Duma, yuan, and beyond: Conceptualizing parliaments and parliamentarism in and after the Russian and Qing Empires

Abstract

The chapter focuses on two new institutions, the State Duma (Gosudarstvennaia duma) and Political Consultative Council (Zizhengyuan), which were introduced in the Russian and Qing Empires, when the two imperial formations joined the global constitutional transformations. The names of the two bodies pointed to the statist (etatist) rather than popular connotations of the new institutions. Furthermore, the State Duma and the Zizhengyuan were often explicitly distinguished from a Western parliament, even though the latter as a generalized notion was undoubtedly the main point of reference during the attempted imperial modernizations. Seeking to expand the current debate on the conceptual history of parliamentarism by including non-European histories, this chapter charts the genealogies of the two terms and positions them in the discussions of parliamentarism during the modernizations of the Russian and Qing Empires and during the post-imperial settlements.

Full text

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DOI: 10.4324/9781003158608
Duma, yuan, and beyond
Conceptualizing parliaments and
parliamentarism in and after the Russian and
Qing Empires
Ivan Sablin, Egas Moniz Bandeira, Jargal
Badagarov, Martin Dorn, and Irina Sodnomova
Introduction
In the early twentieth century, the Russian and Qing Empires, together with
other Eurasian polities, became part of the global constitutional transforma-
tions,1 which included the introduction of new institutions – the State Duma
(Gosudarstvennaia duma, 1905/1906) in the former and the Political Consultative
Council (Zizhengyuan 資政院, 1907/1910) in the latter. Some hundred years later,
the State Duma in Russia and the Legislative Yuan (Lifayuan 立法院) in Taiwan
were generally accepted as vernacular variations of the globalized institution of an
elected legislature,2 that is, a parliament. At the time when the two imperial par-
liamentary bodies were introduced, their names pointed to the etatist rather than
popular connotations of the new institutions. Furthermore, the State Duma and
the Zizhengyuan were often explicitly distinguished from the Western parliament,
even though the latter as a generalized notion was undoubtedly the main point of
reference during the attempted imperial modernizations. Seeking to expand the
current debate on the conceptual history of parliamentarism by including non-
European histories,3 this chapter charts the genealogies of the two terms – duma
and yuan – and positions them in the discussions of parliamentarism during the
modernizations of the Russian and Qing Empires and during the postimperial
settlements.
The parliamentary concepts and institutions in the Eurasian empires had a dif-
ferent history from that of their Western counterparts. The attention given to for-
eign experiences with parliamentarism during the imperial modernizations and
the explicit aim of strengthening the imperial states, which were perceived as
lagging behind their Western or previously modernized counterparts, may be seen
as key aspects. In the case of the Russian and Qing Empires, the successful expe-
rience of inter alia political modernization of Japan was especially important. In
both cases, the elite understandings of parliamentarism were state-centered. Even
though they did not necessarily prevail, like in the case of the State Duma, the
imperial elites sought to create not an institution of dissensus, that is, a parlia-
ment in the Western sense of the word,4 but a new institution for receiving local

14 Sablin et al.
information and managing the populace, along a bureaucratic rationalizing logic.
In the Russian Empire, the Tsarist administration feared a constituent State Duma,
rushing with the adoption of the Fundamental Laws before the assembly’s con-
vocation. In the Qing Empire, the Zizhengyuan, itself a provisional precursor of
a parliament, was also supposed to operate on the basis of the previously adopted
legislation.
Another key dierence between most Eurasian empires (for instance, Russian,
Qing, and Ottoman) and Western states, which often had empires of their own,
was the representation of dependent groups or territories in the parliamentary
bodies of the former. In the practical implementation of parliamentary ideas
in the Russian and Qing Empires in the early twentieth century, the non-Rus-
sian and non-Chinese constituencies were included in the State Duma and the
Zizhengyuan. The very creation of these institutions, which were interpreted as
imperial (pre)parliaments, undermines the idea of a unidirectional transition from
empires to nation-states. Furthermore, some sub-imperial parliamentary institu-
tions, such as the Kuban Cossack Rada (see Oleksandr Polianichev’s Chapter 6 in
this volume) or the planned Siberian Regional Duma, were explicitly connected
to the projects of imperial modernization and reconguration, rather than its dis-
integration. Not just the imperial elites but also many oppositional intellectuals,
coming from diverse backgrounds, often foregrounded the benets of parliamen-
tarism for the state rather than the people, which may be seen as a manifestation
of their state-centered imperial nationalism. Indeed, the two concepts, duma and
yuan, also had ethno-nationalist meanings. Russian conservatives, for instance,
attempted to reinterpret the duma as a Russian national parliament, while Sun
Yat-sen conceptualized the Legislative Yuan as a specically Chinese political
institution.
The two concepts must be understood in their respective dynamics. The two
major schools in the history of concepts – the German Begrisgeschichte (con-
ceptual history) and the Cambridge School of intellectual history – have helped to
distinguish between temporal and relational aspects of these dynamics. Whereas
Reinhart Koselleck, representing the former, focused on the temporal implica-
tions and changes in meanings, Quentin Skinner of the latter stressed that contex-
tualized texts should be understood as political actions in the authors’ pursuit of
specic objectives rather than mere reections.5 The idea of the imperial situation,
which can be dened as the “unstable balance in a composite society” with “con-
ditional, uid, and situational” social boundaries and, hence, social categories,
have helped grasp the Russian and Qing contexts as themselves being dynamic.6
The chapter studies duma and yuan in the context of the concrete imperial
situations and the respective conceptual histories and political mythologies, that
is, myths and their interpretations connected to these terms. The main sources
for the study are the writings of Russian and Chinese politicians and intellec-
tuals. Although the trajectories of the two terms were dierent, the conceptual
language initially developed through the reception of Western institutions in both
cases. In both cases, however, this reception was critical, and the ultimate use of
vernacular (rather than directly borrowed) terms demonstrates that the adoption

Duma, yuan, and beyond 15
of a seemingly global form of organizing authority7 entailed its signicant trans-
formations along the logic of the Russian and Qing bureaucratic approaches to
governance.
Concepts in the Russian imperial context
The terminology that was later used for parliamentary institutions developed on
the territory of the future Russian Empire through reection on both domestic
and foreign institutions. The experience of the Grand Duchy of Muscovy proved
especially important, but that of the Grand Duchy of Lithuania established an
early reference point of a Western parliamentary history for the Muscovite and
Russian elites and intellectuals.
The term duma (“council”), together with veche (“gathering” or “council”)
and sobor (“gathering” or “assembly”), was used in early East Slavic texts dat-
ing to the twelfth century. Duma initially denoted the process of the princes of
Rus’ taking advice from the senior members of their retinues.8 In the rst half of
the sixteenth century, the Boyar Duma (boiarskaia duma, “the council of lords”)
developed into a key institution in Muscovy. During the infancy of Ivan IV, the
Boyar Duma was in fact the main governing body.9 Veches, community assem-
blies, had survived until the early modern period only in Novgorod and Pskov,
but there too they disappeared with (or soon after) the annexation of the two poli-
ties to Muscovy in the late fteenth and early sixteenth century, respectively.10
The term sobor was mainly used for ecclesiastical assemblies. Although in the
sixteenth and seventeenth centuries there were several nonexclusively ecclesias-
tical sobors, it was only duma which functioned as a coherent institution at the
time. Furthermore, later authors (inaccurately) used the term duma when speaking
about the larger assemblies, which were called sobor or sovet (“council”) in the
historical sources (see Chapter 4 by Ivan Sablin and Kuzma Kukushkin in this
volume).
During the Oprichnina, the period of political violence in the second half of
the sixteenth century, there were Boyar Dumas in both zemshchina (“the land”)
and oprichnina (“the external part”) – the two parts into which Ivan IV nominally
divided the Tsardom of Russia. Furthermore, the Tsar himself formally remained
in charge only of oprichnina, which made the Zemskaia duma (“the Council of the
Land”) the nominal head of zemshchina. Although its members also suered from
persecutions of the Oprichnina, the Zemskaia duma participated in foreign-policy
decision-making as a consultative body. In oprichnina the duma became more
socially diverse with the rise of the duma gentry (dumnye dvoriane), a bureau-
cratic social group, which developed in the chancellery (prikaz) system and coun-
terbalanced the boyars.11 All this made the duma strongly associated with the
bureaucratic centralization of Muscovy.
The Grand Duchy of Muscovy, however, was not the only major state forma-
tion in the European part of the future Russian Empire. The Grand Duchy of
Lithuania, which, according to some sources, included Rus’ and Samogitia into
its ocial name, also left a prominent conceptual legacy.12 In the Grand Duchy of

16 Sablin et al.
Lithuania (by the sixteenth century) and in the Polish–Lithuanian Commonwealth
(1569–1795), the supreme authority belonged to the sejm (“gathering” or “assem-
bly”). In the Polish–Lithuanian Commonwealth, the General Sejm (Sejm walny)
included the Senate (Senat) of nobility and the Ambassadorial Chamber (Izba
poselska) of regional representatives as its two chambers, as well as the King.
This made it a vernacular version of the “King in Parliament.” By 1573 the nobil-
ity had institutionalized the notion of an elected monarch, with the decision being
made at an electoral sejm.13 Muscovy borrowed the concepts of sejm and rada
(“council”), the council of lords which since the late fteenth century limited
the ruler’s authority, from the Grand Duchy of Lithuania.14 Andrei Mikhailovich
Kurbskii, a former courtier of Ivan IV and at the time his erce opponent, used the
term rada to describe the advisory council during the early years of Ivan IV’s rule
in his book A Story of the Grand Duke of Muscovy, which he wrote in the Grand
Duchy of Lithuania.15
The Tatar polities on much of the territory of the future Russian Empire in
the early modern period and the legacies of the Mongol Empire did not seem to
inuence the concepts pertaining to assemblies.16 Tatar institutions in Muscovite
texts were described with Russian terms. The diplomatic documents of the 1550s,
related to the relations with the Nogai Horde, for instance, mentioned a duma
under the latter’s ruler. Similarly, according to a 1568 intelligence document, the
Crimean Khan had a duma of his own.17
The Russian elites were aware of the contemporary early modern assemblies
in Europe. The manuscripts, which were read to the Tsars and the boyars in the
seventeenth century and were collectively known as the “News Columns” (Vesti-
Kuranty), frequently mentioned them. In 1620, Vesti-Kuranty described the
Portuguese Cortes, the assembly of the estates, as a sejm (rendered in Russian as
soim and seim). The word sejm was also used for an assembly in Hungary in 1622
and for the assemblies in Lubeck and Mecklenburg in 1627. The same 1620 Vesti-
Kuranty, however, discussed another assembly in Hungary as zemskoe sobranie
(“assembly of the land”), which meant that terminology was not standardized.
Other manuscripts used vernacular and loan terms in dierent combinations.
A 1626 letter rendered the Dutch States General as staty but called the English
Parliament zemskaia soim (“the sejm of the land”). During the detailed discus-
sion of the conict between the English King Charles I and the Parliament, the
1627–1628 Vesti-Kuranty called the Parliament sejm; when translating the speech
of George Villiers, the First Duke of Buckingham, it used both sobor and sejm
and called the members of Parliament dumnye (“those of the duma”).18 The use of
multiple terms when speaking about the Parliament may imply its understanding
as a foreign institution (sejm), which had no equivalent in Russia, but at the same
time it may point to its interpretation as a “bureaucratic” body comparable to that
of the duma.
The world parliament (parlament) was rst used in Vesti-Kuranty (in the trans-
lated correspondence of English merchants discussing the English Civil War) in
1646 to describe the English Parliament.19 Historically, the use of the word parlia-
ment in Russian coincided with the direct relations between the Tsar’s envoy and

Duma, yuan, and beyond 17
the Parliament in 1645–1646.20 The term parliament became continuously used
for the English Parliament but was also mentioned in relation to an institution in
France in 1649, probably the Estates General rather than a court (for which the
word parlement had been used in France).21
The early modern centralization of the Russian administration did not eliminate
the particularistic approaches to governance in the Tsardom’s peripheries. The
Mongolic term khural (“assembly”), which was used in the Mongol Empire, for
instance, returned into the Russian political language with the Buryat and Kalmyk
Buddhists who used it for their religious ceremonies. The expansion to the Black
Sea region contributed to the continued use of the word rada. The Zaporozhian
Cossacks, who originally organized according to egalitarian principles, used the
word rada, together with kolo (“circle”), for the assemblies which elected their
leader (hetman) and made other decisions.22 The Sich Council (Sichova Rada)
became the supreme governing body in the Zaporozhian Sich between the Russian,
Polish–Lithuanian, and Ottoman imperial polities.23 In 1654, the Pereyaslav Rada,
which convened on the initiative of Hetman Bohdan Khmel’nyts’kyi, pledged the
Cossacks’ allegiance to the Russian Tsar, but the Zaporozhian Sich remained an
autonomous polity until the second half of the eighteenth century.24
In the empire’s center, Peter I replaced the duma with a new advisory body, the
Senate (Senat), in 1711. Duma, however, returned to Russian political discourse
later the same century as part of Catherine II’s eorts to further centralize the
state. In the process of bureaucratic standardization, Catherine II abolished some
of the autonomous polities, such as the Kalmyk Khanate and the Zaporozhian
Sich, in the 1770s, establishing a unied system of provinces. The 1785 Charter
to the Towns introduced standardized urban self-government bodies, the munici-
pal dumas, which were elected by the triennial assemblies of prosperous urban
dwellers.25
The debates on political modernization became especially prominent in the
Russian Empire after the American Revolutionary War (1775–1783) and the
French Revolution (1789–1799). Alexander I approved the rst modern consti-
tution on the territory of the Russian Empire, in the newly annexed Kingdom of
Poland, in 1815. The Polish Constitution established an elected legislature, the
bicameral State Sejm, although the Russian Tsar (as the Polish King) remained
the supreme authority.26
The proposals to establish a parliament in the empire as a whole used the
terms duma and sejm. The bureaucrat Mikhail Mikhailovich Speranskii suggested
establishing the legislative State Duma and further dumas at dierent levels of
self-government in 1809.27 The intentions of Speranskii’s project had long been
debated. Some viewed it as an attempt to limit autocracy, while others considered
his State Duma a bureaucratic institution, tasked with rationalizing the autocratic
government.28 In 1820, Nikolai Nikolaevich Novosil’tsev, the Russian ocial in
charge of the Kingdom of Poland at the time, used sejm and duma interchangeably
for the parliament which he proposed.29
Although Speranskii’s and Novosil’tsev’s projects were rejected, the Sejm of
the Kingdom of Poland (abolished in 1832) and the Diet of the Grand Duchy of

18 Sablin et al.
Finland (Finland was annexed in 1809) can be seen as proto-parliamentary institu-
tions of the Russian Empire. Furthermore, Speranskii used the term duma in his
reform of indigenous self-government in Siberia in 1822, establishing the Steppe
Duma as a council of clan elites for the Buryat-Mongols and other groups.30 A
system of local self-government, which was reminiscent of that proposed by
Speranskii, was introduced by Alexander II in 1864, but the new assemblies were
called zemskoe (zemstvo, “local” or “rural”) sobranie (“assembly”) instead of
duma. Soon after that, in 1870, however, municipal dumas were turned from
executive councils into larger assemblies, which appealed to Speranskii’s project
conceptually.31
Premodern and early modern terms informed the debates among intellectuals
in the nineteenth century. In his The History of the Russian State (1818–1829),
Nikolai Mikhailovich Karamzin, who was the main authority on Russian history
in the rst half of the nineteenth century, stressed that the Boyar Duma was an
advisory body under the Tsar and became important in the centralization, and
hence improvement, of the Russian state.32 The much more liberal historian
Vasilii Osipovich Kliuchevskii, active in the late Russian Empire, supported such
an interpretation of the Boyar Duma. He stressed that in the seventeenth century
giving advice to the Tsar was not the political right of its members but their loyal
duty.33
Karamzin used the term zemskaia duma not for the Boyar Duma in zemshchina
but for the multiple larger early modern assemblies, which were called sobor and
sovet in the historical sources. Thanks to Karamzin’s use of the term, duma was
the name for a parliament, which a number of oppositional intellectuals proposed
or demanded over the nineteenth century. Very few, however, claimed that par-
liamentary institutions existed in Russia prior to 1905. Most of those who did saw
veche and sobor (or zemskii sobor) but not duma as comparable to European par-
liaments, although some continued to use the term zemskaia duma when speak-
ing about sobors. Whereas liberals and socialists viewed the nonequivalence of
Russian institutions to Western parliaments as a sign of Russia lagging behind
Europe, Slavophiles and conservative intellectuals argued that duma and sobor
were not and should not be equivalents of Western parliaments, foregrounding
the supposed consensus between the Tsar and his subjects at such assemblies in
the past and, possibly, in the future. Those who favored the establishment of a
popular assembly, even when dismissing its equivalence to a parliament, fore-
grounded the need to improve the state machinery and, in the case of Slavophiles
and conservatives, to establish direct communication between the Tsar and the
people. More radical intellectuals insisted on the need for a constituent assembly
(uchreditel’noe sobranie), sometimes calling such an institution zemskii sobor
(see Chapter 4 by Sablin and Kukushkin in this volume).
Discussing parliamentarism in the nineteenth and early twentieth centuries,
Russian intellectuals often used the term narodnoe predstavitel’stvo (“popular
representation”) when talking about the parliament in an abstract sense. Boris
Nikolaevich Chicherin, who arguably authored the rst theoretical work on parlia-
mentarism in Russian, summarized the liberal understanding of parliamentarism

Duma, yuan, and beyond 19
as a consequence of the demand for freedom, which swept the peoples of Western
Europe after the French Revolution, implying a natural yet repeatedly challenged
progress.34 In the early twentieth century, the term parlament was also used exten-
sively in the debates both on representative government in general and on its
concrete forms in the Russian Empire.35
Concepts in the Qing imperial context
Although in East Asia the use of parliamentary terminology was even more driven
by contact and observation of foreign practices, the concepts which pertained
to parliamentarism were also vernacularized and positioned within the histori-
cal and mythologized context of the empire. Increased contacts with European
countries as well as the United States in the nineteenth century necessitated the
creation of a vocabulary to describe concepts and institutions specic to those
places.36 Chinese-language books describing the countries of the world, including
their respective political institutions, began to mushroom from the 1830s. The
most well-known of these works, Wei Yuan’s 魏源 Illustrated Treatise on the
Countries of the Seas (Haiguo tuzhi 海國圖志), rst published in 1843 in the
wake of the First Opium War (1839–1842) between the Qing and British Empires,
compiled excerpts from a large number of other works and was seminal for the
formation of the mental world map of Chinese intellectuals in the middle of the
nineteenth century.
The encyclopedia showed two possible strategies of coping with the chal-
lenge of explaining parliamentary institutions to a Chinese readership. On the one
hand, it quoted extensively from the US American missionary Elijah Coleman
Bridgman’s 1838 Sketch of the United States of America (Meilige Heshengguo
zhilüe 美理哥合省國志略), which translated the US American House of
Representatives as “Elected Department for Deliberation” (xuanyichu 選議處),37
and the Senate as “Chamber for Deliberation of Matters” (yishige 議事閣). On the
other hand, the Haiguo tuzhi is also well-known for its treatment of the English
Parliament under the phonetic transcription Baliman 巴厘滿.38 As a matter of
fact, the encyclopedia employed a whole set of transcriptions for the parliamen-
tary institutions of the United Kingdom, United States, and France: Ganwen
Haosi 甘文好司 (“House of Commons”); Lü Haosi 律好司 (“House of Lords”);
Gun‘elishi 袞額裏士 (“Congress”); Libolixian Haosi 裏勃裏先好司 (“House
of Representatives”); Xiye 西業 (“Senate”); Zhanma’afu 占馬阿富 (“Chambre”
[des députés]).39
Whether mid-nineteenth-century East Asian intellectuals used newly coined
words or phonetically transcribed the English- and French-language terms, their
renditions mostly appealed to preexisting East Asian notions of governance, as
these institutions got rendered as bureaucratic institutions. In the case of transcrip-
tions, the Haiguo tuzhi and others specied the meaning of the unheard-of term by
adding the general Chinese word for an administrative oce. The “Parliament,”
thus was actually a “Parliamentary oce” (Baliman yamen 巴厘滿衙門),40 and
the Congress was the “Congress oce” (Gun’elishi yamen 袞額裏士衙門).41 The

20 Sablin et al.
Haiguo tuzhi also oered the clearest example of this understanding of parlia-
ments as bureaucratic organs in its description of the French parliament: “For
administrative matters, [France] established one Chambre oce with 430 o-
cials staed by every district, just like in the example of the English House of
Commons.” 42
In the more frequent case of new coinages such as “chamber for deliberation
of matters,” Chinese – as well as Japanese43 – writers mostly attached suxes
which referred to types of buildings and, by extension, to bureaucratic oces in
the Chinese and Japanese government systems. The by far prevailing sux, yuan
院, originally denoted a courtyard, and later became “a common nal element in
agency names, impossible to render consistently in English: Oce, Bureau, Court,
Academy, Institute, etc.”44 From the late nineteenth century, it not only came to be
employed as the general term to denote parliaments (yiyuan/Jap. giin 議院 – “court
of deliberation”) and as a sux in the name of various parliamentary institutions
such as the late Qing “Political Consultative Council” (Zizhengyuan 資政院) and
the legislative branch (“Legislative Yuan”) of the Republic of China (Lifayuan
立法院). Actually, it came to be the sux for all branches of government of
the Republic of China. Although using certain signiers in a translation does not
necessarily pre-dene how the understanding of a term evolves later, Kuei Hung-
chen 桂宏誠 rightly points out that the understanding of parliamentarism as seen
in the rst texts about foreign parliaments set the basis for a bureaucratic under-
standing of parliaments which prevailed throughout the Qing Empire.45
Yet, there is also another, less bureaucratic and more national-stately46 notion
which gained general currency: that of an assembly (hui 會). Throughout Imperial
China, a deliberative assembly (huiyi 會議) of court ocials used to be convened
in order to deliberate about policies and make recommendations to the Emperor,
and the term hui 會 was also used as equivalent for the Mongol khural.47 In its
modern parliamentary sense, it reappeared in 1837 and 1838 in Karl Friedrich
August Gützla’s Eastern Western Monthly Magazine (Dong-xi-yang kao meiyue
tongji zhuan 東西洋考每月統紀傳), which referred to the English Parliament
as the “public assembly for the administration of the state” (guozheng gonghui
國政公會), the “public assembly of the state” (guojia gonghui 國家公會 and
guogonghui 國公會), or simply the “state assembly” (guohui 國會).48 This last
form stuck. In the literature it was used, for instance, in the seminal 1864 Chinese
translation of Henry Wheaton’s Elements of International Law.49 Later, it became
the name of the Japanese Imperial Diet (jap. pronunciation kokkai), the National
Assembly of the Republic of China, and eventually the National Assembly of the
Republic of Korea (kor. kukhoe).
Whereas works such as the Haiguo tuzhi or Karl Gützla’s magazine merely
described foreign parliaments and other foreign political concepts, sooner or later
East Asian intellectuals were bound to discuss them in light of their own politi-
cal realities. In Japan, intellectuals were vigorously debating possible reforms to
the Tokugawa-led bakumatsu government even before the “Meiji Restoration”
of 1868 (see Yuri Kono’s Chapter 2 in this volume). In China, it took less than a
decade until, in the mid-1870s, the rst intellectuals began to discuss not only the

Duma, yuan, and beyond 21
adoption of European technology, but also the adaptation of Western statecraft as
a means to counter the country’s political and economic decline and to strengthen
it against external threats.
Indeed, parliamentarism was the rst such concept to be seriously discussed
for the Qing Empire, nearly two decades earlier than the closely related “consti-
tutionalism.”50 From the beginning, this happened with reference to Japan. For
example, an editorial of the Shanghai newspaper Shenbao 申報 published on June
17, 1874, can be taken as indicative of the public debates on parliamentarism that
would be held in the last decades of the Qing. According to the paper, parliaments
facilitated the communication between “high” (shang 上) and “low” (xia 下).
Yet, they needed well-informed representatives who could “be above the peo-
ple” (ju min shang 居民上), something which was lacking in the Qing Empire. If
the development of parliamentary institutions in Europe and America had been
gradual, the paper implied, it needed to be even more so in the Qing Empire.51
The newspaper-led debate of the 1870s was gradually taken up by men-of-let-
ters.52 The tropes set in the Shenbao in the 1870s continued to pervade in discourse,
but given such events as the Sino–French War of 1884–1885, an increasing num-
ber of intellectuals began to downplay the aspect of gradualism and instead main-
tained that the Qing Empire needed a parliamentary institution not in some distant
future after gradual preparation, but here and now. As the proposal for such an
institution had to be justied in light of the ruling ideology, they argued that, from
ancient times, it had been a Confucian ideal that ocials be well-informed about
the concerns of the populace. Zhang Zimu 張自牧, for example, argued in 1884
that parliaments were a source of the political strength of a nation and that the
“West preserved the idea from [Chinese] antiquity” whereby the concerns of the
people were brought to the attention of the ocialdom.53
One of the contributors to the Shenbao, Zheng Guanying, began to publish
his book Easy Words (Yiyan 易言) in 1871, wherein he painted the international
scene of the time as a re-edition of the ancient Chinese Warring States period
(475–221 BC). In the subsequent editions of the book as well as in the successor
book Words of Warning in Prosperous Times (Shengshi weiyan 盛世危言), rst
published in 1894, Zheng developed his position that the Qing Empire should
adopt modern instruments of statehood in order to survive in a Warring States
like cut-throat competition, with parliamentarism being one of the main elements
in strengthening the Qing Empire’s competitiveness. Zheng devoted a section of
his book to the bicameral parliamentary system found in the “Western countries,”
which, he argued, ensured concord between government and the people, as well
as the quality of political measures. 54
For long-standing political traditions to be radically changed in a short period
of time, references to foreign examples alone did not suce to make arguments
in favor of – or against – reforms. Rather, until the fall of the empire, the notion
of parliamentarism was also analyzed in view of one’s own tradition. This was
even more important in a culture which valued its own classics and ancestors
as much as China. Scholarship has pointed out that the recourse to the vener-
able classics was used to legitimize modern phenomena from railroads to political

22 Sablin et al.
institutions.55 But this was not the only use: as was pointed out at the time, the con-
nection between the classics and modern phenomena was also made to protect the
classics at a time when their authority stood under heavy attack.56 Furthermore, it
should also not be forgotten that the classics were also used in conservative argu-
ments against new institutions.57
Zheng Guanying had no unied approach to possible ancient Chinese equiva-
lents of parliamentarism. In his chapter on parliaments, he raised the question
whether parliamentarians would not be the same as the Court Gentlemen of
Consultations (yilang 議郞), who had existed in the Han state (206 BC–AD 220),
or the same as the censors and remonstrators of later periods, but denied the ques-
tion and argued that the parliament was a dierent institution which would avoid
China’s traditional vices.58 Yet, in the revised 1895 edition of his book, Zheng
added a chapter in which he made a reference to a Han-time practice of “local
selection,” of which the actual historical meaning is obscure. Zheng placed strong
emphasis on the point that it was imperative to revive this institution, framing his
chapter with references to it at the beginning and at the end.59 At any rate, Zheng’s
views about possible Chinese parliamentary precedents did not aect his opinion
about why the introduction of a parliament was imperative and which he had laid
down in his parliamentary chapter. It is representative of a large portion of late
Qing arguments in favor of a parliament:
Hence, if we want to implement public international law, nothing is more
important than strengthening the country’s clout; if we want to strengthen
the country’s clout, nothing is more important than conquering the people’s
hearts; if we want to conquer the people’s hearts, nothing is more important
than letting the concerns of the lower [part of society] ow; if we want to let
the concerns of the lower [part of society] ow, nothing is more important
than establishing a parliament.60
Imperial modernizations
Like elsewhere in the nineteenth and twentieth century, parliamentarism and con-
stitutionalism were frequently discussed in Eurasia in the context of political mod-
ernization. The Japanese and the Ottoman Empires (see Ellinor Morack’s Chapter
7 in this volume) introduced constitutions and parliaments in the second half of
the nineteenth century. Although in the latter constitutionalism was suspended,
the success of political modernization of Japan, which supposedly led to its mili-
tary prowess and turned it into a colonial power, aected the Qing and Russian
Empires directly – in the Sino–Japanese (1894–1895) and the Russo–Japanese
(1904–1905) Wars – and contributed to the discussions of political reforms in the
Qing Empire and a revolution in the Russian Empire.
Until the end of the nineteenth century, the debates on parliamentarism in the
Qing Empire stayed within intellectual circles. Although memorials referring to
the establishment were presented to the throne, the government did not take up
the topic, and it was not even included in the abortive Hundred Days’ Reform

Duma, yuan, and beyond 23
promulgated in the summer of 1898. The negative evaluation is shown by the
diary of Li Jiaju 李家駒, an ocial who was accompanying the Qing minister
to Tokyo in order to study the Japanese education system, and who later would
become one of the main gures of the constitutional reforms. In 1899, however,
the balance of the Meiji reforms contained in his diary still emphasized the con-
vening of a parliament as one of its main drawbacks, as opposed to the moderniza-
tion of the military and the revitalization of the education system.61
In Russia, the so-called zemstvo constitutionalists and other liberal groups of
nobility and intellectuals reinvigorated the discussions of introducing a parliament
in the 1890s. After the demise of the conservative Alexander III, his son, Nicholas
II, was asked to convene a parliament in 1895. Nicholas II, however, rejected the
idea, pledging to defend autocracy. As noted by an oppositional politician several
years later, that very same year the fatal decision of expanding to East Asia was
made as if to counterbalance the dreams of liberalizing the empire.62
Ten years later, however, in the wake of the disastrous war with Japan and
the Revolution of 1905–1907, Nicholas II conceded. Although Nicholas II was
inclined to support an irregular consultative zemskii sobor, the governmental
commission, which was created on the initiative of Minister of Internal Aairs
Aleksandr Grigor’evich Bulygin in 1905, suggested a permanent assembly.
Sergei Emovich Kryzhanovskii of the Ministry of Internal Aairs was the main
advocate of introducing the Duma.63 Its name, the State Duma, was taken up from
Speranskii’s project, which was referenced directly during the ocial discussions
of the new institution at the closed Peterhof Conference chaired by the Tsar. Some
participants of the conference once again deemed the gathering of local informa-
tion and the communication between the Tsar and his subjects the main objec-
tive of the Duma. The historian Kliuchevskii, one of the few liberal voices at the
Peterhof Conference, located the Duma in the history of popular representation
in Russia, which he traced to the zemskii sobors, and stressed the need to base
legislation on the will of the majority of the people, hence attempting to dene the
Duma as a parliament. Although most of the ruling elite did not see the Duma as a
parliament and rejected the very idea of limiting autocracy, Nicholas II’s attempt
to “de-modernize” the proposed institution by calling it a Gosudareva (“of the
autocrat”) rather than Gosudarstvennaia (“of the state”) duma was shut down at
the Peterhof Conference.64
Although initially it was designed as a consultative body, the establishment
of the legislative State Duma (on October 17, 1905, in the so-called October
Manifesto) and the adoption of the new Fundamental State Laws of the Russian
Empire (on April 23, 1906) seemed to make Russia a constitutional state. In 1907,
Vladimir Matveevich Gessen and Boris Emmanuilovich Nol’de, two prominent
liberal legal scholars, listed Russia, together with Persia and Montenegro, as a
new constitutional state in their comprehensive collection of contemporary con-
stitutions. Articulating a popular progressive view, they claimed that the failures
of the Russo–Japanese War unmasked the ineciency of bureaucratic autocracy,
spreading the critical attitudes to the ancien régime beyond intellectual circles and
transforming them into a broad liberation movement across the whole country.65

24 Sablin et al.
Indeed, before and especially during the Revolution of 1905–1907, the ine-
ciency of the Russian state played a key role in the broader debates on democracy,
which contrasted the public and the bureaucracy. The liberal program included
not only parliamentarization but also decentralization of the empire, with the
introduction of zemstvo and municipal self-government on the basis of universal
surage. As argued by Gessen, since bureaucracy lacked information on particu-
lar aairs, it could not govern them eectively and needed to be substituted by
local and professional self-organization.66 The same logic applied to the parlia-
ment. Articulating a widespread opinion, the Tomsk liberal newspaper Sibirskaia
zhizn’ celebrated the October Manifesto as the liberation of the people from “the
tutelage of bureaucracy.” According to the newspaper, the Russian Empire had
become a constitutional state and “joined the family of modern civilized states
as an equal,” and in such a state the population had supreme authority. At the
same time, Sibirskaia zhizn’ voiced a popular liberal argument in favor of gradual
political change.67
Few contemporary observers, however, viewed the Duma (1906–1917) as a
parliament equal to its Western counterparts. It occupied a subordinate position
to the State Council, which was reformed from a bureaucratic advisory council
into a partly appointed upper chamber (for a similar conservative take on parlia-
mentarism, see Bruce Grover’s Chapter 3 in this volume), and did not control the
cabinet, which contributed to the term “sham constitutionalism” being applied to
the new Russian regime.68 The non-universal, indirect, and unequal elections were
further limited with the dissolution of the Second Duma on June 3, 1907. Nol’de
nevertheless stressed that the Russian Empire could be called a constitutional state
and deemed the State Duma the rst normally functioning parliament in Russia,
implying the country’s connection to Western constitutional modernity.69
Liberal intellectuals made gradualist arguments about the situation. Sergei
Andreevich Kotliarevskii, a historian, legal scholar, and one of the founding mem-
bers of the liberal Constitutional Democratic (KD) Party, favored “democratic
parliamentarism,” but the notion of political evolution and Russia’s inferiority
compared to the West helped him justify the existence of the “Prussian regime”
of a non-answerable cabinet as a transitional stage. Despite his skepticism of the
Duma’s “parliamentarism,” he urged Russia’s progressives to set parliamentarism
(rather than radical republicanism) as their ultimate goal.70 In practical terms this
translated into the KD program of constitutional monarchy featuring a potent uni-
versally elected “popular representation.”71
Even after the Duma was made legislative, conservative opponents of parlia-
mentarism remained vocal. Vasilii Vasil’evich Rozanov, a conservative philoso-
pher, refused to admit that a “constitution” and a “parliament” were introduced
in Russia, maintaining that the Duma was a product of Russian history, produced
by the Russian soul, enthusiasm, patience, and work, and not a “foreign nov-
elty.” Although Rozanov acknowledged that the Russian people also moved to
liberation like elsewhere, this movement was parallel to those of the others. For
Rozanov, however, it did not have the same direction. For him, the Duma did
not mimic Western institutions and was not a place for representing dierence.

Duma, yuan, and beyond 25
Rozanov called for the unity of Russia’s political groups there, which would miti-
gate the splits in the Russian society.72
Although it did not become a potent parliament, the State Duma proved to be a
key site of imperial nation-making, both in the sense of imagining the larger inclu-
sionary political community of the empire and the smaller communities (based on
ethnicity, religion, region, social estate, and class) in the composite space of the
empire.73 As argued by Alexander Semyonov, the State Duma was a microcosm
of empire not because it ostensibly represented the national or ethno-confessional
distinctions but because the parliament itself was based on uneven or multidi-
mensional heterogeneity. The elections, albeit restrictive and representative of
just a fraction of the overall population, were based on several principles, which
alternately referenced territorial, social estate, ethno-national, and confessional
markers or combinations of them. This owed to the dierentiating and individuat-
ing approach of the government to imperial space. In the Duma itself it resulted
in the articulation of multiple and overlapping categories, with some having been
politicized before and with others being operationalized only in the imperial par-
liament. There were multiple caucuses (with overlapping memberships) based on
ethnicity (for instance, Poles), religion (Muslims), social estate (Cossacks), and
region (Siberians) in addition to the party factions. There was also a caucus of
Autonomists which united nationalist and regionalist advocates of decentraliza-
tion.74 A popular print of the First Duma accentuated the diversity of the deputies
by placing Muslim and peasant deputies at the foreground of the composition (see
Figure 1.1).
Despite their criticism of the Duma, liberal and moderate socialist and nation-
alist thinkers generally supported parliamentarism. The KDs included parlia-
mentarism, as the answerability of the cabinet to the parliament’s majority, into
their program in 1905. The other two largest oppositional parties – the Party of
Socialists Revolutionaries (SR) and the Russian Social Democratic Labor Party
(SD) – supported the slogan of democratic republic. The SRs also included
the slogan of revolutionary dictatorship of proletariat, if it became necessary,
into their draft program in 1905 but ultimately dropped it in favor of demo-
cratic republic ruled by the people through their elected representatives and
referendum.75
Left and right radicals, by contrast, questioned the very necessity of a parlia-
ment. The former rejected parliaments as part of class exploitation and oppressive
state machinery and called for direct rule of the toilers to represent an alterna-
tive democratic modernity. The prominent anarchist writer Petr Alekseevich
Kropotkin rejected the idea of dividing the struggle into two steps – a political
coup and economic reforms ostensibly to be implemented by a Russian parlia-
ment. For him, the struggle against autocracy and capital was to be simultane-
ous, and any parliament was a deal between the parties of the past and those
of the future and hence would never introduce revolutionary measures. Arguing
that Russia was unique and opposing parliamentary gradualism, Kropotkin main-
tained that the Russian people had a historic chance to take the power into their
own hands and surpass the stages which the West went through.76

26 Sablin et al.
Figure 1.1 Zasedanie pervoi Gosudarstvennoi dumy [The session of the First State Duma].
Moscow: Lit. T-va I. D. Sytina, [1906]. The text at the top reads “State Duma.
(Tauride Palace).” The text at the top right corner reads “Chairman of the State
Duma S. A. Muromtsev.”
For the far right, the threat to the “greatness” of the state was intertwined with the
supposed threats to the ethnic Russians. Rozanov’s aspiration for unity in the State
Duma was shattered by the oppositional majorities of the rst two Dumas, which
triggered their dissolution. Anticipating the convocation of the Third Duma, based
on the limited electoral law, Rozanov expected the new Duma to nally become
one of the “state” and not one of the “society,” rejecting thereby the liberal notion
of societal self-organization. Rozanov expressed hope that the Duma would be a
“national Russian” representation and personally attacked the SD deputies from the
Caucasus. What progressives and non-Russian nationalists saw as the non-Russians
nally gaining a voice through the Duma, for Rozanov was a clear indication that
the Russian state and the ethnic Russians (who in practice made up some 44.3 per-
cent of the imperial population in terms of language but legally also included the
17.8 percent speaking Ukrainian and 4.7 percent speaking Belarusian, becoming
thereby a majority)77 could become marginalized, as he claimed that the “grey-
haired old Rus’,” embodied by the people of “serious positions and professions,”
had to listen to the “nonsense” of the deputies from the Caucasus.78 Some right
radicals even saw the roots of Russian parliamentarism in a Jewish conspiracy.79

Duma, yuan, and beyond 27
Whereas the defeat against Japan in 1895 did not seem to boost government
interest in parliamentarism in the Qing Empire, subsequent events did. The Boxer
War of 1900–1901 and the Russo–Japanese War led the Qing government to
agree to political reforms. The aforementioned Li Jiaju thoroughly changed his
opinion on this matter, coming to act rst as the Qing constitutional commissioner
to Japan in 1908, and eventually as one of the Imperially appointed drafters of
the nal constitution in 1911. However, subscribing to a gradualist policy, the
government maintained that a full bicameral parliament (yiyuan) could only be
convened after a thorough reform of the state, as delegates were not expected to
legislate from scratch, but instead to deliberate policy matters on the basis of an
already existent body of laws.80 The gradualist approach was not only the one
recommended by a large part of foreign observers, but it was also reinforced by
the Qing government’s perception of Russia, where the speedy adoption of a con-
stitution and the convening of the First Duma in 1906 did not do much to mitigate
the crisis through which the country was going.81
Following this principle, the government promised in 1906 to study the adop-
tion of constitutional government and foresaw the creation of a proto-parliamen-
tary body, the Political Consultative Council (Zizhengyuan 資政院 ), as a place to
“broadly collect public speech” (bocai qunyan 博采羣言 ).82 In the following years,
the government followed through, setting up the Zizhengyuan as well as delib-
erative assemblies at lower administrative levels, called “oces for consultation
and deliberation” (ziyiju 諮議局 ) at provincial level and “deliberative assemblies”
(yishihui 議事會 ) at lower levels. As the ocial documents issued by the govern-
ment at the time made clear, the lower provincial assemblies should be a basis for
the Political Consultative Council, serving as a talent pool for it (wei Zizhengyuan
chucai zhi jie 爲資政院儲材之階 ) and as gathering points of public opinion (caiqu
yulun zhi suo 採取輿論之所 ).83 These local assemblies were not to be treated as
national parliaments, but were conned to a consultative role.84 They were, how-
ever, parliamentary “forerunners” (xiansheng 先聲 )85 which should be transformed
into provincial legislative organs after the convening of the National Assembly.86
For the government, such parliamentary assemblies were thus mainly meant
as consultative bodies that should bring the concerns of the people to the govern-
ment. Equally, it was hoped that they would foster national cohesion by bringing
those governing and those governed closer together. This was true even for vast
parts of the empire which were deemed unt to participate in the new system,
that is, the large non-Han regions of Mongolia, Xinjiang, and Tibet. The new
parliamentary system presupposed “the existence of a pool of educated Han gen-
try outside the bureaucracy – a milieu conspicuously lacking” there.87 Hence, no
provincial assemblies were established in Mongolia and Tibet, and the one for
Xinjiang never assembled. Yet, by giving elites of these regions, particularly from
Mongolia, special group representation by Imperial appointment to the Political
Consultative Council, the Qing tried to parliamentarize their traditional method of
creating loyalty by conferring aristocratic privileges.88
The government’s slow approach to parliamentarism met with increasing
impatience on the part of a public which, to a large extent, although by far not

28 Sablin et al.
exclusively, had come to see constitutionalism as a panacea for the Qing Empire’s
ills, and called for a much faster pace of reforms. A large number of people
signed petitions calling for the “speedy convening of a parliament” (su kai guo-
hui 速開國會), including Li Jiaju himself. But even the mere “right to express
proposals” (jianyan zhi quan 建言之權)89 had a tremendous impact on late Qing
politics. As the provincial assemblies were allowed to memorialize to the Political
Consultative Council, they had a communication channel to the Emperor and were
less dependent on the governor.90 When the provincial assemblies were convened
in 1909 and the Political Consultative Council in 1910, the local elites represented
in them made extensive use of their “right to speak.” Using the assemblies as
platforms, they severely pressured the court, which became one of the immediate
causes of its demise in 1911/1912.91
Postimperial settlements
The logic and contradictions of imperial parliamentarism persisted during the post-
imperial settlements. On the one hand, there were attempts to constitute inclusion-
ary Russian and Chinese postimperial civic nations, which would include not only
the titular groups but also other groups of the former empire. Both the projected
Russian federative republic and the Chinese Republic of “Five Races under One
Union” were to have inclusionary parliaments. At the same time, the discussions
of parliamentarism also continued as part of particularistic, exclusionary national
projects, and the use of vernacular terminology very much reected that.
The events at the turn of 1911 to 1912 – that is the Xinhai Revolution and the
replacement of the Qing Empire by the Republic of China – meant an at least
nominal transition from monarchical to popular sovereignty. Prima vista, the
founding constitutional texts of the Republic of China seem to reveal this momen-
tous shift of focus. While Article 1 of the Imperial Outline of a Constitution,
adapted from the Japanese Constitution of 1889, had declared that the Empire was
to be governed by the Emperor in “one dynastic line for ages eternal.”92 Article 2
of the Republic’s rst Provisional Constitution, promulgated on March 11, 1912,
declared that “the sovereignty of the Republic of China is vested in the entirety
of the nation.”93
The establishment of the republic was accompanied by a rough exercise in a
more democratic form of government. In theory, the political structure laid down
in the Provisional Constitution as well as in the Law on the Organization of the
National Assembly of August 10, 1912, conferred a paramount importance to the
bicameral National Assembly (Guomin yihui 國民議會, short Guohui 國會): next
to its attribution of passing legislation, it was also entrusted with drafting a perma-
nent constitution for the Republic, and furthermore it elected the President of the
Republic and the Prime Minister as the head of the Cabinet.94
The election to the National Assembly at the turn of 1912–1913 was not only
the rst one to be ever held in China at a national level, but also drew from a mas-
sively enlargened basis of voters of more than 40 million people.95 Whereas suf-
frage for the 1909 provincial elections had stood at 0.39 percent of the population,96

Duma, yuan, and beyond 29
it had increased to more than 10 percent of China’s population of roughly 400
million inhabitants in 1912. Next to letting much broader sections of society par-
ticipate in the political process, it also continued and deepened the shy attempts of
the Qing Empire at parliamentarization of the imperial situation. While the Qing
had merely integrated the vast non-Han regions of the Empire into the upcoming
parliamentary system via upper-house indication, the Republic insisted on having
these regions represented in the lower house as well.
However, at the same time, these elements of democratization and increased
participation of the masses in politics, as well as of greater national integration,
also had clear limits both in the political realities and in the intellectual debates
of the time. As to the integration of the non-Han regions into the new National
Assembly, the 1912–1913 elections faced numerous diculties and delays in
Xinjiang97 and could not be carried out in Tibet and Outer Mongolia, which had
separated themselves from the Republic of China. Tibetan and Outer Mongolian
seats were lled from loyal Mongol and Tibetan communities in Beijing. Combined
with the fact that the sparse population of these regions required overproportional
delegate quotas, this led to the perception that the Republic was actually granting
ethnic, not territorial, representation to Tibetans and Mongols, and to correspond-
ing frictions with the ocially sanctioned ideology of ethnic equality.98
The parliamentarization of the Chinese post-empire was celebrated by Russian
socialists as a marker of global progress, even though they viewed parliamenta-
rism not as a goal but merely as a means of achieving socialism. Commenting on
the Xinhai Revolution and the developments in the Republic of China in 1912,
Vladimir Il’ich Lenin, celebrated the awakening of the “four hundred million
backward Asians” to political life and stressed the importance of the convocation
of the Chinese parliament – “the rst parliament in a former despotic country.”99
Returning to the issue in 1913, Lenin called the Chinese parliament “the rst par-
liament of a great Asian country” and praised Sun Yat-sen’s 孫逸仙 Guomindang
for bringing the broad masses of Chinese peasants into politics, which he described
as “a great factor of progress of Asia and progress of humanity.”100
In the chaotic struggles of the early Republic, the elected National Assembly
did not last for long. By November 1913, President Yuan Shikai 袁世凱 eectively
replaced the National Assembly with two other assemblies – a “Political Assembly”
(Zhengzhi huiyi 政治會議, see Figure 1.2) and a “Constituent Assembly” (Yuefa
huiyi 約法會議, see Figure 1.3). In 1914, Yuan ocially disbanded the National
Assembly and had another provisional constitution approved.101 This Constitution,
which provided for an extraordinarily strong position of the President, foresaw
the establishment of a bicameral national assembly – styled “Legislative Yuan”
(Lifayuan 立法院) – and of a presidential Privy Council (Canzhengyuan 參政院;
see Egas Moniz Bandeira’s Chapter 5 in this volume). Proposed by the Japanese
constitutional advisor Ariga Nagao 有賀長雄 as the equivalent to the Japanese
Privy Council (Sūmitsuin 樞密院), only the latter institution convened at the time.
Consisting of 50–70 delegates personally selected by Yuan, it was immediately
decried as an instrument of Yuan’s monarchic ambitions and megalomany. While
these accusations are not false, they do not depict the whole story, for Yuan’s

30 Sablin et al.
Figure 1.2 Zhengzhi huiyi quanti sheying [Group photo of the Political Assembly].
Dongfang zazhi 東方雜誌 11, no. 2 (Minguo 3 [1914]).
constitutional design conformed to the recommendations given to him by advisors
such as Ariga Nagao and Frank Johnson Goodnow. Hence, these institutions also
reected a current of contemporary constitutional scholarship which accorded a
powerful position to the head of the executive, regardless of whether he be an
emperor or a president.102
Yuan’s Canzhengyuan was disbanded after his death in 1916, while the origi-
nal National Assembly convened again. A new National Assembly, elected in
1918,103 functioned comparatively smoothly for two years before it was disbanded
again. By that time, the Beijing government had already lost control over much
of the country and China was experiencing the beginning of a decade full of civil
war and warlordism.104 The Beijing government’s parliament, while strong in
theory, was subject to maneuverings by political strongmen. The old National
Assembly was convened again, but its widespread corruption contributed to the
disillusionment with parliamentarism and constitutional politics as such.105 When
the Guomindang troops conquered Beijing in June 1928, eectively ending the
Warlord Era, “China’s experiment with parliamentary politics was over.”106
The parliamentarization of the Russian postimperial space followed a some-
what similar trajectory of initial success and quick demise. It was the Duma which

Duma, yuan, and beyond 31
Figure 1.3 Yuefa huiyi quanti sheying [Group photo of the Constituent Assembly].
Dongfang zazhi 東方雜誌 11, no. 2 (Minguo 3 [1914]).
formed the Provisional Government during the Revolution of 1917, while a uni-
versally elected omnipotent parliament – the All-Russian Constituent Assembly
– was supposed to resolve the Russian imperial crisis, which inter alia manifested
in the disastrous First World War (1914–1918). At the same time, parallel to the
institutions of the Provisional Government and the new zemstvo and municipal
authorities, which were reformed on the basis of universal surage, the soviets
(“councils”) reemerged (after their brief appearance in the Revolution of 1905–
1907) as the bodies of class self-government. Although this situation was fre-
quently interpreted as “dual power,” some socialists and liberals in fact viewed
the soviets as “legislative chambers of deputies” and the Petrograd Soviet as “a
surrogate people’s duma,” which replaced the State Council in a two-house par-
liament of new Russia.107
The ideas of gradualism and what can be called “parliamentary tutelage,”
however, were still articulated by some Russian liberals. In his pre-revolutionary
work, which was published and discussed in 1917, Gessen rejected the notion of
popular sovereignty. For him, the people were the source of legislative author-
ity in a representative republic but were not seen as capable of exercising it due
to the lack of a deliberate unity of wills. Legislative authority was exercised by
the parliament on behalf of the people and in its interests, but the election of
deputies was not a delegation of legislative competence, since the people did not

32 Sablin et al.
have it in the rst place. A citizen was a voter and not a lawmaker who adopted
legislation through his or her representatives. According to Gessen, the parlia-
ment received its competence from the constitution and not from the people, but
elections were still needed for the will of the parliament to correspond to popular
interests. Gessen concluded that popular representation implied the incapacity of
the people. In his view, a parliament was not and could not be a cliché of the
popular masses; it organized and created the general will, turning the anarchy of
circulating opinions into one.108
Moderate socialists did not share such a view on popular representation, with
Mark Veniaminovich Vishniak, a legal scholar and a member of the SR Party,
insisting that according to the idea of democracy (narodopravstvo), as initially
formulated by Jean-Jacques Rousseau, only the people were the source of public
opinion, that is, of the will directed at the common good. A parliament, according
to Vishniak, was only a secondary institution articulating but not creating popular
will,109 which very much corresponded to Georg Jellinek’s interpretation of the
people as the primary body and the parliament as the secondary body.110
Liberals and moderate socialists hence agreed that Russia needed a parliament,
which could be uni- or bicameral. A possible second chamber, as discussed by a
committee under the Provisional Government, could reect decentralization and
include the representatives of autonomous territories and local self-government
bodies, as well as the representatives of the most important “organized social
and cultural forces of the country,” such as representatives of trade and industry,
cooperatives, trade unions, and academic institutions.111
The establishment of a Bolshevik–Left SR government, supposedly legiti-
mized by the soviets, on October 25–26, 1917, however, reected the growing
popularity of leftist anti-parliamentarism. The new government allowed the con-
vocation of the Constituent Assembly on January 5, 1918, but since the two radi-
cal parties did not have a majority there and did not nd the assembly’s support,
they disbanded it the very next day. With the expulsion of the Left SRs from
the Soviet government, the Bolsheviks established a one-party autocracy. Indeed,
they introduced a sham federation but opted for a complete and explicit oppo-
sition to parliamentarism in favor of an exclusionary class government.112 The
Soviet non-parliamentary system, however, was formally abandoned in 1936 with
the adoption of the new Soviet Constitution, which introduced a Soviet “parlia-
ment” – the Supreme Soviet (Verkhovnyi sovet) of two chambers113 (see Olga
Velikanova’s Chapter 8 in this volume).
China experienced a similar departure from Western-style parliamentarism,
yet following a dierent logic. In spite of the optimistic attempts at amplifying
surage in 1912, the same republicans who had attacked the Qing for installing
sham constitutionalism and for not adopting a constitution soon enough came to
subscribe to similar positions, that is, that a full constitution could not be adopted
at once, but only after a suciently long preparatory phase. Sun Yat-sen, who had
been the rst President of the Republic in 1912 and led the so-called Constitutional
Protection Movement against the Beijing-based Beiyang 北洋 government from
1917, came to conceptualize such a gradualist thinking in his 1924 “Outline of

Duma, yuan, and beyond 33
National Construction” (Jianguo dagang 建國大綱). Therein, he foresaw devel-
opment in three stages, from a military government (junzheng 軍政) to a govern-
ment of “tutelage for the people” (xunzheng 訓政) to, eventually, “constitutional
government” (xianzheng 憲政).114 A popularly elected Legislative Yuan was only
foreseen for the last phase, and thus still away from a fractured China that was still
considered to be in the rst phase of military government. Eectively, thus, the
parliament became the coronation rather than the main agent of the nation-build-
ing process of the Chinese Republic, not unlike it had been for the Qing Empire.
According to ocial ideology, the unication of most of China under the
Guomindang in 1928 marked the transition from military government to the era
of “tutelage,” which was to be exerted by the Guomindang. The subsequent revi-
sion of the Organic Law of the National Government of October 4, 1928, adopted
Sun’s ve-branch system of government and introduced the Legislative Yuan
together with four other yuans. The new legislative body was only one element in
the legislative process, since the adoption of a law required the joint countersig-
nature of the presidents of all ve yuans. The next revision of the Organic Law
(November 24, 1930) elevated its status a bit by requiring only the President of
the National Government to countersign law bills.115 However, the members of
the Legislative Yuan continued to be unelected, being appointed instead by the
National Government. In 1931, the Guomindang convoked a constituent assem-
bly – called People’s Convention (Guomin huiyi 國民會議). Most of its delegates
represented the territorial subdivisions of the Republic as well as overseas com-
munities, but were elected by a number of legally registered organizations at the
local level, giving the Guomindang the power to directly or indirectly control
the Convention.116 The Provisional Constitution of the Political Tutelage Period,
adopted by the People’s Convention in May 1931, consolidated the system laid
out in the organic laws and the place of the Legislative Yuan in it. Hence, in the era
of Guomindang-controlled “tutelage,” the party dominated both the establishment
as well as the functioning of these institutions, and the Legislative Yuan remained
a bureaucratic body.117 The result was a one-party regime similar to that in Soviet
Russia and the Soviet Union. Furthermore, the 1931 Provisional Constitution can
be seen as an early constitutional formalization of a one-party regime.
After the end of the Second World War, the Republic of China ocially tran-
sitioned from “tutelage” to “constitutional” government, promulgating a new con-
stitution in 1947 and convening the rst popularly elected Legislative Yuan in
1948. Yet, China was amid a civil war which eventually forced the Guomindang-
led government to ee to Taiwan. While the victorious Communist Party estab-
lished its own one-party regime, the Chinese People’s Political Consultative
Conference – China’s main parliamentary institution from 1949 to 1954 – sought
to integrate other political currents and to create some continuity to the Republic
(see Henrike Rudolph’s Chapter 9 in this volume).
The postimperial settlements witnessed a number of further vernacular parlia-
mentary developments, which followed the particularistic national projects after
the two empires. The newly established sovereign Polish and Lithuanian repub-
lics, for instance, called their parliaments sejm. Many polities, however, did not

34 Sablin et al.
succeed in retaining their autonomous or independent status. Here the examples
of Ukrainian and Mongolian parliamentary formations were especially illustra-
tive of the use of the concepts which had been relevant for larger imperial spaces
before in political nation-building.
Diverse Ukrainian nationalists were among several postimperial groups
which used the concept of rada. As a national institution, it emerged in the con-
text of the Habsburg Empire during the Revolution of 1848–1849, when the
Supreme Ruthenian Council (Holovna Rus’ka Rada) was formed.118 Mikhailo
Hrushevs’kyi, a prominent Ukrainian historian and politician, contributed to the
integration of the Cossack past, and hence its institutions, into a coherent narrative
of democratic Ukraine.119 During the crisis of the Habsburg and Russian Empires,
radas were being formed in both. On March 4, 1917, the Ukrainian Central Rada
(Ukraїns’ka Tsentral’na Rada) was formed in Kyiv as the governing body of
the anticipated Ukrainian autonomy in postimperial Russia. Although the body
consisted of nominees rather than popularly elected deputies, it was occasionally
called a parliament – and after its constitutionalization, the Ukrainian polity was
supposed to have a universally elected one.120 The Ukrainian Central Rada, chaired
by Hrushevs’kii, proclaimed the formation of the Ukrainian People’s Republic
in November 1917, following the Bolshevik–Left SR coup in Petrograd and in
anticipation if the All-Russian Constituent Assembly. When the latter was dis-
banded, the Ukrainian Central Rada declared Ukraine’s independence in January
1918. The Ukrainian National Rada (Ukraїns’ka Natsіonal’na Rada) became the
supreme legislative body of the self-proclaimed independent Western Ukrainian
People’s Republic on the former Habsburg territory in October 1918.121 Radas as
governing bodies were also formed by Kuban Cossack, Belarusian, and regional
Ukrainian groups (for instance, in the Russian Far East).122
Mongolic-speaking politicians and intellectuals of the Russian and Qing
Empires participated in constitutionalizing Outer Mongolia. There, the term
khural was used for the new institutions. Following the declaration of independ-
ence in 1911, which in 1915 was internationally recognized as mere autonomy
within the Republic of China, the Bogd Khan ordered the establishment of a
bicameral consultative assembly – the State Khural (Ulus-un khural). The Bogd
Khan’s decree on the establishment of the State Khural referred to the experience
of the “powerful, rich, and cultured” states of the world, which had general assem-
blies of representatives, and stressed the need for deliberation and consideration
of dierent opinions when resolving challenging and important issues.123 The fact
that both chambers of the State Khural were appointed, while all decisions were
to be approved by the Bogd Khan, led Pavel Dudin to conclude that the regime
remained an absolute theocratic monarchy.124
The Buryat intellectual Tsyben Zhamtsarano participated in the debates on
parliamentarism in Outer Mongolia. In his Ulus-un erke (“Power of the State”),
Zhamtsarano presented a comparative study of political systems. He paid spe-
cial attention to parliaments, their structures, and elections, as well as the rela-
tions between central and local authorities in most states, dominions (such as
Australia and New Zealand), and parts of states (such as Finland or the states of

Duma, yuan, and beyond 35
the German Empire) with constitutions, probably using an available collection in
Russian. Zhamtsarano used the word khural for parliaments. He interpreted their
emergence from a progressive standpoint, explaining that the authorities had to
adapt to changing times and gather representatives to establish khurals “to dis-
cuss problems, benets, interests, income and expenditure, and many other mat-
ters” of the respective countries, as well as “to make laws to foster and rule the
people.” He continued, “Thus established, state khurals proved to be benecial
in many respects, therefore making the state more powerful. [People] denitely
understood that and nowadays most of sixty big and small countries have state
khurals.”125
Whereas the Ukrainian radas and the rst Mongolian State Khural ceased to
exist as institutions in the 1910s, the concepts were integrated into the Soviet
imperial formation, which extensively used non-Russian nationalisms. Even
though the Ukrainian Central Rada was the enemy of the Soviet government in
Ukraine, the translation of soviet into Ukrainian as rada practically appropri-
ated the term for the Bolsheviks. Indeed, the Ukrainian Socialist Soviet Republic
(Ukrains’ka Sotsiialistychna Radians’ka Respublika), which was formed in
1919 as a nominally independent state, became one of the USSR’s constituent
republics in December 1922. In 1921, the Mongolian People’s Government,
which proclaimed Mongolia’s independence with Soviet support, established the
Provisional State Khural as a consultative body.126 Furthermore, the assembly
which constituted the Mongolian People’s Republic after Bogd Khan’s demise
in 1924 was called the First Great Khural. It adopted the rst Constitution of
Mongolia, establishing the Great Khural as a constitutional parliamentary body.127
Both the radas and the khurals in the Soviet empire, however, were nominal bod-
ies, fully subordinate to the Ukrainian and Mongolian ruling parties, themselves
accountable to the Bolshevik Party.
Conclusion
Duma and yuan emerged as signiers of Russian and Qing/Chinese legislatures in
a contested conceptual landscape, with multiple alternative terms being used by
the proponents and opponents of parliamentarism. They did not, however, une-
quivocally point to the establishment of parliaments in the two contexts. Although
the Western system was largely perceived as universal, there was a critical recep-
tion of Western models rather than their simple “import,” and suggestions that the
Eurasian empires were not yet ready for such popular participation as in Western
Europe and America were frequent in the discussions among Eurasian intellec-
tuals. Some intellectuals, and especially the imperial elites, foregrounded the
state-centeredness of the new institutions which were supposed to rationalize and
facilitate governance of the populace rather than shift the source of sovereignty to
it, which often had bureaucratic connotations.
In both cases, parliamentarism did not seem to help preserve the Russian and
Qing Empires. Furthermore, after their collapse, pluralistic parliaments were estab-
lished only for brief moments, giving way to nominal representative institutions

36 Sablin et al.
under dominant political parties – the Bolsheviks and the Guomindang, respec-
tively. It was the parties which were supposed to be at the core of political and
other modernization. Even though the one-party regimes were formalized, the
new elites still viewed parliaments, albeit nominal, as important markers of a
modern state.
Notes
1 Egas Moniz Bandeira, “China and the Political Upheavals in Russia, the Ottoman
Empire, and Persia: Non-Western Inuences on Constitutional Thinking in Late
Imperial China, 1893–1911,” Transcultural Studies 8, no. 2 (2017): 40–78; Charles
Kurzman, Democracy Denied, 1905–1915: Intellectuals and the Fate of Democracy
(Cambridge, MA: Harvard University Press, 2008).
2 Fred M. Shelley, ed., Governments around the World: From Democracies to
Theocracies (Santa Barbara, CA: ABC-CLIO, 2015), 4.
3 Pasi Ihalainen, Cornelia Ilie, and Kari Palonen, eds., Parliaments and Parliamentarism:
A Comparative History of a European Concept (New York: Berghahn Books, 2016).
4 Pasi Ihalainen, Cornelia Ilie, and Kari Palonen, “Parliament as a Conceptual Nexus,”
in Parliaments and Parliamentarism: A Comparative History of a European Concept,
eds. Pasi Ihalainen, Cornelia Ilie, and Kari Palonen (New York: Berghahn Books,
2016), 1–16.
5 Jakob Norberg, “Concepts, Political,” in The Encyclopedia of Political Thought, eds.
Michael T. Gibbons et al., vol. 2 (Malden, MA: Wiley-Blackwell, 2015), 647–657;
Reinhart Koselleck, Futures Past: On the Semantics of Historical Time, trans. Keith Tribe
(New York: Columbia University Press, 2004), 4; Quentin Skinner, Visions of Politics,
vol. 1: Regarding Method (Cambridge: Cambridge University Press, 2002), 4–5.
6 Ilya Gerasimov et al., “New Imperial History and the Challenges of Empire,” in
Empire Speaks Out: Languages of Rationalization and Self-Description in the Russian
Empire, eds. Ilya Gerasimov, Jan Kusber, and Alexander Semyonov (Leiden: Brill,
2009), 3–32; Ilya Gerasimov et al., “The Centrality of Periphery,” Ab Imperio, no. 1
(2012): 19–20.
7 Arjun Appadurai, “How Histories Make Geographies,” Transcultural Studies 1, no. 1
(2010): 4–13.
8 V. Panov, V. Lebedev, and A. A. Shakhmatov, eds., “Nachal’naia Letopis’,” in
Drevnerusskie Letopisi (Moscow: Academia, 1936), 14, 35, 44, 51, 57, 70, 86, 102,
106, 109, 117; V. Panov and V. Lebedev, eds., “Kievskaia Letopis’,” in Drevnerusskie
Letopisi (Moscow: Academia, 1936), 117, 123, 129–130, 135, 146–147, 155, 205, 235.
9 M. M. Krom, “Vdovstvuiushchee Tsarstvo”: Politicheskii Krizis v Rossii 30–40-Kh
Godov XVI Veka (Moscow: Novoe literaturnoe obozrenie, 2010), 430–431, 434–435.
10 P. V. Lukin, Novgorodskoe Veche, 2nd ed. (Moscow: Akademicheskii proekt, 2018).
11 R. G. Skrynnikov, Rossiia Nakanune “Smutnogo Vremeni” (Moscow: Mysl’, 1981),
10–13; R. G. Skrynnikov, Ivan Groznyi (Moscow: Nauka, 1983), 105–106, 193–194;
A. A. Zimin, Oprichnina Ivana Groznogo (Moscow: Mysl’, 1964), 364–365, 369–370.
12 A. Iu. Dvornichenko, Rus Lietuvos: Velikoe Kniazhestvo Litovskoe ot Rassveta do
Zakata (Saint Petersburg: Evraziia, 2019).
13 Mark Brzezinski, The Struggle for Constitutionalism in Poland (Basingstoke:
Macmillan Press, 1998), 34–36.
14 M. M. Krom, Rozhdenie Gosudarstva: Moskovskaia Rus’ XV–XVI Vekov (Moscow:
Novoe literaturnoe obozrenie, 2018), 105.
15 Andrei Kurbskii, “Istoriia o Velikom Kniaze Moskovskom [Excerpts, 1570s],” in
Russkaia Sotsial’no-Politicheskaia Mysl’ XI–XVII Vv.: Khrestomatiia, eds. S. V.
Perevezentsev et al. (Moscow: Izdatel’stvo Moskovskogo universiteta, 2011), 309–322.

Duma, yuan, and beyond 37
16 For a discussion of the Mongol legacies in the development of Russian and Tatar rep-
resentative institutions, see Donald Ostrowski, “The Assembly of the Land (Zemskii
Sobor) as a Representative Institution,” in Modernizing Muscovy: Reform and Social
Change in Seventeenth-Century Russia, eds. Jarmo Kotilaine and Marshall Poe
(London: RoutledgeCurzon, 2004), 111–136.
17 V. V. Trepavlov and D. A. Mustana, “Posol’skaia Kniga Po Sviaziam Rossii s
Nogaiskoi Ordoi, 1551–1556 Gg.,” Vostochnaia Literatura, accessed May 12, 2019,
http://www.vostlit.info/Texts/Dokumenty/Russ/XVI/1540-1560/Posol_kniga_nog_
orda_1551_1561/text3.htm; P. A. Sadikov, “Pokhod Tatar i Turok Na Astrakhan’ v
1569 g.,” Vostochnaia Literatura, 1947, http://www.vostlit.info/Texts/Dokumenty/
Russ/XVI/1560-1580/Malcev_reci_1569/pred.htm.
18 N. I. Tarabasova et al., eds., Vesti-Kuranty: 1600–1639 Gg. (Moscow: Nauka, 1972),
42, 47, 69, 76–77, 88–90, 112–115, 182–183; Ingrid Maier, “Newspaper Translations in
Seventeenth-Century Muscovy: About the Sources, Topics and Periodicity of Kuranty
‘Made in Stockholm’ (1649),” in Explorare Necesse Est Hyllningsskrift till Barbro
Nilsson, eds. Per Ambrosiani et al. (Stockholm: Almqvist & Wiksell International,
2002), 181–90; Ingrid Maier and Stepan Shamin, “‘Revolts’ in the Kuranty of March–
July 1671,” in From Mutual Observation to Propaganda War: Premodern Revolts in
Their Transnational Representations, ed. Malte Griesse (Bielefeld: Transcript Verlag,
2014), 181–204.
19 N. I. Tarabasova, V. G. Dem’ianov, and S. I. Kotkov, eds., Vesti-Kuranty: 1645–1646,
1648 Gg. (Moscow: Nauka, 1980), 95–96.
20 Maija Jansson, “A Parliamentary Reception (of Sorts): The Russian Mission of 1645–
46,” Parliaments, Estates and Representation 37, no. 1 (2017): 32–40.
21 V. G. Dem’ianov, R. V. Bakhturina, and S. I. Kotkov, eds., Vesti-Kuranty: 1648–1650
Gg. (Moscow: Nauka, 1983), 77, 78, 81, 82.
22 Andreas Kappeler, Kleine Geschichte Der Ukraine, 4th ed. (Munich: C. H. Beck,
2014), 55.
23 Orest Subtelny, Ukraine: A History, 4th ed. (Toronto, ON: University of Toronto Press,
2009), 110.
24 Brian L. Davies, Warfare, State and Society on the Black Sea Steppe, 1500–1700
(London: Routledge, 2014), 110.
25 Nancy Shields Kollmann, The Russian Empire, 1450–1801 (Oxford: Oxford University
Press, 2017), 313, 384–390, 399, 434.
26 “Ustawa Konsytuctjna Królestwa Polskiego z Dnia 27 Listopada 1815 r.,” Biblioteka
Sejmowa, accessed November 19, 2019, http://libr.sejm.gov.pl/tek01/txt/kpol/1815-r0
.html.
27 M. M. Speranskii, “Vvedenie k Ulozheniiu Gosudarstvennykh Zakonov [1809],” in
Konstitutsionnye Proekty v Rossii XVIII – Nachala XX Veka, ed. A. N. Medushevskii
(Moscow: ROSSPEN, 2010), 220, 244–248.
28 A. N. Medushevskii, ed., Konstitutsionnye Proekty v Rossii XVIII – Nachala XX Veka
(Moscow: ROSSPEN, 2010), 22.
29 N. N. Novosil’tsev, “Gosudarstvennaia Gramota Rossiskoi Imperill [1820],” in
Konstitutsionnye Proekty v Rossii XVIII – Nachala XX Veka, ed. A. N. Medushevskii
(Moscow: ROSSPEN, 2010), 270, 283.
30 The Russian Empire, “Vysochaishe Utverzhdennyi Ustav ob Upravlenii Inorodtsev,
1822 g.,” in Polnoye Sobraniye Zakonov Rossiiskoi Imperii s 1649 G., vol. 38 (Saint
Petersburg: Tipograia II Otdeleniia Sobstvennoi Ego Imperatorskogo Velichestva
Kantseliarii, 1830), 394–417.
31 Mary Schaeer Conroy, ed., Emerging Democracy in Late Imperial Russia: Case
Studies on Local Self-Government (the Zemstvos), State Duma Elections, the Tsarist
Government, and the State Council before and during World War I (Niwot, CO:
University Press of Colorado, 1998).

38 Sablin et al.
32 I. B. Borisov et al., eds., Politicheskie Instituty, Izbiratel’noe Pravo i Protsess v Trudakh
Rossiiskikh Myslitelei XIX–XX Vekov (Moscow: Tsentral’naia izbiratel’naia komissiia
Rossiiskoi Federatsii, 2008), 48.
33 D. K. Burlaka et al., eds., Petr Velikii: Pro et Contra (Saint Petersburg: Izdatelstvo
Russkogo Khristianskogo gumanitarnogo instituta, 2003), 357.
34 B. N. Chicherin, O Narodnom Predstavitel’stve (Moscow: Tipograia Gracheva i
Komp., 1866), v.
35 V. I. Ger’e, “O Konstitutsii i Parlamentarizme v Rossii [1906],” in Politicheskie Instituty,
Izbiratel’noe Pravo i Protsess v Trudakh Rossiiskikh Myslitelei XIX–XX Vekov, eds. I.
B. Borisov et al. (Moscow: Tsentral’naia izbiratel’naia komissiia Rossiiskoi Federatsii,
2008), 585–598; M. M. Kovalevskii, Chto Takoe Parlament? (Saint Petersburg:
Brokgauz-Efron, 1906); P. G. Mizhuev, Parlamentarizm i Predstavitel’naia Forma
Pravleniia v Glavnykh Stranakh Sovremennoi Evropy (Saint Petersburg: Izdanie G. F.
L’vovicha, 1906).
36 See Shen Guowei 沈國威, Kindai Nitchū goi kōryūshi: shinkango no seisei to juyō
近代日中語彙交流史：新漢語の生成と受容 (Tokyo: Kasama shoin, 2008).
For studies on the history of the concept of parliament in China, see Fang Weigui
方維規, “Yihui, minzhu yu gonghe gainian zai xifang yu Zhongguo de shanbian”
議會、民主與共和概念在西方與中國的嬗變, 21 shiji 二十一世紀, no. 58 (2000):
49–62; Wang Qiang 汪強, “Cong yuwai xinzhi dao chaozhong shijian: Wanqing
yihui zhishi yanjiu lungang” 從域外新知到朝中實踐——晚清議會知識史硏究
論綱, Jinling falü pinglun 金陵法律評論, no. 32 (2017): 3–22; Yang Tangchen
楊湯琛, “Chuantong meiying xia de zhengzhi jingxiang: Wanqing yuwai youji
zhong de zizuan shuxie” 傅統魅影下的政治鏡像：晚清域外遊記中的議院書寫,
Jiangxi shehui kexue 江西社會科學, no. 10 (2019): 112–118; Kuei Hung-
chen 桂宏誠, “Qingmo Minchu renzhi zhong de ‘yiyuan’ yu ‘guohui’”
清末民初認知中的「議院」與「國會」, Guohui yuekan 國會月刊 36, no. 4
(Minguo 97 [2008]): 20–42; Liu Shantao 劉善濤, “Hanyu wailai yiming-tongshi
gainianci de cihui fenbu yanjiu” 漢語外來異名同實概念詞的詞彙分佈硏究, Yuyan
jiaoxue yu yanjiu 語言敎學與硏究, no. 4 (2017): 87–96.
37 Bridgman, Elijah Coleman [Gao Liwen 高理文], Meilige Heshengguo zhilüe
美理哥合省國志略 (Singapore: Jianxia shuyuan, 1838).
38 On the translations of Anglo-American institutions in the Haiguo tuzhi, see also
Taniguchi Satoko 谷口知子, “Kaikoku zushi ‘Shishūshi’ ni mirareru shin kainen no
hon’yaku: Gensho to no taishō o tōshite” 『海國圖志·四洲誌』に見られる新概念
の翻譯：原書との對照を通して, Wakumon 或問, no. 14 (2008): 81–97.
39 Wei Yuan 魏源, Haiguo tuzhi 海國圖志, 47 vols. (100 fasc.) (N.p.: n.e., [1853]), vol.
27 (fasc. 50), 2a–3b, vol. 33 (fasc. 60), 5b, vol. 22 (fasc. 41), 1b.
40 Ibid., vol. 27 (fasc. 50), 2b.
41 The transcription Haosi was also directly glossed as meaning yamen 衙門, “oce.”
Ibid., vol. 33 (fasc. 60), 5b.
42 Ibid., vol. 22 (fasc. 41), 1b.
43 See Tao Ping 陶萍, “Kōbei Nichiroku ni okeru shisetsu goi o megutte: Gokōsei no kanten
kara miru sanji kango” 『航米日録』における施設語彙をめぐって：語構成の観
点からみる三字漢語, Ritsumeikan gengo bunka kenkyū 立命館言語文化研究 25,
no. 3 (2014): 119–135.
44 Charles Hucker, A Dictionary of Ocial Titles in Imperial China (Taipei: Southern
Materials Center, Minguo 77 [1988]), 595–596.
45 Kuei, “Qingmo Minchu renzhi zhong de ‘yiyuan’ yu ‘guohui’.”
46 On the distinction between yiyuan 議院 and guohui 國會, see Kuei Hung-chen 桂宏誠,
Zhonghua Minguo lixian lilun yu 1947 nian de xianzheng xuanze 中華民國立憲理論與
1947 年的憲政選擇 (Taipei: Xiuwei zixun keji chuban, 2008), 88–90.
47 For example, in an eighteenth-century textbook of Mongol, yeke khural is translated
as dahui 大會 (“large assembly”). See Kuribayashi Hitoshi 栗林均 and Sechenbat

Duma, yuan, and beyond 39
斯欽巴図, eds., “Shogaku shinan” no kenkyū: 18 seiki no kōgo Mongorugo
「初学指南」の研究：18世紀の口語モンゴル語 (Sendai: Tōhoku Daigaku tōhoku
Ajia kenkyū sentā, 2012), 85. In the Secret History of the Mongols (Mongγol-un niγuča
tobčiyan; Yuanchao bishi 元朝秘史), qurilta is rendered as juhui 聚會 (“gathering”).
See Kuribayashi Hitoshi 栗林均, “Genchō hishi” bōyaku kango sakuin「元朝秘史」
傍訳漢語索引 (Sendai: Tōhoku Daigaku tōhoku Ajia kenkyū sentā, 2012), 184.
48 “Lun” 論, Dong-xi-yang kao meiyue tongji zhuan 東西洋考每月統紀傳, no. 5
(Daoguang dingyou 道光丁酉 [1837]): 1a–3a; “Zhiwai feng shu shu” 姪外奉叔書,
Dong-xi-yang kao meiyue tongji zhuan 東西洋考每月統紀傳, no. 6 (Daoguang din-
gyou 道光丁酉 [1837]): 1a–2a; “Yingjili guozheng gonghui” 英吉利國政公會, Dong-
xi-yang kao meiyue tongji zhuan 東西洋考每月統紀傳, no. 4 and no. 5 (Daoguang
wuxu 道光戊戌 [1838]): 63a–65a; 81a–83a.
49 Henry Wheaton [Huidun 惠頓], Wanguo gongfa 萬國公法, trans. William Alexander
Parsons Martin [Ding Weiliang 丁韙良] (Beijing: Chongshiguan, Tongzhi 3 [1864]),
passim.
50 The rst Chinese intellectual to propose an elected assembly was Feng Guifen 馮桂芬
in 1860/61, although his writings did not gain wider circulation until 1884. See Joshua
Hill, Voting as a Rite: A History of Elections in Modern China (Cambridge, MA:
Harvard University East Asia Center, 2019), 11–39.
51 Shenbao 申報, “Lun chuangxing yiyuan shi” 論創行議院事, June 17, 1874, 1.
52 On the Shenbao debates, see Rudolf G. Wagner, “The Free Flow of Communication
between High and Low: The Shenbao as Platform for Yangwu Discussions on Political
Reform 1872–1895,” T’oung Pao 104, no. 1–2 (2018): 116–188. On the continuation
of the debates by literati, see Onogawa Hidemi 小野川秀美, Shinmatsu seiji shisō
kenkyū 清末政治思想研究 (Tokyo: Misuzu shobō, 1984), 52–85; and Lloyd Eastman,
“Political Reformism in China before the Sino-Japanese War,” Journal of Asian Studies
27, no. 4 (1968): 695–710.
53 Zhang Zimu 張自牧, Lice zhiyan 蠡測卮言, in Xiaofanghuzhai yudi congchao
小方壺齋輿地叢鈔, ed. Wang Xiqi 王錫祺 (Shanghai: Zhuyitang, 1897), 499a–b. See
also Wagner, “The Free Flow of Communication between High and Low,” 173, whence
the translation of the sentence is adapted.
54 The title is variously translated as Words on Change, On Change, Easy Words or Easy
Remarks. The translation with “easy” or even “careless” is more appropriate, for Zheng
himself explains the title by citing various loci classici for the saying “talking is easier
than doing.” Zheng Guanying 鄭觀應, Zheng Guanying ji 鄭觀應集, ed. Xia Dongyuan
夏東元, 2 vols. (Shanghai: Renmin chubanshe, 1988), 1:63–64. On Zheng’s discourse
see Xiong Yuezhi 熊月之, Zhongguo jindai minzhu sixiang shi 中國近代民主思想史,
2nd ed. (Shanghai: Shanghai Shehui Kexueyuan chubanshe, 2002), 155–165.
55 On the tendency in general, see Michael Lackner, “Ex Oriente Scientia? Reconsidering the
Ideology of a Chinese Origin of Western Knowledge,” Asia Major 21 (2008), 183–200.
56 See Hawkling Lugine Yen, A Survey of Constitutional Development in China (New
York: Columbia University, 1911), 14.
57 Egas Moniz Bandeira, “China and the Globalisation of Constitutions: Constitutional
Thought in the Qing Empire (1838–1911)” (Ph.D. diss., Heidelberg University/Tohoku
University, 2019), 375–383.
58 Zheng, Zheng Guanying ji, 1:313. Also contained in Xia Xinhua 夏新華 et al., eds.
Jindai Zhongguo xianzheng licheng: shiliao huicui 近代中國憲政歷程：史料薈萃
(Beijing: Zhongguo Zhengfa Daxue chubanshe, 2004), 13. Zheng’s discourse is a con-
tinuation of Feng Guifen’s. See Hill, Voting as a Rite, 11–39.
59 Zheng, Zheng Guanying ji, 1:328–330.
60 Ibid., 313; Xia et al., eds., Jindai Zhongguo xianzheng licheng, 13.
61 Li Jiaju 李家駒, “Youzhengye Zhai zaji” 有正業齋雜記, in Li Jiaju riji 李家駒日記,
ed. Li Jiaju 李家駒 (Diaries of Li Jiaju) (N.p., 1898–1903); Shelfmark t4746, National
Library of China, Beijing. Entry for Guangxu 25/2/22 (April 2, 1899).

40 Sablin et al.
62 Gosudarstvennaia duma, tretii sozyv, pervaia sessiia, Stenogracheskie Otchety,
Chast’ 2: Zasedaniia 31–60, s 21 Fevralia po 5 Maia 1908 G. (Saint Petersburg:
Gosudarstvennaia tipograia, 1908), 971–972.
63 I. V. Lukoianov, ed., “Perepiska A. A. Kireeva i F. D. Samarina,” Nestor, no. 3 (2000):
24–27.
64 P. N. Miliukov, Petergofskoe Soveshchanie o Proekte Gosudarstvennoi Dumy pod
Lichnym Ego Imperatorskogo Velichestva Predsedatel’stvom: Sekretnye Protokoly
(Berlin: Eberhard Frowein Verlag, 1910), 21–22, 34, 80–81, 220.
65 V. M. Gessen and B. E. Nol’de, eds., Sovremennye Konstitutsii: Sbornik Deistvuiushchikh
Konstitutsionnykh Aktov, vol. 2: Federatsii i respubliki (Saint Petersburg: Pravo, 1907),
565–566.
66 V. M. Gessen, ed., Avtonomiia, Federatsiia i Natsional’nyi Vopros (Saint Petersburg:
Narod i svoboda, 1906), 22–28.
67 Sibirskaia zhizn’, October 27, 1905: 2.
68 Max Weber, “Russlands Übergang zum Scheinkonstitutionalismus,” Archiv für
Sozialwissenschaft und Sozialpolitik 23, no. 1, Beilage (1906): 165–401.
69 Although he did treat the Finnish Diet as a parliament by practices since 1863, see B. E.
Nol’de, Ocherki Russkogo Gosudarstvennogo Prava (Saint Petersburg: Pravda, 1911),
10–11, 13–14, 49, 545.
70 S. A. Kotliarevskii, “Problema Demokratizatsii Gosudarstva [1906] [“The Problem
of State Democratization”], in Politicheskie Instituty, Izbiratel’noe Pravo i Protsess
v Trudakh Rossiiskikh Myslitelei XIX–XX Vekov [Political Institutions, Electoral Law
and Process in the Works of Russian Thinkers of the Nineteenth–Twentieth Century],
eds. I. B. Borisov et al. (Moscow: Tsentral’naia izbiratel’naia komissiia Rossiiskoi
Federatsii, 2008), 568–570, 572.
71 G. F. Shershenevich, Programma Partii Narodnoi Svobody (Konstitutsionno-
Demokraticheskoi) [The Program of the Party of People’s Freedom (Constitutional
Democratic)] (Moscow: Tipograia G. Lissnera i D. Sobko, 1906), 6.
72 V. V. Rozanov, “Gosudar’ i Gosudarstvennaia Duma [1906],” in Politicheskie Instituty,
Izbiratel’noe Pravo i Protsess v Trudakh Rossiiskikh Myslitelei XIX–XX Vekov, eds. I.
B. Borisov et al. (Moscow: Tsentral’naia izbiratel’naia komissiia Rossiiskoi Federatsii,
2008), 607–608.
73 Benedict Anderson, Imagined Communities: Reections on the Origin and Spread of
Nationalism, Rev. and extended ed. (London: Verso, 1991).
74 Alexander Semyonov, “‘The Real and Live Ethnographic Map of Russia’: The Russian
Empire in the Mirror of the State Duma,” in Empire Speaks Out: Languages of
Rationalization and Self-Description in the Russian Empire, eds. Ilya Gerasimov, Jan
Kusber, and Alexander Semyonov (Leiden: Brill, 2009), 211–213, 216.
75 Partiia Sotsialistov-Revoliutsionerov, Nasha Programma: Obshchedostupnoe
Izlozhenie (Saint Petersburg: Partiia Sotsialistov-Revoliutsionerov, 1908), 24–26;
Programmy Russkikh Politicheskikh Partii (Saint Petersburg: Izdanie V. Kharitonova,
1905), 54–55, 64–65; G. F. Shershenevich, Programma Partii Narodnoi Svobody
(Konstitutsionno-Demokraticheskoi) (Moscow: Tipograia G. Lissnera i D. Sobko,
1906), 9–10.
76 V. V. Kriven’kii, ed., Anarkhisty: Dokumenty i Materialy 1883–1935 Gg., vol. 1: 1883–
1916 gg. (Moscow: ROSSPEN, 1998), 230–234, 241–242.
77 Institut demograi Natsional’nogo issledovatel’skogo universiteta Vysshaia shkola
ekonomiki [The Institute of Demographics of the National Research University Higher
School of Economics], “Pervaia Vseobshchaia Perepis’ Naseleniia Rossiiskoi Imperii
1897 g.” [“The First General Census of the Russian Empire of 1897”], http://demoscop
e.ru/weekly/ssp/census.php?cy=0 (accessed 1 December 2015).
78 V. V. Rozanov, “Chastnyi i Obshchestvennyi Interes v Gosudarstvennoi Dume
[1907],” in Politicheskie Instituty, Izbiratel’noe Pravo i Protsess v Trudakh Rossiiskikh

Duma, yuan, and beyond 41
Myslitelei XIX–XX Vekov, eds. I. B. Borisov et al. (Moscow: Tsentral’naia izbiratel’naia
komissiia Rossiiskoi Federatsii, 2008), 616–617.
79 The preceding fragment is based on Ivan Sablin, “Russia in the Global Parliamentary
Moment, 1905–1918: Between a Subaltern Empire and an Empire of Subalterns,” in
Locating the Global: Spaces, Networks and Interactions from the Seventeenth to the
Twentieth Century, ed. Holger Weiss (Berlin: De Gruyter Oldenbourg, 2020), 257–282.
80 Norbert Meienberger, The Emergence of Constitutional Government in China (1905–
1908): The Concept Sanctioned by the Empress Dowager Tzʻu-hsi (Bern: P. Lang,
1980), 12.
81 Moniz Bandeira, “China and the Political Upheavals in Russia, the Ottoman Empire,
and Persia,” 40–78; Egas Moniz Bandeira, “Political Reforms in a Global Context:
Some Foreign Perspectives on Constitutional Thought in Late Imperial China,”
Contemporary Chinese Political Economy and Strategic Relations 3, no. 1 (2017):
139–185.
82 Gugong Bowuyuan Ming-Qing dang’anbu 故宮博物院明清檔案部, ed., Qingmo
choubei lixian dang’an shiliao 清末籌備立憲檔案史料, 2 vols (Beijing: Zhonghua
shuju, 1979), 1:43–44; 1:472.
83 Ibid., 2:667.
84 See Xianzheng biancha guan 憲政編查館, Xianzheng biancha guan fuyi ziyiju quan-
xian zhepian 憲政編查館復議諮議局權限折片, in Zhonghua Minguo shi dang'an zil-
iao huibian (di yi, er ji) 中華民國史檔案資料滙編（第一、二輯）, ed. Zhongguo di
er lishi dang'anguan 中國第二歷史檔案館, 1:113–121 (here, particularly 116).
85 Gugong Bowuyuan Ming-Qing dang’anbu, Qingmo choubei lixian dang'an shiliao, 2:689.
86 Yikuang 奕劻 et al., “Zun zhi fu Hanlinyuan sidu xueshi Wu Shijian qing shenming
ziyiju quanxian zhe” 遵旨覆翰林院侍讀學士吳士鑑請申明諮議局權限摺, 1910, in
the les of the Ministry of War (Lujunbu dang’an 陸軍部檔案), Second Historical
Archives of China, Nanjing, cit. in. Gao Fang 高放, Qingmo lixian shi 清末立憲史
(Beijing: Huawen chubanshe, 2012), 252.
87 David Brophy, “Five Races, One Parliament? Xinhai in Xinjiang and the Problem of
Minority Representation in the Chinese Republic,” Inner Asia 14, no. 2 (2012): 350.
88 Egas Moniz Bandeira, “Late Qing Parliamentarism and the Borderlands of the Qing
Empire—Mongolia, Tibet, and Xinjiang (1906–1911),” Journal of Eurasian Studies
11, no. 1 (2020): 15–29. See also Brophy, “Five Races, One Parliament,” 358.
89 The Qing Empire, Daqing lichao shilu: Daqing Dezong Jing Huangdi shilu
大清歷朝實錄：大清德宗景皇帝實錄, 593:20.
90 See also Meienberger, The Emergence of Constitutional Government in China, 74.
91 See, e.g., Chen Fei 陳飛, “Disassembling Empire: Revolutionary Chinese Students
in Japan and Discourses on Provincial Independence and Local Self-Government,”
Journal of Asian History 51, no. 2 (2017): 283–315.
92 The text is collected in Xia et al., eds. Jindai Zhongguo xianzheng licheng, 127. On
Art. 1 of the Meiji Constitution and its signicance in China and Korea see Egas
Moniz Bandeira, “From Dynastic Cycle to Eternal Dynasty: The Japanese Notion of
Unbroken Lineage in Chinese and Korean Constitutionalist Debates, 1890–1911,”
Global Intellectual History (2020), DOI: 10.1080/23801883.2020.1796236, 1–16
(ahead of print).
93 Ibid., 156–159. The English translation is adapted from “The Provisional Constitution
of the Republic of China,” American Journal of International Law VI, S3 (1912):
149–154 (where the translation writes “… is vested in the people”). For a French
translation, see Scié-Ton-Fa, “Notice sur le changement de régime (Révolution et
République), sur les réformes constitutionnelles et le mouvement législatif de 1911 et
1912: Publié par la société de législation comparée contenant le texte des principales
lois votées dans les pays étrangers en 1913,” Annuaire de législation étrangère 43
(1914): 595–597.

42 Sablin et al.
94 Xia et al., eds., Jindai Zhongguo xianzheng licheng, 169–171.
95 See Chang P'eng-Yüan 張朋園, Zhongguo minzhu zhengzhi de kun-
jing: Wanqing yilai lijie yihui xuanju shulun 中國民主政治的困境,
1909–1949：晚清以來歷屆議會選舉述論 (Taipei: Linking, Minguo 96 [2007]),
80, with further references. On voting in China see also Hill, Voting as a Rite.
96 See Chang, Zhongguo minzhu zhengzhi de kunjing, 55, with further references.
97 Brophy, “Five Races, One Parliament,” 349–350.
98 Ibid., 351–353.
99 V. I. Lenin, “Obnovlennyi Kitai” [1912], in Polnoe Sobranie Sochinenii, 5th ed.,
vol. 22 (Moscow: Izdatel’stvo politicheskoi literatury, 1968), 189–191.
100 V. I. Lenin, “Bor’ba Partii v Kitae” [1913], in Polnoe Sobranie Sochinenii, 5th ed.,
vol. 23 (Moscow: Izdatel’stvo politicheskoi literatury, 1973), 138–140.
101 Xia et al., eds., Jindai Zhongguo xianzheng licheng, 471–476.
102 It is a matter of debate whether Yuan Shikai’s US American advisor Frank Johnson
Goodnow supported Yuan’s application of his recommendations, and to what
extent his advice was being politically abused by his hosts. On Goodnow, see, e.g.,
Xu Guoqi, Chinese and Americans: A Shared History (Cambridge, MA: Harvard
University Press, 2014), 139–203; on the Japanese Ariga Nagao 有賀長男 (1860–
1921) and his activities in both Imperial and Republican times, see Matsui Naoyuki
松井直之, “Shinmatsu-Minsho-ki no Chūgoku ni okeru rikkenshugi no keiju:
Ariga Nagao no Tennō-kikansetsu ni chakumokushite” 清末民初期の中国にお
ける立憲主義の継受：有賀長雄の天皇機関説に着目して, in Nitchū ni okeru
Seiō rikkenshugi no keiju to henyō 日中における西欧立憲主義の継受と変容,
ed. Takahashi Kazuyuki 高橋和之 (Tokyo: Iwanami shoten, 2014), 93–122.
103 On these elections, see Chang, Zhongguo minzhu zhengzhi de kunjing, 118–164.
104 On the 1918 parliament see e.g., Kaneko Hajime 金子肇, “Min’i ni fukusanu daihyō:
Shin kokkai no ‘gikai sensei’” 民意に服さぬ代表：新国会の「議会專制」,
in Chūgoku gikai 100-nen shi: Dare ga dare o daihyōshitekita no ka
中国議会１００年史：誰が誰を代表してきたのか, ed. Fukamachi Hideo
深町英夫 (Tokyo: Tokyo Daigaku shuppankai, 2015), 63–82.
105 See Andrew J. Nathan, “A Constitutional Republic: The Peking Government, 1916–
28,” in The Cambridge History of China, vol. 12: Republican China 1912–1949, Part
1, ed. John K. Fairbank (Cambridge: Cambridge University Press, 1983), 279–283.
106 Ibid., 283.
107 Ivan Sablin, The Rise and Fall of Russia’s Far Eastern Republic, 1905–1922:
Nationalisms, Imperialisms, and Regionalisms in and after the Russian Empire
(London: Routledge, 2018), 88.
108 V. M. Gessen, Osnovy Konstitutsionnogo Prava (Petrograd: Izd. iurid. kn. sklada
Pravo, 1917), 138–141.
109 M. V. Vishniak, Uchreditel’noe Sobranie i Proportsional’nye Vybory (Petrograd: Tip.
Ts. K. Partii Sotsialistov-Revoliutsionerov, 1917), 16.
110 Georg Ellinek, Obshchee Uchenie o Gosudarstve, 2nd ed. (Saint Petersburg: N. K.
Martynov, 1908), 429–433.
111 A. N. Medushevskii, ed., Konstitutsionnye Proekty v Rossii XVIII – Nachala XX Veka
(Moscow: ROSSPEN, 2010), 587–591.
112 Ivan Sablin and Alexander Semyonov, “Autonomy and Decentralization in the Global
Imperial Crisis: The Russian Empire and the Soviet Union in 1905–1924,” Modern
Intellectual History 17, no. 2 (2020): 543–560.
113 The preceding fragment is based on Ivan Sablin, “Russia in the Global Parliamentary
Moment, 1905–1918.”
114 Sun Yat-sen 孫逸仙, Guofu yijiao: Jianguo fanglüe; Jianguo dagang
國父遺教：建國方略．建國大綱, 9th ed. (Taipei: Sanmin shuju, Minguo 83
[1994]), 350.

Duma, yuan, and beyond 43
115 Meredith P. Gilpatrick, “The Status of Law and Lawmaking Procedure under the
Kuomintang 1925–46,” The Journal of Asian Studies 10, no. 1 (1950): 46–47.
116 William L. Tung, The Political Institutions of Modern China (The Hague: Martinus
Nijho, 1964), 125–126.
117 C. L. Hsia, “China’s People’s Convention: National Constitution and Ten-Year Plan,”
Pacic Aairs 4, no. 9 (1931): 779–798.
118 O. Turyi, ed., Holovna Rus’ka Rada, 1848–1851: Protokoly Zasіdan’ і Knyha
Korespondentsії (Lvіv: Іnstytut Іstorіi Tserkvy Ukrains’koho Katolyts’koho
Unіversytetu, 2002), ix.
119 Serhii Plokhy, Unmaking Imperial Russia: Mykhailo Hrushevsky and the Writing of
Ukrainian History (Toronto, ON: University of Toronto Press, 2005), 90, 193–94.
120 V. F. Verstiuk and V. A. Smolii, eds., Ukraїns’ka Tsentral’na Rada, vol. 1 (Kyiv:
Naukova Dumka, 1996), 81, 139, 263.
121 Vasyl Kuchabsky, Western Ukraine in Conict with Poland and the Bolshevism,
1918–1923 (Edmonton, AB: University of Alberta Press, 2009), 25.
122 See V. A. Chornomaz, ed., Zelenyi Klyn (Ukrains’kyi Dalekyi Skhid):
Entsyklopedychnyi Dovіdnyk (Vladivostok: Vid-vo Dalekoskh. federal. un-tu, 2011).
123 E. Zhavzandulam and Y. Delgermaa, eds., Mongol Ulsyn Deed, Dood Khural: Barimt
Bichgiin Emkhtgel, vol. 1 (Ulaanbaatar: Soembo printing, 2003), 23–25.
124 P. N. Dudin, “Stanovlenie i Normativnoe Zakreplenie Teokraticheskoi Monarkhii v
Mongolii v 1911–1924 Gg.,” Pravo: Zhurnal Vysshei Shkoly Ekonomiki, no. 2 (2013):
158.
125 Tsyben Zhamtsarano, Ulus-Un Erke (Khüree, 1914), 3.
126 Dudin, “Stanovlenie i Normativnoe Zakreplenie Teokraticheskoi Monarkhii v
Mongolii v 1911–1924 Gg.,” 160–161; I. I. Kudriavtsev et al., eds., Mongoliia v
Dokumentakh Kominterna, 1919–1934, vol. 1: 1919–1929 (Ulan-Ude: BNTs SO
RAN, 2012), 79.
127 D. Dash, Bügd Nairamdakh Mongol Ard Ulsyn Ankhdugaar Ikh Khural: 1924 Ony XI
Saryn 8–28: Delgerengüi Tailan, ed. M. Sanzhdorzh (Ulaanbaatar: Ulsyn khevleliin
gazar, 1984).
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