floor, with his head down. His heart was thumping with excitement.

“Tell Grand Secretary Yan Song to bring Hu Zongxian here tomorrow,” Emperor Jiajing’s voice lingered in the big hallway. “Invite the Prince of Yu to the meeting as well.”

Governor Hu arrived at the Imperial Guest House, where he washed briefly and changed into civilian clothes. Then, he left again without supper. His sedan chair stopped at about three hundred metres away from Yan Song’s mansion. It was seven o’clock in the evening, and darkness had just descended. Stepping off from his sedan, he paused. From a distance, he gazed at the sprawling courtyard house that he had visited countless times before. The façade hadn’t changed much. Under the eave hung the same four big red lanterns, with the characters The Yan Mansion printed on them.

How time had flown past! Twenty years before, when he had scored the highest in the annual Imperial Examination, Grand Secretary Yan Song summoned him there for a meeting. Governor Hu could remember it as if it had only happened the day before. But things were different today. He had never felt so remote from the grand secretary, even though he was only about three hundred metres away from the Yan Mansion. To give himself enough time to mentally prepare for the possible insults and rebukes that the grand secretary could hurl at him, or some unexpected conspiracies plotted against him, he decided to walk the last three hundred metres.

“I’ll go by myself, and you can all wait for me here,” he said to his aide, who handed him a square package wrapped in cloth.

“Oh, it’s you, Governor Hu,” a guard at the entrance greeted him warmly – it was obvious that he knew Governor Hu very well. However, beneath the familiar tone, Governor Hu could tell that the guard sounded a little uneasy and guarded.

“How is the grand secretary?” Governor Hu enquired with smiles.

“Fairly well,” the guard answered, quietly sizing him up.

“Could I bother you to take me to see the grand secretary?”

“I hate to broach this to you, but I received instructions from the grand secretary this afternoon that he does not think it appropriate to see you because you have been summoned back by His Majesty,” the guard said haltingly.

Governor Hu was taken aback by the guard’s message. On his way there, he had prepared himself for all sorts of awkward scenarios, but he hadn’t anticipated that Yan Song would refuse to see him. A pang of disappointment and sadness overcame him. He stood there for a few minutes, contemplating what to do next.

“Could you go and tell the grand secretary that I need to see him first for both personal and work-related reasons?” he requested again.

“All right, Your Highness,” the guard said reluctantly. “Why don’t you wait here while I go and relay your message.”

Since he had been away from Beijing over the past two years, Governor Hu had not been advised of the changes in the Yan family. The grand secretary had long ago lost the energy that kept him on top of every decision. His son, Yan Shifan, had taken over the Privy Council. It was more so at home. Everyone had to follow Yan Shifan’s order. Everything, big or small, had to go through him. Earlier that day, Yan Shifan specifically instructed the guards to stop Governor Hu at the door.

“Grand Secretary Junior,” the guard came to the study to notify Yan Shifan of Governor Hu’s visit. It so happened that at that moment, Yan Shifan was dictating a letter to Mao Qing, the deputy minister of justice, who was arduously taking notes at a desk. Yan Shifan was so engrossed in the rebuttal letter that he ignored the guard.

During my tenure, I neither shared His Majesty’s concerns for the country nor alleviated hardships for the people,” Yan Shifan read. “My failure was such that it could no longer be explained away by simply calling it ‘ignorance or incapability’. Given the harm I had done to my country and the people, how could I continue to hold the governorship which you bestowed upon me? With your permission, I resign from my positions as the governor of Zhejiang and the imperial inspector of Zhejiang. With gratitude, Hu Zongxian.

He peered at the guard and asked, “Governor Hu is out there, isn’t he?”

“Yes, Your Highness.”

“Didn’t you parrot what I told you to him?”

“Yes, Your Highness,” the guard replied. “But Governor Hu insisted that I pass on this message to the grand secretary. He said he should see the grand secretary for both personal and work-related reasons.”

By then, Mao Qing had finished copying Yan Shifan’s dictation – it was a resignation letter that Yan Shifan had drafted on behalf of Governor Hu. Mao handed over the letter and, while reviewing it, Yan Shifan shouted to the guard, “Tell Governor Hu, this is the grand secretary’s private residence. If he wants to talk about business, he can bring it up in the palace tomorrow, or we can send someone to the royal guest house to discuss with him. If he’s here for a personal visit, tell him that the grand secretary has no personal relations with him.”

The guard didn’t leave. “If I tell him this, don’t you think it’ll hurt his feelings?” he mumbled.

“Hurt your mother’s fucking arse!” Yan Shifan roared. He picked up an inkstone from the desk and hurled it at the guard, who quickly ducked his head.

“Your humble servant will follow your instruction…” the guard pledged before running out of the house.

Having witnessed such irate outbursts before, Mao Qing sat at the desk calmly. “I guess I have to find a new inkstone,” he muttered.

“Why don’t you ask?” Yan Shifan chided. “Can’t you send someone to get it for you?”

Even though the guard dodged the inkstone, he was shivering with fear. Upon returning to the gate, he passed on Yan Shifan’s message verbatim to Governor Hu, who mistakenly thought that the message had been dictated by the grand secretary. Standing alone, Governor Hu felt overwhelmed with sadness.

“I assume Your Highness will have the chance to see the grand secretary before going to meet with His Majesty tomorrow morning,” reminded the guard, who couldn’t bear to see Governor Hu suffer like that. “You can bare your heart to him tomorrow then.”

“Thanks for your kindness,” Governor Hu said slowly. “If possible, could you tell the grand secretary that I have something urgent? If we wait until tomorrow, it could be too late.”

“I will definitely report what you said to the grand secretary,” the guard promised.

Governor Hu turned around and strode away.

Inside the Yan Mansion, the grand secretary, known for his placid temperament, seemed unusually agitated and distracted tonight. Lying on a recliner in his study, he was wide awake while listening to books, which, under normal circumstances, tended to make him drowsy. Fixing his eyes on the horizontal beams on the ceiling, he was lost in thought. Luo Wenlong sat next to a floor lamp, reading aloud the verses in Chapter 58 of Tao Te Ching.

When the country is ruled with a light hand

The people are simple.

When the country is ruled with severity,

The people are cunning.

Happiness is rooted in misery.

Misery lurks beneath happiness.

Who knows what the future holds?

There is no honesty.

Honesty becomes dishonest.

Goodness becomes witchcraft.

Man’s bewitchment lasts for a long time.

Yan Song raised his hand to stop Luo. “When His Majesty chanted Chapter 58 this morning, do you think he had got wind of the secret plan to destroy weirs and flood the farmland in Zhejiang?” he asked, with his eyes staring at the ceiling.

“I doubt it,” Luo replied. “We have full control of the Zhejiang government, and the South China Textile Bureau is staffed with Lu Fang’s henchmen. Since several of the eunuchs were also involved in the scheme, I’m highly sceptical that Lu Gonggong would foolishly reveal it to His Majesty. Apart from them, nobody knows what happened, and no one has any evidence against us. Who would dare speculate and spread rumours?”

“Then, why did the emperor quote Chapter 58 in the middle of our meeting today?” Yan Song asked.

Yan Shifan barged in and shouted, “If you truly believe that His Majesty knows something about it, Governor Hu has to be the leaker. Governor Hu personally travelled to Chun’an County with Tan Lun to direct the disaster relief work. After the two returned to Hangzhou, Governor Hu had Mayor Ma arrested. I think Tan Lun must have read Mayor Ma’s confession and passed on the information to the Prince of Yu. If His Majesty is in the know, I’m sure he got it from the crown prince.”

“I don’t think so,” Yan Song shook his head. “Governor Hu is prudent in nature. I know that part of him well. When he interrogated Mayor Ma, there was not another person on site. I doubt he has shown it to Tan Lun.”

“Father, you are way too trusting!” Yan Shifan accused.

“I’ve mentored him for years, and I know him better than anyone else,” Yan Song insisted. “If His Majesty learned about this scheme from the Prince of Yu, other Privy Council members, such as Gao Gong, Zhang Juzheng and Xu Jie, would have been briefed as well because they’re the crown prince’s advisers and confidants. If that’s the case, I would have heard something.”

Yan Song struggled to sit up, and Luo rushed over to help.

“Let’s ask Governor Hu when he’s here,” Yan Song said expectantly as he peered at the courtyard. “He should be here any minute. Why don’t you go and ask the guard? Bring him to me immediately upon his arrival.”

“Don’t count on it,” Yan Shifan said dismissively. “I just asked the guard. He’s not going to be here tonight. His betrayal is obvious to everyone, except you. Please don’t be too trusting.”

“I’m sure he will show up,” Yan Song reassured his son.

Inside the Prince of Yu’s mansion, Gao Gong, deputy minister of the treasury, and Zhang Juzheng, who headed the Ministry of Defence, were chatting with the Prince of Yu. The deputy grand secretary, Xu Jie, was absent. The prince paced about the room nervously.

“All we can do at the moment is to watch closely and wait,” Gao suggested. “The fact that His Majesty explicitly summoned Tan Lun to the capital shows that he is laying the blame on us. It’s probably not a good idea to see Tan Lun before he meets with His Majesty.”

“If we don’t see Tan Lun before the meeting, it’ll give people a reason to suspect that the prince has something to hide,” Zhang objected. “Tan Lun used to be your chief of staff. It would sound strange if he doesn’t see you upon arrival. Besides, you’re the crown prince. It is only natural you take a strong interest in national affairs. This land-conversion scheme could turn into a big political scandal.”

“I understand what you are saying,” Gao Gong argued. “But you don’t have to be overly exuberant tonight. If His Highness, the Prince of Yu, sees Tan Lun tonight, what would he say if His Majesty asks about it tomorrow?”

“His Highness can just answer truthfully,” Princess Li’s voice came from inside the chamber. Her interjection took the two guests by surprise. They both stood up as a gesture of respect for the princess, but the Prince of Yu signalled for them to sit down.

“I personally think that Zhang Juzheng is right,” said Princess Li, who argued from inside the chamber. “Your Highness should see Tan Lun tonight. It’s better if you ask Feng Bao to bring Tan Lun over. Father and son should act as one. There is nothing to hide from each other.”

The men’s eyes brightened.

“I’m embarrassed to say that Princess Li is more insightful than us,” Zhang quipped, and Gao Gong nodded in agreement.

As planned, Feng Bao brought Tan Lun to the prince’s mansion. Just as Feng was about to exit, the prince stopped him.

“I want you to take tonight off and return to the palace,” said the prince.

“Master, what do you need me to do?” Feng asked, his head bowed down.

“Tell Lu Gonggong that I have summoned Tan Lun to my house tonight.”

“Master… Master… your humble servant wouldn’t dare do something like this,” Feng dropped to his knees and mumbled.

“There’s nothing wrong with that,” the prince reassured him. “There is no such thing as a private affair here. I’m the emperor’s son. My private affairs are also part of our national affairs. Go as you’re told.”

Feng knelt there without moving.

The prince stamped his feet and asked, “Are you listening?”

“Yes, Master,” Feng said. He rose to his feet and exited with a look of confusion on his face.

By the time Governor Hu returned to the Imperial Guest House, it was quite late. Despite the exhaustion from his week-long trip, he couldn’t sleep. So he got up and decided to organise his thoughts before his meeting in the palace. Regardless of how things would develop, honesty was his best strategy to cope with the emperor and to tackle any unpredictable turn of events during his meeting.

As he was lost in contemplation, his door suddenly burst open. Yan Shifan walked in, surprising him only partially. In a way, he had somewhat expected Yan Shifan’s visit.

Before Governor Hu had the chance to formulate a proper greeting, the grand secretary’s son had already swaggered in and sat down on the only chair in the room.

“I’m told that you have in your possession a signed confession,” Yan Shifan said bluntly. “That confession has something to do with damaging the weirs to flood the farmland.”

“Grand Secretary Junior, I’m not aware of such a written confession,” Governor Hu replied calmly but tenaciously.

Yan Shifan stared at Governor Hu; his eyes widened like two lanterns. After a long pause, he said, “All right, it’s good to know that you don’t have it. Even if you have it, it’s not a big deal. The worst of it would be that His Majesty deposes my father and me, and puts us in prison. But I want to warn you – throughout history, those who served two masters always ended up in a bad way. Even if you drive us out, I don’t think they’ll grant you a seat on the Privy Council.”

Governor Hu listened carefully and responded to Yan Shifan’s accusation with silence.

Exasperated by Governor Hu’s reticence, Yan Shifan yelled, “Are you trying to present the mayor’s confession to the crown prince as a coronation gift?”

“Brother Shifan, you can always use this to gauge the motives of people around you, but it doesn’t apply to me,” Governor Hu retorted. “The grand secretary is already eighty-one years old. As his son, you should at least think first for your own ageing father, if not for the well-being of common people in our country.”

Yan Shifan stood up and roared, “What gives you the right to lecture me? I’ve been given the responsibilities of managing two capital cities and thirteen provinces. Speaking of caring about the well-being of common people, you have to wait your turn. Answer me – are you willing to implement the land-conversion policy in Zhejiang, or are you not?”

“I’ve stated it clearly in my report,” Governor Hu replied.

“Does that mean you’re not planning to change your position?”

Once again, Governor Hu ignored his question. His silence further infuriated Yan Shifan, whose body trembled in frustration. Lifting his right hand, Yan Shifan suddenly began slapping himself across the right side of his face. “I smack this side on behalf of my father,” he ranted. “He deserves it for mentoring and promoting you.” Baffled at the show of self-punishment, Governor Hu was tempted to rise and stop him. But Yan Shifan lifted his left hand and slapped himself on his left cheek. “This smack is a reward I give to myself for trusting you. I have no idea how my father and I could be so blind and stupid as to appoint you as the governor of this important province.”

Governor Hu rose from his chair and walked over to the door. “I have long lost interest in the governorship,” he said. “Feel free to file a report with His Majesty and have me removed from my current position.”

“I didn’t force you to say it,” Yan Shifan pointed out. “You said it yourself. I hope you mean it.”

“Feel free to tell me what I need to do. There is no need to beat around the bush,” Governor Hu said calmly.

“Fine. I’ve already drafted a resignation letter for you,” said Yan Shifan, who brought out a letter from his pocket and tossed it on the tea table. “All you need to do is hand copy it.”

Before Governor Hu had the chance to read it, Yan Shifan headed for the door.

Wealthy families in the capital city usually hired watchmen to mark the time by beating the clappers hourly. As Yan Song was lying on his recliner, he could hear the watchman’s clapper coming from the front yard. He opened his eyes and asked, “How late is it?”

“It’s close to bedtime,” Mao Qing replied. “I don’t think Governor Hu will show up tonight.”

A rare expression of sadness flashed in Yan Song’s eyes. “I guess I’m wrong about Governor Hu,” he sighed. “What did you say about human hearts earlier on?”

“Human hearts are fickle like flowing water,” Mao Qing repeated.

Yan Song shook his head in disagreement. “Water always flows downward, but a human heart always aims higher and higher,” he added, implying that Governor Hu was dropping him for the Prince of Yu.

Mao eyed Luo, who stepped up and advised Yan Song to go to bed. “You need to get up early for the meeting tomorrow morning,” he reminded.

“I’m just going to stay here for the rest of the night,” Yan Song insisted.

At the crack of dawn, Governor Hu left the Imperial Guest House alone, with the resignation letter tucked inside his breast pocket. By the time the gigantic bronze bell on top of the Gate of Heavenly Peace boomed forth to signal the start of a working day, he was already standing outside the Yuxi Palace, waiting for the arrival of Yan Song and the Prince of Yu. When he saw a royal palanquin and an official sedan chair approaching, Governor Hu was seized with pain and dismay. He had no idea how to face Yan Song, his mentor with whom he desperately wanted to consult before the emperor’s meeting. Following the previous night’s snub, he knew that the greeting was bound to be awkward. Besides, how was he going to handle the Prince of Yu?

Based on royal etiquette, Governor Hu was required to greet the crown prince first. So he dropped to his knees when he caught a glimpse of the prince’s golden robe and his boots, which were embroidered with a dragon. By the time the prince emerged from inside the palanquin, Governor Hu had kowtowed three times.

“Thanks for your hard work,” the prince consoled Governor Hu, trying at the same time to tame his enthusiasm so he wouldn’t offend Yan Song.

Two aides helped Yan Song alight from his sedan chair. Governor Hu, who was still on his knees, tilted his body towards the grand secretary. “Your humble subordinate is pleased to see the grand secretary,” he greeted.

“All right then,” Yan Song threw him a quick glance and replied coldly. “Let’s go and meet His Majesty now.”

The indifference pained Governor Hu. After pausing for a few seconds, he said, “Yes, Your Highness.”

By the time Governor Hu got to his feet, the Prince of Yu and Yan Song had already entered the courtyard. He composed himself and caught up.

At seven o’clock, a eunuch on duty ushered them into the Yuxi Palace. The Prince of Yu took a seat reserved for the crown prince on the east side of the throne. Given his advanced age, Yan Song was granted a designated stool on the west. As usual, Lu Fang, the emperor’s top eunuch, stood behind the throne. In the cavernous hall, Governor Hu was the only one kneeling.

Emperor Jiajing appeared in his usual baggy robe. Though the season was still in the middle of winter, he wore only a thin silk robe. What seemed odd was that the emperor would change into a thick cotton outfit with nine printed dragons in the summer. Based on his explanation, such unusual sartorial preference showed the power of his decade-long Taoist meditation and alchemic practice. But many around him knew that the immortality pills supplied by Taoist monks made his body hot in the winter and chilled it in the summer.

But nobody dared question this odd condition. Instead, they flattered him profusely on his diligent Taoist practices that had given him “magic” powers.

Emperor Jiajing started the meeting by directly addressing Governor Hu.

“You ordered the execution of four senior regional officials – a mayor, a palace-appointed river flood control supervisor, and two magistrates who had excelled in the Imperial Exams,” the emperor charged. “How brazen!”

The opening remarks, abrupt and straightforward, startled Governor Hu. “Your Majesty, your humble servant closely followed the Ming Dynasty Law,” he explained. “The negligence by officials in charge of dam repairs and maintenance caused severe flooding that led to the deaths of thousands. Their crime was no different from that committed by military officers who desert their cities at times of war. As the governor and regional military commander, I’m entrusted with the authority to order summary execution on behalf of Your Majesty.”

“You could have obtained prior approval from the Privy Council before you applied the law, couldn’t you?”

“Your Majesty, yes, of course.”

“Then why didn’t you?” Emperor Jiajing questioned. “If memory serves me correctly, you’re prudent by nature. But this time, you acted quite recklessly and impetuously. The officials you beheaded included people favoured by the grand secretary junior or Lu Gonggong. Weren’t you afraid of retaliation?”

“Your Majesty, this land is your land, and all of us who serve the Imperial Palace are solely at your disposal. There’s no division among us,” Yan Song interjected.

“The Imperial Palace is nothing more than a bureaucracy that owns a few palaces and government ministries,” Emperor Jiajing retorted, in half jest. “We don’t eat from the same pot, do we?”

Before Yan Song had the chance to respond, Emperor Jiajing turned to the Prince of Yu, enquiring about Tan Lun. “Early this year, you recommended that your chief of staff be sent to Zhejiang to undertake more training,” he asked. “Has he accomplished anything?”

The prince looked visibly nervous. He thought for a few seconds before speaking up. “Father, Tan Lun served as a military adviser to Governor Hu at the beginning,” he said. “Now, he’s been assigned to the military there to assist General Qi Jiguang. Since he only started a few months ago, it’s still too early to talk about accomplishment.”

“Well, accomplishment doesn’t mean that one has to conquer the enemy on the battlefield and take over a whole enemy city,” rebutted Emperor Jiajing. “Don’t you consider it an achievement for someone who has the audacity to step up and do things that others wouldn’t dare to do?”

The Prince of Yu eyed the calligraphy on the wall behind Emperor Jiajing’s throne. It bore the famous Taoist Teaching: I have three treasures which I cherish. The first is called compassion. The second frugality. The third humility or not daring to step to the front. To the Prince of Yu, the third one about “not daring to step to the front” seemed specifically glaring. He quickly dropped to his knees, and the others held their breath.

Governor Hu raised his head and broke the silence. “Your Majesty, I was a man of mediocre talent, but you championed on my behalf and appointed me to be the Governor of Zhejiang,” he asserted. “After I took over the position, I followed the orders of Your Majesty and the Imperial Palace. I have not bowed to the will of others, and nobody can sway my decisions. But, unfortunately, I have not been able to implement the rice-to-mulberry conversion policy. On top of this failure, an unprecedented flooding occurred during my tenure there. If one gets to the roots of the problems, the blame is on me, not anyone else. I take full responsibility.”

Then, Governor Hu paused. Pulling his resignation from inside his long sleeve, he presented it to Emperor Jiajing. “Your Majesty, this is my request for resignation. Please accept it,” he said.

The sudden resignation took everyone by surprise. Emperor Jiajing did not ask Lu, his chief eunuch, to accept the resignation letter on his behalf. Instead, he gazed at Governor Hu for a few minutes before turning to the crown prince. “Did you listen to what he just said,” Emperor Jiajing said. “He’s trying to exculpate Tan Lun.”

The prince sat there, with his head down. Emperor Jiajing eyed Governor Hu and fired a string of questions at him, his tone growing harsher.

“As you mentioned just now, the shoddy repairs of river dams caused severe harm to people and property,” the emperor upbraided. “The offence was no different from that of deserting land or a city at time of war. On top of that, the flooding disrupted the implementation of the rice-to-mulberry conversion policy. If I were to punish you for such offences, do you think you can get away with it by simply resigning?”

“Be it thunders or morning dew, they are all heaven’s blessings,” said Governor Hu. “I will throw myself at the mercy of Your Majesty.”

“I’m not done with my questions,” Emperor Jiajing continued. “The Imperial Palace allocated two and a half million taels of silver to repair the weirs along Xin’an River last year. All the weirs leaked or collapsed in one big rainstorm. Didn’t you have an inkling of what happened there before?”

The question caused jitters among Yan Song, the Prince of Yu and even Lu Fang. They all looked at Governor Hu.

“I inspected the weirs before, but failed to discover any potential trouble,” Governor Hu replied. “It was an oversight on my part.”

“Was it mere oversight?” Emperor Jiajing asked.

The other attendants were waiting nervously for Governor Hu’s reply.

“Your Majesty, I have a written confession given by Mayor Ma and two of his magistrates who served on the Xin’an River Flood Control Commission.” Governor Hu pulled out a folded document from inside his breast pocket. “It states whether it was oversight or not. Please review.”

The air was thick with tension and awkwardness. Emperor Jiajing turned around and signalled Lu. The head eunuch reluctantly walked over, took the written confession from Governor Hu and handed it over to Emperor Jiajing.

As the steely-eyed Emperor Jiajing was reading the confession, Yan Song closed his eyes, but one could tell that his face was twitching slightly. The Prince of Yu cast down his eyes, trying to control his breathing and his emotions.

As he was perusing the confession, Emperor Jiajing bore an expression that changed from surprise to contemplation and calm.

“Grand Secretary Yan,” Emperor Jiajing called.

Yan Song, who was deep in thought with his eyes closed, didn’t hear his name being called. Emperor Jiajing’s face registered a subtle expression of sympathy and perhaps a bit of disapproval. Instead of waiting for Yan Song’s response, he asked Lu, who was standing behind him, “Did you know what is written in this confession?”

“Your Majesty, I did not know,” Lu bowed his head.

“This confession provides some interesting details about how the weirs fell into disrepair.”

Lu Fang was taken aback at first – he had thought the confession would shed light or expose the scheme of sabotaging the weirs to flood the farmland. Then, with a visible sigh of relief, he looked at the emperor. The two smirked, giving each other a knowing glance.

“Please hand over the confession to the grand secretary.”

As Lu Fang was walking over towards Yan Song, Emperor Jiajing peered at the Prince of Yu, who sat there quietly and calmly, as if nothing important had been discussed.

“Grand Secretary,” Lu spoke softly in his ear.

Yan Song opened his eyes and gazed at Lu. His eyes were filled with uncertainty.

“His Majesty has reviewed the confession,” Lu raised his voice slightly. “It’s about how the weirs fell into disrepair.”

Yan Song’s eyes brightened momentarily.

“His Majesty wants you to review it as well,” added Lu, who handed over the confession.

With his trembling hands, Yan Song unfolded the confession, took a quick glance at the first page and then raised his head. “Your Majesty, the characters are tiny. My poor vision has rendered it impossible for me to read,” he confessed.

“Take it home and share it with members of the Privy Council,” Emperor Jiajing suggested.

“Yes, Your Majesty.”

“We have one more thing on the agenda,” Emperor Jiajing continued. “Let’s discuss Governor Hu’s resignation. He has requested that the Privy Council and I fire him. Do you think we should grant his request?”

After pausing for a few moments, Yan Song said slowly, “Promotion, transfer or dismissal of imperial officials are the sole decisions of His Majesty, and it is not something with which my peers and I dare interfere.”

A shade of displeasure crossed Emperor Jiajing’s face. “You know you’re not speaking sincerely,” he accused.

Yan Song sprang to his feet.

“You were the one who recommended Hu Zongxian for the position of minister of defence and subsequently the governor and imperial inspector of Zhejiang,” Emperor Jiajing pointed out. “When was the last time I promoted or dismissed someone without consulting with my advisers?”

Stunned by the emperor’s rebuke, Yan Song stood there speechless.

Governor Hu raised his head. “At that time, Your Majesty put me in an important position upon the recommendation of the grand secretary,” he said. “Both of you had hoped that I would live up to your expectations and bring peace and economic benefits to people in Zhejiang. But I have faltered in my responsibilities. Obviously, I’m not the best fit for the position. Therefore, I sincerely request that you remove me from my current position.”

Emperor Jiajing gazed into Hu’s eyes. “Are you trying to throw up your job and dodge responsibility?”

“I wouldn’t dare,” Governor Hu lowered his head and replied timidly.

“Regardless of whether you have requested it, I won’t let you get away with it,” Emperor Jiajing insisted. “There are two things that I know about you. First, you have the ability to always see the big picture and put the interest of our country above all. Second, you are a hard worker. Zhejiang provides a large portion of income for the Imperial Palace, but it is under constant attacks from the pirates. Nobody can handle the situation there better than you do.”

Before Governor Hu had the chance to respond, Emperor Jiajing turned to Yan Song. “What do you think?”

“The comments manifest Your Majesty’s wisdom,” Yan Song replied. “At the moment, Governor Hu’s leadership is crucial to the well-being of Zhejiang Province. But I personally think that he’s been shouldering too big a burden. Now that Your Majesty asks my opinion, I would recommend that he resign from the post of imperial inspector and retain his current governorship. In this way, he can oversee the major tasks there and focus on fighting and defeating the pirates. We have to clear the shipping routes for our merchants and fulfil the Textile Bureau’s order of five hundred thousand bolts of silk. I urge Governor Hu to try his utmost to accomplish these tasks.”

“These are the words of a truly experienced strategist,” Emperor Jiajing complimented. “You should call a meeting for Governor Hu so he can discuss with other Privy Council members how to help out the rescue efforts in Zhejiang and implement the rice-to-mulberry conversion plan. It would be ideal if we can work out something that can accommodate both ends.”

“Yes, Your Majesty,” Yan Song bowed.

“Hu Zongxian, do you agree with what I just said?” the emperor asked.

“I will obey, Your Majesty,” he answered, his face awash with tears.

“I understand your predicament,” Emperor Jiajing sighed. “It’s also a tough situation for me. We’ll just have to do the best we can.”

The Prince of Yu and Yan Song dropped to their knees. “It is our responsibility to serve you with all our heart,” they chanted.

“Oh, I forgot about that Tan Lung,” Emperor Jiajing said to the prince. “Keep him in Zhejiang and, as you wish, let him continue with his training there.”

With that, Emperor Jiajing waved his long sleeves in the air and headed for his meditation room. “Beat your drums and hawk your sweets, we each return to our own trade and profession,” he chanted.

“Long live His Majesty,” all the attendants chanted after him.

Once everyone had left the palace, Emperor Jiajing sat cross-legged on his meditation cushion to prepare for his daily practice. Lu put on a pair of thick cotton gloves and pulled out a small tea kettle from the enormous bronze incense burner. Before putting the lid on the burner, Lu tossed a few pieces of sandalwood in there. Then, he carried the tea kettle to the table, poured some warm water into a brown clay cup and presented the water, along with a medicine box, to Emperor Jiajing.

“Master, it’s time to take your immortality pills,” he spoke softly.

Emperor Jiajing slowly opened his eyes, and, with three of his slender fingers, he pinched a bright red pill from the medicine box and swallowed it down with water. Then, instead of resuming his meditation right away, he asked, “Tell me which faction do you think Hu Zongxian belongs to? He’s certainly tricked all of us.”

“I don’t think anyone dares to trick Your Majesty,” Lu replied matter-of-factly. “I think he’s stuck in the middle.”

“Oh well, he’s in a tough place,” Emperor Jiajing observed.

“More tough days are awaiting him,” Lu answered, while wiping the water marks on the table with a piece of cloth. “I don’t think the grand secretary will trust him again. Based on his personal character, I doubt he’ll join the other faction led by Gao Gong and Zhang Juzheng. While maintaining stability and keeping the farmers from rebelling, he also needs to implement the land-conversion policy. It will be tough because neither Yan Song’s nor the Prince of Yu’s side will trust him. Even if he doesn’t work himself to death, he’ll worry himself to death.”

“The Imperial Palace cannot sustain itself without the stability of the southeastern region, and the stability of that region cannot be maintained without Governor Hu,” Emperor Jiajing commented. “We need to defeat the pirates and appease the farmers. Let’s make sure that he’s not burned out fast. At the moment, we’re relying on Yan Shifan to bring in more money and replenish the treasury. I don’t mind if he takes a twenty per cent cut on the money he brings in. I can even turn a blind eye to it if he takes a thirty per cent cut. But if he becomes greedier, and if he cannot even tolerate a competent and honest official like Governor Hu, he’ll have to face the consequences. If farmers in Zhejiang feel squeezed amid the land merger and start rebelling against the Imperial Government, I’m going to hold Yan Shifan responsible. It is good that the Prince of Yu has sent Tan Lun over to keep an eye on Yan Shifan’s appointees. We need to protect Hu Zongxian. At the same time, we should recruit more people like Tan Lun. Please relay a message to the Prince of Yu, telling him in private that he has my permission to dispatch more of his people to Zhejiang.

“Yes, Your Majesty,” Lu Fang replied.

“Please tell your boy, Yang Jinshui, not to create trouble for Governor Hu.”

“Understood, Your Majesty.”

5

Having recently advanced from his position as a mere editor at the Hanlin Academy to become the mayor of Hangzhou, Gao Hanwen felt more anxious than elated, especially after he received notice that Yan Shifan, known as the grand secretary junior, had summoned him for a meeting at the Yan Mansion.

At his office, Yan Shifan looked visibly pleased with himself for securing what he believed was an ideal candidate to fill the Hangzhou mayor’s position vacated by the disgraced Ma Ningyuan, who had been executed by Governor Hu for his role in the dam-breaking scandal. In his self-congratulatory mood, Yan Shifan even assumed the air of an eager mentor who thirsted for and respected young talents. His unusually amicable attitude put Gao Hanwen somewhat at ease, mollifying some of his earlier fears. He felt less rigid, and his smile seemed less contrived.

Taking a box from an expansive mahogany cabinet with both hands, Yan Shifan stepped up to Gao, who quickly rose to his feet.

“Oh, please sit,” Yan Shifan motioned to Gao while opening the box, which revealed four smaller similar boxes inside. Luo Wenlong and Mao Qing, both of whom were present, grinned at one another knowingly. Among the four smaller boxes, Yan Shifan slowly removed the lid from a thin rectangular one and plucked out a calligraphy brush which, from a mere glance, looked exquisite. The handle, as thick as that of an ordinary inkbrush, looked like it was made from mottle bamboo, with bluish black spots covering its body. The brush was securely sheathed in a jade cap – a piece of pointed Hotian jade with a hollow interior. “This pen handle was made from a rhinoceros horn that explorer and diplomat Zheng He had brought back from his overseas expedition one hundred and forty years ago,” Yan Shifan boasted. “Since then, we haven’t seen such a perfect-sized rhinoceros horn. The jade cap is quite ordinary, a piece of carved jade for good luck.”

Pulling off the cap, Yan Shifan showed off a shiny red inkbrush. “It’s made from a type of rare animal hair,” he said. “About thirty years ago, a tribal leader in the province of Yunnan captured a rare weasel and shipped it to us as a gift. This brush came from the hair of the weasel’s tail. I’ve shown the weasel to many experts. They all said it was a very precious specimen, one that is only seen in a thousand years. I’m not asking you to use it. Since you come from a family of scholars, you should keep it as an antique that can be passed on to future generations.”

Gao’s eyes sparkled. Yan Shifan placed the pen in the rectangular box and handed it over to Gao, who was overwhelmed with gratitude. “There are four identical calligraphy brushes in this box. They are all yours,” Yan Shifan said before opening another box. “Here is a piece of ink stick from the Song dynasty, with Mi Nangong’s^(1) signature carved on it, an inkstone with Huang Tingjian’s^(2) signature engraved on it, and a stack of papers autographed by Li Qingzhao.^(3) These are yours. Go and admire them in the comfort of your home.”

Gao held the gift box and stood there in a daze. “My dear teacher, I can’t accept these precious gifts,” he said while declining to take the antique ink stick, the inkstone and the papers.

“I insist,” Yan Shifan said while putting the gifts back in the boxes.

“It’s like awarding a precious dagger to a warrior,” Mao Qing observed. “In our Hanlin Academy today, there aren’t too many scholars who deserve this gift. It shows that the grand secretary junior has full confidence in you. Please accept the gifts.”

With trembling hands, Gao accepted the gifts, which prompted Luo to joke in a melodramatic tone. “Oh well, well, these have long been my coveted items, and I’ve begged the grand secretary junior multiple times to gift them to me, but he never did. I guess he’s found new talents, and it’s time for us to retire.”

Flushed with embarrassment, Gao quickly presented the gift box to Luo. “If that’s the situation, I think you should take them,” he pleaded.

“Oh, no, no, you’d better keep them,” Luo declined. “You have a big job ahead of you. Implementing the rice-to-mulberry land-conversion programme in Zhejiang is a key initiative that is beyond my ability. When you succeed at the end of the year, we’ll be waiting to hear your good news and read your report written with the brush and the ink stick.”

Gao fell on his knees. “Thank you for your generosity, Teacher Yan, and two of my respected superiors. You can rest assured that I will get it done for the Imperial Court. If I can’t accomplish the task in one year, I’ll use the inkbrush and paper to write my own obituary,” he pledged.

Yan Shifan helped him up. “I’m sure you’ll do a good job and return with flying colours,” he encouraged. “You will be rewarded in due time.”

Gao nodded with tears shimmering in his eyes.

Zhang Juzheng, the deputy minister of defence, went to see the Prince of Yu right after the Privy Council meeting.

Tan Lun, who was also at the mansion, rose from his chair and asked in earnest, “What is the verdict?”

Even though the Prince of Yu did not appear too eager, his searching eyes glimmered with curiosity.

“The outcome had already been predetermined, and it didn’t really make any difference whether we discussed it or not,” Zhang complained.

Silence fell upon the room.

“Shouldn’t the council at least grant Governor Hu’s request to allocate more food subsidies for flood victims in Zhejiang Province,” the prince spoke up.

Zhang shook his head.

The prince rose to his feet, appearing indignant. “Did the council say why?”

“It’s quite obvious, isn’t it?” Zhang said. “By refusing to grant food subsidies, they can drive down the land prices, allowing the large silk producers in Zhejiang to barter prime farmland with a tiny amount of grain. It’s a blatant land-merger scheme in the name of helping flood victims with the land-conversion programme and killing two birds with one stone.”

“Didn’t you all speak up at the meeting?” the prince questioned.

Zhang did not answer.

“Where are Xu Jie and Gao Gong now?” the prince said, noticing the absence of his two advisers.

“Governor Hu refused to give up and dragged Xu Jie and Gao Gong to the Ministry of Revenue,” Zhang explained. “He’s hoping that the ministry could allocate some disaster relief fund for Zhejiang Province.”

“Can the ministry do something about it?” asked the prince.

Gazing into the prince’s eyes, Zhang fell into silence again.

Having realised that he had posed a redundant question, the Prince of Yu waved his hand dismissively and mumbled to himself, “I should know better about the Ministry of Revenue. They are not allowed to provide the funds Governor Hu needs.”

“Your Highness, you might not want to hear this, but we wouldn’t allocate the money to Zhejiang even if we could.”

“What do you mean?” the prince asked, looking baffled.

“Why don’t we simply allow Zhejiang to fall into chaos?” Zhang responded emphatically.

The prince widened his eyes in disbelief.

“We have reached the point where I need to share with you what my peers are thinking,” said Zhang. “The Yan family has monopolised political power for twenty years. They are rotten to the core. They are able to get away with it because they flatter and curry favour with His Majesty. As a consequence, the palace staff’s unrestrained and extravagant spending and rampant corruption at every level of the government have caused us such a huge budget deficit. Your Highness knows as well as we do that the rice-to-mulberry conversion policy is a desperate attempt on their part to fill the gap. But this is such a major undertaking, and even Governor Hu doesn’t think they can fully implement the programme in one year. But those folks in the Yan Mansion can’t wait that long. Their cronies also want to exploit the policy for their own personal gains. That’s how they came up with the wicked flooding scheme.

“Even though they’re snatching the food out of the mouths of ordinary people, they are eating away at the foundation of our empire. These are obvious facts, but the Imperial Court is turning a blind eye to such blatant robbery. Fortunately, we have Governor Hu who dares to speak out against it – he is also doing this for the good of the Yan family, but they now see him as an arch foe. The fact that they won’t tolerate Governor Hu shows that they’re at their wits’ end. Your Highness, it’s better to suffer the short-term pain than the long-term torture. Why don’t we just allow Zhejiang to fall into chaos, just like the way we let a piece of our flesh become gangrenous. That’ll get people’s attention, making it easier for us to cut out the piece of rotten flesh and drain the abscess.”

Zhang’s rousing remarks prompted excitement as well as consternation. “Do Xu Jie and Gao Gong share your view?” the prince asked.

“Yes, absolutely,” Zhang replied.

The prince turned to Tan Lun. “What do you think?”

Tan Lun rose from his chair and replied, “It is a wise strategy, but ordinary folks in Zhejiang will have to suffer on their account.”

Suddenly, Tan stopped, turning his gaze into the prince’s inner chamber – someone shuffled out of there. He quickly lowered his head. So did Zhang.

It was Princess Li who sauntered in with their son in her arms. “What are you doing here with our son?” the prince said in a tone that denoted displeasure. “We’re in the middle of a meeting.”

“Nothing in particular – I just want you to hold our baby,” said Princess Li with a serious look as she handed him their son

“Oh for heaven’s sake, what are you trying to prove here?” asked the Prince of Yu, who grew impatient but had no choice but take the baby.

“I just want to ask Your Highness a simple question,” said Princess Li calmly. “How many sons do you have?”

“Don’t beat around the bush. Tell me what you are trying to get at.”

“Your humble wife wants Your Highness to answer this question,” Princess Li insisted.

“Isn’t it obvious that we only have one son?”

“It might be presumptuous for me to say, but your answer is both right and wrong,” the princess claimed.

Zhang Juzheng and Tan Lun, who always held her in high esteem for her intelligence and insightful comments, raised their heads with the knowledge that she had something up her sleeve and was about to reveal it.

The princess faced the three men. “I happened to overhear what you discussed. I understand that some problems cannot be resolved in the short-term, but one should never forget the fact that every inch of this land and every person living on this land are part of our Ming empire. Your Highness is the crown prince, and the boy you are holding in your arms will be inheriting the empire from you. Based on this assumption alone, you should think afar to ensure that you and your son inherit an empire where the ruler has the wholehearted support of his subjects.”

These words caught the prince’s attention.

“This is what I meant when I just said that Your Highness was both right and wrong,” Princess Li continued. “As the crown prince and future emperor, you will govern these people, who will also be the loyal subjects of your son. Therefore, how can a future emperor stand idle when his own people are suffering? Governor Hu knows how to take care of the people under his jurisdiction. What about Your Highness? And all of you here? Do you think you can do better than Governor Hu?”

The three men in the room looked at one another, flickers of guilt and embarrassment, typical with men in front of their female matches, passed through their faces. Oblivious to their reaction, the princess continued, “The Ming empire does not belong to the Yan family. Neither to those corrupted officials and wicked merchants. They can ruthlessly exploit and oppress the common people, but Your Highness, and your righteous officials, cannot simply watch passively without doing anything.”

“This is the true spirit of righteousness,” Zhang praised enthusiastically. “The princess’s remarkable words put my peers and me to shame. She is right. Even though the dire situation in Zhejiang Province is irrevocable, we need to fight, piece by piece, for those flood victims. We cannot let the flood erode our support from those ordinary folks, who constitute the very foundation of our empire.”

The Prince of Yu handed the baby back to Princess Li with a look of approval and affection before speaking to Tan Lun. “You’ve been in Zhejiang Province for quite some time,” the prince said. “Can you figure out a way that we can help Governor Hu and alleviate, if possible, the suffering of the flood victims?”

“I think there is only one thing – I can help to make sure that local officials and big silk merchants don’t take advantage of the disaster and acquire farmers’ land on the cheap,” Tan Lun said contemplatively. “To do this, we need to secure enough grain for the victims and tide them over until next year. I discussed this with Governor Hu before our trip. If the palace cannot provide timely help for the victims, he and I will go to the city of Nanjing and borrow some grain from Governor Zhao Zhenji.”

The Prince of Yu nodded. “That might work. Zhao is also the imperial inspector in Nanjing. If I remember correctly, he’s been friends with Governor Hu for years. I doubt it’s going to be a problem if Governor Hu merely asks for a loan.”

“Even if we get the loan, we still won’t be able to stop the massive land acquisition,” Tan Lun pointed out. “Now that Governor Hu is no longer the imperial inspector, some of the disaster relief supplies will be handled by Hu’s deputy Zheng Bichang and the magistrates. Governor Hu ordered the execution of the Hangzhou mayor and two magistrates. If the Yan family appoints two of their people to take over these posts, the disaster relief supplies will no doubt be hijacked before they get into the hands of the victims.”

“Have they appointed anyone to be the mayor of Hangzhou?” the prince asked.

“Yes, they picked one of Yan Shifan’s protégés,” replied Zhang. “His name is Gao Hanwen, an editor at the Hanlin Academy.”

“Didn’t he score the third in last year’s Imperial Examination? Doesn’t he consider himself a true follower of neo-Confucianism?” asked the Prince of Yu.

“Yes, that’s him,” Zhang said. “The Yan faction carried out an extensive search before they found him. This person has written several influential articles on neo-Confucianism. In comparison with other corrupt officials, he has a relatively clean record. At the meeting, Yan Shifan praised him to the sky. He’s the one who came up with the idea to use the land-conversion policy to both accommodate the challenges of disaster relief and ease the budget deficit.”

“If this person takes over the city of Hangzhou, and Zheng Bichang becomes the new imperial inspector of Zhejiang, the whole province is bound to be in chaos,” the prince brooded.

“What about the other two counties, Chun’an and Jiande?” Princess Li interjected again.

“These two positions are still vacant,” Zhang replied. “The Privy Council has entrusted Zheng Bichang and Gao Hanwen to pick candidates of their own choosing.”

“Can we find two capable and honest men to fill the positions?” Princess Li asked.

“What’s the point?” the prince argued. “These two magistrates will be reporting to the provincial imperial inspector and the mayor of Hangzhou, both of whom are Yan’s surrogates. It would probably be a waste of effort.”

“No, it’s not,” Tan Lun disagreed. “The princess’s suggestion makes a lot of sense because county chiefs are critical. They deal with the grassroots. At the moment, Chun’an County has been completely flooded, and half of Jiande is under water. The greedy merchants are eyeing the prime farmland in these two counties, waiting to snatch it away from farmers. If the magistrates, especially the one leading Chun’an, really want to help ordinary folks, simply being nice is not enough. They have to be prepared to fight their superiors. Whoever is appointed has to be willing to sacrifice his life, if necessary.”

“In our country today, it’s hard to find someone like this…” Zhang sighed.

Silence fell.

“I have someone here who might fit the profile,” Tan Lun said after a long pause.

“Who? Where? Bring him over now,” the Prince of Yu said eagerly.

“I’m afraid that it wouldn’t be possible to summon him here immediately,” Tan Lun explained. “We might not be able to meet this person, but I can read you an article he has written on the harmful impact of land monopolies by the wealthy. Are you interested in hearing what he has to say?”

“Where is the article?” Zhang asked.

“Who would carry the physical article with him?” Tan Lun said. “Since this one was well-written, I have memorised it. If you like, I can recite a few paragraphs.”

Seeing that the Prince of Yu was nodding, Tan Lun collected himself and began. “When a couple begets a son, they shoulder the responsibility of raising and nurturing the child. When heaven brings a person to the world, nature provides him with food and protection so he can survive. We call this nature’s law of existence or even the basic principles of human existence. Is it not a violation of heaven’s law and basic humanity to allow a few people to rob hundreds and thousands of people of their land, reducing them to hunger and abject poverty? Ignoring heaven’s law and degrading humanity lead to chaos. When the people lose their land, the rulers will inevitably lose the support of their subjects. I don’t know of an empire that can still prevent chaos and survive when it loses the support of its people.”

“Wait,” Zhang stopped Tan Lun. “The last few lines sound familiar.”

“You are right,” Tan Lun agreed. “Governor Hu modified them slightly and quoted them in his report. Hu’s version reads, ‘People without land will not support the ruling government. A government without the support of its people will be toppled.’”

“Excellent,” Zhang patted his balled fist on his thigh and exclaimed. “Who is the author? Where is he now?”

The prince and his wife were also waiting for Tan Lun to answer.

“His name is Hai Rui, and he’s currently a schoolmaster in Nanping County in Fujian Province.”

“It shouldn’t be a problem,” Zhang championed with greater gusto. “Promoting a well-educated schoolmaster to the position of a mayor is a legitimate move. Your Highness, I personally think this person can be our precious dagger. He might not be able to rescue people from misery, but at least he could contain and combat the Yan faction with force. Could you recommend him to the Ministry of Personnel, urging them to send Hai Rui to Chun’an County immediately.”

“Yes, I’ll talk with the Ministry of Personnel,” said the prince, nodding in agreement. “Sounds like he’s a rare talent.”

“Things might not be that simple,” Tan Lun cautioned.

This threw a bit of cold water on the plan, taking everyone by surprise.

“What are the challenges?” Zhang enquired. “This is a legitimate promotion unless he himself declines it.”

“It’s easy to justify the promotion and persuade the Ministry of Personnel, but I am not sure if we can convince Hai Rui himself to accept the position,” Tan Lun explained. “I know something about his personal character. If he’s willing to take up a cause, nobody can stop him. However, if he’s unwilling, nothing can change him. Political power never appeals to him. If we can spell out the significance of this appointment, making him realise that he can put into practice what he has written, I have no doubt that he would take it. But there’s one hurdle that I don’t know if he can cross.”

“What is it?”

“His filial obligation,” Tan Lun said.

Intrigued by the assumption, Princess Li asked, “Could you give us some more details?”

“Hai Rui was born in Hainan Province. At the age of four, the death of his father plunged his family into poverty,” Tan stated. “His mother raised him by working for a clothing mill. He attended school and became a certified scholar in the county. When he was young, he harboured strong aspirations to right the wrongs in this world and wrote some remarkable essays. After his failed attempts to excel in the Imperial Examination, which could qualify him for senior government positions, he lost interest in politics and decided to devote his energies to taking care of his mother. You probably won’t believe me if I tell you this – even though he’s in his forties, he sleeps in his mother’s room twenty-two nights out of a month.”

“Isn’t he married?” Princess Li asked curiously.

“This is a critical element for us to consider,” Tan Lun added. “Yes, he is married because he’s the only child in the Hai family clan. But, at the moment, he only has a daughter. If he takes the offer as the magistrate of Chun’an, the likelihood of him returning home is almost nil. It’s like sending a warrior to the battlefield. If he goes, he won’t be able to take care of his mother and produce a male heir for the Hai family.”

Silence fell.

“Let’s draft a letter and send it along with the appointment letter from the Ministry of Personnel,” Zhang suggested. “We’ll urge him to substitute his filial piety with loyalty to the country.”

Tan Lun hesitated. “I can draft a letter, but I can’t guarantee that it would convince him to serve,” he said.

“Let’s write it together,” Zhang volunteered. “I can at least prepare the ink for you.” He walked over to the prince’s desk and poured a few drops of water on the inkstone before rubbing an ink stick on it. Tan Lun paced up and down, contemplating what to write in the letter. Once the ink thickened, Zhang retreated to the side while Tan Lun took over with his inkbrush and began writing. He finished it before everyone had time to finish a cup of tea. The Prince of Yu and Princess Li leaned over and nodded their heads approvingly. But when Tan handed it to Zhang, he expressed some reservations. “I like the first part,” he said. “The second half needs a boost. Why don’t I take a stab at it.”

Zhang dictated his words, and Tan Lun jotted them down:

You used to harbour the aspiration to rid the world of injustices and bring the people out of misery. But at the age of forty, you have not been granted the opportunity. A pearl lay hidden in a corner, and it was piteous that none in this world discovered your talent. Heaven might have intended for you to step out and show your outstanding talent today. In the county of Chun’an, thousands of farmers live in abject misery, and they look forward to your leadership, like they do with clouds and rain during a famine, like an orphan craves the presence of their parents. With wild beasts running rampant, would you prefer to keep your dagger idle inside its sheath or would you rather use it to behead the ferocious monsters? Even if you die on the job in Zhejiang, your mother would be the mother of all people in our country and your daughter will be the daughter of all people. I’m aware of the fact that the Hai family has no heir, but your family name will be revered in temples; the incense and candles will never die off, and your life story will inspire generations to come.

“Wonderful,” the Prince of Yu exclaimed while the princess grinned; a flicker of admiration, reserved by a young woman for a talented young man, flashed across her eyes.

By then, Tan Lun had finished transcribing it; his head was covered with dripping sweat. “Your literary talent is truly worthy of its stellar reputation,” Tan Lun praised. “This passage goes hand-in-hand with Hai Rui’s essay, like two shining stars hanging side by side. This letter has given me hope that he will take the job. But, on the other hand, I’m afraid that if for some reason this precious dagger breaks itself in Chun’an County, I will have another mother to take care of.”

“If anything happens, we can bring his mother to the palace and take care of her here.”

An old woman’s unbound feet revealed themselves underneath the light blue cloth pantaloon skirt. They planted squarely on a stone slab next to a well. The grey-haired woman was pulling a hemp rope with both hands, trying to draw water from the well. Soon, a bucket was lifted in mid-air, filled to the brim with water. Holding the rope with one hand, she reached out the other to grab the bucket by the handle. Then, she poured the water into one of the two empty buckets on the floor next to her. The whole manoeuvre seemed a bit laborious, but she handled it skilfully.

As she was trying to put the bucket back and let it drop into the well, a man, who stood by her, grabbed the bucket from her hands, but she resisted. “I can do it,” the woman insisted; her voice was soft but authoritative. At her persistence, the man let go of the bucket.

He was a mild-mannered man in his forties, and the elderly woman was his mother. Holding onto a shoulder pole with chain hooks on both ends, he looked on helplessly. When the old lady filled up her own buckets from the well, the son rushed over, trying to hook the buckets by their handles to his shoulder pole.

“Oh, I don’t need shoulder poles,” she waved her hand dismissively. “Put that away.”

“Amah, I’ve told you many times that you can’t do this alone,” the middle-aged man persuaded, as he slowly unhooked the bucket. “Let your son carry the buckets.”

Ignoring the man’s plea, the elderly woman hoisted the two buckets, one in each hand, and walked over to her house in big strides.

Shaking his head helplessly, the man picked up his clanking shoulder pole and followed his mother.

Inside the house, a middle-aged woman removed the lid from a steamer on the stove. A plume of white steam rose, spreading through the room. Seeing that the steamer was packed with rice cakes wrapped in lotus leaves, a little girl, about five years old, jumped up and down, her eyes sparkling with excitement. “Mummy, Mummy, rice cakes, why so many?” Her mother wiped the sweat off her forehead with the back of her hand and picked up a cake from the steamer, flipping it in her hands as she tried to cool it off.

“These are for Daddy,” she said, with a hint of sadness in her voice. “He’s going on a long trip. Don’t touch them today. Mummy can make some more tomorrow. Take this one to Grandma.”

The girl, who was salivating over the cakes, nodded quietly. Cupping the rice cake with both hands, she dashed out. In the courtyard, she saw her father, the middle-aged man, standing outside her grandmother’s room with a shoulder pole in his hands. The girl slowed down and crept up to him. Suddenly, loud sounds of water splashing that came from inside the room startled her – her grandmother was scrubbing the floor again. Drops of dirty water splattered outside. The middle-aged man motioned to his daughter with his eyes, asking her to carry the rice cake inside.

The little girl stood at the door and shouted to her grandmother, “Granny, here is a piece of rice cake for you.”

There was silence.

“What rice cake?” the elderly woman finally spoke up.

“Rice cake in lotus leaves,” the little girl answered. “Mummy has steamed a big bunch. She says they are for daddy. He’s going on a long trip.”

“Who says your daddy is going on a long trip?” the elderly woman asked in a stern voice, which stunned the little girl.

“I heard it from Mummy,” she mumbled.

The elderly woman stepped out. “Over my dead body.”

The middle-aged man immediately fell to his knees. The little girl followed suit.

It was in the early evening and darkness was descending.

The official appointment letter, along with Tan Lun’s note, had reached the government office in Nanping, Fujian, and an official there had delivered the mail to Hai Rui in person. When Hai Rui’s mother learned about it, her face fell, and, for several days, she seldom talked to her son. As a way to vent her displeasure, she would fetch water from the well and then lock herself up inside, scrubbing the floor multiple times a day.

The starting date for Hai Rui’s new job was approaching fast. The day before his scheduled departure, Hai decided to have a sensible conversation with his mother, but…

Now, the whole courtyard was enveloped in darkness. A crescent moon hovered over the south wall which was covered with sprawling vines. Crickets hidden inside the weeds started chirping.

Inside Hai’s bedroom, a small stack of books and manuscripts, along with a few sets of neatly folded clothes, lay on top of a blue sheet on his bed. His wife sat distractedly by a lamp with a pea-sized oil flame. When Hai Rui stepped in, carrying his daughter in his arms, his wife rose and took the little girl from her father. The couple did not speak to each other. Hai walked over to a big armoire that stood against a wall and picked out a thin light blue quilt. As he stepped out, his wife asked from behind, “Are you still planning to leave tomorrow?”

Hai paused. Without answering, he kept on walking.

Outside his mother’s room, Hai removed his shoes, placing them carefully near the doorstep. Then, he fumbled his way in and struck a match to light up an oil lamp on a small wooden table. The lamp gave out a faint glow. Putting down his quilt on a cot next to the table, Hai Rui glanced impishly at a bed across the room. His mother was curled up in bed quietly. A thick linen mosquito net was left wide open and her quilt was untouched. Hai tiptoed over and cautiously put the quilt over her body, leaving her big feet uncovered. His mother remained motionless. Hai grabbed a wooden stool and sat by the side of the bed.

A breeze rustled the leaves outside, and the sounds of bugs rose and fell. A few mosquitoes buzzed around the flickering lamp. Hai picked up a cattail-leaf fan, waving it vigorously to drive the mosquitoes out of the net before sealing it. “Leave the net open,” his mother suddenly spoke up, with her back towards him.

Hai obeyed.

“Let me ask you a question,” she asked without moving her body.

“All right,” Hai replied, realising that his mother was wide awake.

“Tell me again what the letter says.”

Hai pulled Tan Lun’s note out of his pocket and planned to read it.

“I don’t want you to repeat the high-sounding words,” she stopped him. “I want you to tell me in your own words what this appointment is all about.”

“All right, Amah,” Hai complied. “Do you know how much grain you can get when you sell a mu of farmland?”

“During a bad harvest year, you can probably get three thousand kilograms of grain, so probably twenty-four thousand,” she answered promptly. “Why are you asking this?”

“In Chun’an County in Zhejiang Province, where I’m going to work, farmers can only get five hundred kilograms of grain for a mu of land.”

“They must have an abundance of land there,” his mother said.

“Not really,” Hai answered. “There’s an old saying about Zhejiang Province – seventy per cent mountains, twenty per cent water and only ten per cent farmland. In other words, farmland is fairly precious there. On average, there’s about one mu of land for each person.”

“Then why is it that land is selling so cheap there?”

“Farmers are forced to do it.”

“How?” Amah suddenly sat up to face her son.

Hai helped her move to the edge of the bed before answering her question. “Government officials and wealthy silk producers are bullying farmers there,” he explained. “The Imperial Palace has run out of money. So the government is planning to convert the farmland in Zhejiang into mulberry fields so we can produce more silk, export it and make more money to replenish the treasury. Some officials at the South China Textile Bureau and large wealthy silk merchants there see this as a big opportunity to make a major killing. In order to force farmers to give away all of their farmland and sell it at cheap prices, local officials have colluded with big silk merchants. They deliberately damaged the dams during the rainy season, causing severe flooding in two counties. Many people have lost everything in the flood, but the local government won’t loan them any grain to help tide them over. So farmers have no choice but to sell their farmland.”

“How could the Imperial Palace allow such a scandalous thing to happen without intervening?” Hai’s mother asked.

Hai Rui didn’t answer.

“Answer me,” his mother pressed him.

“I’m afraid it’ll make you more concerned,” the son said timidly.

“Tell me first,” she insisted.

“The fact is, several people in the Imperial Palace know about this scheme,” Hai said, dropping his eyes to the floor.

Shocked, Hai’s mother asked, “Are you saying that the schemers have the approval of the Imperial Palace?”

“Well, yes,” Hai confirmed. “I think several powerful people in Beijing, including the grand secretary and his cronies and a few people at the Interior Ministry are masterminding this.”

Amah’s eyes widened. She sat there, contemplating something. Then, out of the blue, she began rummaging through her quilt.

“Amah, what are you looking for?” Hai asked.

“The letter you showed me,” she answered.

“I have it here,” Hai said, bringing out the letter from his pocket and handing it to her.

She gazed at the letter with intensity. The faint glow from the small lamp on the table made it impossible to read, but it was apparent that she had not intended to read the words. It seemed that she wanted to penetrate the letter, trying to find something that she could feel but hadn’t been able to articulate.

Hai understood her impulse. “The people who have written to me are loyal and honest officials,” Hai said softly. “They’re the ones who have made the arrangement for me to be the magistrate in Chun’an.”

“They have designated you as their representative to fight those corrupt officials?” Hai Rui’s mother said without taking her eyes off the letter.

Hai nodded.

“Why can’t they pick someone in a senior position to take up the fight?” Amah shifted her gaze to her son. “Why do they send a mere magistrate to do the job?”

Like a sharpened cleaver, these simple words cut in half the befuddled mess that lingered in his mind, enabling him to discover many clues. However, as he pondered more, the clues themselves became entangled with others, forming two more piles of mess that he found impossible to sort out. Hai simply sat there, without knowing what to say.

“Why don’t you answer me?”

“Amah, I’m sure the situation is more complex than we think, and I don’t have a good grasp of it now,” Hai admitted.

“Then why do you still promise them to go before you sort out everything?”

“Several hundred thousand people are affected, and nobody is willing to speak for them and seek justice for them. For this reason alone, I have decided to go.”

“Why would they pick you?”

“Because they know that your son will go all out to fight for ordinary folks.”

Silence fell. The crickets outside had stopped chirping. In the room next door, Hai’s wife could be heard singing a lullaby to their daughter: The sun is taking a rest, isn’t it? Yes, it is. The moon is taking a rest, isn’t it? Yes, it is… My little girl is taking a rest, isn’t she, yes she is… Amah is taking a rest, isn’t she, yes she is…

Amah slowly stretched out her hands and tightly grabbed her son’s.

The lullaby, melancholy and sad, continued in the other room: When Amah is in bed, the sun dims and the moon also dims…

“Why is it that the heavenly god always subjects all mothers in the world to such misery?” Amah mumbled, her eyes staring at the lamp distractedly.

Hai tightened his grip on his mother’s hand.

“Why don’t you go and bring Amah a bucket of water?” she said.

Hai hurried out. A few moments later, he returned to the courtyard, carrying two buckets of water on his shoulder pole. Removing his robe and shoes, and rolling up his trouser legs, he scooped out some water from the bucket and poured it onto the brick floor.

His mother got off her bed and said, “Why don’t I pour the water and you scrub the floor?”

Reluctantly, Hai handed the ladle to his mother who scooped up the water and poured it onto the brick floor. Hai swept the water with a broom made of palm leaves. The water on the floor glistened with the lights from the oil lamp. The moon cast a faint glow on their bare feet.

“Do you know which part of you comes directly from me?” Amah asked.

“You have given me everything,” Hai replied.

“No, I’m asking which part of your body resembles mine?”

Hai did not know. He wiped the water on the floor without answering.

“You have my feet,” Amah reminded. “We both have big feet that are hot all year round, even in the winter. The doctor said that people with hot feet have too much internal heat and tend to be warm-hearted and hot-tempered. For this, you really take after Amah.”

“I know that my ancestors were true followers of the Ming Jiao,” Hai added. “Its core principle was to burn up yourself to warm others.”

“I have been told that the founder of our Ming empire was also a believer of the Ming Jiao,” Amah said. “That is why he named his empire Ming, isn’t it?”

“Yes, Amah.”

“Why is it that our current ruler doesn’t act like the founder of Ming?” Amah asked.

Without knowing how to answer that question, Hai bent over and resumed scrubbing.

“Let’s call it a night,” Amah finally said, putting the ladle in the bucket.

“Why don’t you go to bed first? After I clean up, I’ll keep you company tonight.”

“Bring your daughter over. You don’t need to be here,” Amah said with a sigh.

Hai stood there, with his head down.

“If the heavenly god has mercy, he will give us a boy tonight to carry the family name,” prayed Amah.

At the crack of dawn, the stars scattered in the sky still twinkled brightly. In the Hai family courtyard, three people stood facing each other silently. With a bundle of clothes and an umbrella in his left hand and a small bamboo basket of rice cakes in his right hand, Hai bid goodbye to his mother and then his wife, who kept her eyes to the ground.

“Amah, I have to go now,” he said, but his feet refused to move. Amah looked at her son, speechless.

“Please take care of Amah for me,” said Hai as he turned to his wife. She nodded.

“You really should get going now,” Amah urged. Hai Rui put his luggage on the ground and dropped to his knees. His wife followed suit. He kowtowed three times, and by the time he finished he noticed that his amah had already stepped away to avoid a sentimental farewell. Hai paused, his eyes glistening.

“Do you want to say goodbye to our daughter?” his wife asked, tears streaming down her cheeks. Hai shook his head. Grabbing his luggage from the ground, he rose and strode towards the door.

“Daddy!” His daughter’s cry, which pierced through the early-morning quietude, tugged at his heart. He turned his head and saw the little girl standing at the living room door. He turned around to face her and his daughter scampered towards him. Once again, he put down his luggage and hugged his little girl.

“Is Daddy coming to fetch me later?” his daughter sobbed.

“Yes, Daddy will come back to fetch you soon,” he promised. Reaching his hand into his basket, he brought out a rice cake and stuck it into her hand.

“Daddy, you should have it because you’re going on a long trip,” the little girl said.

“But Daddy wants you to take it,” he insisted.

His wife came over and picked up the little girl from the ground. Hai reloaded his luggage into his arms, took one more look at his wife and daughter, and then marched through the narrow courtyard entrance.

In Beijing, Gao Hanwen, the new mayor of Hangzhou, left with an impressive entourage, creating quite a spectacle. His carriage was flanked on each side by a guard on horseback. At the front, four soldiers on horses led the way, and four more followed behind. Gao’s entourage traversed several provinces, and, at each rest stop, special personnel had been instructed to greet the entourage and change horses for them, providing the best stallions they had. Such royal treatment, unprecedented for a mayor, was meticulously arranged by Yan Shifan, but outsiders saw it as the works of the Privy Council. Before Gao even reached Hangzhou, his reputation preceded him. His arrival heralded the Imperial Palace’s determination to make the rice-to-mulberry conversion a success.

Inside his carriage, Gao’s mind remained as turbulent as his ride. It had been barely four years since he passed the Imperial Examination and joined the Hanlin Academy. Securing this appointment as the mayor of Hangzhou was a milestone for him, an avid follower of the political philosophy of Mencius, who urged rulers to provide material conditions for the livelihood of common citizens and moral and educational guidance for their edification. Throughout his life, Gao had been pursuing the dream of becoming a politician, like he was today, who travelled with an entourage of guards and horses, and made decisions that affected people the world over. Yan Shifan had made his dream come true, plucking him from obscurity, offering him a rare opportunity to put his abilities to good use. However, given that many Confucian scholars and members of the “Clean Stream” faction within the palace took a dim view of the Yan family, Gao was concerned that this appointment might have tainted his reputation.

He had been tasked with implementing the rice-to-mulberry conversion policy while appeasing several hundred thousand flood victims. Even Hu Zongxian, renowned for his political experience and ability, felt at the end of his wits. Would he be able to accomplish anything? If, by a stroke of luck, he succeeded in the land-conversion programme, he was unsure how farmers would react to it. How would the emperor and the rest of the Imperial Palace treat him if farmers rioted for the loss of their land? He did not even want to think about it.

Despite the trepidation, he decided to take the job because the monotonous and neglected life at the Hanlin Academy had become unbearable. After all, one nurtured one’s talent and aspiration for the purpose of applying them someday. Even though the road to success was paved with perils, it was still worth it. Such thoughts motivated him. He ordered his entourage to travel night and day without a break. It was late May, and the scalding sun made it unbearably hot inside the carriage. He removed the top of the carriage and took down the curtains. At times, when the carriage was accelerating, he would stand with both hands holding the horizontal bar. The hot air assaulted his face, sending his baggy robe flying. He felt both inspired but also apprehensive, like a warrior going to his death.

The horses were galloping. For most of the trip, the thrash of his carriage seemed to have jolted the soul out of his body, and he allowed his mind to roam freely. Suddenly, the carriage slowed down, and the breeze that fanned his cheeks stopped. Waking up from his reverie, he found himself in front of a small inn. “Why don’t we take a short break here?” he suggested.

His guards led their horses into the courtyard but paused at the entrance. The inn served as a relay station for the Imperial Palace. A dozen or so horses sauntered around the small courtyard, and a few uniformed guards were feeding and washing the animals. There was hardly any space left.

Gao’s personal aide got out and asked, “What is happening inside?”

The guards did not answer. Instead, they urged him to go in and survey the situation himself.

Gao’s aide stepped into the yard and yelled, “We’re from the capital city. Do you know who’s in charge here?”

People went about their business, feeding and washing their horses, and nobody answered him. The aide raised his voice. “Anybody in charge here?”

There was silence. By then, Gao Hanwen had stepped in. An innkeeper emerged from inside the stable and greeted Gao. “I’ve met Your Honour before,” he said with a grimace.

“His honour has been appointed mayor of Hangzhou, and we’re passing through here,” said the aide. “Why is it that nobody comes out to take care of our horses?”

“As you can see, another official got here first, and we’re taking care of them,” replied the innkeeper. “We’re out of feed now. We have to make do with our own food to keep the horses going.”

Gao and his aides glanced at the troughs and noticed millet and beans, over which the horses were fighting.

“I don’t care what the situation is – our horses can’t leave here with empty stomachs,” said the aide.

“Why don’t you go and talk with them and see if they can share some of their feed with you,” the innkeeper pointed at a group of uniformed guards who were escorting another official.

“Do you know who that official is?” Gao Hanwen asked.

“I didn’t dare ask,” the innkeeper replied, somewhat mischievously. “With so many guards around him, he must be at least a level-two.”

“Could it be Governor Hu Zongxian?” the aide speculated.

“Probably,” the innkeeper nodded.

“All right, let’s go somewhere else,” said Gao Hanwen.

As he was about to leave, he heard someone calling his name. “Is that the mayor of Hangzhou?” Gao turned around and saw a uniformed guard walking towards him.

“Yes, I am Gao Hanwen.”

“Your Honour, Governor Hu Zongxian has been waiting for you here for a few hours,” Hu’s aide said. “Please follow me.”

Initially, Gao Hanwen appeared reluctant, but it would have been highly inappropriate to decline an invitation from the governor of Zhejiang Province, where he would be serving. After pausing for a few minutes, he followed Hu’s aide and went in.

At first glance, Gao Hanwen thought Hu had been taken ill. He was lying on a recliner with his eyes closed and a wet handkerchief on his forehead. His aide tiptoed over to him and removed the handkerchief before whispering in his ear, “Mr Gao is here.”

Hu opened his eyes and motioned to Gao Hanwen, who was standing at the door. “Please come in and take a seat,” Hu invited.

“If I may be bold enough to ask, are you Governor Hu Zongxian?”

“Yes, I am.”

Gao took a deep bow and introduced himself. “I have long heard your great name.”

“Do sit down.” Hu Zongxian pointed at a chair. “Even though I’m still the governor, you’re no longer under my jurisdiction. You report directly to the imperial inspector of Zhejiang, and we have no direct reporting relationship. But I want to see you today for the mere sake of Zhejiang Province and for the sake of our Imperial Palace.”

“Your Honour, please go ahead,” Gao said, with his head down.

Hu did not start the conversation right away. Instead, he asked his aide to go out and share their horse feed with Gao’s guards.

“Mayor Gao, do you know how many people are being affected by the flood in Chun’an and Jiande Counties?” he asked. “Also, as of today, do you know how much rice we have in storage? If we distribute half a pound of rice to each farmer per day, how long can we last?”

“As far as I know, we have about two hundred and ninety thousand flood victims in Chun’an County and one hundred and forty thousand in Jiande,” Gao responded readily. “Before the flood, Zhejiang Province had ten million kilograms of rice in storage. At the moment, each victim gets about four pounds of grain per day. That amounts to three hundred and fifty thousand kilograms. It’s been like this for twenty days. There isn’t much left. At most, we can probably last ten more days.”

“I’m impressed by your familiarity with the situation,” Hu said, nodding his head. “But what are you planning to do after we run out of supplies in ten days?”

“Your Honour, do you have any reservations about my proposal?” Gao raised his head and confronted Hu, who did not answer. “As you’re probably aware, I’m the one who has put forward the proposal of using the land-conversion policy to rescue flood victims. Based on my idea, the wealthy silk merchants will be asked to barter for the farmers’ land with grain after the government runs out of supplies ten days later. Once the situation is stabilised, the merchants who have purchased the land will be asked to grow mulberry, rather than rice. I think the proposal is reasonable and practical, and it is the only option we have now, don’t you think?”

“But what price would you set for the land purchase?” Governor Hu asked.

Gao was taken aback. “As the saying goes, land changes hands from year to year in north and south,” he said. “Land transactions are based on market prices, and I personally do not think it should be the government’s responsibility to interfere.”

“But when farmers run out of food supplies at the end of ten days, they will be desperate and have to sell their land way below the market price,” Hu replied. “Don’t you think the government should intervene?”

“We have stringent laws,” said Gao. “If this happens, the Imperial Government would definitely intervene.”

“Which government agency are you talking about? The mayor’s yamen? The imperial inspector’s yamen or the civil affairs yamen or the Justice Department?”

By then, Gao felt that he had grasped what Hu was trying to get at.

“Are you implying that the Imperial Government in Zhejiang might be encouraging the wealthy merchants to take advantage of the flood and buy farmers’ land cheaply?” Gao asked.

Hu gazed into his eyes and asked, “If this is the case, what would you do then?”

Gao paused for a minute before answering, “I’ll fight them every inch of the way.”

“How would you fight them?”

Gao looked at Hu Zongxian and became speechless.

“If this happens, you cannot raid rich people’s homes and force them to distribute the rice that they have hoarded,” Hu continued. “Neither can you force farmers to sell the land on which their livelihoods depend at lower prices. In other words, you can’t use force on either side. If peasants rise up against the government, our province could be plunged into chaos. When that scenario occurs, it is likely that the proposal you have put forward to the Imperial Palace will be blamed for causing the chaos. I doubt this is what you originally intended.”

Shocked by the analysis, Gao quickly asked, “What should I do then? Please advise.”

“Since you proposed the strategy of using conversion to rescue flood victims, you should have the right to interpret the way you intended,” Hu counselled. “First, you should set a minimal land-transaction price, making it mandatory for silk merchants to buy up the land at no lower than one thousand five hundred kilograms of grain per mu. In this way, you would allow some farmers in Chun’an and Jiande Counties to keep their land. For example, a family may have three sons. The eldest can sell his share and will have enough grain to lend to his two brothers so they don’t have to sell theirs. If by next year, two-thirds of the farmers still have land to grow food, there wouldn’t be riots.”

Gao nodded in agreement. “But, if we encourage farmers to keep their land, how are we going to reach the land-conversion target and produce three hundred thousand bolts of silk?” he asked. “There wouldn’t be enough raw materials to go around. How do we resolve it then?”

“This land conversion itself is not a wise proposition,” sighed Hu. “It’s like cutting off flesh to cure a boil. At this point, we probably don’t have any choice but to do it. That’s actually my second point. We should also encourage the big silk merchants to buy land in counties outside the flooding zone, and they should pay the regular price of two thousand five hundred kilograms of rice per mu. If the land conversion is spread across the counties, the impact might not be as big, and we can probably prevent chaos.”

“What if the silk merchants refuse to pay high prices and buy land in other counties?” Gao asked.

“Then, you submit a report to His Majesty, requesting the Privy Council to come up with ideas,” Hu suggested. “Make sure you don’t propose anything.”

Gao looked befuddled.

“Do not worry,” Hu reassured him. “I won’t allow you to fight alone. You go to Zhejiang first. I’m going to Suzhou now to see if I can get a loan from Zhao Zhenji, who is the imperial inspector for Nanjing. I think I should be able to get us a loan in ten days. Once that’s done, you can go and fight the land purchase price with the big silk merchants. Besides, the newly appointed magistrates for Chun’an and Jiande Counties, Hai Rui and Wan Yongji, would be able to help you. You need to trust them and share the responsibilities with them.”

Following a long pause, a still-confused Gao ventured to ask, “Your Honour, I wonder if it’s appropriate to ask you a question.”

“Please go ahead.”

“Why didn’t you share what you just told me with His Majesty?”

“Sometimes, one doesn’t grasp the full implications of life’s difficulties until one experiences them,” Hu said, with a wry smile. “You’ll understand as time goes by.”

Hu took a glance outside and rose from his recliner chair. “It’s already past noon,” he said. “You have another forty kilometres to go before you reach your next inn. You should get going.”

Gao, who had by then let his guard down, fell on his knees and kowtowed before striding out of the room. “Your Honour, please take care of yourself,” he said.

Hu followed Gao out with his eyes. Suddenly, a fainting spell struck him. As he was trying to grab the recliner chair, he lost balance and fell to the floor. His aide, who happened to be outside, heard the plop and rushed in.

Tan Lun appeared at a side door and ordered, “Don’t touch him yet. Please go and get the doctor.” After the aide left, Hu opened his eyes and struggled to get up. Tan Lun lent him a hand and put him back on the recliner chair.

“It takes another three to four days to reach Suzhou,” Tan Lun said. “If you’re not up to it, we can stay here for a couple of days. You need more rest.”

“If we can’t get the loan and transport the grain to Zhejiang in ten days, what was the point of talking with Gao Hanwen then?” Hu said.

“Do you really think that Gao would heed your advice?” Tan Lun asked.

“Do you truly think that the two magistrates that you people have recommended, Hai Rui and Wang Yongji, would follow your advice?” Hu retorted.

Tan Lun knew that Governor Hu was upset that he had kept him in the dark about his discussions with the Prince of Yu regarding the appointment of Hai Rui as the magistrate of Chun’an.

“Nowadays, there’s no longer such a thing called friendship among officials,” Governor Hu sighed.

“Zongxian,” Tan Lun said, blushing with embarrassment. “I didn’t intend to hide it from you…”

“There is no need to explain,” Hu interrupted him. “As I said before, I would do what I have to do, regardless of whether you share the information with me or not. I’m just hoping that Gao would follow what I told him today. With Gao, and the two new magistrates that your people have appointed, we may have a chance to win the battle.”

Hu leaned on the arms of the recliner chair and stood up. “Get the carriage ready, and let’s go,” he ordered.

At dusk, Hai Rui reached Hangzhou. Walking on the blue-stoned streets at dusk, one felt like stepping into a painting, with green hills mirrored in the clear waters of the lake. Hai felt a bit out of place here. He led a big mule which carried his luggage and his bamboo basket, and he was wearing a long blue cotton robe with mud stains and a pair of straw sandals that revealed his big toes. The mule trod on the blue stones with weary steps, but Hai felt invigorated. The Zhejiang imperial inspector’s yamen was coming into view. Gradually, he saw a big flag pole and the gigantic wooden entrance.

The lanterns and torches in and outside the yamen illuminated the big characters Zhejiang Imperial Inspector, which were emblazoned in gold on a red plaque above the entrance. Within the bureaucracy, the imperial inspector used to hold the highest administrative position in a province. However, during Emperor Xuande’s rule, the governor’s position was elevated to the top. Even so, the imperial inspector still held more de facto power. Therefore, the layout for the inspector’s yamen was designed similarly to that of the governor’s – tall roofs, a grand entrance flanked on each side with a red wall, and a spacious public square with flagpoles. On this particular night, luxury sedans, specifically reserved for senior local officials, occupied the public square.

This was Zheng Bichang’s first meeting since his appointment as the imperial inspector of Zhejiang Province. Upon hearing that Gao Hanwen, the new mayor of Hangzhou, would arrive from Beijing that evening, he quickly summoned officials from different departments to devise strategies overnight on how to implement the land-conversion-and-flood-relief policy. Despite the challenges ahead, they had to convert five hundred thousand mu of rice paddies to mulberry fields within a month.

That explained why the area around the imperial inspector’s yamen had been blocked off since mid-afternoon. Stores on nearby streets had closed. When Hai and his mule plodded towards the yamen, it was eerily quiet, and the sound of the footsteps of Hai and his mule broke the silence as if the steps were distant thunder.

“Stop there,” a guard shouted at Hai when he was a few feet away from the yamen. “Can’t you see this is the imperial inspector’s yamen?”

Hai stopped and took out from his pocket the appointment letter from the Ministry of Personnel. The guard was illiterate, but his attitude softened when he saw the big red imperial stamp on the letter. “Which yamen do you belong to?”

“I’m the magistrate of Chun’an.”

The guard eyed him with suspicion. “Does anyone know if the magistrate of Chun’an has been invited to attend tonight’s meeting?” he shouted to a scholarly-looking person by the entrance.

“Let him in,” the man replied.

The guard returned the appointment letter to Hai. “You can go in, but not your mule,” he said.

Hai paused for a second before tossing the rein to the guard and then marched into the yamen.

“Hey, why do you leave the mule to me?” the guard yelled.

By then, Hai had already disappeared behind the screen wall. It was 1561, the fortieth year under the reign of Emperor Jiajing. Hai was appointed the magistrate of Chun’an County in Zhejiang Province. The moment he walked into the capital city of Zhejiang Province and marched into the imperial inspector’s yamen to report for work, he began a new chapter in life, declaring war against the corrupted forces within the Ming government. He was on a path of no return.

6

The imperial inspector’s yamen was so enormous that it was equipped with two rooms for visitors, one on each side of the entrance with different services. Those who maintained a perch high up on the hierarchy were normally ushered into the one on the left, while the right-side one was reserved for lower-level officials.

Upon learning about Hai’s official title, the greeter led the new magistrate into the room on the right, a Spartan space with two rows of benches against the wall. “Take a seat here first,” said the greeter before he turned on his heel and walked away. “When your name is called, I’ll come to get you.”

Having waited outside in the well-lit public square, Hai found it hard for his eyes to adjust to the dim light in the visitors’ room. After sitting a few minutes, he noticed another man was also seated inside, eyeing Hai with curiosity.

The man stood up and introduced himself. “It is an honour to meet you here. I’m Wang Yongji, the newly appointed Jiande magistrate.”

Hai quickly rose and greeted Wang. “It is my honour as well. I’m Hai Rui, the new magistrate of Chun’an County.”

“Your reputation precedes you,” Wang said. “I’ve read your articles and heard a story about how you refused to kowtow to a corrupt local official.”

“I’m truly flattered,” Hai replied. “What is the proper way to address you?”

“Call me Yongji. Tan Lun is my former classmate and a good friend,” Wang said.

The mention of their mutual friend, Tan Lun, brought them closer. “Did Tan Lun recommend you for this position?” Hai asked.

“Oh, not quite,” Wang explained. “I served as the magistrate of Kunshan County for years, and it was quite a cushy job. But Tan Lun captured me and insists that I come and work here. You know how persuasive he can be. After a few correspondences, he just had me under his spell.”

Fascinated by his story, Hai said, “Your transfer from Kunshan is truly a blessing for the people of Jiande County.”

“Chun’an is beset with more challenges,” Wang said reverentially. “With you taking the lead, I feel much better. I’ll try my best to follow you.”

As the conversation progressed, Wang noticed that Hai looked a bit worn out. “Did you just arrive in the city?” he asked.

“Yes. I was on the road for five days and got here before dusk.”

“Have you had supper yet?”

Hai shook his head.

Wang got up and said, “Let me go and see if I can scrounge up some food for you.”

Hai stopped him. “There is no need. This is not the proper place.”

Untying his luggage, Hai Rui brought out a piece of dry rice cake. “I’ve got food here,” he said while removing the lotus leaves. Watching Hai taking a big bite of the rice cake, Wang was filled with the sense that knowing a person by repute is not as good as seeing him in the flesh. He stood up and walked over to grab a warm teapot from a table, trying to serve his new friend, but the teapot was empty.

At this point, Gao Hanwen also arrived. Seeing the flaming torches and the sedans sitting in the public square, he ordered his entourage to stop. “I’ll only need two guards to wait for me here, and the rest can report to the mayor’s yamen,” he said.

Alighting from his carriage, he walked towards the imperial inspector’s yamen alone. A guard, who had questioned Hai before, had learned to be more tactful with people in civilian clothing. Instead of shooing away Gao, as he normally would, he accosted him by asking, “Which county do you represent?” Gao handed him an appointment letter. Taking a quick glance at the big red stamp, he said, “Please go ahead.”

Strangely, nobody greeted him at the entrance. As he was waiting, he saw a receptionist yelling at Wang Yongji, who was holding the empty teapot.

“I’ve told you that it is not my job to get water for you,” he said impatiently. “Why don’t you wait until you’re called to the meeting. They’ll serve you tea inside.”

“May I ask…” Gao stepped up and asked.

The receptionist glanced at him and interrupted, “Which county are you from?”

Repressing his disgust and anger at the receptionist’s behaviour, Gao asked, “Are all of the county officials waiting here?”

“Yes,” said the receptionist. “Sit down and wait.”

“What about the two magistrates from Chun’an and Jiande? Are they here?” Gao asked.

“He’s there,” the receptionist pointed to Wang with his eyes and left.

Wang was about to bow and greet Gao when he saw the newcomer caught up with the receptionist. “Sorry to bother you, but could you get us a pot of tea?” Wang pleaded.

“What happened to you people…” the receptionist glared at Gao.

Removing a piece of decorative jade from his belt, Gao placed it in the receptionist’s hand. The receptionist shifted his gaze from the jade to Gao, and his face softened. “All right, give me a few minutes,” he said. Accepting the jade from Gao and snatching the teapot from Wang, he stepped out.

“I am Wang Yongji, the new magistrate of Jiande.” Wang bowed as they retreated into the waiting room. “And you?”

“It doesn’t matter who I am,” Gao said, waving his hand in modesty. “The two of you have a big task ahead. The devastating flood struck most of Chun’an. Half of Jiande was also affected. I wonder what your views are relating to the Imperial Palace’s strategy of using land conversion to help with disaster relief? How can we implement it?”

“It’s not an easy task,” Wang replied. Hai ignored Gao and continued munching on his dried rice cakes.

“Why is that?” Gao asked. “I want to hear more.”

From his demeanour and the questions he raised, Wang figured that the newcomer was likely to be their new boss, Gao Hanwen. Seeing that Gao was reluctant to reveal his identity, Wang did not probe further. Instead, he turned to Hai Rui.

“Your Honour should probably get your answers from the new Hangzhou mayor,” Hai said indifferently.

Gao was shocked at Hai’s sarcasm. Wang also attempted to make eye contact with Hai Rui, signalling for him to show some courtesy, but Hai paid no heed. Putting a piece of unfinished rice cake on his chair, he stood up and continued, “I hear that the new mayor of Hangzhou has come up with the idea of disaster relief through rice-to-mulberry land conversion. Based on his reasoning, the conversion programme would be accomplished if farmers in Chun’an and Jiande Counties sell their land on the cheap. In this way, the wealthy silk merchants could make a big killing on this, and officials in Zhejiang can obtain their deserved promotions. But nobody cares to ask what would happen next year. When farmers run out of food and have no land to farm, starvation would occur. By then, it would be time for us two magistrates to be fired. So I wonder if the new mayor of Hangzhou intends to see this outcome from his new initiative.”

Surprised by the vehement response to his policy initiative, Gao Hanwen fixed his eyes on Hai, wondering if the new magistrate had discovered his identity. Wang Yongji, helpless because he was unable to stop Hai, cast his eyes down on the floor.

“Do you really think that the disaster-relief-through-conversion initiative could lead to starvation in your two counties?” Gao asked.

“It won’t happen this year, of course,” Hai replied. “The silk merchants have stored enough grain, and they’re willing to buy flooded farmland at four hundred or at most five hundred kilograms per mu. The grain that farmers get from the land sale can probably last them a year or so.”

“How do you know that the Imperial Palace will allow those wealthy landowners to purchase land at such cheap prices?” asked Gao.

“I don’t,” Hai said. “That’s why I’m going to consult with the new mayor. When land conversion becomes a priority, the government refuses to give out loans to flood victims. Instead, it encourages farmers to sell their land. Imagine if your family is affected by flood and you have nothing to eat, would you sell your land at four or five hundred kilograms per mu?”

The argument seemed to chime with Governor Hu’s words. Gao Hanwen did not answer. Fearful that Gao could take offence at Hai’s fiery rhetoric, Wang Yongji had attempted to bow to his new boss and interrupt the conversation, but he resisted the urge because he did not feel it appropriate. In the end, the three of them simply stood there, falling into an awkward silence.

Fortunately, the tea arrived. The receptionist even brought three clean cups. “Please forgive us,” he said while pouring. “The yamen is getting bigger, and there are too many idlers around. Take today for example – a fair number of big shots are here, but the people who work in the kitchen and tea room are playing cards. Nobody bothers to tell me where they store the tea leaves. Fortunately, I have some fresh dragon-well tea leaves in my bag. It’s fresh and tastes good. I know that it’s a trying time for you. Enjoy the tea.”

To his surprise, none of his visitors stepped up to take the tea.

“I’m not going to drink it because it’s not clean,” Hai protested before sitting down to finish the rest of his rice cake.

Assuming that the three visitors had been complaining about him all this time, the receptionist glared at Hai. “Are you here for your appointment, or to find fault with me?” he spouted. “Let me be clear – this is the imperial inspector’s yamen.”

Hai Rui looked the receptionist in the eye. “I know it’s the imperial inspector’s yamen. Do we have to bribe someone for a cup of tea here?”

“You… you’re…” The receptionist choked on his own words.

“Our discussion here had nothing to do with you,” Gao intervened. “You can go now.”

At this moment, an official appeared at the door. “Do you know if Mayor Gao has arrived?” he asked the receptionist.

“Let me go and find out,” he said. Before leaving, he glanced at Hai and mumbled, “Full of nonsense.”

“There is no need to ask about,” Gao said. “I am the new mayor.”

The receptionist stopped, as if his feet had been nailed to the floor.

“Your Honour, we didn’t realise that you’re already here,” the official said apologetically. “Please… everyone is waiting for you.”

“Could you tell the imperial inspector that we’ll be there shortly?” Gao said.

“Sure, but please hurry up,” the official said before striding away.

Gao Hanwen turned to his two magistrates. Wang was about to conduct the fist and palm salute when Gao stopped him. “It doesn’t matter whether you recognised me or not,” he said. “I’m glad to hear Magistrate Hai’s honest view on the land-conversion policy. As he said, it’s very important that we don’t plunge ordinary farmers into misery. I know that you care about your people, and I just hope that you can back me up during the meeting. Let’s go.”

After Gao stepped away, Wang and Hai exchanged guilty glances. At the same time, the receptionist suddenly came to his senses. He reached into his pocket and brought out the jade. “Please wait,” the receptionist called out to Gao.

As Hai rose slowly from his chair, Wang advised, “We have a lot to do, but we need to pace ourselves.”

“But if folks in Chun’an and Jiande are starving, do you think you and I can walk out of here alive?” Hai said before marching out.

Wang followed Hai out with a solemn expression.

The conference hall was packed with officials in red and purple robes, who sat behind two rows of desks on the left and right sides of the room as they waited for Gao’s arrival. Bored and impatient, two officials sitting next to each other were toying with a fine porcelain tea set produced by pottery mills inside the Forbidden City. Another pair was poring over a new opera aria, hand-copied on a sheet of paper, and at times crooning while tapping out the rhythm with their fingertips. The imperial inspector, Zheng Bichang, hunched over a large desk in the middle, waited quietly, with his eyes closed.

“Hey, hey,” Ho Maocai, the director of justice howled with a look of annoyance. “Could you people act a bit more professionally? This is not an opera house or an antique market.”

Silence fell. The officials sat up straight and put on a serious look.

“By the way, I was told that some farmers in Chun’an and Jiande are instigating trouble by stopping others from selling their land,” he continued. “Are you aware that some families are banding together to scrounge up silk and silkworms so they can buy rice? In this way, they don’t have to sell their land.”

“We’re closely monitoring the situation,” responded the official who was playing with his teacup. “We have spotted a dozen boats lingering along the river in these two counties, waiting to buy rice from merchants. I think they’re negotiating the price now. After they conclude the transactions, we’ll detain them.”

Zheng Bichang opened his eyes and commented, “We need to control the rice market. We want to make sure that the transactions don’t sabotage the rice-to-mulberry conversion. Those who secretly sell rice to flood victims should be arrested on charges of disrupting the implementation of a national policy.”

“Understood,” the official replied. “We will confiscate everything and arrest both the sellers and buyers.”

“That’s good,” Ho Maocai said. At this point, an official rushed in and whispered in Ho’s ears.

“The mayor from the Hanlin Academy has finally arrived,” Ho announced with a hint of impatience.

Before he even finished, Gao marched in. Hai Rui and Wang Yongji paused at the entrance. Seeing that Zheng Bichang had risen from his chair, the others stood up reluctantly.

“Your Honours, I apologise for keeping everyone waiting,” Gao said. “The trip has been arduous.”

“I totally understand,” Zheng Bichang said with a smile. “It is not easy to compress a month-long trip into fifteen days. Please take a seat.”

Gao was given a centre seat, next to Ho Maocai. For a mere mayor, the seat arrangement seemed to have violated the basic imperial etiquette. Zheng Bichang’s intention was obvious: Gao was selected by Yan Shifan, the grand secretary junior, and the preferential seat arrangement for Gao reflected Zheng’s respect for Yan. More importantly, Gao authored the disaster-relief-through-land-conversion strategy. If Zheng could secure Gao’s full endorsement of the land-acquisition plan he and the South China Textile Bureau had formulated, it would make things much easier. Within a month or so, the programme could conclude swiftly and successfully.

As part of the protocol, Gao should have thanked the organiser and politely declined the seat with official jargon such as “I wouldn’t dare take the seat” or “I don’t deserve the seat”. Then, others would stand to flatter him, insisting that he should take the seat. He, in turn, would then bow to Zheng in gratitude before sitting down. Finally, he would sign off on whatever plan his peers had devised and promise to implement it the next day.

On the contrary, Gao did not follow the protocol at all. Instead of politely declining the seat, Gao walked over and sat down, as if he deserved it. Worse, he did not even bow to Ho Maocai and the other senior officials, who looked displeased but resisted the urge to chastise him. After all, they needed Gao to implement their plan.

Once Gao was seated, he noticed that Hai Rui and Wang Yongji were still standing by the door, like two pens stuck in a holder. Gao rose and requested, “Your Honour, could you arrange two seats for two of my county chiefs?”

“We never invite county officials to provincial meetings,” Ho Maocai said dismissively. “There is no such precedent. Their job is to implement whatever we have decided.”

Then, he paused and motioned for Hai and Wang to leave. Wang was about to leave when he saw, through a quick glimpse, that Hai was planting his feet squarely on the ground, glaring at Ho Maocai. He decided to stick with Hai.

When Ho looked up and noticed Hai’s cold stare, which lit up like two beams of dazzling light, he felt a cold shudder travelling down his spine. He wondered: What is going on today? The new mayor, who has kept everyone waiting for hours, turns out to be an insolent bookworm. Now, a menial magistrate is giving his superior such an icy menacing stare.

Ho Maocai was not the only one who felt the chill. Zheng Bichang experienced it too, and so did others. Given his senior position, not to mention the fact that he was in charge of all of the criminal investigations in the province, Ho felt that he had to put this rookie in his place. Adopting an air of authority, he asked in a harsh tone, “Did you hear what I just said?”

Gao decided to intervene. “The whole county of Chun’an has been flooded, and half of Jiande County is also affected by the disaster,” he stated. “Our plan to convert rice paddies into mulberry fields concerns the lives of several hundred thousand farmers. If we want the magistrates to implement the plan, we need their input so we can do it in a proper way. That’s why I have invited them to our meeting.”

Gao’s remarks infuriated Ho so much that he couldn’t breathe. As he turned around to vent his fury, he caught sight of Zheng Bichang’s stern look signalling him to stop.

“Set two chairs and bring two cups of tea for the county chiefs,” Zheng Bichang announced.

Two of Zheng’s aides carried two benches into the room, placing one on the left and another on the right. Hai chose the left bench while Wang sat on the right. Then, the receptionist came in with a tea tray. First, he went up to Gao and raised the tray – the cups were arranged in the shape of a triangle, with one cup facing Gao and the other two closer to the receptionist. Gao picked up the cup near him, and, as he was planning to put it down on the desk, he was puzzled that the receptionist still held the tray in front of him. Then, he noticed the jade that he had used to bribe the receptionist earlier was hidden underneath the cup. A smile flickered around the corner of his mouth. He used his other hand to pick up the jade from the tray and then held the teacup with both hands. Nobody took note of it. Grateful that Gao had handled it subtly without a hint of blame, the receptionist gave an awkward smile. He took the tray to Hai and Wang, placing their tea on the vacant end of their benches.

Clearing his throat, Zheng declared, “Let’s start.”

The conference hall quietened down.

“I assume that you have been briefed on the situation in Zhejiang,” Zheng addressed Gao. “The Imperial Palace has sent us an express letter, outlining your proposal to use our land-conversion programme to assist with the disaster relief efforts. All of my colleagues here are impressed with your talent, and we’re in full support of your idea. For the past several days, we have deliberated your proposal and finalised a specific plan. Please take a few minutes to review it. Once you sign off on it, we’ll start implementing it tomorrow.”

Zheng motioned his secretary to distribute copies of the plan to Gao Hanwen and the two new magistrates, all of whom began reading it earnestly. The so-called plan was nothing more than a one-pager, which listed in two hundred words a summary of six actionable decisions. Zheng and the other officials looked down at their desks, waiting. It was widely anticipated that the new mayor would applaud the items of action listed and give his written authorisation. Once the plan gained approval from attendees, the two new magistrates would pledge to accept the plan on the spot and start implementing it the next day.

Gao Hanwen and his two magistrates finished simultaneously. Hai stood up, and all eyes fixed on him. But, before he had the chance to speak, Gao rose and stopped him. “Magistrate Hai, please sit down first,” he said.

From the glint in Gao’s eyes, Hai knew that Gao’s order was well-intentioned. He paused and then sat down. Meanwhile, Zheng, the imperial inspector, turned to Gao. “I assume that you have no objections to the plan,” he said.

“I do!” Gao Hanwen replied; his voice, though soft, resonated in the room, taking everyone by surprise. “This plan contradicts the spirit of the Imperial Palace’s strategy of using land conversion to support disaster relief.”

Zheng’s face fell. The others looked baffled by the unexpected turn of events. Hai’s eyes sparked with expectation.

Zheng suppressed his anger and demanded an explanation in a harsh tone. “Please tell us which part you do not like.”

“The current plan only reflects the first part of the Imperial Palace’s strategy, but not the second half,” Gao replied emphatically.

“Excuse me, this is not the Hanlin Academy,” Ho blurted out in frustration. “Don’t be too scholarly. Please clarify in simple terms what you are trying to convey.”

“All right,” Gao organised his thoughts and began. “A couple of days ago, someone confronted me with a question, which I found hard to answer – if farmers in Chun’an and Jiande Counties sell their land cheaply and survive the flood with the grain from their land sales, how are they going to support themselves next year or the year after?” Gao paused for a second and exchanged glances with Hai before continuing. “Initially, I took offence at the question. As the saying goes, land changes hands from year to year in north and south. There is no such thing as permanent land ownership. By allowing the wealthy silk merchants to first buy up land from flood victims and then grow mulberry on the land they have purchased, we hope to achieve financial gains for the palace and help flood victims at the same time. My original intent was to make this a win-win situation for both the country and for individual farmers. But a quick look at this plan makes me think twice about what I have proposed earlier. If we approve and implement this plan, farmers in Chun’an and Jiande Counties would have nothing to live on next year. A single focus of this plan is to help big silk merchants buy up the farmland and accelerate the pace of rice-to-mulberry conversion. There is not a single mention of how to prevent silk merchants from exploiting the flood situation and fixing the land prices. Your Honour, what if the silk merchants decide to lower the land prices to five hundred kilograms of rice per mu or even four hundred kilograms per mu? Should farmers sell their land or not? Should the government intervene? My initial proposal was to accommodate both our national priorities and the livelihood of ordinary farmers. If we don’t intervene, we will bring misery to ordinary people, who could be forced to rebel against the government. If we don’t resolve it, this plan could lead to chaos and costly trouble.”

While Gao’s tirade shocked the bureaucrats at the conference, it captivated Hai and Wang, who looked at Gao with admiration, agreement and support.

Regardless of the attendees’ negative reaction, Gao continued to address his concerns. “Therefore, I believe that the imperial inspector and other senior officials in attendance today should reconsider the plan.”

When Gao finished and sat down, there was total silence.

Zheng did not anticipate what he disdainfully characterised as high-sounding remarks from the new mayor, which almost amounted to an open challenge to him personally and to the government of Zhejiang. This was something that he could never tolerate. On the other hand, since Gao was the author of the proposal to offer disaster relief through land conversion and it had won the approval of the Imperial Palace, one had to take his interpretation seriously. However, if this person was recommended by the grand secretary’s son, how could he be vehemently opposed to the plan? Why hadn’t the grand secretary’s son briefed him beforehand?

Baffled and lost, Zheng looked to Ho for clues, but Ho seemed as clueless as he was.

In fact, Yan Shifan, the grand secretary junior, had other considerations when he and his advisers handpicked Gao and sent him to Zhejiang at this critical juncture. Even though the government yamen in Zhejiang was staffed with people he trusted, Yan Shifan felt they had become complacent and corrupt after serving in the government for too long a time, to the point of being disloyal. In meetings and correspondence, officials there appeared compliant and even obsequious, but, when it came to action, they always put their own interests ahead of that of the Imperial Palace. In other words, they were mercenary, and Yan knew that very well. But he had no intention of beating them too hard. As the saying goes, when you drop a piece of soft tofu on a dusty floor, you can only pat it lightly to remove the dust. If you hit it too hard, the tofu could be crushed to pieces.

This dilemma had been plaguing Yan Shifan for several years. With the severe floods in Zhejiang and the pending implementation of the land-conversion policy, Yan became worried that those avaricious bureaucrats could mangle the situation if left to their own devices. After careful consideration, he settled on Gao Hanwen, a Confucian scholar with a clean record who also expressed firm support for the land-conversion policy. He hoped that Gao could restrain the powers of local officials, making sure they did not stray too far.

However, Yan Shifan had not anticipated that his protégé would “accidentally” run into Governor Hu on his way to Hangzhou. Their private conversation had profoundly changed Gao’s views, leading to his fierce clash with his superiors in Zhejiang upon his immediate arrival in the city of Hangzhou.

The new mayor’s vocal opposition to the land-conversion plan took Zheng by surprise. He felt he had to bite the bullet and put the newcomer in his place before more damage was done.

Zheng eyed Ho, who recollected himself and began his line of questioning. “Land transactions are conducted between sellers and buyers,” Ho said to Gao. “Why does the government need to intervene?”

“If the transactions are conducted fairly – I mean if the land is sold at a fair price – the government has of course no reason to interfere,” Gao replied.

“What do you mean by ‘fair price’?”

“In a good year, a mu of land is bartered with three thousand kilograms of rice, and in a bad year it should be twenty-five hundred kilograms of rice. At the moment, even though Chun’an and Jiande Counties have been struck with terrible floods, the price for a mu of land should not be lower than fifteen hundred kilograms of rice.”

Ho uttered an incredulous gasp. “If farmers sell their land at the price of fifteen hundred kilograms of rice, the local silk merchants wouldn’t be able to buy up fifty thousand mu of land in Chun’an and Jiande counties to grow mulberry,” he blurted out, revealing the unspoken motive that Zheng and others had tried to cover up. “There is no way we can fulfil the quotas of three hundred thousand bolts of silk for export.”

Gao jumped at the slip. “I don’t understand why we only target farmland in these two flooded counties for conversion? What about the farmland in other counties that have not been affected by the flood?”

“In those non-flooded counties, a mu of land can fetch at least three thousand kilograms of rice,” Ho admitted. “Who would buy it?”

“If growing mulberry is more lucrative than planting rice, why wouldn’t they buy it?” Gao asked.

Ho was speechless. His face turned pale and grim, frozen and immobile like that of a corpse. It finally dawned on him that Gao’s arrival meant that they could lose an important source of revenue and profit. Regardless of Gao’s connections with the grand secretary junior, Ho decided that he had to take the political risk and defeat Gao. There was no way he would allow a subordinate, a new transplant, to disrupt a well-established plan. “You can restrict the purchase in these two flooded counties, but the government’s disaster relief grain can only last five days or so,” he pointed out, his voice quavering. “If the land buyers don’t make any purchases five days later, starvation could occur. If this happens, who is taking responsibility for it?”

“If it happens, the Imperial Palace would make a fair judgement on whose fault it would be,” Gao persisted.

“How dare you utter such a presumptuous statement?” Ho yelled. Smacking his fist on the desk, Ho rose and turned to Zheng. “Your Honour, this mayor is acting impudently in front of his superiors,” he accused. “This is not only a blatant breach of etiquette but also a violation of ethical standards. Our empire has laws and rules governing this type of behaviour. Aren’t you going to report him to the Imperial Palace and have him censured?”

“There’s no need to censure me,” Gao said calmly. “I can submit my resignation if you think it appropriate.”

Once again, Ho found himself at a loss for words. Zheng was also fumbling for an answer.

Hai Rui stood up abruptly to offer his resignation. “I’m also requesting to be dismissed from my position.”

“Given the challenges of implementing this plan, I’m also asking to be removed from my position,” said Wang Yongji.

The situation was threatening to get out of control. Three new officials appointed by the Ministry of Personnel had just offered to resign before they even began. Zheng felt that his hands were tied. Even if he was authorised by the Imperial Palace to fire those new political hires, he lacked the nerve to act on it.

Another deadly silence followed. All eyes turned to Zheng, who finally rose slowly from his chair. “Since we are convening today to review and discuss this plan, we certainly must allow free discussions and different viewpoints,” he said, trying to pacify all sides. “Besides, since we rely on the mayor and the county chiefs to implement the plan, we have to make sure they are on board with us. However, the three of you are still new to the region and may not be aware of certain thorny and complicated issues, which are specific to the region. For example, how much land do we need in order to fulfil the export order of five hundred thousand bolts of silk? How much rice can we secure from the market and private suppliers to subsidise flood victims? At what price are big silk mill owners willing to pay for the farmland? These are tough issues. I want to put forward a suggestion. Why don’t the three of you go around the counties tomorrow and get some first-hand insight? We’ll reconvene here and resume our discussion the day after tomorrow.”

Ho waved his hand and declared, “All right then, the meeting is adjourned.” His face was contorted in disgust and anger, and he raced out the door before the other officials had the chance to ask questions.

Half an hour later, Zheng Bichang and Ho Maocai showed up in the spacious visitors’ room next to Shen Yishi’s silk mill. Upon hearing that Shen was not available, Ho burst into an angry rant. “Go and find him,” he taunted Shen’s servants. “Wherever he is, go and find him before I break your legs. Tell your master that he will have to pay two thousand kilograms of rice for a mu of land if he doesn’t come to see us quickly.”

Shen’s personal aide stood there helplessly with his hands hanging at his sides. “Sir, I can try, but it’s quite late, and my master hasn’t told us where he has gone,” he said. “What if I can’t find him right away? I hate to keep you waiting…”

“Don’t worry – we do not mind waiting,” Zheng reassured him. “Go and find him.”

The servant went reluctantly. Ho plopped down on a chair, fuming. “I still cannot figure out what the grand secretary’s son is playing at? They have many options, so why send a troublemaker? What are they thinking? Besides, what’s happening with Yang Gonggong? Does he know that his own backyard is on fire? When is he returning from Beijing? If he doesn’t care, why should we? Why don’t we just rescind the land-conversion policy? Let the South China Textile Bureau handle the export orders. They can find another source to produce an extra three hundred thousand bolts of silk.”

Zheng had toyed with different solutions, but none satisfied him. He saw himself as the helmsman for Zhejiang Province, and, when a storm arose out of nowhere, he had a lot to reckon with; the situation put him in a bad mood. Therefore, when Ho let loose on him during his uncontrollable rant, he became incensed. “I hope you can stop it here,” he castigated. “What did you mean by saying we should rescind the land-conversion policy or ask the Textile Bureau to handle the export order? If you’re that gutsy, why don’t you write to the grand secretary directly and put down what you just said in the report? Or, you can tell Yang Gonggong in person when he returns.”

Ho Maocai’s eyes widened, and his face flushed red with poorly suppressed anger.

“You and I have worked together in Zhejiang for years, and I have always treated you like a confidant,” Zheng cajoled with a soft tone. “When something bad happens, you have to learn how to hold back and act calmly. I’m the imperial inspector, and you’re in charge of the Justice Department. In this region, you and I are considered senior ranking officials. But if we mess up this deal and offend the Imperial Palace, our punishment wouldn’t be any different from that of Ma Ningyuan.”

Even though Ho was nursing a grievance, he held back. After all, Zheng was his superior and the captain of this ship. Ho simply sat there, sulking. But soon, his temper got the better of him again. He rose and dashed to the door. “Where the hell is your master?” he yelled at Shen’s assistant. “Does he still want to buy land or not? Where are the servants? Are they all dead or what? Why can’t they send more people to look for him?”

With a dour expression, Zheng shook his head helplessly.

Actually, Shen’s personal aide knew his master’s whereabouts – Shen was staying the night at a secret courtyard house next to his residence. Since Shen had specifically requested that nobody disturb him, the aide wouldn’t dare burst into the house as he normally did when something urgent was happening. Quietly opening the door to Shen’s secret sanctuary, the aide paused, trying to figure out an unobtrusive way to notify his master. The yard stood very quiet. He could hear faint music floating out of a room in the back.

The big room, inconceivably unique in the city of Hangzhou or in the whole country at that time, served as a music studio. Fifty-five feet deep and one hundred feet wide, it covered an area as big as the Palace of Heavenly Purity inside the Forbidden City. To hide it from government officials or curious onlookers walking past the courtyard, the room only stood twenty-two feet high. The inside walls were covered from top to bottom with pieces of one-by-two-inch sandalwood panels, a feature that was absent in the Palace of Heavenly Purity. Shen left the large space in the middle unfurnished. Rows of clothes racks made of ebony wood lined the walls on the south, north and west. On each rack hung a dozen women’s silk dresses, in various colours, styles and fabrics. On the east side stood a large, eleven-foot-long by eleven-foot-wide wooden platform bed. A short mahogany music stand was placed in the middle of the bed. Shen, dressed in his usual blue cloth robe and with his long hair hanging loose over his shoulder, sat cross-legged behind the music stand on the bed, playing the guqin. Wisps of smoke from incense burners wafted around the bed past his gaunt face, which, in the dim light, seemed pale. His long slender fingers plucked at the strings, and, from a distance, they seemed to be dancing back and forth on the guqin. A beautiful melody seeped from those fingers.

In another part of the room, a flowing silk dress, thin and transparent as cicada wings, suddenly came alive, gliding away from the clothes rack and into the middle. Shen’s eyes sparkled, and his fingers moved wildly. As the music began to crescendo, the dress swirled around, revealing, in a dreamlike sequence, the tall willowy body of a young woman, her long jet-black hair floating in the air. Suddenly, both the music and the dance came to an abrupt halt. One could see that the lovely face belonged to Madam Yun.

Shen picked up a flute next to the guqin and started playing. The soft gentle tune sounded like a woman’s weeping. An air of melancholy filled the room, and Shen’s eyes exuded sadness. Madam Yun stopped her dizzying dance, and her long sleeves fell onto the floor like feathers. “You and I fly side by side, like wild geese; and we traverse the sky like dragon and phoenix,” crooned Madam Yun. “A wrecking storm broke us apart; each is yearning for the love of the other…”

Shen put down his flute with a long sigh. Madam Yun also paused, tears glistening in her eyes. Moving slowly towards Shen, she climbed onto the platform bed and snuggled next to him, gently touching his hair. But when Madam Yun gazed into his eyes, he looked away. “Before he died, Li Xuan claimed to the guards that you had made his death worthwhile,” he said, grabbing her wrist and pushing it gently away. “What did you do to make his death so worthy?”

The colour drained from Madam Yun’s face.

“I spent twenty thousand taels of silver getting you out of the whorehouse,” Shen continued, without looking at her. “The fact that you can make a eunuch so madly in love with you shows I’ve certainly got my money’s worth.”

Tears welled up in Madam Yun’s eyes; before they streamed down her powdered face, she wiped her eyes, rose and got off the bed. Then, she removed her long silk robe and changed into her everyday clothing. Shen sat there motionless.

As Madam Yun was walking towards the door, Shen spoke up. “Where are you going?”

“To be with the eunuchs at the Textile Bureau,” she replied, coldly.

“Do you know that Yang Jinshui’s appointment at the South China Textile Bureau will expire in a year?”

Madam Yun turned her head and said, “Of course, I know. You gifted me to him when I was seventeen. Since then, I’ve been counting with my fingers every day. As of today, I’ve been serving him on your behalf for one thousand five hundred days. When he returns to Beijing next year, you can send me to a convent, if you still allow me to live.” She could see hate and murder in Shen’s eyes.

“What about your mother and your siblings?” Shen said, his voice was sharp and cold like a dagger. “Do they have to go to the convent with you as well?”

Madam Yun stood there, her body shaking

“Do you see this string over here?” Shen pointed at his guqin; his voice had calmed down a bit and did not sound as murderous as before.

Madam Yun shifted her gaze to the instrument in Shen’s long slender fingers. Shen pulled hard at the string. Bam it was broken. Madam Yun winced involuntarily.

“From now on, I won’t touch that body of yours,” Shen vowed, without looking at her. “But I do have a request. Show me what you did to Li Xuan that night. Do it again right here.”

“You really want to see it?” Madam Yun asked; her voice turned equally icy, and her eyes glistened.

“I want you to re-enact it for me,” Shen repeated, looking up at the ceiling. “It’s up to me to decide whether to watch it or not.”

“I can’t do that,” Madam Yun replied, her eyes cast downward.

“Is it because what you did was too cheap and disgusting?” asked Shen, his voice filled with contempt.

“Yes, I am cheap and disgusting.”

“Then go ahead and show it to me,” Shen demanded.

“I can’t,” Madam Yun said. “It involved two people. How can I do it alone? If you truly want to find out how cheap and disgusting I was, why don’t you try, for once in your life, and play Li Xuan’s part?”

Shen didn’t expect that Madam Yun would mock him like that. Grabbing the guqin with his cigarette-thin fingers, he smashed it on the floor. The precious instrument bounced around, and the strings broke with a snap. Two remaining strings boomed with vibrations, followed by total silence.

Then, there was a soft tap on the door. “Master,” called the personal aide in his timid voice.

“What is it?” Shen shouted without opening the door.

“Master, Mr Ho and Mr Zheng are waiting for you in the visitors’ room…” the aide replied in his trembling voice. “They want to discuss with you the farmland purchase… There seem to be some changes…”

“Tell them if they want to make a fortune, they can buy the farmland themselves,” Shen yelled. “Get out of my courtyard.”

Silence resumed outside.

Having vented his frustration, Shen slumped into the bed, his face as white as the fine sheets. Then, he jumped off the bed and moved, with his socked feet, towards Madam Yun.

“Did you ask me to imitate Li Xuan, the eunuch?” he asked.

Madam Yun, who could feel his heavy breath on her face, was unusually calm. “You won’t be able to,” she replied softly. The tears in her eyes had dried up.

“What if I really want to?” Shen said, pursing his mouth in a creepy smirk. “Show me what he did to you.”

Madam Yun shook her head slightly and said, “I’ve already told you that you’re not capable of doing it. Li Xuan treated me like a fairy, and you see me as a disgusting whore. How can you imitate him?”

Her remarks shamed Shen into silence. Raising her head to face the ceiling, as if she were watching a replay of the scene with Li Xuan before his execution, Madam Yun recounted, in her calm voice, “I was sitting on the bed while he sat on the floor. He wept while drinking one cup of liquor after another. For hours, he wouldn’t even dare look at me. Finally, he became so intoxicated that he fell asleep on the floor. I went down and took him in my arm. His head reclined on my bosom. Before dawn, the eunuchs at the Textile Bureau came to get him. Since he was still drunk, they poured cold water over his head to sober him up. Then, he was dragged to the execution ground. So, if you are willing to get yourself drunk, weep in front of me and lie down on the floor, I promise I will put your head in my bosom and keep you company until tomorrow morning.”

Shen was dumbfounded. The coldness in his eyes gradually melted. Looking apologetic and sympathetic, he stretched a hand out to take Madam Yun’s.

“Don’t touch me,” Madam Yun said, pulling her hand back. “Didn’t you just say that you won’t touch me again?”

Shen had never experienced such rejection from a woman. The fleeting apologetic and sympathetic feeling was taken over by embarrassment and his inborn arrogance. He felt as if he had been nailed onto the floor.

“Since you paid money to get me, my life is yours,” Madam Yun said. “But you can’t touch my body in the future. You have an inexhaustible supply of money, and, in this city, you have an endless supply of prostitutes who are willing to service you.”

“Good,” Shen was at a loss for words. “You’re right.”

Without putting on his shoes, he dashed over to the door in his socked feet. Before he opened the door, he mumbled without turning his head, “It is true that I have a lot of money and that I have an endless supply of prostitutes to give me pleasure. In fact, I’m going to spend my money on them now. Since I’m the owner of your life, I want you to stay here until Yang Gonggong comes back. Let me tell you something. The day when I paid money to purchase you, I no longer saw you as a fairy or even a virtuous woman. You’re nothing but a hussy.”

When Shen finished, he pulled the door open and walked out. A breeze blew in. Madam Yun stood there, stunned.

“I’m terribly sorry,” Shen resumed his usual humble self and bowed to his two guests, who had waited a long time in the visitors’ room. “I had to handle an urgent matter. Several dozens of boats loaded with rice from Jiangxi Province are being detained at the provincial border. Authorities in Jiangxi demanded fifty taels of silver per boat before allowing them to come to Zhejiang. The people who work under me wouldn’t pay the money until I gave approval.”

“Why don’t you ask the boatmen to show the authorities in Jiangxi the disaster aid document issued by my office?” asked Zheng.

Shen shrugged his shoulders. “The paper you have issued doesn’t work in another province. Money works the best.”

“We should write a complaint letter to the imperial inspector in Jiangxi,” Ho suggested. “It’s so corrupt over there.”

Shen waved his hands and sat down. “There is no need now. It’s only a matter of ten thousand taels of silver. We don’t want this to ruin relations between the two provinces.”

“Let’s get down to business,” Zheng said to Shen. “The plan we have put forward was rejected by the new mayor this evening.”

“Was it Gao Hanwen, the one chosen by the grand secretary junior?” Shen asked in surprise.

Zheng nodded.

“How come? What did he say?” Shen asked.

“He says we have to set a minimum price for farmland sales, at two thousand kilograms of rice per mu,” Zheng said. “We did a quick calculation just now. Based on his idea, it would cost an extra five hundred thousand tonnes of rice to buy five hundred thousand mu of farmland. That amounts to seven million taels of silver.”

“If that’s the case, I wouldn’t be able to come up with that much money,” Shen replied, somewhat shocked by the figures.

“This is the best scenario,” Zheng argued. “The truth is that in the flooded counties of Chun’an and Jiande, we probably won’t be able to buy up five hundred thousand mu of land at this price. With the exorbitant rate of two thousand kilograms of rice per mu, farmers only need to sell some of their land to cope with the food shortages caused by the current flooding. In other words, we have to find alternatives in those non-flooded counties, where a mu of land is sold at three thousand kilograms of rice. If we take this into account, the price tag could go up to ten million taels of silver. This could jeopardise the whole land-conversion plan.”

“Why would this person want to do something like that?” Shen said, looking baffled.

“He wants to have it both ways,” said Ho Maocai furiously. “As the saying goes, he leads the life of a whore and expects a monument to his chastity. I think offering him a cheque of a hundred thousand taels of silver would shut him up, don’t you think?”

“If this works, I can write him a cheque right away,” promised Shen.

“Let’s not get too far ahead of the game,” Zheng interjected. “This person is a well-known Confucian scholar, but deep down he’s harboured big political ambition. That’s probably the reason the grand secretary junior picked him to appease the opposition. Knowing his character, I doubt he’s going to openly accept bribe money.”

“So, with your prestige and authority, the two of you still can’t rein him in, can you?” Shen asked.

“Well, he’s only a mayor, and we can easily keep him under control if we want,” Zheng mused. “But he comes highly recommended by the grand secretary junior, and he has authored the disaster-relief-through-land-conversion strategy. If he rejects our plan and reports us to the Imperial Palace, we could face inquisition. Nobody would back us – not even the grand secretary junior.”

“We have to find a way to rein him in or at least to shut him up,” Shen replied with a crafty smile.

Zheng and Ho fixed their gaze on Shen.

“How much do you know about this person?” Shen asked.

“Two friends of the grand secretary junior corresponded with me last month, saying that this person writes good poetry and he’s well versed in music,” Zheng said.

“Really?” Shen’s eyes sparkled. “Could you postpone the discussion about land conversion and disaster relief for a day or two?” he asked.

“Of course,” Ho replied. “Mr Zheng has already done that. We have decided to discuss the plan again the day after tomorrow.”

“I actually only need one day,” said Shen.

“Do you have a plan in mind?” Ho asked in earnest.

Shen rose and said with a determined look, “As the saying goes, there’s always a way to make money in the world, and there’s always a way to kill your enemy if you put your mind to it. As long as you two give permission, I can make him change his mind at your meeting the day after tomorrow.”

Ho patted his lap and said with gusto, “If you can make him change his mind, we’ll do everything. What’s your plan? Just tell us.”

Shen turned to Zheng, who was obviously better at reading Shen’s unexpressed thoughts than Ho.

“If you use beautiful women as a trap, I doubt it’ll work on him,” Zheng said with some hesitancy.

“Your Honour, I know sex traps don’t always work, but what if we make a real match?” Shen said with a cunning smile.

Ho finally figured out what Shen was getting at. “This person is the pick of the grand secretary and his son,” he questioned. “If we orchestrate this, it would probably be hard to explain away to the grand secretary.”

“I know it is inappropriate to get you two involved,” Shen assured them. “What about having someone at the Textile Bureau handle this? Like someone from His Majesty’s staff?”

Zheng thought about it for a minute and answered, “That might work. We’ll let you take care of it.”

“But Your Honour needs to arrange a meeting for me,” Shen added, trying to smile so he didn’t betray his disgust at Zheng.

“Can you suggest a legitimate business excuse for your meeting with Gao Hanwen?”

“You can use the excuse that he needs to visit the South China Textile Bureau and meet with a silk merchant to understand the full impact of the land-conversion policy,” Shen replied. “I’ll take care of the rest.”

“That sounds good,” Zheng said contemplatively. “I think I can do it.”

Ho banged his balled fist on the tea table and bragged, “Excellent. The two new magistrates are no angels. Once you have taken care of Gao Hanwen, let me handle the other two.”

Since the Hangzhou municipal government yamen was located in the city centre, Gao Hanwen was able to move into his living quarters in the yamen’s backyard after the meeting. Hai Rui and Wang Yongji stayed temporarily at a government guest house. Before dawn the next morning, the two new magistrates arrived at the municipal yamen, waiting for Gao Hanwen – they had been scheduled to visit the rice market at the Caoyun Wharf.

Hai had changed into a new grey cotton robe, and Wang, who grew up in a well-to-do family, wore a thin silk outfit.

“Brother Hai,” Wang said somewhat hesitantly after they were seated in Gao’s living room. “Why don’t you buy a couple of silk robes? In this way, people won’t think you’re my aide-de-camp or something.”

Hai, who sat there silently, lost in thought, raised his head and looked at Wang for a few seconds before answering. “I don’t mind being your aide-de-camp,” he joked.

“I’m not worthy of that,” Wang immediately said, flustered. “You’re at least ten years older, and you deserve my respect. If you don’t mind, I can gift you a couple before we depart tomorrow.”

“Thanks, but I only wear cotton robes.”

“I apologise for being so presumptuous,” Wang said, looking embarrassed.

“No, that’s not what I mean,” Hai quickly explained. “The region I come from is quite remote and poor. Only a few people can afford silk clothing. Besides, it’s hot all year round, so we don’t actually need silk clothing. Except for formal events, we seldom wear shirts. So I have got into the habit of wearing cotton robes. Speaking of being your aide-de-camp, I don’t think age has anything to do with it. For example, Mayor Gao is very young, but I don’t mind being his aide at all, as long as he’s devoted to the Imperial Palace and the people.”

Even though they had known each other for barely a day, Wang already saw Hai – a man of few words – as a friend or someone in whom he could confide. Hai’s remarks about Gao further confirmed his judgement and warmed his heart. “I was about to tell you the same thing about Gao,” he nodded.

“Then why did you bring up the subject of my clothing?” Hai teased.

“Well, no matter what one does, one has to eat and clothe oneself, right?”

“I still prefer my cotton robe,” Hai replied with a rare grin.

As they were bantering, Gao emerged from his bedroom. He was also wearing a thin silk robe. “Sorry to have kept you waiting,” he said. “Let’s get going.”

In the courtyard, two men came up to them with ingratiating smiles. The one at the front was the mayor’s personal attendant. Dropping to one knee and bowing his head, he announced, “Your Honour, the imperial inspector has entrusted us to bring you his letter. He has invited you to visit a silk mill this morning and see how silk is produced.”

“We’ve been here for a while to wait for Your Honour.” The man standing behind the mayor’s personal assistant stepped up and bowed.

Gao thought for a moment. “Could you tell the imperial inspector that I have made plans to visit the rice market with two magistrates,” he said. “I can visit the silk mill another time. There’s really no rush.”

“Your Honour, I wouldn’t be in a position to relay this message of yours,” Zheng’s attendant replied. “The imperial inspector has already notified the Textile Bureau to expect you this morning.”

The mention of the Textile Bureau gave Gao pause. He turned to Hai and Wang and said, “Since the invite comes from the Textile Bureau, I guess I have to go. Why don’t you two go ahead and check out the rice market without me?”

As the litter carried Gao off, Wang saw a glint of worry in Hai’s eyes.

Gao Hanwen found himself in a large silk mill. He had never seen so many machines weaving different types of silk fabric. Despite his natural inhibitions, Gao had to admit that he was impressed. “Half of the silk that the Imperial Palaces use is made here.” Shen talked loudly so he could be heard above the noise of the machines. “Before the sea route was blocked in 1553, half of the silk we exported to the west came from here.”

Gao nodded. By then, he was already overwhelmed with the feeling that there was such a lot to know about this large industry and he knew so little of it.

“It’s too noisy here,” Shen suggested. “Why don’t we go and see the silk samples first?”

Shen took the unprecedented step of taking Gao to his secret residence – a sanctuary that he had never shown to anyone before. Outside the cavernous house, Gao stopped suddenly, his face awash with surprise. “Someone is playing The Guangling Melodies,” he murmured to himself. The music wafting out from inside a studio enthralled him.

Shen also stopped. Taking a side glance at Gao, he knew that his plan had started to work its magic. “Your Honour…” he jolted Gao out of his reverie.

“Where are we?” Gao asked. “Are you going to show me the silk samples here?”

“Oh yes. We used to bring western merchants here to see silk samples.”

Gao eyed Shen curiously. “You’ve hired a guqin virtuoso to play The Guangling Melodies and entertain western merchants who are here to see the silk samples?” Gao asked.

“I’m impressed that Your Honour can tell that she’s playing The Guangling Melodies,” Shen remarked with feigned surprise.

Distracted, Gao did not respond.

“Both guqin music and fine silk are part of our cultural heritage,” Shen bragged. “When we do business with the west, we don’t just sell our silk. It is also our responsibility to spread our culture. I’m in awe of your deep knowledge about music. We’ll have a lot to talk about. Please go in.”

Gao felt that his legs no longer belonged to him as he followed Shen mechanically to the spacious music studio. Even during the day, Shen left the lanterns burning, which, along with rows of transparent silk dresses, had transformed the room into a dreamland. Gao, dazzled and distracted, scanned the chamber. It was apparent that the young official was not paying attention to the silk, but rather searching for the source of the music, which seemed to come from behind a flowing silk curtain.

“Your Honour, please look at this,” Shen presented a piece of silk with embroidery on both sides. “This sells really well overseas, but its name sounds really plain. It’s called ‘Flowers in Four Seasons’. The foreigners really like it.”

Gao felt obligated to show some interest in the product, or at least pretend to be enthused about it. But, after briefly studying the fabric, he became immediately captivated. On one silk dress alone, craftsmen had embroidered more than one hundred different species of flowers in various stages of blooming, and their colours and shades matched perfectly.

Shen put down the dress and led Gao towards a silk curtain, behind which the music arose. Gao’s eyes were filled with anticipation and curiosity.

As they were ambling across the room, Gao suddenly stopped. Shaking his head in disapproval, he mumbled, “A pity, a pity.”

“May I ask, what do you mean by that?” Shen asked, feigning ignorance.

“I’m talking about the music,” Gao expounded. “Many musicians who play The Guangling Melodies tend to err at this spot. As you know, Ji Kang^(1) was a non-conformist by nature, and yet for some reason he was offered a senior post within the government in the Kingdom of Wei. He despised his job and was critical of the ruling Confucian philosophy. Instead, he worshipped nature and spent his whole life studying the life-cultivating methods. For years, he was searching for a resting place where he could consecrate his heart, and he subsequently found his inspiration in Mount Mang, which he saw as the beginning of all creatures in China and the true destination of his soul after death.

“Therefore, before his execution, he was seized with mixed emotions – both grief and joy – and at his request, his executioners allowed him to play The Guangling Melodies on his guqin. While his fingers danced on the instrument, his spirit rose and flew towards Mount Mang. In this piece, one traditionally would use jue in the pentatonic scale to play the part about Mang Mountain, so a low pitch would be applied. However, nowadays, many musicians have turned to a high pitch, falsely presuming that Ji Kang was grief-stricken before his death. That’s a wrong presumption.”

Gleams of excitement flickered in Shen’s eyes. While congratulating himself on ensnaring Gao in his trap, he also felt a strong attachment to the new mayor, someone whose talent he truly admired and who shared similar interests.

“I have a humble, or maybe unreasonable, request, and I wonder if Your Honour is willing to grant me the privilege,” Shen requested.

Gao had guessed what Shen would say next – inviting him to guide and teach the musician. A sense of pride surged through him. “Please go ahead,” he said to Shen.

“I would invite Your Honour to critique the work of this musician because your guidance will not only help promote our products and culture to the west but also ensure that the true spirit of The Guangling Melodies will not be misinterpreted by future generations.”

“We’ll learn from each other,” Gao replied immediately, with an air of presumptuous confidence.

“I want to thank you in advance.” Shen bowed before lifting the silk curtain. With a light pull, the whole piece fell down like a wisp of cloud. Gao’s eyes were fixed on the platform bed; a red rug covering the platform surface transformed it into a stage. The virtuoso was actually a young woman dressed in a flowing white silk costume, with a tinge of lotus pink. She was beautiful and full of grace. Her attraction retained a perceptible aura of worldliness and the sophistication of a fille de joie.

As he quickly shifted his bashful gaze to the silk curtain, he caught a glimpse of her slightly parted lips under her arching eyebrows, reminding him more of The Guangling Melodies. Like Ji Kang, he was willing to pull his heart out and consecrate it, but to whom and where?

“You’re a lucky girl,” Shen said, his voice bringing Gao back to reality. “We have a true master here, and I hope you can learn from His Honour.”

Shocked slightly at the coldness in Shen’s voice, Gao could not fathom why the silk merchant would treat a woman of heavenly beauty with such indifference, which almost bordered on cruelty.

In her kneeling position, Madam Yun gently straightened her upper body. Crossing her two long sleeves in front of her chest, she bowed slightly and said, “Your Honour, I will play from the beginning, and I welcome your guidance.”

As her slender fingers moved deftly on the strings, The Guangling Melodies rose, filling the whole room with music even though the room was insulated with sandalwood panels. Gao stood there, transfixed by the music and by Madam Yun, who gradually immersed herself in her performance.

Seeing that everything was going smoothly according to his meticulous plan, Shen sidled towards the door, pulled it open slightly and stepped out with his body tilted sideways. When he closed the door behind him, he left them alone in the room.

At the time this story took place, China’s handicraft industry and commerce had reached a peak, especially in the southeast region around the Tai Lake. Music and arts also flourished in the region, making it the cultural centre of China and creating a large group of music- and art-loving officials and merchants. These practitioners of beaux arts hovered between their political careers and their artistic pursuits. Those who passed the Imperial Exams entered the bureaucracy, while those who failed indulged in women and music.

In those days, it was very common for officials and merchants to frequent brothels and befriend courtesans. The literati helped nurture many beautiful young courtesans who were well versed in the arts, music and literature, most of whom set up shop in the booming cities of Nanjing and Hangzhou. Theatres and brothels competed to host operas and music performances, and visiting those venues had become a fad and national pastime.

There was a popular saying among officials that illustrated the rich cultural traditions in the south and the lack thereof in the north: “One would rather be a county chief along the Yangzi River than a mayor along the Yellow River.” Another saying among the ordinary folks stated, “One would rather be a dog in the cities of Hangzhou and Suzhou than a human being in the north and northwest.”

In other words, Hangzhou, this paradise on earth, had become a coveted destination for China’s cultural elite. Gao grew up in a family of distinguished scholars and was greatly influenced by the literati of his time. Not only was he a talented and accomplished writer, artist and musician but he also held a true passion for these artistic activities. However, one could not have it both ways. His political aspirations took precedence over his artistic bent as he began shifting his interest in arts and music to the study of neo-Confucianism.

An aficionado of literature and music, Shen shared Gao’s literary temperament. His familiarity with the cultural elite and his knowledge about Gao’s past gave him the confidence that he could succeed in luring the magistrate into his trap and eventually bring him to his knees. The literati might be incorruptible by money because of their self- righteousness, but they would never refuse an offering that displayed true elegance and good taste.

Shen was right. At this very moment, Gao sat with his eyes shut. His mind broke free from the enclosed music studio, travelling to Mount Mang, where Master Ji Kang was laid to rest. Meanwhile, Madam Yun was playing the finale, which Gao had critiqued earlier. She suddenly stopped. Too shy to look Gao in the face, she gazed at Gao’s chest, with her beautiful eyes that shimmered like water. “Your Honour, I understand what you just said about using Jue in the pentatonic scale, but none of the music scores that I have read had such mention. Could you tell me why?”

Across the bank, a deer bleats, in the wilds where it eats.^(2) Gao felt as if a deer were bleating, hopping up and down violently in his heart. For a while, he simply stared at the woman, rapt.

Curious at the silence from Gao, Madam Yun moved her gaze from Gao’s chest to his face. Their eyes met. Gao’s scalp was tingling. He quickly looked away and noticed that Shen was no longer in the room.

Having studied the Confucian moral teachings for more than a decade, Gao was well- aware of his boundary. A precious shining pearl was beckoning him, but he knew that darkness was lurking behind. Conscience whipped him in like a horseman’s rein. Gao quickly became alert at Shen’s absence. “Mr Shen, where are you?” Gao shouted. There was no answer. He quickly strode to the door. As he was about to pull it, the door opened. In came Shen, looking self-possessed. “Your Honour, are you looking for me?” he said.

Gao eyed him suspiciously.

“When Master Ji Kang played The Guangling Melodies before his execution, three thousand of his disciples crowded around him, listening to the music, but none fully comprehended its essence and impact,” said Shen. “That explains why Ji Kang’s version of The Guangling Melodies has been lost forever. It’s truly lamentable. A few years ago, a fellow music-lover friend of mine said something that I didn’t quite grasp at first. This person said The Guangling Melodies can only be played by one individual to another. Adding another member to the audience would create dissonance. I did not understand that, but later on, when I tried playing the piece a few times, I realised that he was absolutely right. We are very lucky to have a true expert today. After you mentor her today, I myself have many questions to consult with you about. I wonder if you would grant me the honour.”

Impressed by Shen’s sincere compliments, which clearly showed the silk merchant’s own expertise, Gao let his guard down a little and began to warm to Shen.

“Can I ask you something,” Gao said. “What is your position at the Textile Bureau?”

“I spend most of my time working with silk weavers on new fabric patterns and designs. My other job is to negotiate business deals with foreign merchants.”

“What a pity,” Gao said, casting a side glance at Madam Yun.

“Your Honour, I am sorry that I forgot to make the introduction,” Shen said with an apologetic smile. “She’s my niece, Yun. Her parents died when she was a little girl, and I brought her here to live with me and to teach her music and literature. As she is cultivating her trade, she’s turned down many marriage proposals. Now she’s turning twenty, it really worries me. While I’m anxious, I have to make sure she finds the right young man.”

“What a rare beauty,” Gao blurted out and quickly felt embarrassed by the slip. “Well, we have more important matters to take care of today. People are starving, and it’s probably not the appropriate time for us to banter about music here. Why don’t we continue with our conversation about the silk production quotas.”

Bottling up his disappointment, Shen slowly followed the young official out. However, before Gao stepped across the threshold, Shen noticed that he involuntarily glanced back at Madam Yun and caught her adoring gaze. Embarrassed, Madam Yun quickly dropped her eyes. As much as Shen wanted Gao to fall into his trap, the subtle eye contacts between Gao and Madam Yun triggered an unknown feeling of jealousy in him.

“Try to digest Master Gao’s words.” Shen broke the awkwardness with his interjection. “Keep practising.”

Madam Yun detected a touch of desolation in Shen’s voice.

Junks and sampans, big and small, black-roofed or white-sailed, moved about in an orderly fashion. After more than a thousand years, the river port in Hangzhou, which marked the start of the Grand Canal, was functioning efficiently and smoothly. Hai Rui and Wang Yongji stood at the tip of the port, quietly watching the different types of moored vessels loading and unloading. Silk-robed merchants and bare-shouldered longshoremen with heavy sacks on their backs scurried back and forth.

“Is this your first time to be in the region?” Wang asked Hai.

“Yes!”

Wang blurted out one of Liu Yong’s poems about Hangzhou. “‘Blessed by nature / Seat of the Wu region / From the old has been thriving / Qiantang River/ With bridges beautiful, willows misty.’ After Liu Yong failed repeatedly to secure a career within the Imperial Government in the tenth century, he became a vagabond and traversed the region, leaving many beautiful poems behind. In a way, his misfortune turned out to be a blessing.”

“I would rather live in the poor remote mountain village where I grew up,” Hai replied curtly. “Wandering around in booming cities like Hangzhou is not my thing.”

“There’s nothing wrong with living in a prosperous city like Hangzhou,” Wang retorted. “In this big country of ours, if we didn’t have towns and cities, farmers wouldn’t have a market to sell their silk, cotton and tung oil. You can’t make a good living planting rice alone.”

“You’re absolutely right, but I’m just worried that the wealthy in the city will become wealthier and the poor in the villages will be poorer.”

“It is impossible to eliminate inequality between the rich and the poor, but we try our best to bridge the gap a bit,” Wang said.

“You must be one of those wealthy ones,” Hai half joked. “No wonder you want to gift me some silk robes.”

“Truth be told, my family owns about seven or eight hundred mu of farmland,” Wang admitted. “My family is probably slightly better off than yours. But I just hope that the Imperial Palace doesn’t appoint you as the magistrate of my home county. Your belief in ‘robbing the rich to help the poor’ won’t bode well for my family.”

“I’m targeting the super-rich whose fortunes are built by exploiting the poor,” Hai teased. “Small landowners like you will be spared.”

“If that’s the case, I’ll lobby Tan Lun, asking him to use his connections in the Personnel Ministry and transfer you to my county. At least, I can take some credit for securing a clean official with a strong sense of justice for my people.”

Hai turned his eyes to the river and said, “I think you have overestimated my abilities as a government official. I don’t even know if I can walk out of Chun’an alive.”

Hai’s remarks dampened Wang’s cheerful mood.

“When is the rice market open?” Hai asked.

“About this time of the day. I think it’s going to start at any moment.”

“Why don’t we go down there together,” Hai suggested.

They were about to leave when they heard hurried footsteps behind. Turning around, they saw a group of uniformed soldiers running up with their matchlock harquebus and handguns.

“Hurry up,” an officer with a dagger strapped to his waist ordered. “See those junks on the left sides? Get them all and don’t let any run away.”

The soldiers dashed down towards the port, running over several longshoremen who were too slow to move to the side. “Get out of our way,” the soldiers yelled. “Seize those illegal rice boats.”

Hai’s face turned grim. “Let’s go and find out what’s happening,” he said to Wang as they hurried down towards the port. The soldiers were relentless. As soon as the sampans pulled in, the soldiers used mooring ropes to tether the grain-carrying sampans to docks and then fired at the grain sacks on deck with handguns. As the magistrates watched, the masts collapsed, and the sails flew in the air before falling down. Sacks of rice were riddled with holes, like beehives. Rice flew out onto the deck and into the river. Farmers on the sampans scurried around out of desperation to block the holes with their bare hands but to little avail. Some even threw themselves onto the sacks, hoping to stem the flow…

“Don’t move,” the soldiers lining the port barked at the farmers on the boats as they reloaded their guns. “Raise your hands and kneel on the deck there.”

The farmers couldn’t bear to drop their hands plugging the holes on the grain sacks, but the soldiers jumped onto their sampans, beating them with gun stocks. Many farmers dropped to their knees helplessly.

On one sampan, the farmers were resisting, standing there in defiance. The officer immediately ordered his soldiers to aim their firearms at the boat. “Did you hear me?” the officer yelled. “Kneel down before I shoot you.”

Under the threat, some farmers bent their legs and were about to comply when a young man urged his fellow farmers to remain standing. “We’re not violating any laws,” he said. “Let me go and talk with them.”

The young man was Chee Dazhu, who had attempted to block the horsemen earlier when they attempted to destroy the rice seedlings. As he climbed onto the gangway, the officer ordered his soldiers to be ready to shoot at Chee. “This man is their leader,” he shouted lividly. “Go and get him.”

Chee paused in the middle of the gangway and decided to address the crowd gathering at the port. “My fellow countrymen, we are farmers in Chun’an County. A terrible flood has destroyed our crops. With each passing day, people are dying of hunger. We have collected some money to buy rice here so we can go home to feed our starving villagers.”

Loud murmurs spread through the crowd. The soldiers, sympathetic to Chee’s predicament, stood there, frozen.

“The government troops are here to arrest us and seize the lifeline to flood victims,” Chee continued. “If we’re killed, I want you to bear witness to such brutality.”

The officer collected himself and changed his order. “Capture him,” he howled. But a soldier who misunderstood his order pulled the trigger on his gun in a moment of sheer panic.

Bam!

Before the crowd figured out what was happening, Chee faltered, his hands grabbing the handrail on the gangway. The shot triggered an uproar in the crowd. Baffled by the commotion, the soldiers who had been ordered to capture Chee panicked. The individual who accidentally fired the shot dropped his gun to the floor in fear. His officer kicked him in the shins. “Why the hell are you dumping your weapon?” the officer howled. “Pick it up. Go and get him.”

The soldier bent over to collect his gun before aiming at the boat. Meanwhile, two other soldiers dashed over to the gangway, where two young farmers came to Chee’s rescue, trying to help him to his feet. Chee urged his fellow villagers to withdraw from the scene and step away from the soldiers.

The two soldiers approached Chee, pointing their long firearms at his head. “Stand up,” they ordered. Chee rose slowly and straightened his body. Fresh blood oozed out of his right leg, prompting a few sympathetic soldiers to stand aside and let Chee take care of the bleeding. Tearing off his shirt, Chee wrapped it around his leg. When he got to his feet, he asked his captors, “Are you two from Zhejiang?”

The soldiers exchanged glances with each other and said nothing.

“We are farmers from Chun’an County and just suffered a terrible flood,” Chee continued. “We’re not stealing rice here. If you take our rice and our boats, many in my village could starve to death.”

Seeing that the soldiers were standing still, listening to Chee’s plea, the officer yelled, “Why don’t you arrest him? Take him.”

Once again, the soldiers pointed their guns to Chee’s head. As they were about to seize Chee, a loud voice sounded in the crowd. “This is outrageous,” bellowed Wang, who looked furious as he stepped forward in front of a large group of surprised onlookers. Hai, who was taken aback by Wang’s action, followed him.

“Who has sent you here?” Wang questioned the officer.

“The Provincial Justice Department,” the officer said, eyeing him suspiciously. “We’re merely following orders. Please stay out of our way.”

“Haven’t these folks told you that they’re flood victims and are trying to buy rice to save lives?” Wang chided. “When you arrest and hurt people like this, aren’t you worried that someone might report you to the Imperial Palace?”

“Who are you? Where do you work?”

“I’m the new magistrate of Jiande County.”

The office looked visibly relieved. “These people are from Chun’an, not Jiande. I have orders from the provincial yamen, and I think Your Honour should mind your own business.”

The officer turned to his soldiers and demanded, “Arrest them and seize their boats.”

“Wait,” Hai stepped forward and stated calmly. “This should be under my jurisdiction then. You claim that these folks are thieves. What have they stolen?”‘

Judging from Hai’s appearance, the officer initially thought Hai was Wang’s assistant, but the tone in Hai’s voice indicated that he might be more powerful than the magistrate of Jiande. Baffled, the officer asked, “You are…”

“There is no need to tell you who I am. Answer my question first.”

“The imperial inspector’s yamen has put up a notice, banning the sale and purchase of rice this month,” the officer recited. “Violators will be subject to arrest and confiscation of vessels.”

“I was just there yesterday,” Hai retorted. “How come I don’t know about it?”

The officer shook his head vigorously. “Don’t ask me. I’m merely carrying out an order issued by the Justice Department.”

“All right, let me take care of it,” Hai commanded. “Please order your soldiers to get off the boats.”

“I don’t think I can. For us to withdraw, I’ll need another order from the Justice Department.”

“Why don’t you release these people first, and I’ll go with you to the Justice Department,” Hai promised.

Before the hesitant officer had a chance to respond, Hai strode towards Chee’s sampan. The crowd stepped aside to let him pass. “Get out of there,” Hai yelled at the soldiers guarding the gangway. Noticing that their officer had shown restraint in front of this unknown person, the soldiers complied and backed out.

Hai mounted the gangway and stopped in front of Chee. “Are you truly from Chun’an?” he probed gently. “Is your family affected by the flood?”

“Yes, sir. I’m a mulberry farmer, and my name is Chee Dazhu.”

“Are you buying rice to help with flood victims?”

“Yes, sir. The price of land has gone down to five hundred kilograms of rice per mu. We don’t want to sell so cheap. So we’ve collected some money to buy rice so we could survive the flood and keep our land.”

Chee’s description seemed to match what he had learned about the situation in Chun’an. Hai nodded and advised, “It is not a good idea to fight the yamen. Take the rice and go home with your fellow villagers. Let me take care of the stuff here.”

At this urging, two farmers came over to carry Chee back to the boat, but Chee wouldn’t move. “Your Honour, may I ask who you are?” Chee asked.

“I’m Hai Rui, the new magistrate of Chun’an County.”

Chee’s eyes glistened with tears. He fell on his knees. So did the other two farmers.

“This is not the place to give salute. Leave now. I’ll be in Chun’an in the next couple of days.”

After Chee embarked on his sampan, Hai remained on the gangway and turned to the soldiers on the other boats. “Get off their boats and come down over here,” he shouted.

The soldiers looked to their officer for command.

Wang, who stood next to the officer, nudged him. “We have already promised to go with you to the Provincial Justice Department. Why don’t you order your men to retreat from there? Do you want your job or not?”

The officer complied and gathered his men from the sampans. Before jumping off the gangway, he waved at the farmers on the boats. “Set sail and ship the rice home!”

Some farmers climbed up onto the mast to fix the broken sails while others hoisted their sails and moved slowly away.

“Let’s go to the Justice Department,” Hai told the officer.

7

When Ho Maocai learned about the events earlier in the day at the port, he flew into a rage. If he could have his way, he would definitely send his soldiers to arrest these two trouble-making magistrates and throw them in prison.

Unfortunately, Ho realised that he was not authorised to touch them. The Ming Law stipulated that only an imperial inspector had the power to impeach or detain current officials who were accused of criminal offences. All he could do was summon Hai Rui and Wang Yongji to the imperial inspector’s yamen. Before he went in to see Zheng Bichang, Ho ordered the two magistrates to wait in the visitors’ room.

“Before we even figure out how to rein in Gao Hanwen, we now have other troublemakers,” Ho fulminated. “The two new magistrates colluded with bandits and resisted orders from the provincial yamen. If these people keep messing with us, we won’t be able to get anything done. How are we expected to purchase the farmland? Once June is gone, we’re going to miss the mulberry-planting season.”

Zheng sat by a tea table, looking petulant. “How do you expect me to fire them?” he ranted.

“You’re the imperial inspector,” Ho suggested. “You can certainly submit a report to the Imperial Palace, requesting that they be censured and their positions terminated. While they’re waiting for their verdicts, I’ll notify the public and appoint the deputies in the two counties as acting chiefs.”

“All right, let’s work hard on getting rid of these two,” said Zheng, who rose from his chair and slowly walked towards his desk. “If possible, why don’t we remove Gao Hanwen from his position as well?”

“We probably need to be more cautious when it comes to Gao,” Ho replied before realising that Zheng had been ridiculing him all along. Pausing for a few seconds, he suppressed his anger and switched gears. “You’ve heard back from our friend Old Shen, have you? Did Gao take the bait?”

“No, I haven’t heard a word from Shen,” Zheng uttered a long sigh. “But I have received a bunch of letters from Beijing, telling me to put a temporary brake on purchasing farmland and implementing the rice-to-mulberry conversion. I have no idea what is going on.”

From Zheng’s defeated look, Ho knew that something bad was about to happen. “Where are the letters?” he asked. “What else do the letters say?”

Zheng picked up a stack of unsealed missives, picking one on the top and tossing it to Ho. “They just arrived – one from the Privy Council and the other from the Interior Ministry,” said Zheng. “The one I gave you is from the grand secretary. Read it carefully.”

Ho skimmed the first few lines quickly and stopped. “These two new magistrates came at the recommendation of the Prince of Yu?” Ho remarked with an expression of disbelief.

Zheng ignored Ho’s remarks. “Read this one.” He handed another letter to Ho. “It’s from Yang Gonggong.”

Looking perturbed, Ho surveyed the pages quickly. “Yang Gonggong is going to stay in Beijing for a few more days?” Ho asked. “The land conversion is a major undertaking, but he chooses to be absent. What does it mean? What are we going to do?”

“The picture is getting clearer now,” said Zheng, who sat down and stared distractedly at the garden outside. “The grand secretary junior has appointed a new mayor for us, but this new mayor took sides against us the minute he arrived. Then the Prince of Yu has chosen two new magistrates for us. Those two have started to boycott and tried to overturn the ban on rice sales before they even assume office. Yang Gonggong’s absence is also intriguing. Why is he hiding in Beijing when we need him the most? There is only one explanation… Up there inside the palace, there’s chaos. Two factions are engaging in a sword fight, and they are getting back at each other by hacking away at us in Zhejiang. Do you understand what I mean? Stop talking about dismissing these new appointees. If you have any ingenious ways to get rid of me, I’ll be forever grateful and gladly let you take over.”

While shocked by Zheng’s diatribe, Ho did not fully share Zheng’s pessimism. “Your Honour, do not forget the fact that the Imperial Palace is facing some huge budgetary problems and the treasury is almost empty,” Ho pointed out. “They see the rice-to-mulberry conversion plan in Zhejiang as a lifesaver. If we fail, those in Beijing will not let us get away with it. We have to make it happen. That’s our only option. Look at Governor Hu Zongxian. He lost his imperial inspector’s job because of his opposition to the land-conversion policy. Regardless of who their backers are, the new mayor and two magistrates will follow Hu’s footsteps and embark on a self-destructive path if they don’t jump on the bandwagon fast.”

“Do you still believe that Hu Zongxian got the short end of the stick?” Zheng asked.

Ho looked baffled.

“We naively thought that Hu had lost his bearings as he was climbing up his career ladder. We thought he had become muddle-headed and out of touch,” Zheng said. “Looking back, it was actually one of his shrewdest political gambits. Now, we have no clue where he stands.”

“I just don’t get it,” Ho shook his head.

“I didn’t get it either,” Zheng explained. “Come to think of it, though, Governor Hu recognised earlier on that the Imperial Palace’s rice-to-mulberry policy would be a suicidal move. So he designed a ruse that could get him out of the mess at the cost of losing his mentor. By openly standing up to the grand secretary, he knew very well that it would incur the wrath of his mentor and get him fired. It was like a cicada sloughing off its skin – using camouflage to create an illusion to distract people so you can hide your real intention and protect yourself. Guess what – the grand secretary junior and his people totally fell for it. They removed him from the imperial inspector’s position and made me his replacement. You also end up getting a promotion as the chief administrator. For a while, the two of us stupidly clutched these promotions as precious gifts. Now, we are stuck and can’t even reverse if we want to.”

Ho tilted his head, trying to detect the proper logic in Zheng’s explanation. The more he thought about it, the more confused he became. “I still have problems following you,” Ho rose from his chair and pleaded. “Could you be more specific?”

“How specific do you want me to be?” Zheng said, with a hint of impatience in his tone. “Now that the Imperial Palace is running out of money, His Majesty passed the bucket to the grand secretary and his son, who have been forced to find ways to lower the budget deficit. If they can bring in money, the father and son can stay around for a few more years. If not, His Majesty would undoubtedly kick them out. Therefore, the Prince of Yu and members of the Clear Stream faction are scheming to sabotage the land-conversion plan here. Their ultimate goal is to topple the grand secretary and his son. If they prevail, you and I will be the first to fall. There’s no doubt about that.”

“If that’s the case, the grand secretary and his son would go all out to make it work. Why would they send an obstructionist over to contain us?” said Ho.

“I’m wondering about the same thing,” Zheng reasoned. “If the land-conversion policy succeeds and we generate enough money for the financially strapped treasury, we could probably help the grand secretary and his son survive the ordeal they’re facing. That would give us a pass as well. As the saying goes, one good deed will sometimes redeem several bad ones. But Gao Hanwen’s fierce opposition yesterday aroused my suspicion, making me rethink this whole deal. If the grand secretary junior truly wants to get this done, he had many candidates to choose from, but why did he choose Gao? I finally figured it out today. The grand secretary junior must have been under a lot of pressure from people who are rallying around the Prince of Yu. Besides, Governor Hu’s betrayal further complicated things, throwing the plan into disarray. That’s why they picked a person who was acceptable to both sides. Everybody knows that the land-conversion policy is like ‘cutting off a piece of flesh to patch up a boil’ – a terrible stop-gap measure. But, now, they want us to carry out this challenging dirty job. At the same time, they don’t trust us and send a self-righteous ‘doctor’ to oversee the operation. In other words, they not only need money to reduce the budget deficit but also want to look respectable. So we have to buy farmland to convert it into mulberry while keeping the farmers at bay. Once the money comes in, every single penny will have to be turned over to Beijing. It’s going to bleed us dry. How can you expect a horse to run faster without feeding it?”

“As the saying goes, leading the life of a whore but expecting a monument to her chastity,” Ho interjected. “Let them get the chastity monument, and I don’t mind being the whore. If the worst comes to the worst, we just don’t share the profit.”

“If only they allow you to be the whore! I’m afraid it’s not that easy,” Zheng continued. “We might not take any commission from the land-conversion deal, but what about the eunuchs and members of the Privy Council? Besides, if we allow Gao Hanwen and his two new magistrates to have their way and fix the land prices at two thousand or twenty-five hundred kilograms of rice per mu, do you really think Shen Yishi would want to pay that much?

“If Shen refuses, our plan to increase silk production by three hundred thousand bolts of silk per year will go up in smoke, and there is no way we could fulfil the five-hundred-thousand export order. We’re already approaching the end of May. If we keep messing around with these people and delaying the implementation of the land-conversion programme to late June and July, the whole deal will fall through. When that happens, the Imperial Palace would no doubt launch an inquisition, and it wouldn’t be hard for them to find out about who deliberately broke the dams to cause the flooding. As you and I know, the grand secretary junior and the South China Textile Bureau would try to wash their hands of it and shift the blame to us. It’s only a matter of time. They probably already have the meat wagon ready, waiting to take you and me to the capital city for our trial.”

Ho felt as if his head were about to explode; his face flushed red, and his eyes flashed with anger. “If so, we’ll drag them down with us,” he muttered through his teeth. “We’re not fish and meat on their chopping board, and we will not simply throw ourselves at their mercy. We can always muddy the water. If they dare touch us, we’ll hurt them as well.” Despite his short temper, Ho was full of ideas, especially when it came to sabotage.

“How would you muddy the water?” asked Zheng.

“Didn’t you say that Gao Hanwen came on the recommendation of the grand secretary junior? Didn’t you also mention that Hai Rui and Wang Yongji were sent by the Prince of Yu? We’ll let them take on the task, forcing them to accept the land purchase price of sixty or eighty kilograms of rice per mu.”

Zheng was incredulous. “You saw Gao’s reaction to our plan yesterday,” he said. “Even though Shen is trying to lure Gao into his trap, we still don’t know if Gao will fall for it or not. Besides, Hai Rui and Wang Yongji are friends of the prince. There is no way they’ll follow our ideas.”

“If so, we will probably need to take a big gamble,” Ho whispered before stepping out. Zheng overheard him telling the receptionist not to let anyone barge in. Then, he re-emerged, shut the door behind him and went over to Zheng.

“What kind of gamble? Tell me!” Zheng asked eagerly.

“Cooking up a ‘collusion with the pirates’ charge,” Ho blurted out.

“Colluding with the pirates?” Zheng asked, his face turning pale. “Are you crazy? Colluding with the pirates is a cardinal crime, and it’s punishable by the extermination of our whole families.”

“We’re not doing that,” Ho explained. “We’ll charge them with colluding with the pirates.”

“How? Where is your evidence?”

Ho stepped over, sat on a chair next to Zheng and whispered, “Do you remember the farmer who was captured last month?”

“Do you mean the mulberry grower from Chun’an who attempted to instigate a riot when we sent troops to destroy the farmland there?”

“Yes. The former mayor of Hangzhou arrested him on charges of colluding with the pirates, but Governor Hu set him free. I just heard from my men at the port that this same person has gathered a bunch of unruly folks in Chun’an, trying to buy up rice and dissuade farmers from selling their land. Our folks got him again, but Hai Rui has ordered his release. I assume he’s going to scout around for more rice during the next few days. I’m going to figure out a way that can lure him and other farmers into buying rice from the pirates. If we can catch both the farmers and the pirates in action, they are doomed. Then I’m going to give that case to Hai Rui to handle.”

Zheng was intrigued. “Please go on,” he encouraged.

“Based on The Great Ming Code, those who are found colluding with the pirates would be executed on the spot. I’ll hand this case to Hai Rui. He’ll have to kill a farmer on the first day at his new job. The execution would help deter those who refuse to sell their land.”

“What if Hai Rui refuses to carry out the executions?”

“He already intervened and had those unruly folks released today,” Ho said. “If he continues to resist the execution order, it will give us the excuse to arrest him on suspicion of colluding with the pirates.”

“That’s not too far-fetched,” Zheng nodded.

“If Hai Rui follows through and allows the execution to go ahead, nobody in Chun’an would dare to raise money to buy rice again,” Ho recounted confidently. “Without food, farmers will have no alternative but to sell their land. By then, it will be futile for Hai Rui and Wang Yongji to block the plan because farmers won’t even listen to them any more. Besides, refusal to sell farmland could inevitably lead to starvation and death, which could be the basis for us to do them in.”

“How can we entice farmers to buy rice from the pirates?” Zheng enquired with scepticism.

“I’ll take care of it,” Ho promised. “You go and check with Shen Yishi. If Gao could turn around and accept our proposal at our meeting tomorrow, it would make things much easier. We’ll use the collusion-with-pirates excuse to nab the two maverick magistrates as well as those leading rebels. It is critical that we trap Gao Hanwen tonight, at whatever cost.”

Zheng sat in his chair, quiet and pensive. Then, he spoke up slowly. “If you want to press the collusion charge, make sure you do a clean job. Don’t leave behind any damning evidence.”

“No need to worry,” Ho bragged. “I have done this for more than ten years.”

Zheng rose from his chair and made his decision. “Since they’ve left us with no choice, let’s do it. By the way, where are the two magistrates?”

“Waiting outside in the reception room.”

“You’ve played the bad cop all day, and I probably need to say a few kind words to calm them down. Go ahead and take care of your business.”

“All right.” Ho nodded and left. Before he reached the door, he turned around and urged, “Please check with Shen to make sure the plan is going smoothly.”

Led by a dozen prison guards holding blazing torches, Ho strode along a wide passageway in the dungeon. In the glaring light from the torches, he could see a row of thick metal bars, behind which were individual cells with exposed sturdy rock walls. In a cell at the far end of the row, a Japanese ronin was imprisoned; fully shackled by thick metal chains. Unlike other prisoners, he was clean-shaven and dressed in a clean silk kimono, with a bun on the top of his head – a typical Japanese pirate hairdo.

Ho sat on a chair outside the ronin’s cell, flanked on both sides by guards and soldiers, who were carrying long firearms. “We always mean what we say,” Ho said gently to the ronin. “For two years, we’ve kept you alive and haven’t killed any of your friends and followers. Each day, we give you whatever you request. Why are you still so distrustful?”

“You didn’t kill me and my men because you wouldn’t dare,” the Japanese replied in a fluent Hangzhou dialect. “Don’t forget that we killed your predecessor and his family after he ordered the execution of my brothers.”

The prisoner’s insolence upset him. Knitting his brows, Ho hardened his tone. “Stop bragging,” he mocked. “If you are truly that powerful, why don’t you go and take revenge on Hu Zongxian and Qi Jiguang and exterminate their families?”

Ho’s words touched a sore spot. Giving a snort of disgust, the Japanese prisoner smashed a low wooden table into pieces. “One of these days, we’re going to kill Hu Zongxian and Qi Jiguang,” he vowed.

In response to his violent reaction, the guards raised their guns and formed a human wall in front of Ho.

“Move away.” Ho brushed his guards aside and continued his conversation. “Mr Inoue Toushirou, I’ve told you what I need you to do. I know you Japanese are known for being faithful to your words and to those who have helped you. If you agree to my request, I’ll release a dozen or so of your friends who are being locked up here. If you do a good job, you’ll be awarded with bolts of high-quality silk. Are you willing to do it or not? I’m waiting for your answer.”

Sitting with his legs crossed and his eyes closed, Inoue Toushirou heaved a deep sigh. It was obvious that he was pondering Ho’s offer. He and the guards held their breath, waiting quietly. Occasional sparks from the torches made loud cracking noises.

“Get me a fugu fish,” Inoue Toushirou suddenly mumbled, with his eyes still closed.

“What?” Ho didn’t catch what he was saying and turned to a guard. “What did he say?”

“Sir, he wanted us to get him a fugu fish,” the guard replied.

“Go and get him one.”

“But sir, where do we get it at this late hour?”

“Go to the yamen of the River Flood Control Commission now, and tell the eunuchs there to find him a Fugu fish, regardless of the cost!”

In the bookkeeper’s office next to his silk mill, the grim-faced Shen Yishi piled up a stack of ledgers on top of a desk. Gao Hanwen sat on a chair nearby, watching. “Now that you and I are alone, let me be bold enough to show you these books, which I haven’t shown anyone yet – not even the imperial inspector. “

“Then I shouldn’t read them either,” said Gao, who immediately rose.

“I’m not asking you to read them.”

Gao looked baffled.

“I just want to confide something in you, both for your sake and mine,” Shen said calmly. “It’s purely for selfish reasons – I’ll enlighten you later. It’s totally up to you to decide whether to believe it or not.”

Gao fixed an intense gaze at Shen.

“Here’s what I’m going to do,” Shen said, picking up a ledger. “You don’t need to go through all of them. I’ll just pick a few important items from the past two years and read them aloud to you. Let’s just pretend that I’m mumbling to myself and you haven’t heard a word of them.”

Out of curiosity, Gao sat down again, his face turning serious.

Shen opened one book on the top and started:

In May 1560, the thirty-ninth year under the reign of Emperor Jiajing, fresh raw silk became available on the market. In June, the South China Textile Bureau ordered one hundred thousand bolts of high-class silk and sent it to eunuchs at the inner palace. In July, the governor’s yamen in Zhejiang and Yingtian purchased with taxpayer’s money fifty thousand bolts of high-class silk, one hundred thousand bolts of medium-class silk and one hundred thousand bolts of printed cloth and shipped them to the Ministry of Public Works, which used them to gift the dukes and princes, as well as kings of the tributary states, on behalf of His Majesty.

In October, the Textile Bureau concluded a trade deal with Persian merchants, who purchased two hundred thousand bolts of silk, translating into two million and two hundred thousand taels of silver. The payment went directly to the Interior Ministry coffers. Note: No need to notify the Ministry of Revenue.

The transactions jolted Gao out of his seat, but Shen ignored his reaction. Picking up another book, he resumed reading and kept his tone calm.

In February of 1561, the Interior Ministry issued an imperial edict, ordering all silk manufacturers in Yingtian and Zhejiang to support a trade deal with western merchants. The previous year, there were one hundred and twenty thousand bolts of silk in reserve. All the reserves should be kept and used for export this year. In March, the Interior Ministry issued an imperial edict, ordering the Textile Bureau to take one hundred thousand bolts of silk in reserve and ship them to the family of Princess Li in Beijing on behalf of His Majesty.

By then, Gao had become too stunned to breathe.

“Why don’t I stop for now,” Shen said, putting the ledger back on the pile. “As you probably know, there are three large silk manufacturers in the cities of Nanjing, Suzhou and Hangzhou. You’ll find hundreds of other smaller ones in the provinces of Jiangsu and Zhejiang. We also produce lots of cotton fabrics. Theoretically, if we collect half of the profits from these textile sales and give them to the national treasury, the money would be sufficient to cover a third of the national spending.”

Gao held his breath and stared at Shen.

“But, unfortunately, despite the large amount of silk and cloth we have produced, we still need more, and the national treasury is still in the red. Why? This year, the Imperial Palace even proposed that we produce three hundred thousand more bolts of silk. Where are we getting the silk? That’s how the land-conversion programme came into being.”

“Why are you sharing this with me?” Gao asked.

“As I said, I’m doing this for a selfish reason. What you’re hearing today will help you get a better idea of the local situation. It also helps you get smarter at your job. By confiding in you, I hope that we can be friends, even though I might be unworthy to be connected with Your Honour.”

Gao simply stared at Shen without talking.

“When the imperial inspector notified me last night, asking me to brief you on the silk industry here in Zhejiang, I was planning to tell you about these transactions,” said Shen. “But, hearing you talk so eloquently about music and history, I’ve recognised that you are the musically talented son of the well-known Gao family in southern Jiangsu Province. I started to feel attached to you. You probably remember the story of poet Su Dongpao. He was accused of implicitly criticising Emperor Zhenzong in his literary works. After the emperor read about it, he had planned to have Su Dongpo executed. But the empress consort opposed the decision on the grounds that it was not auspicious to eliminate a talented poet. That simple advice saved Su Dongpo’s life, who, during his subsequent exile, left us many literary masterpieces. I don’t mean to compliment you, but I really think it a pity for such a talented scholar like you to fall into this big messy political vortex. What a waste. It’s such a loss to the literary circles in southern China.”

Shen’s words, even though a bit grandiose and sycophantic, sounded sincere and personal. Gao was deeply touched by the silk merchant’s gesture. “Mr Shen, what are you trying to say?” he asked.

“I shouldn’t have shared these records with you because I have many friends in the government, such as Mr Zheng, Mr Ho and Yang Gonggong at the Textile Bureau,” Shen admitted. “But my relationship with these people is purely business. One might know many people for life without any true connections, but, for a special few, one feels like old friends at their first meetings. If you see me as a good friend, I want to offer some heartfelt advice.”

“Please! I’m all ears.”

“You should urge the flood victims in Chun’an and Jiande to sell their land as soon as possible so we could start planting mulberry in June,” admonished Shen. “Once this major task is complete, you should leave Zhejiang. I’ll lobby Yang Gonggong, asking him to use his connections to transfer you back to Beijing or to another province.”

Gao became alarmed. “If I understand you correctly, Mr Shen, you are suggesting that I should vote yes to the imperial inspector’s proposal and allow flood victims to sell their land at six hundred kilograms of rice or less per mu.”

“The arrow is fitted to the string, and we’re at the point of no return,” Shen replied resolutely. “If you don’t support this proposal, there is no way we can implement the land- conversion policy this year. If we fail, you’ll be the first scapegoat. They’ll put all the blame on you.”

“If the sole purpose of the Imperial Palace is to implement the land-conversion policy, I wouldn’t have accepted the assignment and come over here,” Gao said, his attitude changing from mere eagerness to righteous indignation. “When I proposed the policy of land conversion through disaster relief, my intention was to both help our country resolve a financial crisis and relieve flood victims of dire poverty. I want to thank you for taking the risk of sharing this inside information with me – it is eye-opening. But these shady transactions that you have shown me shouldn’t prevent me from acting on behalf of the one hundred thousand farmers who could lose their livelihood next year. If I did otherwise, I would be selfishly putting my career above public interest.”

“Please forgive me for saying this… If I put it mildly, I would say that Your Honour lacks familiarity with the local situation. If I’m being harsh – I would call your views too bookish and one-sided.”

“May I ask what you mean by bookish?” Gao asked, looking disappointed.

“You argued against the proposal because you think farmers would lose their livelihood after selling their farmland. But you have overlooked some critical facts. After the silk merchants buy up their land, who do they hire to grow mulberry and weave the silk?”

Gao did not answer.

“Many farmers today don’t own an inch of land. They simply lease the land from landowners and split the profits at harvest time. They make a pretty good living. Are you aware of any starvation among this population? At the same time, when we convert farmland and start to grow mulberry, we need to hire people to plant mulberry seedlings, pick mulberry leaves and rear silkworms. In the end, we also have to employ workers to weave them into silk. Think about it. Rice farmers who sell their own land this year could all become hired hands of big silk merchants next year. They can make a living growing mulberry or rearing silkworm. Nobody will be starving. Besides, our Imperial Government will not turn a blind eye to starvation if it occurs, will it?”

Gao thought about it for a few minutes before looking up at Shen. “Based on what you just told me, big silk merchants who have acquired farmland from flood victims will hire them next year. Is that correct?”

“Of course. Silk merchants don’t do field work. Without hiring those farmers, who is going to grow mulberry for them?”

“Will the flood victims get the sixty-forty split on the profits, like they do with planting rice?”

Shen was stumped by the question.

“As we can predict, there would be a large number of landless farmers competing to lease land. If landowners increase their profit split to seventy-thirty or eighty-twenty or even ninety-ten, what would farmers do? Are you going to lease or not?”

“I apologise for being unable to answer your detailed queries, but, since time immortal, people have always remained unchanged while officials come and go like flowing water,” Shen sighed. “If all the Ming officials are so concerned about ordinary folks like you are, we don’t even need to have this conversation.”

“Regardless, it is an honour to make your acquaintance.” Gao rose from his chair. “When I have a moment of peace one of these days, I’ll have to come and chat with you about music. Thanks for sharing with me the information regarding imperial spending. I promise I will keep it to myself and give your ideas some serious thought.”

“You seem to imply that we won’t be able to see each other again,” Shen said with a charming smile. “It’s still early. Would it be possible if I could take up another half an hour of your time?”

Gao knew exactly what Shen wanted, but he asked anyway. “What do you have in mind?”

“I wonder if you could spend a little time with my niece, enlightening her with your understanding of The Guangling Melodies.”

Gao looked hesitant; though excitement appeared on his face, deep down he had already said yes.

“Only half an hour,” Shen pleaded. “Then, if she gets it, it’s her good karma. If not, I can take comfort in the fact that I have tried.”

Gao turned his gaze to the sky outside the window. It was still light outside. “Mr Shen, you’ve put me on the spot,” he said. “Your niece plays elegantly.”

Shen took those remarks as “yes” and bowed deeply to thank Gao.

When Gao re-entered the studio with Shen, he saw that Madam Yun was standing in the middle of the room, rather than sitting on the platform bed, practising her guqin. There was an embroidered silk cushion next to her feet.

“It is my honour and your luck to have His Honour as your mentor,” Shen said to Madam Yun. “Please pay respect to your teacher now.”

Madam Yun slowly dropped to her knees and bowed.

“Oh, please stand,” Gao interjected, looking flustered.

Madam Yun bowed three times before rising. Then, she stood there with her head down. Silence fell.

“We only have half an hour,” Shen finally spoke up. “Why don’t you ask His Honour to play the piece and then tell you why you did it wrong. Try to learn it by heart. Once you have taken lessons from His Honour, I don’t think I’ll be able to coach you any more. In comparison, my knowledge and skills are too limited.”

Gao might have taken Shen’s remarks at face value, but Madam Yun understood their hidden meaning – Shen was not talking about music. Rather, it was a statement of how their heart-wrenching breakup felt. Conceited and ambitious, Shen set up a lethal trap for this talented young scholar, who could have swept any woman off her feet. How could outsiders see through such deceit and rancour?

“Understood,” replied Madam Yun, who was slightly choked with emotion. When Shen shot a parting glance at Madam Yun, their eyes met. Gao seemed to have sensed something odd between the “uncle” and the “niece”. As Gao was trying to figure out what it was, Shen quickly moved his stare away from Madam Yun’s face. “Please start,” he said softly. “I’ll wait outside and listen.”

Shen left the studio and closed the door behind him. Music wafted out from inside. Shen returned to his office and sat by his desk. He kept his eyes wide open but had problems focusing. His mind wandered unfettered in the air like the sound of Madam Yun’s guqin music, which he carefully monitored. Holding his breath, he attempted to capture every single note. Sometimes, the melody became so intricately gentle that it blended seamlessly with the sound of nature.

Suddenly, urgent footsteps sounded outside the door. Involuntarily, Shen knitted his brows and looked up impatiently. His personal aide tiptoed in, announcing the arrival of four eunuchs from the South China Textile Bureau. Shen looked away. Thinking that his master was deeply immersed in the music, the aide backed out. He put a finger to his lips and urged the eunuchs to keep quiet and wait until the music was over.

The eunuchs felt slighted and annoyed. “You are the one who called us over,” one of them whined loudly. “But then you kept us waiting outside. What’s going on?”

“Forgive me, my friends,” the aide whispered. “Just bear with me for a few more moments.”

Barely had the aide finished his sentence when the study door opened. Shen emerged.

“Mr Shen,” the four eunuchs bowed in respect.

Shen motioned for them to be quiet before inviting them inside. The four eunuchs, of diverse body types and shapes – one tall, one short, one fat and one thin – were trained like military men. They sat down on four chairs in unison. Shen walked over and handed each eunuch a money certificate.

“Please have some tea,” the aide offered.

The eunuchs ignored the tea. Without any pretence, they quickly looked down at the certificates – each carried one thousand taels of silver. The generous amount on the certificates brought satisfied smiles to their faces. Tucking his cheque into his breast pocket, the fat eunuch asked, “Do you want us to act now?”

“No rush,” Shen said. Then, he sat down on his chair and resumed listening to the music, with his eyes closed. The four eunuchs waited patiently. The music from the studio reached a crescendo.

Inside the music studio, Gao Hanwen sat next to Madam Yun on the stage, solid like Mount Jade. The fingers on his left hand, which pressed and slid across the strings, moved so swiftly that it gave the illusion that multiple hands were flickering. At the same time, his right hand deftly plucked at the strings, dancing across like blurry raindrops pelting against a window. His silk robe flew like clouds surrounding a mountain. Madam Yun sat on her knees on the far left side of the guqin, looking catatonic and oblivious to the violent rhythm of the music.

His two hands stopped abruptly in mid-air. The sudden change jolted Madam Yun from her stupor. She fixed her eyes on Gao’s hands. He seemed to have forgotten about Madam Yun’s presence. Slowly, his left hand struck the strings at an angle while his right hand plucked it gently. The guqin gave out a forceful dint, which sounded like a howl or the cry of a final farewell, followed by a sorrowful and yet enchanting melody that captured what Gao described as the essence of Ji Kang’s spirit before walking towards the execution ground. As the poet Qu Yuan wrote: Because straight is the gate, and narrow is the way that leads into life, and few there be that find it. Seeing the glistening tears in Gao’s eyes, Madam Yun started to weep silently, tears streaming down her cheeks.

Outside, Shen sat there, transfixed. Holding back his own tears, he moved both of his hands slightly in the air, as if he were playing the guqin himself. The four eunuchs observed him, looking baffled. Suddenly, the music came to another abrupt stop. It took a while for Shen to realise that the music had come to an end. He stood up. The four eunuchs also rose. “Can we go and snatch him now?” the fat one asked.

Shen paused for a moment before sitting down again. “Let’s give it a few more moments,” he said.

Inside, Gao collected himself and turned to Madam Yun, who was sitting on her knees, rapt. The sight of Madam Yun made him dizzy, and his heart was beating violently. This feeling must have been what poets call “a high mountain being joined by a flowing stream”. Gao no longer avoided Madam Yun’s gaze. “You come and play it for me,” he urged.

Madam Yun did not move. “Your Honour, it’s time you left,” she suddenly said. “We’ve already exceeded the half-hour limit. You’ll be late for your next appointment.”

Gao was shocked and somewhat offended by the abruptness of her words. But, when he looked at her again, he saw the sincerity in her eyes.

“Overstaying a few more moments wouldn’t make much of a difference,” he said with a smile. “I already promised your uncle that I was going to offer some guidance on the last movement. Come and play it.”

Gao slid his body away and vacated the seat in front of the guqin, but Madam Yun did not move. Then, her eyes sparkled with determination, as if she had made an important life decision at that instant. “Your Honour, we all have to die anyway,” she said. “When death arrives, would you be willing to make Mount Mang the final destination of your spirit?”

Gao was taken aback, but seeing the solemn expression on Madam Yun’s face, he turned serious as well. “Of course, I would follow Ji Kang’s path,” he pledged.

“I will too,” Madam Yun said before sitting in front of the guqin. Pressing a finger firmly on the guqin at an angle, she gently plucked a string, producing a similar howling sound, followed by a melody that bore a close similarity to that produced by Gao. While Madam Yun’s rendition began to echo that of Gao, capturing the pain and sorrows of Ji Kang’s last moments before his execution, it was also imbued with a sense of fearlessness, which accurately reflected Ji Kang’s upright character and his uncompromising disdain for the ruling class in the Kingdom of Wei. Gao’s heart leapt with admiration.

Outside, Shen noticed the unexpected tone in the music. Livid, he muttered to the eunuchs, “Go and get him.”

The four eunuchs, who had waited impatiently for this moment, jumped up and swarmed towards the door like bees dashing out of the hives.

“Wait,” Shen stopped them. “All I want is a piece of written proof. Don’t hurt him.”

“Understood,” the fat eunuch replied. “Let’s go.”

The four eunuchs kicked the door open and burst into the studio. Their sudden appearance startled Gao.

The fat eunuch shot Gao a disdainful glance. “Your Honour is certainly a talented and romantic person.”

“You’re not only romantic but also bold,” the thin eunuch jumped in with sarcasm. “How dare you seduce Yang Gonggong’s feeder?”

“What shall we do?” the tall eunuch asked, feigning helplessness. “We’re supposed to keep an eye on her. If Yang Gonggong finds out, we’re all going to be in big trouble.”

“I have an idea,” the short eunuch suggested. “Can we bother Your Honour with a request? Could you be kind enough to write a note, claiming that your affair has nothing to do with us. I’m sure you understand our situation. Please have mercy and spare us the trouble.”

“What are you talking about? Who is Yang Gonggong? What is a feeder?” Gao shouted. By then, he had realised that someone had set up an elaborate trap and he had fallen right into it. But still, he was incredulous and turned to Madam Yun, who sat in front of the zither, calmly.

“Yang Gonggong is the director of the South China Textile Bureau, and I’m the girl who services him,” Madam Yun replied. “In the palace, people like me are called feeders.”

Gao’s face turned pale, and his body trembled. “Who is Mr Shen, really?” he asked. “Is he your uncle?”

“No, he’s the largest silk merchant who bought me while I was a little girl in Suzhou and gifted me to Yang Gonggong.”

The revelation stumped Gao, who felt as if someone had struck him on the chest with a blunt instrument. Meanwhile, Madam Yun gazed at him unabashedly. Her eyes showed guilt and deep affection.

“Please tell your owner who orchestrated this that I’m NOT going to write anything,” he told Madam Yun. “By the way, please do not play The Guangling Melodies again. Maestro Ji Kang will condemn you from above for your treacherousness.”

As Madam Yun lowered her head to hide her tears, Gao strode towards the door. The four eunuchs quickly formed a human wall and blocked him.

“We can’t let you go,” the fat eunuch said. “If we allow you to escape, what are we going to say to our master?”

Gao confronted the eunuch with disdain. “Are you asking my advice on what to do?”

“Yes,” the fat one replied.

“Let me give you an idea,” Gao said.

The four eunuchs made eye contact with each other and said, “All right. Please advise.”

“Go and get your daggers, and kill me right here.”

The four eunuchs were stunned momentarily before collecting themselves. “Are you blackmailing us?” asked the short one. “We’re so scared.”

“He is a mayor – killing someone means nothing to him,” the thin one muttered sarcastically.

“Stop it,” the fat eunuch chastised his colleagues before turning to Gao. “We don’t have the right to kill you, but Yang Gonggong can kill us. All four of us have been assigned to watch Madam Yun while our master is away. But now, this woman has snuck away to cheat on him. If Yang Gonggong is back, he’s going to kill us. Since we’re going to die regardless, why don’t you kill us first before you run away?”

Tearing his shirt open, the fat eunuch bared his chest, revealing a pile of pale flesh. Then, he dropped to his knees in front of Gao. The other three followed suit and fell on their knees with bare chests.

Gao stood there, exasperated at the eunuchs’ shameless exhortation, but he had no idea what to do.

Darkness was descending, and there was no sign of Gao Hanwen. Hai Rui and Wang Yongji anxiously rose and walked to the door. They had been waiting inside the visitors’ room at the mayor’s yamen for hours. An aide stepped in to light the candles. “Could you go again and find out when His Honour is returning?” Wang asked. “Does anyone know where he has gone?”

“He went to visit a silk factory in the morning and came out of there in the early afternoon,” replied the aide. “Then, he sent all of his assistants back here and went elsewhere. Nobody knew where. All he said was that the South China Textile Bureau would arrange a sedan chair to take him home. May I recommend that you take a rest at your hotel? Once His Honour is back, I’ll let him know right away.”

Hesitant, Wang looked to Hai, who insisted that they should stay.

“All right,” the aide said. “I’ll prepare some food for you.”

After the aide left, Wang became more concerned. “We’re discussing the proposal tomorrow morning, but our mayor is nowhere to be seen,” he said. “Do you think something might have gone wrong…”

“Let’s just wait a bit longer,” Hai suggested. “If he doesn’t show up at seven o’clock, we’ll look for him at the imperial inspector’s yamen.”

As they were talking, Gao Hanwen stepped in with the aide, who carried a lantern. Both Wang and Hai rose to greet him, but Gao looked too distracted to notice them.

“You can go now,” Gao said to his aide; his voice sounded a bit hoarse.

After the aide exited the room, Gao realised that Hai and Wang were standing there, waiting to greet him. He quickly collected himself and said, “I’m sorry – I didn’t realise that you two would be still waiting for me at this late hour.”

“Since we’re revisiting the proposal tomorrow, we hope to strategise and hear your views,” said Hai.

Gao shifted his gaze away uneasily. “I have nothing to be ashamed of before the heavenly god and men,” he said. “I hope the two of you can fight for the interests of people in Chun’an and Jiande.”

Shocked and baffled, Wang looked at Hai, who fixed his eyes on Gao’s face. They both suspected that something had happened, but neither knew what it was.

The meeting to discuss the land-conversion proposal resumed. What a difference a day made. The mood in the room had changed from sombre to confident. Zheng Bichang was sitting in his old chair behind the centre of the desk. Despite his grave expression, he remained alert. His eyes scanned the room, sizing up everyone in attendance.

Ho, surly and disagreeable at the previous discussion, looked unusually relaxed. He sat slumped on a chair on the left side of the desk, playfully tapping his fingers on the desk. What was officialdom, anyway? It was the domain of officials. Outside the domain, one hankered after the pomp and style. Once inside, Ho tried to build charisma, creating a positive aura around him.

The officials who attended the discussion today could feel a different vibe from Zheng and Ho, even though they had no clue as to what had happened after their previous meeting.

Could the proposal sail through? They couldn’t help scrutinising Gao’s face, trying to find some clues. Gao sat upright on the right side of Zheng, looking his usual self. But upon closer inspection, one could discover a subtle difference on his face, which looked haggard and showed traces of fatigue – probably from the long journey. He stared off into space. In addition, there was no aura of excitement in the meeting that typically surrounded a new appointee. In fact, he seemed to be a bit lost.

Hai and Wang sat on two benches that had been brought in at the last minute and placed at each end of the desk. With a heavy heart, Wang watched Hai at the opposite end while Hai was studying Gao’s reaction.

“Let’s start,” Zheng spoke up, looking straight ahead at the garden outside. Attendees straightened their backs and became attentive.

“As the saying goes, one does not realise the difficulty of an undertaking until one has experienced it oneself,” he said. “Mayor Gao visited the Textile Bureau yesterday. Our two new magistrates had the chance to walk around the rice market. By now, I assume that they should have a better idea of how to implement the disaster-relief-through-land-conversion policy. Let’s take another stab at the proposal today.”

Zheng’s aide picked up a stack of newly copied proposals and began walking around the room, placing a copy in front of each attendee. Since Hai and Wang sat on benches without a desk, he handed them the proposal. Except for the faint sounds of the pages turning, the room was quiet. It didn’t take long to peruse the two-page document, which merely contained six paragraphs of more than two hundred characters. Everything remained the same – not a single character had been changed or added.

People exchanged glances knowingly before turning to Zheng, who was still gazing straight ahead into the garden outside. Wang peeked at Hai, who had closed his eyes with the proposal sitting on his lap.

Meanwhile, Ho kept his eyes trained on Gao. When he noticed that the new mayor did not even touch the proposal in front of him, he couldn’t help asking, “Mayor Gao, are you done with both pages?”

“Do I have to?” Gao raised his head and replied with an uncompromising tone. “Not a character has changed since I last read it.”

“It’s true that we haven’t changed a word,” said Ho, who leaned back in his chair, with an arrogant demeanour as if he could instantly crush any opponent into flying ashes. “Mr Gao, you started out as a scholar and should know that a good article often requires no addition or deletion, and it stands as a masterpiece regardless.”

When Ho deliberately emphasised the word masterpiece, Gao flinched, as if someone had thumped at his chest, but he managed to stare right into Ho’s eyes in defiance.

“If we do need to modify anything, I would change the slogan to Resolving both challenges without a single word change,” said Ho with complacency.

Gao held on to the edge of the desk, attempting to rise, but suddenly looked like he was experiencing dizziness. Meanwhile, Zheng stood up. Scanning the room, he said, “Yesterday, we held a long discussion with Mayor Gao regarding how to implement the rice-to-mulberry land conversion in Zhejiang, especially in the counties of Chun’an and Jiande. At the moment, we only have three days’ worth of rice for flood victims. At the same time, the mulberry season is upon us, and the seedlings will need to be planted by June. Also, the flooding problem is still pretty dire. If we keep postponing and can’t make a decision soon, we will be condemned for failing to live up to His Majesty’s expectations as well as for ruining the lives of ordinary people here. Therefore, after getting a better grip on the situation, Mayor Gao has agreed to our plan. Now that we don’t have any opposition, let’s sign off on it.”

Calligraphy brushes and ink had been prepared for every official, most of whom quickly hunched over the proposal to sign their names on it. But Gao sat there without picking up his brush.

Zheng looked Gao in the eye and reminded him, “Mayor Gao, are you going to sign it?”

“Without any changes, I can’t give my approval,” Gao said, after summoning up whatever courage he had left.

Zheng eyed him critically. “Why don’t you think about it more?” he asked Gao calmly.

As Gao struggled to stand up, Zheng shouted out to the servants, “Bring out the tea.”

As if on cue, a male servant stepped in carrying a tray with eight cups of tea on top. Rather than following the order of each official’s ranking, the servant reversed it, starting with Hai and Wang, two low-level magistrates who had been invited as guests. After placing the tea on their benches, the servant went around the room, serving those who were sitting behind the long desk. Soon, there was only one cup left on his tray. The servant stopped in front of Gao. With a faint smile, he raised the tray slightly.

Gao did not take the cup. “Please put it down on the desk,” he mumbled.

The servant ignored him. Instead, he pushed the tray closer to Gao, who responded with a look of disgust. But then, Gao noticed that the servant tried to signal something on the tray with his eyes. When he glanced down, he saw a piece of letterhead paper with writing on it under the teacup. Gao’s face went pale. He stood there, stunned, without picking up the teacup. The servant did not force him. Instead, he lifted the cup from the tray and placed it on the desk. Before walking away, the servant tilted the empty tray slightly towards Gao. The letterhead paper revealed two lines of characters – I take sole responsibility for my meeting with Madam Yun. Gao’s own signature was printed at the bottom.

The servant exited quietly like a breeze. All attendees, except Hai, fixed their eyes on Gao, waiting for him to express his views. Hai’s eyes remained closed. Gao slowly raised his right hand and reached out to grab the paintbrush from the holder. Even though he tried to control his emotions, his hands were still trembling.

Seeing that Gao was about to sign on the proposal, Zheng and Ho looked visibly relieved. They leaned back in their chairs.

Wang rose from his chair all of a sudden and shouted, “Your Honour, Mayor Gao,”

Holding the paintbrush in his right hand, Gao stopped and looked up. So did Zheng and Ho. Hai also opened his eyes.

“I have a few questions that need your attention,” Wang pleaded.

“Please go ahead,” Gao replied. Like a person who had been abruptly pulled back from the edge of an abyss, Gao looked jolted. He put the paintbrush back in the holder.

“The imperial inspector stated that he had conversed with you about the proposal yesterday,” Wang said. “While it is true that the rice allocated for flood victims can only last three days and that mulberry seedlings need to be planted by June, these are the same facts that we discussed during our previous meeting. You opposed the plan the day before, citing that it wouldn’t work. With the situation remaining unchanged, what makes you think it will work today? Could you help us understand the rationale?”

Boom, boom, boom! Ho banged on his desk, yelling at Wang, “Why is the document confusing to you? The plan is based on facts. It should have been approved the day before.”

“Sir, please allow me to finish,” Wang said, joining his hands in front of his chest respectfully. “Even though I have just been transferred from Kunshan County, I know Jiande very well because I served there before. Based on my knowledge, there are two hundred and seventy thousand registered households in Jiande, with four hundred and forty-four thousand mu of registered farmland. About one hundred and fifty thousand mu are covered with mulberry trees, and they are currently owned by large silk merchants. The rest, two hundred and ninety thousand mu, grow grain. For each season, farmers can expect a yield of one hundred and twenty-five kilograms of grain per mu. In a bad year, the yield is about one hundred kilograms. On average, each farmer can get one hundred and fifty kilograms of grain per year. Once the husks are removed, it’s about one hundred and twenty-five kilograms of rice. In other words, each person has about three hundred and fifty grams of rice per day. That might be sufficient for young children and the elderly, but it’s not enough for an adult. Fortunately, Jiande is rich in natural resources. Families can grow tea or Tung trees, or they can catch fish or shrimp in the river to sell them on the market for extra cash. With the money, they can pay their taxes and use the leftover to buy oil and salt. Most families live from hand-to-mouth. Life is hard.”

“We can get those stats from the Civil Affairs Department,” Ho interrupted impatiently.

Wang did not look at Ho. Instead, he continued with his argument. “The flood this year has destroyed half of the farmland, about one hundred and forty thousand mu. If farmers sell this land, they’ll have no choice but to grow crops on leased land. If they plant rice, they could split the yield with landowners. This means that they could probably get seventy-five kilograms of grain each year. Once you remove the husks, each person can probably get one hundred and fifty grams of rice per day. But, if they grow mulberry trees, the landowner wouldn’t split the silkworms at fifty-fifty. It would be less. If farmers barter the silkworms with rice, they will get less than one hundred and fifty grams per day. Your Honour, would you be able to subsist on one hundred and fifty grams of rice per day?”

Gao did not answer. His eyes were filled with pain as he stared at Wang. “It’s certainly not enough,” he finally replied.

Wang went on to cite Mencius. “Yu, the Great^(1) thought that if anyone in the kingdom was drowned, it was as if he drowned himself. Sheji^(2) thought that if anyone in the kingdom suffered hunger, it was as if he famished himself. Your Honour, whatever you’re going to write with that paintbrush in your hand could affect the livelihood of tens of thousands who are drowning and starving. I strongly urge prudence.”

The attendees, most of whom were locals, knew that Wang was telling the truth. But having worked inside the government bureaucracy for so long, they had become numb and inured to the harsh realities. To protect their own interests, they often chose to look the other way. Wang’s remarks touched them deeply. Everyone looked grim. Silence fell.

Knowing that his peers expected him to issue the final word on the proposal, Zheng stood up. “Everything that Magistrate Wang has stated is true,” he said. “I used to head Zhejiang’s treasury department and took charge of grain distribution. I was very familiar with the situation in Jiande. In fact, I knew by heart what was happening in every county. Every county has its own difficulties, and every province faces its own challenges. But all these are trivial if one takes into consideration the grim fiscal situation of our country – our national treasury is empty. Along the north and northwestern border, we are facing constant invasion from the Mongols. Here, along the coasts in Zhejiang and Fujian, the pirates are rampant. We need to strengthen our military to protect our borders and build ships to fight the pirates and safeguard our sea routes. All these efforts require money, and we don’t have it. That’s our reality.”

Then, Zheng suddenly raised his voice and reprimanded Wang. “You’re a menial magistrate. All you care about is your county. How dare you hijack a national initiative with your ranting and try to stop senior officials from signing the proposal? Based on the rules here, lowly magistrates like you have no right to intervene in provincial decisions.”

Before Wang had the opportunity to respond, Zheng called out to his aides waiting outside, urging them to remove Wang and Hai from the room.

The servant who had served tea to the attendees came in. He walked up to Wang, who was standing, and grabbed his bench from behind. Then, he stopped in front of Hai. “Sir, please rise as I need to take your seat away,” he pleaded.

Hai stood up reluctantly. The servant snatched the bench. With the two benches secured under each of his arms, the servant dashed out. Hai and Wang stood there firmly, waiting for Gao to speak up.

Gao turned to Zheng and begged, “Your Honour…”

“Don’t forget who is in charge here,” Ho interrupted Gao. Pointing his fingers to Hai and Wang, he yelled, “Did you hear what the imperial inspector just said? Get out.”

“Where do you want us to go?” Hai asked calmly.

“You can go wherever you want,” Ho said with utter indignation.

“All right then. We’ll want to go to Beijing and visit the Ministry of Personnel and Ministry of Justice,” Hai said. “Then, we’ll get ready for our execution at the Meridian Gate.”

“What are you talking about?” Ho glared at Hai.

“We’re going to ask whoever has appointed us – Why did you send us here?”

“Are you threatening the Ministry of Personnel or are you simply threatening the provincial yamen in Zhenjiang?”

“In a matter of hours, you have succeeded in cowering the newly appointed mayor of Hangzhou into silence,” Hai replied in sarcasm. “I’m a mere magistrate – who do you think I can threaten? Nobody.”

Hai’s bold remarks infuriated Ho, but Hai disregarded him. Instead, he confronted Gao. “Mayor Gao, we made an arrangement to visit the rice market yesterday morning and a silk mill later, but you were called away by the imperial inspector at the last minute,” Hai said. “Just now, the imperial inspector told everyone that the two of you had a deep conversation over the proposal. Where did the conversation take place? We went to look for you at the imperial inspector’s yamen and the Textile Bureau, and nobody knew where you were. Would you mind sharing with us what you discussed? I’m asking this because it strikes me as odd. You were strongly opposed to the proposal the day before. But today, you suddenly agree to the very same proposal. What has made you change your mind?”

“That’s offensive!” Ho banged on his desk. “Come in and get him out of here,” he shouted to the guards outside.

Ho’s aide and two uniformed guards stepped in.

“Don’t you dare!” Hai howled, his voice vibrating in the hall. The guards stood there, stunned. Hai glowered at Zheng and stated, “You don’t have the right to detain me. Read the Ming administrative law. For an official appointed by the Ministry of Personnel, unless he has committed the crime of colluding with enemies, deserting the city of which I have custody during war or embezzling public funds, an imperial inspector can report him but has no right to detain him. Your Honour, please order your guards to withdraw.”

Nobody had expected that such a daredevil would emerge among them. The attendees looked at each other in shocked silence. Zheng was trembling with anger, but he also knew that Ho’s decision to detain Hai was highly risky and could lead to a political deadlock.

Taking a deep breath, Zheng conceded, motioning the guards to withdraw. “All right, all right, I won’t put you in detention,” he muttered under his breath with a fierce menacing look; his trademark calmness and civility had evaporated. “But I want to warn you… It is not because I don’t have the right to detain you. Given your disruptive behaviour at the meeting and your attempts to derail the implementation of an important national policy, this office of mine can lock you up in a cage and ship you to the capital for punishment. But I have decided not to do that now. I want you to travel to Chun’an County and work on the disaster relief and land-conversion programme right away. The government food subsidies for disaster victims are running out in three days. If your county doesn’t implement the land-conversion policy, if starvation occurs, if there are riots, I’m going to request an order to have you beheaded. I don’t have to seek permission from His Majesty – do you know that? You’re probably aware that the former mayor of Hangzhou, your predecessor, Chang Boxi, and the former magistrate in Jiande County, met their ignominious fate this way.”

Hai remained undeterred. “The former mayor and my predecessor deserved capital punishment. In fact, that’s the very topic that I intended to bring up myself,” Hai said in defiance. “Last year, the neighbouring province of Yingtian spent three million taels of silver to repair and boost the dams along two rivers, which have remained intact during this year’s flooding. Here, in Zhejiang, we allocated two-and-a-half million taels on one river. But the dams broke in nine counties. Sir, you were in charge of the treasury, and the money was spent under your supervision. How do you explain the sudden dam breaks along the Xin’an River? I know I will not be able to get an answer from you today, but one of these days someone may want an explanation. Chun’an and Jiande Counties became flooded due to the government’s emergency flood-diversion plan. All government agencies should focus on finding ways to help the victims. But, unfortunately, none is doing it. Instead, you allow ordinary people to shoulder the burden by themselves and take advantage of their dire circumstances. If starvation and riots occur, the Imperial Palace will no doubt launch investigations and get to the bottom of the matter. You can certainly have me executed for saying this, but in the end it won’t exonerate the true criminals from facing justice.”

Zheng’s face turned pale while Ho and the other officials looked flabbergasted. With his trembling hands, Zheng grabbed his gavel and banged on the desk. “Hai Rui, you’re fabricating stories to frame your superiors,” he shouted. “Do you know that there are specific clauses in our law to punish people like you?”

“I used to be a teacher in Nanping, a small county in Fujian Province,” Hai replied calmly. “I’ve only been here for three days. It is probably not a good idea to assign blame on me for the breaking dams in nine counties along the Xin’an River, is it? Last year, Zhejiang Province allocated two and a half million taels of silver to river repairs. I didn’t fabricate that figure, did I?”

Before Zheng had the chance to repudiate Hai’s accusations, the Chun’an magistrate turned to Gao. “Your Honour, this motion contains six provisions with a little more than two hundred words. But, in the future, if you want to probe into the true stories behind this motion, you can probably fill up a whole archival room with files. No matter what happened to you yesterday, I think it’s your personal matter, and, if any injustices have been done to you, I’m confident that they will be cleared. But if you have erred, you should confess and seek redress. Regardless, the current proposal involves a crucial national policy and concerns the lives of several hundred thousand. The water is deep and murky, and there’s a lot that we don’t understand. You’ve only been here for three days. If you sign off on it and the whole thing proves to be a trap, the consequences could be irreversible.”

There was dead silence in the conference hall. Gao looked up, and his eyes, filled with confusion and pain, met Hai’s, which were sparkling with anger. Gao seemed to be touched, and his body shifted slightly in his chair. Zheng, Ho and the other officials looked on with murderous hostility.

At this moment, a guard rushed in and got down on one knee in front of Ho. “Your Honour, we have received an emergency report from Chun’an County.”

Ho sprung to his feet and grabbed the report. After skimming through it, Ho glowered at Hai and Wang. “That’s just great,” he said sarcastically. “Thanks to your delay and boycott, the scoundrels in Chun’an have teamed up with the pirates and started a riot. Magistrate Hai, did you know that you released a rebel leader called Chee Dazhu yesterday? He led a group of peasants in Chun’an and tried to instigate an uprising with the help of the pirates. Fortunately, we have captured him.”

Wang appeared shocked, but Hai stood motionless. He still fixed his gaze on Ho’s wrinkled face, waiting for him to finish.

Ho looked away and turned to Gao, who turned ghastly pale. “Mayor Gao, both Chun’an and Jiande fall into your jurisdiction,” Ho said. “What do you think we should do?”

Summoning all his strength, Gao stood up. “We still need to find out if those peasants from Chun’an have colluded with the pirates,” he said. “If the allegations prove to be true, they should be punished right away. But Magistrate Hai just arrived in Zhejiang two days ago. I don’t think he should be held accountable…”

“He is the one who ordered the guards to release the rebel leader,” Ho replied, banging his fist on the desk. “How can you claim that he has nothing to do with the case?”

Even though Gao was lucid enough to know exactly what his opponents were trying to do, he felt helpless. This sense of helplessness gradually moved up in his heart, making him dizzy. He closed his eyes, reminding himself not to fall. But then, a sharp pain in his lower abdomen struck him. He clenched his teeth and muttered to himself, “Don’t fall… don’t fall…”

Those were the last words that Gao remembered before collapsing on his back like a cheap wooden stake. His sudden fall took everyone by surprise. Zheng jumped to his feet, and the others rushed over. Hai and Wang looked utterly confounded. They stared at Gao’s empty chair and desk.

“Can we get some help?” Zheng shouted. Footsteps sounded in the hallway, and soon several guards barged in. “Who has ordered you to come?” Zheng yelled. “Please leave.” Before the guards retreated, Zheng left instructions for his aide. “Get someone to take Mayor Gao to the back and call a doctor right away.”

The aide ran to the door and shouted, “I need two people here.” Two office assistants, one of whom had brought in the tea, rushed in and went behind Gao’s desk. The new mayor was lying flat on the floor, unconscious. “Please be careful,” the aide instructed the two assistants. “Put your hands underneath his shoulder and back, and let’s carry him with his face up.”

Slowly, the three men lifted Gao in the air and, amid everyone’s shocked gasps, carried Gao to an area segregated by a screen at the back of the hall.

“Let’s forget about the proposal today,” Zheng announced decisively before turning to Hai. “We’re going to find out later if you have anything to do with the case involving peasants colluding with pirates. For now, I’m sending you to Chun’an with police officers from the Justice Department. First, I order you to supervise the execution of the pirates and their collaborators. Then you start implementing the land-conversion programme, as we have discussed.”

Hai stood there without moving. Wang shot him a worried glance.

Seeing that Hai Rui looked reluctant, Ho barked at a police officer who had been called in. “Get your men ready, and escort Magistrate Hai to Chun’an immediately.”

“Yes, sir,” the officer saluted before going up to Hai. “Magistrate Hai, this way please.”

Hai remained still. He looked at Zheng and asked, “May I pose a question? If these policemen go with me to Chun’an, should they listen to me or is it the other way around?”

Startled by Hai’s unexpected question, Zheng replied, “They’ll listen to you if you follow the instructions from my yamen.”

“What if I handle the case truthfully? Will they follow my orders?”

“What do you mean by truthfully?” Zheng asked.

“The provincial police allege that several peasants in Chun’an have colluded with pirates,” Hai answered. “How did they do that? Which pirates did they contact? I have to look into these allegations carefully. If they prove to be true, I’ll apply the law accordingly. But, if these are false, do you intend for me to have them executed even if they are innocent?”

“Are you trying to instigate a boycott against our national policy?” Zheng accused.

“Your Honour, I’m merely asking if you want me to ignore truth, abuse power and kill the innocent?”

“I would never ask you to ignore the truth and kill the innocent,” Zheng yelled as he slammed his fist on the desk.

“That’s exactly what I want to hear,” Hai said, putting his palms together in front of his chest to show his respect. “I will handle the case in accordance with the truth.”

Before departure, Hai said to the police officer, “You just heard what His Honour has said. Get everyone ready and let’s go to Chun’an.”

Baffled by Zheng’s words, the officer stood there, looking to Ho for guidance.

“Don’t stare at me,” Ho scolded him. “Do whatever you need to do. Go.”

As the officer was dashing to the door, Wang’s eyes anxiously searched for Hai, who had by then reached the outer entrance. “Magistrate Wang,” Zheng called out. “You know what to do in Jiande, don’t you? Leave now and start the land-conversion plan immediately.”

Wang bowed to Zheng before marching out.

In the public square outside the imperial inspector’s yamen, Hai mounted his horse. “Let’s go,” the officer ordered. Police officers, about thirty or so on horses, escorted Hai onto the street. As they galloped away, Wang waved at Hai. In the distance, Hai’s body bobbed up and down among the horses, which looked like moving hills. In a few minutes, they disappeared in the setting sun, which painted the sky in bloody red.

Back in his hotel room, Wang sat down behind his desk and struck a match to light up a candle. “Go and pack your stuff,” he told his aide. “I’m going to draft a letter for you to deliver to Mr Tan Lun in Suzhou.”

“But who’s going to accompany you to Jiande?” his aide asked.

“I can go by myself,” Wang replied impatiently. “No need to worry about me. Go and pack.”

After his aide left, he pulled up a chair next to his desk, set out a piece of paper on the desk and began writing with his paintbrush.

Then, there was a soft knock on the door.

“Who is it?” Wang asked, sounding alarmed.

“Someone from the imperial inspector’s office wants to see you,” his aide answered from outside.

Wang quickly hid the letter inside a book. “Do you know what the visit is for?” he enquired.

“The person said Your Honour left some documents at the meeting today, and he has brought them over,” his aide answered.

Wang picked up the book from his desk and tucked it underneath his bedding. Then, he walked over to open the door. It was the imperial inspector’s assistant who served tea at the conference. He walked in with a nervous smile on his face. Wang did not offer him a seat.

“Where are the documents?” he asked. The assistant handed him a stack of papers.

“Thank you for doing this,” he said. “Anything else?”

The assistant simply stood there without saying anything. Knitting his brow in annoyance, Wang walked over to his bed and took out a few coins from his wallet. When he turned around, he saw that the assistant had closed the door. “Is there anything else you need?” Wang handed him the change. “If not, please leave.”

The assistant shook his head and refused to take the change. “What the hell do you want?” Wang asked again.

The assistant tried to move closer, but Wang winced and involuntarily took a step back.

“Sir, I have something important to tell you,” he said quietly. “You have to memorise it.”

Wang looked at him with scepticism.

“The Provincial Justice Department released a pirate from prison and sent him to Chun’an to sell rice to peasants,” the assistant whispered to Wang’s ear. “So the whole thing is a trap.”

Wang was shocked; his eyes bored into the assistant’s.

“The imperial inspector set another trap for Mayor Gao,” the assistant continued. “They sent him to visit Mr Shen, an important silk businessman here. Mr Shen arranged a seductive young woman for the mayor. I think he might have fallen for it and they caught him red-handed.”

“Why are you telling me this?” Wang asked, shocked and alarmed.

“Your Honour, I’ve worked at the imperial inspector’s yamen for more than four years.”

Wang failed to comprehend what he meant by that.

The assistant stomped his feet on the floor and said impatiently, “Don’t you remember the previous imperial inspector?”

Wang understood, but he didn’t say anything.

Seeing that Wang would not respond to his hints, the assistant felt obliged to state it more explicitly. “I started my job when Hu Zongxian was the imperial inspector. I’m his man.”

Convinced by his explanation, Wang began to warm to him and nodded in gratitude.

“Both Governor Hu and Tan Lun are in the city of Suzhou at the moment,” he reminded. “You should probably send someone to deliver the news as soon as possible.”

Then, he turned around and bolted out. Wang stood at the door, watching him disappear in the darkness. The news sent his mind into a tailspin. He shut the door, pulled out the letter that he had written from under his bedding and set it over the candle. The letter quickly went up in flames. Blowing the ashes onto the floor, he sat down at his desk, laid out a piece of paper and began writing a new letter.

8

The crimson cinnabar ink inside the violet gold alms bowl brought to mind the image of fresh blood. When Grand Secretary Yan Song dipped his paintbrush in the bowl, the ink rippled. He was sitting opposite his deputy, Xu Jie. The two old men, one in his eighties and the other in his sixties, were hunched over their desks, contemplating and composing what was known as the “blue essay”, a laudatory paean to the heavenly god and the emperor on a special porcelain blue paper made from a special recipe of fibres and ground leaves. Every now and then, they stared at the crimson characters through their thick reading glasses, while pondering what words would come next.

The blue paper looked sumptuous, and the crimson calligraphy manifested strength and elegance.

The outside world might be in chaos, but nothing was important enough to distract the two senior ministers from their regular writing routine – composing grandiose prose inside the Western Palace for Emperor Jiajing, who, according to historians, was a big fan of blue essays. Given that this type of prose had its origin in Taoist ceremonies during the Tang dynasty, it came as no surprise to his ministers. Rumour had it that Emperor Jiajing frequently assigned essay topics to his two senior ministers. After reading their essays, he would burn them as tributes to heaven. Since Grand Secretary Yan Song and his deputy Xu Jie knew how to write in the styles that the emperor liked, their compositions had won much praise. Historians sometimes referred to Yan and Xu as “blue-essay ministers”. Those essays might sound flowery and superficial, but deep beneath the sometimes ludicrously sumptuous prose lay hidden the two men’s philosophies and concerns about national affairs, as well as their complex relations with the capricious monarch.

“I’m too old for this,” said Yan Song, as he put the finishing touches on his essay and then carefully placed his paintbrush inside a holder. Removing his reading glasses, he rested his hands on the edge of the desk and slowly got up.

“Are you finished already?” Xu looked across at Yan. He was still working on his ending but felt obligated to take off his glasses and rise.

“It took me more than a whole hour to write one hundred and sixty-nine characters,” Yan sighed, patting his lower back. “Age creeps up on you, whether you like it or not.”

“If that’s the case, I’m the one who’s truly old and dim-witted,” Xu said. “For that one hundred and sixty-nine words, I’m a couple of lines behind you.”