Article 46, Paragraph 1 of the Administrative Litigation Law of the People's Republic of China explicitly stipulates that where citizens, legalns, or other organizations directly bring a lawsuit to the people's court, they shall file the lawsuit within six months from the date on which they knew or should have known that the administrative was made. The time limit for filing an administrative lawsuit is an institutional arrangement designed to safeguard the lawful and timely exercise of the right of action by citizens, legal persons, and other orizations, as well as to support and supervise administrative organs in exercising administrative power in accordance with the law. It plays a crucial role in standardizing litigation procedures and substantially resolving administrative dispute. On April 30, the "Interpretation of the Supreme People's Court on Several Issues Concerning the Application of the Time Limit for Filing Administrative Litigation" ter referred to as the "Interpretation") was issued. This further unifies standards for the application of the law and clarifies adjudication rules, providing authoritative guidance for ct all levels to accurately apply the provisions on the time limit for filing when hearing administrative cases. At the same time, the Supreme People's Court released four typical cases regarding the application of ew rules for the time limit for filing administrative litigation, further strengthening adjudication guidance. Determining the Starting Point of the Time Limit: Content and Subject When an administrative organ makes an adstrative act without preparing or serving legal documents, and subsequently refuses to acknowledge the implementation of the act, how should the starting point of the time limit for filing be determined if the parts unaware of the subject that implemented the administrative act? The Case No. 1 released this time provides clear judicial guidance on this issue.

Henan Qianmou Agricultural Technology Co., Ltd. (hereinafter referred to as "Qianmou Company") sublet part state-owned farm land it had contracted to a third party, Zhengzhou Shuimou Ecological Agriculture Co., Ltd. (hereinafter referred to as "Shuu Company"). On the remaining land involved in the case, Qianmou Company constructed ancillary facilities and conducted operations, naming it Wanmou Garden.On May 25, 2020, the Forestry and Gardening Bureau of Huiji District, Zhengzhou City, Henan Province, issued a "Notice" to Waen, ordering it to cease destructive activities and rectify the situation to restore the original state within 7 days, citing the unauthorized conduct of production and business activities that destroyed the ecological environment aresources of the Yellow River wetland within the protected area. From July 12 to 15, 2020, some attachments on the land involved were forciblyolished, but the relevant administrative authorities all denied carrying out the demolition.

Company S filed a lawsuit prior to Company Q. An effective judgment rendered on December 10, 2021, confirmed that the Town People's Government of Huiji District, Zhengzhou City, Henan Province (hereinafter referred to as the "Guxing Town Government") and the Management Commitof Zhengzhou Agricultural High-tech Industry Demonstration Zone, Henan Province (hereinafter referred to as the "Demonstration Zone Committee") committed an illegal act by demolishing the attach on the land belonging to Company S. Upon learning of the content of the aforementioned judgment, Company Q filed this lawsuit on March 1, 2022, requesting a judgmenconfirm that the forced demolition acts of the Guxing Town Government and the Demonstration Zone Committee were illegal.

The crux of the dispute in this case is whether Company Qian failed to exercise its right of action in a timely manner following the forcedolition, and whether the lawsuit it filed has exceeded the statutory limitation period. The "Interpretation" provides clear stipulations on this issue, indicating that the content of "knowi should have known" includes not only knowing or should have known the content of the administrative act, but also knowing or should have known the administrative agency that made the administrative act. ractice, the plaintiff may know or should have known the fact that their house or facilities were forcibly demolished, but when the relevant administrative agency refuses to admit being the implementing entity, the piff may face difficulties in providing preliminary evidence to prove the implementing entity. In this case, the alleged forced demolition of facilities occurred between July 12and 15, 2020. At that time, Company Qian only knew that part of its facilities had been forcibly demolished by the relevant administrative agency. It was not until Deember 10, 2021, that an effective judgment in another case determined that the Guxing Town Government and the Demonstration Zone Management Committee carried out the forced demolition. Therefore, ny Qian only knew or should have known the administrative agency that made the alleged forced demolition of facilities. Consequently, the court determined that Company Qian's filing of the lawsuiton March 1, 2022, did not exceed the statutory limitation period. Duties Must Be Fully Performed; Right of Action Must Be Fully Protected Where there is , there must be responsibility. The lawful performance of statutory duties by administrative agencies is the inherent requirement for safeguarding the legitimate rights and interests of the people and standardizing social governance order.ely assuming duties, fulfilling responsibilities, and actively responding to public demands are not only basic requirements for law-based administration but also the key to improving the efficiency of government services and consoe foundation of people's livelihood protection.

In Case Two, in March 2010, the People's Government of Hohhot City, Inner Mongolia Autonomous Region (hereinaf referred to as the Hohhot Municipal Government) made a decision to phase out the fireworks and firecracker production industry and shut down production enterprises; a certain Ke Fireworks Manufaing Co., Ltd. (hereinafter referred to as Ke Fireworks Company) was within the scope of the shutdown. However, Ke Fireworks Company received only partial compensation due to thutdown. The administrative authority neither made a compensation decision in accordance with the law nor explicitly rejected the remaining compensation claims, leaving the compensation dispute unresolved for a long time. How should thme limit for filing a lawsuit be determined in cases where administrative authorities are passively negligent in performing their statutory compensation duties ex officio? The court held that, in general, the statutory compens duties that administrative authorities are legally obligated to perform do not cease to exist due to their negligence, especially when the administrative counterpart has already submitted an application for performance. In such cases, the adve authority is even more obligated to perform its duties in a timely manner in accordance with the law. Therefore, Ke Fireworks Company's lawsuit did not exceed the statutory time limit ng a lawsuit. Industrial adjustment requires orderly shutdowns; active performance of duties demonstrates responsibility. This case focuses on the rules for determining the time limit for filing a lawsuit in cases involving administrativeauthorities' failure to perform statutory duties. It clarifies that under circumstances where administrative authorities perform statutory duties ex officio, their statutory duties do not cease to exist due to their neg and parties may lawfully initiate litigation from the date they believe the administrative authority has determined not to perform its duties.

Whether administrative agencies timely inform parties of the handling results after making them not only concerns the parties' right to know but also dire affects the normal exercise of subsequent litigation rights. Case Three released this time is also worth noting. On January 11, 2022, Yuan Mou and three others cained to the Chongchuan District Comprehensive Law Enforcement Bureau of Nantong City, Jiangsu Province (hereinafter referred to as the Chongchuan District Enforcement Bur that Hu Moudong had illegally demolished load-bearing walls, affecting building safety. On March 4, 2022, the Chongchuan District Enforcement Bureau issuCancellation Approval Form" but did not inform Yuan Mou and the three others. On February 16, 2023, the Chongchuan District Enforcement Burealied to Yuan Mou and the three others regarding a government information disclosure request, informing them that "after collective discussion, a decision was made to 'not impose administrative punishment and handle the case s cancelled' regarding the involved demolition and alteration behavior." On January 15, 2024, Yuan Mou and the three others initiated administrative litigation, requesting the court order the Chongchuan District Enforcement Bureau to perform its duty of investigation and punishment regarding the complaint. Regarding whether the lawsuit filed by Yuan Mou and the three others exceeded the statutory time limit, the court held that the "Case Cancellation Approval Form" issued by the Chongchuan District Enforcement Bureau circulated only within the bureau and was not served to Yuannd the three others; therefore, it did not have external legal effect and could not be used to calculate the time limit for filing a lawsuit. Yuan Mou and the three others received the governmentn disclosure reply from the Chongchuan District Enforcement Bureau on February 16, 2023, and learned of the above handling result, then filed the lawsui on January 15, 2024, which did not exceed the time limit. In other words, when an administrative agency makes an administrative act without externalizing it throurtain method, and the administrative act has not yet taken external legal effect, the prerequisite conditions for determining the starting point of the time limit for filing a lawsuit have not been meterefore, the time when the administrative agency made the internal decision to cancel the case cannot be used as the starting point of the time limit for filing a lawsuit. 

Choose petitioning to seek with caution to avoid exceeding the time limit for filing a lawsuit

Article 48(1) of the Administrative Litigation Law stipulates that where a citizen, legal person, or other ation misses the time limit for filing a lawsuit due to force majeure or other reasons not attributable to itself, the period of delay shall not be counted within the time limit ng a lawsuit. However, if a party chooses to reflect their demands and seek resolution through the petition channel, whether this petition period falls under "other reasons not attributable to itselfn be legally deducted from the time limit for filing a lawsuit? Case No. 4 released this time provides an answer to this issue: petitioning for rights protection does not constitute a staty reason for deducting the time limit for filing a lawsuit as stipulated in Article 48(1) of the Administrative Litigation Law. In M2, the Jiangkou County Comprehensive Administrative Law Enforcement Bureau of Tongren City, Guizhou Province (hereinafter referred to as the Jiangkou County Comprehensive Law Enforcement Bures rectifying the environment around schools. Due to Yang Moumin's street vending, the bureau issued Notice No. 21 on May 9, 2022, iing him that his behavior violated the *Regulations of Guizhou Province on Urban Appearance and Environmental Sanitation*, ordering him to immediately cease the illegal act and rectifyit by May 9, 2022. The specific rectification required the removal of the illegal street stall. On the same day, the Jiangkou County Comprehensive Law Enforcement Bureau mad decision to impound Yang Moumin's tricycle, with the impoundment period from May 9, 2022, toMay 13, 2022. The bureau also informed Yang Moumin that if he was dissatisfied with the decision, he could apply for administrative reconsideration within 60 days from the date oceipt of the decision, or directly file an administrative lawsuit with the people's court within 6 months. From July 2023 to January 2024,continuously petitioned relevant departments regarding the impoundment of his tricycle. On May 16, 2025, Yang Moumin filed an administrative lawsuit, ing that the impoundment of his tricycle by the Jiangkou County Comprehensive Law Enforcement Bureau prevented him from continuing his business and caused losses. He requested the court to confirm impoundment act as illegal and order compensation for losses. The focus of the dispute in this case was whether Yang Moumin's lawsuit exceeded the time limit for filing. The court hthat the key to whether the time limit could be deducted lies in whether the delay was caused by objective reasons not attributable to the party. Yang Moumin's petitioning to relevant departmt constitute a legitimate reason for deducting the time limit. Consequently, the court ruled to dismiss the appeal and uphold the original ruling on the grounds that the statutory time limit for fili lawsuit had been exceeded. In practice, some parties believe that petitioning to relevant departments can be analogously applied to the provisions on "interruption" or "exten the statute of limitations in civil litigation, thereby filing a lawsuit years later after petitioning for rights protection. However, the time limit for filing an administrative lawsuit is an unchangeod; petitioning to relevant departments cannot produce the legal effect of suspension or interruption of the time limit. The typical cases released this time provide specific guidance for continuously improving the fairness, stnd authority of judicial adjudication in administrative cases, and also provide a behavioral guide for citizens, legal persons, or other organizations to exercise their right of action in accordance withe law and in a timely manner. Looking ahead, the people's courts will further improve the quality and efficiency of administrative trial work, promote the realization of case closure and dispute resolution, and provger judicial guarantees for the construction of a government under the rule of law. (Outlook New Era)