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Chinese law

Chinese law is one of the oldest legal traditions in the world. The core of modern Chinese law is based on Germanic-style civil law, socialist law, and traditional Chinese approaches.

For most of the history of China, its legal system has been based on the Confucian philosophy of social control through moral education, as well as the Legalist emphasis on codified law and criminal sanction. Following the Xinhai Revolution, the Republic of China adopted a largely Western-style legal code in the civil law tradition (specifically German- and Swiss-based). The establishment of the People's Republic of China in 1949 brought with it a more Soviet-influenced system of socialist law. However, earlier traditions from Chinese history have retained their influence.

Chinese legal tradition
The word for law in classical Chinese was fǎ (法). The Chinese character for fǎ denotes a meaning of "fair", "straight" and "just", derived from its water radical (氵). It also carries the sense of "standard, measurement, and model". Derk Bodde and Clarence Morris held that the concept of fǎ had an association with yì (義: "social rightness"). Yan Fu, in his Chinese translation of Montesquieu's De l'esprit des lois published in 1913, warned his readers about the difference between the Chinese fǎ and Western law: "The word 'law' in Western languages has four different interpretations in Chinese as in lǐ (理: "order"), lǐ (禮: "rites", "decorum"), fǎ (法: "human laws") and zhì (制: "control").

A term which preceded fǎ was xíng (刑), which originally probably referred to decapitation. Xíng later evolved to be a general term for laws that related to criminal punishment. The early history Shang Shu recorded the earliest forms of the "five penalties": tattooing, disfigurement, castration, mutilation, and death. Once written law came into existence, the meaning of xíng was extended to include not only punishments but also any state prohibitions whose violation would result in punishments. In modern times, xíng denotes penal law or criminal law. An example of the classical use of xíng is Xíng Bù (刑部, lit. "Department of Punishment") for the legal or justice department in imperial China.

The two major Chinese philosophical schools discussed below, Confucianism and Legalism, strongly influenced the idea of law in China. Briefly, under Confucianism, the state should lead the people with virtue and thus create a sense of shame which will prevent bad conduct. Under Legalism, law is to publicly promulgate standards of conduct backed by state coercion. The tension between these two systems is that Confucianism relies on tradition to make the leader the head of household of all China, while Legalism makes standard law that even the emperor should be bound by. The common factor is that both endorse to different degrees a paternalistic conception of the state, which knows better than its citizens and makes laws to protect them. This concept persisted throughout the imperial period, into the republican period, and can still be seen acting today.

Unlike many other major civilizations where written law was held in honor and often attributed to divine origin, law in early China was viewed in purely secular terms, and its initial appearance was greeted with hostility by Confucian thinkers as indicative of a serious moral decline, a violation of human morality, and even a disturbance of the total cosmic order. Historically, the people's awareness and acceptance of ethical norms was shaped far more by the pervasive influence of custom and usage of property and by inculcating moral precepts than by any formally enacted system of law. Early emperors however embraced the Legalist ideal as a way of exerting control over their large and growing territory and population. This process was integrated with traditional Chinese beliefs in the cosmic order, holding that correct behavior was behavior consonant with the appropriate responses set by fǎ. Xíng states the potential costs to the individual of exceeding them and imposes penalties for these actions.

The imperial period was characterized mainly by the concept of law as serving the state, a means of exerting control over the citizenry. In the late Qing dynasty there were efforts to reform the law codes mainly by importing German codes with slight modifications. This effort continued and was amplified in the republican period resulting in the Provisional Constitution of 1912 which included the idea of equality under the law, rights for women, and broader rights for citizens vis-à-vis the government. The onset of the communist period at first rolled back the development of individual rights with the primary concept of law returning to that of a tool of the state. After the Cultural Revolution devastated the ranks of intellectuals and legal professionals, it took until 1982 for the idea of individual rights to reemerge as a significant influence on Chinese law.

The current constitution, created in 1982, states in Article V that no organization or individual is above the law and in Article III makes the People's Congresses and state administration responsible to the people, paving the way for later efforts to allow enforcement of individual rights. Passage of the Administrative Litigation Law of 1987 created legal recourse for individuals from arbitrary government action, an avenue previously unavailable. Despite the deep-seated norm against legal proceedings, litigation in the Chinese courts has increased dramatically, especially in recent years. The continuing weakness of courts resulting from their dependence on the local government for financial support and enforcement undermines the effectiveness of these remedies but this has also begun to change with China's initiatives to increase legal training and the professionalism of the judiciary.

One avenue of individual appeal from government action which continues to be important is the custom of xìnfǎng 信访 (or shàngfǎng 上访) or petitions by citizens to the individuals officials for change. The continuing wide use of xìnfǎng reflects the fact that many officials are still able to avoid legal sanctions and the underlying avoidance of the legal system, as well as the personal ability of officials to personally intervene to change unjust results. Recently xìnfǎng has been institutionalized to some extent with the central government mandating that every level of administration establish a xìnfǎng office to handle petitions and report them up to high levels. This solution by exertion of personal power clearly goes against the idea of rule of law, and worse, some scholars have noted that xìnfǎng today functions more as an informational collection system for the government than an effective review mechanism.

Confucianism and Legalism
Confucianism and Legalism are two major Classical legal theories or philosophies developed during the Spring and Autumn period and the Warring States period, a time that saw the most impressive proliferation of new ideas and philosophies in Chinese history. While both theories call for governmental hierarchy, they differ drastically in their views of human potential and the preferred means to achieve political order. Nevertheless, both theories have influenced and continue to influence the development of cultural, social, and legal norms in China.

Confucianism
The basic premise of Confucianism is the idea that human beings are fundamentally good. With this optimistic view on human potential, Confucius advocates for ruling through li – traditional customs, mores, and norms – which allow people to have a sense of shame and become humane people with good character, rather than through government regulations and penal law. The idea is that people will internalize the acceptable norms and only take proper actions. This will not only lead to a harmonious social order, but it will also provide the additional benefit of improving an individual's inner character and the overall quality of the society. In contrast, codified laws require external compliance, and people may abide by the laws without fully understanding the reason for compliance. As such, a social order achieved through formal laws does not come with the additional benefit of better citizenry. It is worth noting, however, that even Confucius did not advocate for the elimination of formal laws. Rather, according to Confucius, laws should be used minimally and reserved only for those that insist on pursuing one's self-interests without taking into account the well-being of the society.

As Confucius rejects the general use of formal laws to achieve social order, what lies vital to Confucius' theory is the willing participation by citizens of the society to search for commonly accepted, cooperative solutions. In addition to willing participation of citizens, there must also be grounds or bases upon which commonly acceptable solutions can be arrived at – the concept known as li. Li is commonly understood as a set of culturally and socially valued norms that provide guidance to proper behaviors that will ultimately lead to a harmonious society. These norms are not fixed or unchangeable over time but rather a reflection of what is accepted at a particular time in a particular context. When conflicts arise, the li have to be applied and interpreted to produce a just result and restore the harmony of the society. However, in the absence of any procedural safeguard afforded by codified laws, interpretation of li is subject to abuse.

Recognizing that people in a society hold diverse interests, Confucius charges the ruler with the responsibility to unify these interests and maintain social order. This is not done by dictatorship but by setting an example. Therefore, a ruler needs not to force his people to behave properly. Instead, the ruler needs only to make himself respectful, and the people will be induced and enlightened by his superior virtues to follow his example – an ideal known as wúwéi. Nevertheless, the ruler must know and understand the li to be able to create solutions to conflict and problems the society faces. As the people are to follow the moral standards and example set by the ruler, to a large extent, the quality of the ruler determines the quality of the political order.

Legalism
In contrast to Confucius' li-based theory, the Legalism advocates the utilization of codified laws and harsh punishment to achieve social order. This is due to the legalists' belief that all human beings are born evil and self-interested. Therefore, if left unrestrained, people would engage in selfish behavior which will undoubtedly lead to social unrest. To cure this defect and force people to behave morally, the only way, believed the legalists, is to publicly promulgate clearly written laws and impose harsh punishments.

Realizing that the abilities of rulers are often limited and that reliance on the ruler's ability and judgment often leads to adverse results, the legalists designed a system in which the law is run by the state, not the ruler. This ensures that the laws will be applied impartially without the interference of personal bias of the ruler or ones who are responsible for applying the laws. It also makes it irrelevant whether the ruler has superior abilities. This non-action promoted by the legalists is their understanding of the concept of wuwei, which is different from the Confucians' understanding of the same concept.

Comparison
Notwithstanding such an understanding, the ruler, like in Confucianism, has the ultimate authority to decide what the law should be. Therefore, like Confucianism, Legalism is subject to abuse as well. In fact, the Qin emperor implemented strict laws and extremely harsh punishments without taking into account mitigating circumstances even for insignificant crimes. For example, books were burned and people holding different ideals were buried alive. While the Qin emperor successfully instilled fear and respect for law into the minds of his people, the harshness of the law led to his quick demise after only 14 years of reigning over China.

In summary, although both Confucianism and Legalism were developed in a period of turmoil and both were aimed at the re-unification of the country, the two theories went opposite directions with one advocating for and one against the use of formal laws to achieve social order. What the two theories have in common is their concession of the ultimate authority to the ruler, who remained above and beyond the li or law. It is true that neither theory is ideal in achieving a social order. Nevertheless, both theories have had a significant impact on the cultural and legal development in China, and their influence remains visible today.

The significant influence of the Legalist tradition in Chinese law has historically been overlooked. Although the Confucian ideology provided the fundamentals for the substance of traditional law, the Legalist school constructed the important framework of the traditional legal system. The Han dynasty retained the basic legal system established under the Qin but modified some of the harsher aspects in line with the Confucian philosophy of social control.

The Han dynasty formally recognized four sources of law: lü (律: "codified laws"), ling (令: "the emperor's order"), ke (科: "statutes inherited from previous dynasties") and bi (比: "precedents"), among which ling has the highest binding power over the other three. Most legal professionals were not lawyers but generalists trained in philosophy and literature. The local, classically trained, Confucian gentry played a crucial role as arbiters and handled all but the most serious local disputes.

Eventually, the incorporation of the essentials of Confucianist li into legal codes occurred with this Confucian conception dominating ancient Chinese law. Ch'ü concludes that the gradual process of Confucianisation of law was the most significant development in the legal system of China prior to 20th century modernization. The line between ruling by moral influence and ruling by punishment was not always clearly delineated. For example, li could be enforced by moral influence and legal means. The metamorphosis of li into law depended on its widespread and unvaried acceptance by society.

Although the codification of law was largely completed by the Tang Code of CE 624, throughout the centuries the Confucian foundations of the Tang Code were retained, and indeed with some aspects of it strengthened by the later dynasties. The Great Ming Code, which was a model for the Qing code, covered every part of social and political life, especially family and ritual, but also foreign relations and even relations of earthly life with the cosmos.

The Confucian notion that morality and self-discipline was more important than legal codes caused many historians, such as Max Weber, until the mid-20th century to conclude that law was not an important part of Imperial Chinese society. This notion, however, has come under extreme criticism and is no longer the conventional wisdom among Sinologists, who have concluded that Imperial China had an elaborate system of both criminal and civil law which was comparable to anything found in Europe.

During the Qing dynasty, criminal justice was based on extremely detailed Great Qing Legal Code. One element of the traditional Chinese criminal justice system is the notion that criminal law has a moral purpose, one of which is to get the convicted to repent and see the error of his ways. In the traditional Chinese legal system, a person could not be convicted of a crime unless he has confessed. This often led to the use of torture, in order to extract the necessary confession. These elements still influence modern Chinese views toward law. All capital offenses were reported to the capital and required the personal approval of the emperor.

There was no civil code separate from the criminal code, which led to the now discredited belief that traditional Chinese law had no civil law. More recent studies have demonstrated that most of the magistrates' legal work was in civil disputes, and that there was an elaborate system of civil law which used the criminal code to establish torts.

Modernization
The introduction and translation of Western legal texts into Chinese is believed to have been started under the auspices of Lin Zexu in 1839. More systematic introduction of Western law together with other Western sciences started with the establishment of Tongwen Guan in 1862. The major efforts in translation of Western law that continued until the 1920s prepared the building blocks for modern Chinese legal language and Chinese law. Legal translation was very important from 1896 to 1936 during which period the Chinese absorbed and codified their version of Western laws. These efforts were assisted by the medium of the Japanese legal language and law developed in Japan during the Meiji period which involved in large part Japanese translation of European Continental laws.

Under pressure from European powers and increasing commercial interactions, the influence of European legal systems on China increased. The First Opium War ended with the 1842 Treaty of Nanjing between China and the United Kingdom. The first of the unequal treaties, it required the establishment of five treaty ports in Chinese cities. The Treaty of the Bogue introduced extraterritoriality in favor of the UK, pursuant to which UK citizens were immune from prosecution in Chinese courts and instead only UK law applied. The United States obtained similar privileges under the 1844 Treaty of Wanghia, as did France under the 1844 Treaty of Whampoa. Concessions, where foreign law applied not just to foreigners but also to Chinese, further accelerated the influence of non-Chinese legal concepts.

In the early 1900s, the Qing dynasty's Imperial Recodification Commission prepared a proposed civil code which was significantly influenced by the German and Japanese legal systems. Jurist Shen Jiaben and Governor Zhang Zidong led late Qing legal reform efforts. The Qing dynasty was defeated before the code was adopted and the Republic of China rejected the proposed code, instead developing its own.

Attitudes toward the traditional Chinese legal system changed markedly in the late-20th century. Most Chinese and Westerners of the early 20th century regarded the traditional Chinese legal system as backward and barbaric. However, extensive research into China's traditional legal system has caused attitudes to become more favorable in the late-20th and early 21st centuries. Researchers of the early and mid-20th century tended to compare the traditional Chinese legal system to then contemporary systems, finding the former to be backward. However, more recent research compared the 18th-century Chinese legal system to European systems of the 18th century, resulting in a far more positive view of traditional Chinese law.

The Department of Punishment was changed to fa bu (法部: "Department of Law") in the early 1900s legal reforms.

Republic of China
The Republic of China discarded the proposed code drafted at the end of the Qing empire and prepared its own civil code which it adopted in 1929. It was significantly influenced by German civil law.

Law in the Republic of China (Taiwan) is mainly a civil law system. The legal structure is codified into the Six Codes: the Constitution, the Civil Code, the Code of Civil Procedures, the Criminal Code, the Code of Criminal Procedures and in Administrative Laws.

People's Republic of China
Unlike traditional Chinese law, modern Chinese law is based mainly on statutory law and court judgments do not have binding precedential value.

After the Communist victory in 1949, the newly established People's Republic of China (PRC) quickly abolished the ROC's legal codes and attempted to create a system of socialist law copied from the Soviet Union. With the Sino-Soviet split (1960–1989) and the Cultural Revolution (1966–1976), all legal work came under suspicion of being counter-revolutionary, and the legal system completely collapsed. A new concept of justice called judicial populism (sifa dazhonghua ) was established. Instead of the requirement for judges to comply with strict judicial procedures, it promoted substantive justice and problem-solving mechanisms. This legal tradition is based on a cultural view of the non-finality in justice as well as the revolutionary practice of the Communist Party that relies on people's justice.

Over the past century China has had several constitutions. The first attempts towards implementing a constitution in China occurred during the final decade (1902–1912) of the Qing dynasty. Various controlling groups subsequently promulgated different constitutions between that time and the establishment of the PRC in 1949. The PRC had a provisional constitution from its inception until the enactment of its first constitution in 1954. This initial constitution was based on the constitution of the Soviet Union. It was shortly ignored, however, and became without legal force. Although it provided for the election of the National People's Congress (NPC) every four years as the highest state power, these guidelines were not adhered to. The second constitution of the PRC, modeled on the ideology of the Cultural Revolution, came into force in 1975. This constitution subjected the NPC to the Chinese Communist Party (CCP) and removed previous constitutional protections such as equality under the law and private-property succession rights. It was also immediately disregarded through breaches of its provisions and non-adherence to guidelines regarding the NPC. The third constitution of the PRC was adopted in 1978. Although this version moved away from the ideologies of the Cultural Revolution, it did retain some remnants of it. It also retained Communist Party control over the state structure. However, reformists subsequently gained power, which led to the breakdown of this constitution as focus shifted to economic construction and modernization.

With the start of the Deng Xiaoping reforms (c. 1979), the idea of reconstructing a legal system to restrain abuses of official authority and developing a "rule of law" to replace rule by dictatorship began to gain traction. New laws were passed and foreign investors sought improvements in property rights which had not been a feature of Maoist government but there was internal conflict in China over the extent of incorporating foreign legal norms into the Chinese legal system. Chinese reformers sought to create a special arbitration body, independent of the local legal system, called the China International Economic Trade and Arbitration Commission (CIETAC). In 1982 Peng Zhen said "It is necessary to draw on beneficial experiences – ancient or modern, Chinese or foreign – in studying the science of law...We study them in order to make the past serve the present and foreign things serve China". Others who were more supportive of reforms like Qiao Shi still urged caution against "just copying blindly" and Deng Xiaoping himself said "we must pay attention to studying and absorbing foreign experience...However, we will never succeed if we mechanically copy the experiences and models of other countries".

The Constitution of the PRC, enacted in 1982, reflects the model of the first PRC constitution. The Constitution provides for leadership through the working class, led in turn by the CCP. The Constitution provides that the NPC is the supreme organ of state power over a structure of other people's congresses at various levels. The NPC has power to:

 * amend the Constitution by a two-thirds majority
 * promulgate legislation
 * elect and remove highest-level officials
 * determine the budget
 * control economic and social-development planning

The NPC also includes a Standing Committee that functions much as the NPC does when the NPC is not in session. Although the Standing Committee has had some powers since 1955, its law-making powers were initially provided for in the 1982 Constitution. The NPC sits at the highest level in the hierarchy of governmental structure in the PRC. This national level is followed in descending order by the provincial level (including autonomous regions and municipalities directly under the national level), the prefectural level, the county level, and the townships and towns level. Government members at the lower two levels are directly elected, and those at the higher levels are elected by the lower levels. In addition to the NPC, the provincial people's congresses possesses legislative power and can pass laws so long as they do not contravene the Constitution or higher legislation or administrative regulations.

The Constitution states its own supremacy. However, it has been theorized that the supremacy of the Communist Party means that the Constitution and law are not supreme, and that this perspective results from the Marxist view of law as simply a superstructure combined with a lack of recognition of rule of law in philosophical or historical tradition. Although the Constitution provides for legislative, executive, judicial, and procuratorial powers, they all remain subject to Communist Party leadership. Often, important political decisions are made through actions which are not regulated by the Constitution. Additionally, courts need not rely on the Constitution in deciding cases, and they may not review legislation for Constitutionality.

Since 1979, when the drive to establish a functioning legal system began, more than 300 laws and regulations, most of them in the economic area, have been promulgated. The use of mediation committees, informed groups of citizens who resolve about 90% of the PRC's civil disputes and some minor criminal cases at no cost to the parties, is one innovative device. More than 800,000 such committees operate – in both rural and urban areas.

In drafting the new laws, the PRC has not copied any other legal system wholesale, and the general pattern has involved issuing laws for a specific topic or location. Often laws are drafted on a trial basis, with the law being redrafted after several years. This process of creating a legal infrastructure piecemeal has led to many situations where the laws are missing, confusing, or contradictory, and has led to judicial decisions having more precedental value than in most civil law jurisdictions. In formulating laws, the PRC has been influenced by a number of sources, including traditional Chinese views toward the role of law, the PRC's socialist background, the German-based law of the Republic of China on Taiwan, and the English-based common law used in Hong Kong.

Legal reform became a government priority in the 1990s. The Chinese government has promoted a reform it often calls "legalisation" (法制化). Legalisation, among other things, has provided the régime with a gloss of legitimacy and has enhanced predictability. There have been major efforts in the rationalization and strengthening of the legal structure and institution building in terms of developing and improving the professionalism of the legislature, judiciary and legal profession. As market reforms have deepened and social inequality has widened, legal forums – ranging from mediation and arbitration commissions to courts – have come to play an increasingly prominent role.

The 1994 Administrative Procedural Law allows citizens to sue officials for abuse of authority or malfeasance. In addition, the criminal law and the criminal-procedures laws were amended to introduce significant reforms. The criminal-law amendments abolished the crime of "counter-revolutionary" activity. However political dissidents are sometimes charged on the grounds of subverting state security or of publishing state secrets. Criminal-procedures reforms also encouraged establishment of a more transparent, adversarial trial process. Minor crimes such as prostitution and drug use are sometimes dealt with under re-education through labor laws. The PRC constitution and laws provide for fundamental human rights, including due process, but some have argued that they are often ignored in practice. (See Human rights in the People's Republic of China.)

As a result of a trade war with the United States of America over violations of intellectual property rights of American corporations in the early 1990s, the People's Republic of China's trademark law has been modified and offers significant protections to foreign trademark-owners.

After their respective transfers of sovereignty, Hong Kong and Macau continue to practice English common law and Portuguese legal systems respectively, with their own courts of final appeal. Hong Kong and Macau lie outside of the legal jurisdiction of the People's Republic of China, except on constitutional issues.

Due to the growing sophistication of Chinese laws, the expansion of the rule of law, as well as an influx of foreign law firms, China has also begun to develop a legal-services market. Foreign lawyers have accompanied foreign capital and their clients to China, which has had an immense influence on the promulgation of new Chinese laws based on international norms, especially in regards to intellectual property and corporate and securities law.

On July 1, 1992, in order to meet growing demand, the Chinese government opened the legal-services market to foreign law-firms, allowing them to establish offices in China when the Ministry of Justice and the State Administration of Industry and Commerce (SAOIC) issued the Provisional Regulation of Establishment of Offices by Foreign Law Firms regulation. As a result, many foreign law firms incorporated consulting firms in their home countries or in Hong Kong and then set up subsidiaries in Beijing or Shanghai to provide legal services.

However, many regulatory barriers to entry remain to protect the domestic legal industry. Issues relating to Chinese law must be referred to Chinese law firms, and foreign lawyers are also prohibited from interpreting or practicing Chinese law or from representing their clients in court. However, in reality many foreign law firms interpret laws and manage litigation by directing the local firms they must have cooperative relationships with. In this regard, China's restrictive legal market can be directly tied to a phobia of people asserting their legal rights in the face of rampant corruption. Information received from the State Council Legislative Office suggests that China may be allowing foreigners to sit the Chinese Lawyers Examination, or have a mutual recognition treaty with other countries to allow foreign lawyers to conduct non-litigation Chinese legal work.

Since the early 2000s, environmental lawsuits have been available in China. 2014 amendments to China's Environmental Protection Law permit public interest environmental litigation, including with non-governmental organizations as proper plaintiffs.

In 2005, China started implementing legal reform, which revived the Maoist-era ideals adopted during the 1950s due to the position that the law is cold and unresponsive to the needs of its citizens. This initiative favored mediation over court trials when it came to resolving conflicts among citizens and conflicts between citizens and the state. It also revived judicial populism at the expense of judicial professionalism and was marked by the return of the mass-trial model used during the 1940s.

China's first comprehensive antitrust law was the Anti-Monopoly Law which was passed in 2007 and became effective in 2008.

In 2009, China amended its Criminal Law to set a low threshold for the prosecution of malicious cybercrimes and illegal data sales.

Xi Jinping encourages legal professionals to selectively integrate elements of traditional legal practice into modern approaches.

In 2015, the Administrative Procedure Law was revised to expand the people's right to sue the government.

The primary laws regarding personal data security and privacy are the 2017 Cyber Security Law, the 2021 Data Security Law, and the 2021 Personal Information Protection Law.

Legal rights
The modern idea of legal rights was introduced to China from the West in the 19th century. Its translation as quánlì (权利) was coined by William Alexander Parsons Martin in 1864, in his translation of Henry Wheaton's Elements of International Law.

Rule of law
One of the most commonly used phrases in contemporary China, by legal scholars and politicians alike, is fǎzhì (法治). Fǎzhì can be translated into English as "rule of law", but questions have often been asked whether Chinese leaders meant "rule by law", which means the instrumental use of laws by rulers to facilitate social control and to impose punishment as understood in the Legalist tradition.

Late Qing dynasty legal reforms unsuccessfully sought to implement Western legal principles including the rule of law and judicial independence. Judicial independence further decreased under Chiang Kai-shek per the Kuomintang's policy of particization (danghua) under which administrative judges were required to have "deep comprehension" of the KMT's principles.

After China's Reform and Opening Up, the Communist Party emphasized the rule of law as a basic strategy and method for state management. The concepts of yīfǎ zhìguó (依法治国: "governing the nation according to the rule of law") and jiànshè shèhuì zhǔyì fǎzhì guójiā (建设社会主义法制国家: "building a socialist rule of law state") have been part of the Chinese Communist Party's official policy since the mid-1990s. Jiang Zemin called for establishing a socialist rule of law at the Fifteenth Party Congress in 1997. In 1999, the NPC adopted an amendment to the Chinese Constitution, incorporating "governing the nation according to the rule of law" and "building a socialist rule of law state" into Article 5.

The existence of the rule of law in China has been widely debated. When discussing Chinese law, it is worth noting that various expressions have been used, including "strengthening the law," "tightening up the legal system," "abiding by the law in administration," "rule by law," and the "rule of law". Different shades of meanings have been attached to each of these terms, but Chinese officials and scholars have employed the expressions rather loosely and sometimes interchangeably. However, the central government had originally preferred the expression, "strengthening the law/legal system" to "the rule of law". It was thought that the latter might give a controversial connotation of the instrumentality, while the former conveyed a straightforward meaning of strengthening the law and institutions. "Strengthening the law" meant reform of legislation and enforcement of laws.

Despite the newly elevated role of courts in Chinese society, there still remains some consensus about defects in China's legal system in regards to progressing towards the rule of law. Scholars point to the following defects as slowing movement toward rule of law. These include:
 * First, the National People's Congress is ineffective at executing its constitutional duty to legislate and supervise the government.
 * Second, the Chinese Constitution is not treated as the supreme law, nor is it enforced.
 * Third, the judiciary is not independent from political pressure. On the other hand, direct intervention in particular cases by the Chinese Communist Party has lessened in recent years, as has the direct influence of the party on the legislative process.
 * Fourth, there is a high level of corruption among public officials. Personal favors, bribery, and taking of public monies are all too common at all levels of government.
 * Finally, the legal profession is inadequate for lack of qualified attorneys and judges. This failure is being remedied by legislation aimed at instituting higher educational standards for judges, opening more courts and law schools throughout China.

Lawyers in China have to swear an oath of loyalty to the CCP. Lawyers who refuse to follow the party line may have their license to practice law revoked.

Xi Jinping opposes Western views of the rule of law, such as the requirement of judicial independence. Xi describes the leadership of the CCP as essential to upholding the socialist rule of law. Xi states that the two fundamental aspects of the socialist rule of law are: (1) that the political and legal organs (including courts, the police, and the procuratorate) must believe in the law and uphold the law, and (2) all political and legal officials must follow the CCP. Xi's view of the rule of law tends to equate the rule of law with the development of legislation. In his writings on socialist rule of law, Xi has emphasized traditional Chinese concepts including people as the root of the state (mingben), "the ideal of no lawsuit" (tianxia wusong), "respecting rite and stressing law" (longli zhongfa), "virtue first, penalty second" (dezhu xingfu), and "promoting virtue and being prudent in punishment" (mingde shenfa).

According to academic Keyu Jin, the revised Administrative Procedures Law codified in 2021 marks a milestone in formalizing the rule of law in China.

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Head of government

In the executive branch, the head of government is the highest or the second-highest official of a sovereign state, a federated state, or a self-governing colony, autonomous region, or other government who often presides over a cabinet, a group of ministers or secretaries who lead executive departments.

In diplomacy, "head of government" is differentiated from "head of state".

The authority of a head of government, such as a president, chancellor, or prime minister, and the relationship between that position and other state institutions, such as the relation between the head of state and of the legislature, varies greatly among sovereign states, depending largely on the particular system of the government that has been chosen, won, or evolved over time.

In most parliamentary systems, including constitutional monarchies, the head of government is the de facto political leader of the government, and is answerable to at least one chamber of the legislature. Although there is often a formal reporting relationship to a head of state, the latter usually acts as a figurehead who may take the role of chief executive on limited occasions, either when receiving constitutional advice from the head of government or under specific provisions in a constitution.

In presidential republics or in absolute monarchies, the head of state is also usually the head of government. The relationship between that leader and the government, however, can vary greatly, ranging from separation of powers to autocracy, according to the constitution (or other basic laws) of the particular state.

In semi-presidential systems, the head of government may answer to both the head of state and the legislature with the specifics provided by each country's constitution. A modern example is the present French government, which originated as the French Fifth Republic in 1958. In France, the president, the head of state, appoints the prime minister, who is the head of government. However, the president must choose someone who can act effectively as an executive, but who also enjoys the support of France's legislature, the National Assembly, to be able to pass legislation.

In some cases, the head of state may represent one political party but the majority in the National Assembly is of a different party. Given that the majority party has greater control over state funding and primary legislation, the president is in effect forced to choose a prime minister from the opposition party to ensure an effective, functioning legislature. In this case, known as cohabitation, the prime minister, along with the cabinet, controls domestic policy, with the president's influence largely restricted to foreign affairs.

In communist states, the General Secretary of the Communist Party is the supreme leader, serving as de facto head of state and government. In China, the de jure head of government is the Premier. The Chinese president is legally a ceremonial office, but the General Secretary of the Chinese Communist Party (top leader in a one-party system) has always held this office since 1993 except for the months of transition.

In directorial systems, the executive responsibilities of the head of government are spread among a group of people. A prominent example is the Swiss Federal Council, where each member of the council heads a department and also votes on proposals relating to all departments.

Titles of respective heads of government
The most common title for a head of government is Prime Minister. This is used as a formal title in many states, but may also be an informal generic term to refer to whichever office is considered the principal minister under an otherwise styled head of state, as minister—Latin for servants or subordinates—is a common title for members of a government (but many other titles are in use, e.g. chancellor and secretary of state). Formally the head of state can also be the head of government as well (ex officio or by ad hoc cumulation, such as a ruling monarch exercising all powers himself) but otherwise has formal precedence over the head of government and other ministers, whether he is their actual political superior (ruling monarch, executive president) or rather theoretical or ceremonial in character (constitutional monarch, non-executive president). Various constitutions use different titles, and even the same title can have various multiple meanings, depending on the constitutional order and political system of the state in question.

As political chief
In addition to prime minister, titles used for the democratic model, where there is an elected legislative body checking the head of government, include the following. Some of these titles relate to governments below the national level (e.g. states or provinces).

Alternative English terms and renderings

 * Chancellor (primarily in German-speaking countries; today used in Germany and Austria)
 * Chief Minister (often subnational)
 * Chief Executive (often subnational)
 * First Minister (often subnational)
 * Minister-President
 * Premier (from French premier ministre)
 * President of the Council of Ministers
 * President of the Council of State
 * President of the Executive Council
 * President of the Government
 * State Counsellor (used exclusively in Myanmar)
 * State President (used exclusively in South Africa)

Equivalent titles in other languages

 * Akan: ɔmampanyin
 * Albanian: Kryeministër
 * Bengali: For the prime minister of Bangladesh and other countries
 * প্রধানমন্ত্রী/ Pradhan Mantri (literally: Prime Minister, official)
 * সরকার প্রধান/ Sarkar Pradhan (literally: Head of the Government, informal)
 * Bambara: minisiriɲɛmɔgɔ
 * Basque:
 * Leader of the Basque Country (Spain): Eusko Jaurlaritzako lehendakaria (literally, 'President of the Basque Government')
 * Leader of Navarre (Spain): Nafarroako Gobernuko lehendakaria (literally, 'President of the Government of Navarra')
 * president, generically: Lehendakari
 * Bulgarian: Министър-председател (transliteration: Ministar-predsedatel, literally 'Minister President')
 * Catalan:
 * For Andorra: Cap de Govern del Principat d'Andorra (literally: 'Head of Government of the Principality of Andorra')
 * For the Balearic Islands (Spain): President/-a del Govern Balear
 * For Catalonia (Spain): President/-a de la Generalitat de Catalunya (literally: 'President of the Generalitat of Catalonia')
 * For Valencia (Spain): President/-a de la Generalitat Valenciana (literally: 'President of the Valencian Generalitat')
 * The terms 'head of government' and 'prime minister', generically: cap de govern and primer ministre or primera ministra, respectively
 * Chinese:
 * For the premier of China: 总理 (zǒnglǐ)
 * Czech: Předseda vlády (literally: 'Chairman of the Government')
 * Danish:
 * For the head of government of Nordic states: Statsminister (literally: 'Minister of the State')
 * For the head of government of non-Nordic states: Premierminister (literally: 'Prime Minister')
 * For the head of government of the autonomous territory of Faroe Islands: Lagmand (literally: 'Lawman")
 * For the head of government of the autonomous territory of Greenland: Landsstyreformand (literally: 'land governance chairman')
 * Dutch:
 * For the head of government of the Netherlands: Minister-President, Eerste Minister (literally, 'First Minister') or Premier
 * For the head of government of Belgium, and as the term 'prime minister' generically: Eerste Minister or Premier
 * Estonian: Peaminister
 * Ewe: Dukplɔlagã
 * Finnish: Pääministeri
 * Filipino
 * For the head of state and government (President) of the Philippines: Pangulo ng Pilipinas
 * French:
 * For France, Belgium and Canada: Prime Minister of France; Prime Minister of Belgium; Prime Minister of Canada: Premier Ministre or Première Ministre, also as the term 'prime minister' generically.
 * For Switzerland: Conseil Fédéral (literally, the 'Federal Council', considered the head of government as a group)
 * Galician (Spain): Presidente/-a da Xunta de Galicia (literally, 'President of the Council of Galicia')
 * German:
 * For Germany and Austria: Chancellor of Germany; Chancellor of Austria: Bundeskanzler (masc.) / Bundeskanzlerin (fem.)
 * For Switzerland: Schweizerischer Bundesrat (literally, the 'Swiss Federal Council', considered the head of government as a group)
 * The term 'head of government,' generically: Regierungschef/-in
 * The term 'prime minister,' generically: Ministerpräsident/-in; or Premierminister/-in
 * historically: Leitender Minister ('Senior Minister')
 * Greek: Πρωθυπουργός (transliteration: Prothipourgos)
 * Hausa: Firayam Minista
 * Hebrew:
 * For the prime minister of Israel: ראש הממשלה (transliteration: Rosh HaMemshala)
 * Hindi/Hindustani/Urdu:
 * The term 'head of government', generically: शासनप्रमुख (translit. Śāsanapramukha), literally:'Chief of government'
 * The term 'Prime Minister', generically: प्रधानमन्त्री (translit. Pradhānamantrī), literally:'Chief of Ministers/Prime Minister'
 * The other Hindustani term generically used for 'Prime Minister'(now used officially only in Pakistan with Urdu as official language) : वज़ीर-ए-आज़म/ (translit. Wazīr-ē-Āzam), lit.:'Grand Vizier/Prime Minister'Indira and Nixon.JPG (Indira Gandhi) and the president of the United States (Richard Nixon) in 1971]]
 * For 'Prime Minister of India' : भारतीय प्रधानमन्त्री/भारत के प्रधानमन्त्री (translit. Bhāratiya Pradhānamantrī/Bhārat Kē Pradhānamantrī), translation:'Indian Prime Minister/Prime Minister of India'(this term is used by the Government of the Union and the State Governments of India, under the umbrella of "Hindi Language");
 * For 'Prime Minister of Pakistan': / (translit. Wazīr-ē-Āzam Pākistān/Pākistān Kē Wazīr-ē-Āzam), This is the term used in India and Pakistan under the umbrella of Urdu, the Hindi term being, पाकिस्तानी प्रधानमन्त्री/पाकिस्तान के प्रधानमन्त्री (translit.Pākistānī Pradhānamantrī/Pākistān Kē Pradhānamantrī)
 * Historically, various terms like Pradhānamantrī, Pradhān, Pantapradhān, Sadr-ē-Riyāsat, Sadr, Wazīr-ē-Āzam, Wazīr-ē-Ālā, Mahāmantrī, Wazīr-ē-Khazānā, Pēśwā, Dīwān, Dīwān Sāhib, Dīwān Bahādur, Dīwān Pramukh, Sadr-ul-Maham, Pantapramukh, Ālāmantrī, etc. have been used by various Empires, Kingdoms and Princely States of India as a title for the prime minister, some of these titles were also used by the sovereign of various kingdoms.
 * Hungarian: Miniszterelnök
 * Irish: Leader of Ireland: Taoiseach
 * Italian:
 * For the head of government of Italy: Presidente del Consiglio dei Ministri della Repubblica Italiana (literally, 'President of the Council of Ministers of the Italian Republic')
 * When referring to other prime ministers: Primo ministro or Prima ministra (masculine and feminine forms; literally 'prime minister')
 * For Switzerland: Consiglio Federale (literally, the 'Federal Council', considered the head of government as a group)
 * Japanese:
 * For the head of government of Japan (Prime Minister): 内閣総理大臣 (Naikaku Sōri-Daijin) or 首相 (Shushō)
 * Khmer:
 * For the prime minister of Cambodia: នាយករដ្ឋមន្ត្រី (Neayuk rothmontrey)
 * Korean:
 * For the president of South Korea: Daetongryung
 * For the prime minister of South Korea: Chongni(총리) or Gukmu Chongni(국무총리)
 * Latvian:
 * For the head of government of Latvia: Ministru prezidents (literally, 'Minister President')
 * When referring to other prime ministers: Premjerministrs
 * Lingala: Premier ministre
 * Lithuanian: Ministras pirmininkas
 * Luganda: Ssaabaminisita
 * Malay:
 * In Malaysia, the prime minister of Malaysia is Perdana Menteri. The head of government of the constituent states are either Ketua Menteri, "chief minister" in the Malaysian states without a monarchy (Malacca, Penang, Sabah and Sarawak), or Menteri Besar "first minister" in the sultanates and other monarchic states.
 * Maltese: In Malta, the head of government is "Prim Ministru".
 * Māori: Pirimia, (literally, 'Premier', the former title for the prime minister of New Zealand.)
 * Norwegian: Statsminister
 * Polish:
 * For the head of government of Poland: Prezes Rady Ministrów ('President of Council of Ministers', literally: 'Chairman of the Council of Ministers')
 * For the term 'prime minister' in general: Premier (also, informally, to the head of government of Poland)
 * Portuguese:
 * For Brazil: Presidente/-a da República Federativa do Brasil (literally, 'President of the Federal Republic of Brazil')
 * For Portugal and as the term 'prime minister' in general: Primeiro-ministro or Primeira-ministra (masculine and feminine forms, literally 'prime minister' or 'first minister')
 * Romanian: Prim-ministru
 * Russian: Prem'yer-ministr
 * Scotland:
 * Scottish Gaelic: Prìomh Mhinistear na h-Alba (literally First Minister of Scotland)
 * Sinhalese: ශ්‍රී ලංකා අග්‍රාමාත්‍ය Shri Lanka Agramathya (literally: 'Sri Lanka Prime Minister')
 * Slovak: Predseda vlády (literally: 'Chairman of the Government')
 * Slovene: Predsednik Vlade (literally: 'Chairman of the Government')
 * Spanish:
 * For the head of government of Spain: Presidente/-a del gobierno de España (literally: 'President of the Government')
 * When referring to other prime ministers: Primer ministro or Primera Ministra (masculine and feminine forms; literally 'prime minister')
 * The term 'head of government', generically: jefe del gobierno
 * Swahili: Sultan
 * Swedish: Statsminister ("prime minister", literally: "state minister")
 * Thai:
 * For the head of government (Prime Minister) of Thailand: Nayok rathamontri
 * Turkish: Başbakan
 * Yoruba: adari igbimọ ijọba

Under a dominant head of state
In a broader sense, a head of government can be used loosely when referring to various comparable positions under a dominant head of state (especially is the case of ancient or feudal eras, so the term "head of government", in this case, could be considered a contradiction in terms). In this case, the prime minister serves at the pleasure of the monarch and holds no more power than the monarch allows. Some such titles are diwan, mahamantri, pradhan, wasir or vizier.

However, just because the head of state is the de jure dominant position does not mean that he/she will not always be the de facto political leader. A skilled head of government like 19th-century German statesman Otto von Bismarck, Minister President of Prussia and later Chancellor of Germany under Emperor/King Wilhelm I, serves as an example showing that possession of formal powers does not equal political influence.

Indirectly referred as the head of state
In some cases, the head of state is a figurehead whilst the head of the government leads the ruling party. In some cases a head of government may even pass on the title in hereditary fashion. Such titles include the following:
 * Mayor of the palace of the Merovingian kingdoms
 * Nawab wasir of the Mughal Empire (also governor of Awadh)
 * Peshwa of Satara and the Maratha empire
 * Shōgun in feudal Japan
 * Sultan in the original case of the Seljuk Turks who made the caliphs of Baghdad their puppets; later both styles were often used for absolute rulers in Nepal

Combined heads of state and government

In some models the head of state and head of government are one and the same. These include: An alternative formula is a single chief political body (e.g., presidium) which collectively leads the government and provides (e.g. by turns) the ceremonial Head of state. The only state in which this system is currently employed is Switzerland but other countries such as Uruguay have employed it in the past. This system is described as the directorial system. See Head of state for further explanation of these cases.
 * President (chief executive)
 * An absolute monarch reigning and ruling without a separate principal minister
 * Chief magistrate
 * Führer (used in Nazi Germany for Adolf Hitler)
 * Supreme leader
 * A State Governor in the United States (subnational executives)
 * Sultan of Brunei
 * King of Saudi Arabia

Parliamentary heads of government

In parliamentary systems, government functions along the following lines:
 * The head of government — usually the leader of the majority party or coalition — forms the government, which is answerable to parliament;
 * Full answerability of government to parliament is achieved through
 * The ability of parliament to pass a vote of no confidence.
 * The ability to vote down legislative proposals of the government.
 * Control over or ability to vote down fiscal measures and the budget (or supply); a government is powerless without control of the state finances. In a bicameral system, it is often the so-called lower house (e.g. the British House of Commons) that exercises the major elements of control and oversight; however, in some (e.g. Australia, Italy), the government is constitutionally or by convention answerable to both chambers/Houses of Parliament.

All of these requirements directly impact the head of government's role. Consequently, they often play a 'day to day' role in parliament, answering questions and defending the government on the 'floor of the House', while in semi-presidential systems they may not be required to play as much of a role in the functioning of parliament.

Appointment
In many countries, the head of government is commissioned by the head of state to form a government, on the basis of the strength of party support in the lower house; in some other states, the head of government is directly elected by parliament. Many parliamentary systems require ministers to serve in parliament, while others ban ministers from sitting in parliament (they must resign on becoming ministers).

Removal
Heads of government are typically removed from power in a parliamentary system by
 * Resignation, following:
 * Defeat in a general election.
 * Defeat in a leadership vote at their party caucus, to be replaced by another member of the same party.
 * Defeat in a parliamentary vote on a major issue, e.g., loss of supply, loss of confidence. (In such cases, a head of government may seek a parliamentary dissolution from the head of state and attempt to regain support by popular vote.)
 * Dismissal — some constitutions allow a head of state (or their designated representative, as is the case in some Commonwealth countries) to dismiss a head of government, though its use can be controversial, as occurred in 1975 when then Australian Governor-General, Sir John Kerr, dismissed Prime Minister Gough Whitlam in the Australian Constitutional Crisis.
 * Death — in this case, the deputy head of government typically acts as the head of government until a new head of government is appointed.

First among equals or dominating the cabinet?
Constitutions differ in the range and scope of powers granted to the head of government. Some older constitutions; for example, Australia's 1900 text, and Belgium's 1830 text; do not mention their prime ministerial offices at all, the offices became a de facto political reality without a formal constitutional status. Some constitutions make a Prime Minister primus inter pares (first among equals) and that remains the practical reality for the Prime Minister of Belgium and the Prime Minister of Finland. Other states however, make their head of government a central and dominant figure within the cabinet system; Ireland's Taoiseach, for example, alone can decide when to seek a parliamentary dissolution, in contrast to other countries where this is a cabinet decision, with the Prime Minister just one member voting on the suggestion. In Israel, while the Government is nominally a collegiate body with a primus inter pares role for the Prime Minister, the Israeli Prime Minister is the dominant figure in the executive branch in practice. The Prime Minister of Sweden, under the 1974 Instrument of Government, is a constitutional office with all key executive powers either directly at his or her disposal or indirectly through the collegial Government, whose members are all appointed and dismissed at the Prime Minister's sole discretion.

Under the unwritten British constitution, the prime minister's role has evolved, based often on the individual's personal appeal and strength of character, as contrasted between, for example, Winston Churchill as against Clement Attlee, Margaret Thatcher as against John Major. It is alleged that the increased personalisation of leadership in a number of states has led to heads of government becoming themselves "semi-presidential" figures, due in part to media coverage of politics that focuses on the leader and his or her mandate, rather than on parliament; and to the increasing centralisation of power in the hands of the head of government. Such allegations have been made against three former British Prime ministers: Margaret Thatcher, Tony Blair, and Boris Johnson. They were also made against Italian prime ministers Silvio Berlusconi and Matteo Renzi, Canadian prime minister Pierre Trudeau and Federal Chancellor of West Germany (later all of Germany), Helmut Kohl, when in power.

Official residence
The head of government is often provided with an official residence, often in the same fashion as heads of state often are. The name of the residence is often used as a metonym or alternative title for 'the government' when the office is politically the highest, e.g. in the UK "Downing Street announced today…"

Well-known official residences of heads of government include: Similarly, heads of government of federal entities below the level of the sovereign state (often without an actual head of state, at least under international law) may also be given an official residence, sometimes used as an opportunity to display aspirations of statehood:
 * 10 Downing Street in London — Prime Minister of the United Kingdom (who also has a country residence, Chequers)
 * The Lodge in Canberra — Prime Minister of Australia (with an additional residence, Kirribilli House, in Sydney)
 * 24 Sussex Drive in Ottawa — Prime Minister of Canada (who also has a country residence, Harrington Lake)
 * Premier House in Wellington — Prime Minister of New Zealand
 * 7, Lok Kalyan Marg in New Delhi — Prime Minister of India
 * Ganabhaban in Dhaka — Prime Minister of Bangladesh
 * Prime Minister's Office in Islamabad — Prime Minister of Pakistan
 * Catshuis in The Hague — Prime Minister of the Netherlands
 * Ballhausplatz in Vienna — Chancellor of Austria
 * Zhongnanhai in Beijing — Premier of the People's Republic of China
 * Kantei in Tokyo — Prime Minister of Japan
 * Kramář's Villa in Prague — Prime Minister of the Czech Republic
 * Chigi Palace in Rome — Prime Minister of Italy
 * Hôtel Matignon in Paris— Prime Minister of France
 * Villa Parkowa in Warsaw— Prime Minister of Poland
 * Federal Chancellery in Berlin — Chancellor of Germany
 * The Lambermont in Brussels — Prime Minister of Belgium
 * Palacio de la Moncloa in Madrid — President of the Government of Spain
 * Palacete de São Bento in Lisbon — Prime Minister of Portugal
 * Kesäranta in Helsinki — Prime Minister of Finland
 * Sager House in Stockholm — Prime Minister of Sweden (who also has a country residence, Harpsund)
 * Grand Kremlin Palace in Moscow — Prime Minister of Russia
 * Palace of the Governorate in Vatican City — Governorate of the Vatican City State
 * Phitsanulok Mansion in Bangkok - Prime Minister of Thailand
 * Hotel Errera in Brussels — Minister-President of the Flemish community and region
 * Bavarian State Chancellery – Minister-President of the State of Bavaria
 * Élysette in Namur — Minister-President of Wallonia
 * Bute House, Edinburgh; First Minister of Scotland
 * Hesse State Chancellery, Wiesbaden; Minister-President of the State of Hesse
 * Kazan Kremlin, Kazan – President of Tatarstan
 * Government House, Hong Kong – Chief Executive of Hong Kong
 * Macau Government Headquarters – Chief Executive of Macau
 * Red City Hall – Governing Mayor of Berlin
 * Quinta Vigia – President of the Regional Government of Madeira

Usually, the residence of the heads of government is not as prestigious and grand as that of the head of state, even if the head of state only performs ceremonial duties. Even the formal representative of the head of state, such as a governor-general, may well be housed in a grander, palace-type residence. However, this is not the case when both positions are combined into one:
 * The White House (1600 Pennsylvania Avenue) in Washington, D.C. — President of the United States of America
 * The Presidential Complex in Ankara – President of Turkey
 * The Blue House (1 Sejongno Jongno-gu) in Seoul — President of South Korea
 * Istana Nurul Iman in Bandar Seri Begawan — Sultan of Brunei
 * Palácio da Alvorada in Brasília — President of the Federative Republic of Brazil
 * The Malacañang Palace in Manila - President of the Philippines
 * The Merdeka Palace in Jakarta - President of Indonesia

Statistics

 * World's longest serving unelected head of government: Prince Khalifa bin Salman Al Khalifa, Prime Minister of Bahrain from 1971 to 2020 (50 years, 326 days).
 * World's longest serving monarchical head of government: Hun Sen, Prime Minister of Cambodia from 1998 to 2023 (24 years, 280 days).
 * World's longest serving republican head of government: Lee Kuan Yew, Prime Minister of Singapore from 1959 to 1990 (31 years, 185 days).
 * World's longest serving female head of government: Sheikh Hasina, Prime Minister of Bangladesh from 1996 to 2002 and from 2009 to date ().

title: Head of government


text:
Cordelia Chase

Cordelia Chase is a fictional character created by Joss Whedon for the television series Buffy the Vampire Slayer; she also appeared on Buffy's spin-off series, Angel. Portrayed by Charisma Carpenter, the character appears as a series regular in the first three seasons of Buffy, before leaving the show and becoming a series regular during the first four seasons of Angel. The character made her last television appearance in 2004, appearing as a special guest star in Angel 100th episode. Cordelia also appears in both canonical and apocryphal Buffy and Angel material such as comic books and novels.

Cordelia is introduced in "Welcome to the Hellmouth" as one of Sunnydale High's popular students, attending school alongside vampire slayer Buffy Summers. Through her interactions with Buffy and her friends, she comes to accept the existence of supernatural forces and helps Buffy fight against them. In the television series Angel, Cordelia joins Angel, a heroic vampire with a soul, in forming a detective agency dedicated to stopping supernatural forces and helping the helpless. After Cordelia acquires the ability to see visions of those in need, she becomes a more compassionate and heroic character. In the middle of the third season, she becomes a love interest of the protagonist Angel. In the fourth season of Angel, she appears to take on a villainous role before it is revealed that she is possessed by a malevolent deity; this storyline eventually leads to her death and subsequent exit from the series. The character makes further canonical appearances in the comic books Buffy Season Eight and Angel: After the Fall, in a dream flashback and as a spirit guide.

Created as a foil for Buffy titular heroine, Cordelia was initially characterized as "shallow", "vain" and "self-centered", and was used in the series to create conflict for the other characters. The character went through changes as she gradually redeemed herself throughout the course of Buffy and Angel, and has received attention in academic texts related to gender studies and social status.

Television
Cordelia Chase first appears in the premiere episode of Buffy the Vampire Slayer, titled "Welcome to the Hellmouth". Introduced as a potential friend for Sunnydale High's newest student, Buffy Summers (Sarah Michelle Gellar), Cordelia reveals her true colors by cruelly mocking Willow (Alyson Hannigan) whom Buffy befriends instead. Ignorant of the supernatural, Cordelia shows up regularly throughout the first season of Buffy to insult and ridicule the other characters. She plays a larger role in the episode "Out of Mind, Out of Sight", in which she falls victim to a social outcast who wants revenge on popular students for ignoring her so much that she turned invisible. In the season finale, Cordelia helps Buffy and her friends battle vampires, finally coming to terms with the existence of supernatural forces. In season two, Cordelia becomes a more active ally to the "Scooby Gang" and begins a romantic relationship with Xander Harris (Nicholas Brendon) in "What’s My Line? Part 2." Dating someone of Xander's social status causes Cordelia's ostracism from her popular peers and she reluctantly breaks up with him. However, when Xander performs a love spell to pay her back for hurting him, Cordelia realises how much he cares about her and takes him back, rejecting her superficial friends in the process. In season three's "Lovers Walk", Cordelia is heartbroken to see Xander kissing Willow and ends their relationship. By the season three episode "The Wish", Cordelia slips back into her antagonistic persona from the first season, disassociating herself from the Scooby Gang altogether. In the episode "The Prom", she reveals that her house and her family's entire wealth has just been seized for tax fraud and both of her parents (never named or seen on-camera) are now in prison. Cordelia later attempts an unsuccessful relationship with Wesley (Alexis Denisof) and makes peace with Xander at the prom. In the season three finale, she rallies alongside Buffy and her friends at graduation against the demonic Mayor of Sunnydale (Harry Groener), where Cordelia slays her first vampire.

After three seasons on Buffy, Cordelia left the series to move over to star in Angel, a spin-off series focusing on Buffy's vampire ex-lover Angel (David Boreanaz). The first season of Angel sees Cordelia move to Los Angeles, in the hopes of escaping her new-found poverty by becoming an actress. After Angel saves her life in the series pilot, Cordelia helps him found the supernatural detective agency Angel Investigations, working in an administrative position. She also becomes close to half-demon co-worker Doyle (Glenn Quinn), but their budding romance is ended by his death nine episodes into the series. Before dying in the episode "Hero", Doyle passes his ability to see people in distress over to Cordelia when he kisses her. Although she initially views the visions as a curse, in the season one finale, a demon causes Cordelia's visions to overwhelm her - causing her to experience worldwide pain - and upon her recovery she vows to help those in need. In season two's "Reunion", Cordelia and the other staff at Angel Investigations are fired by Angel, who is becoming increasingly obsessed with bringing down the evil law firm Wolfram & Hart. Cordelia joins Wesley and Charles Gunn (J. August Richards) in re-forming the agency on their own. Angel and Cordelia eventually reconcile in the episode "Epiphany". As her acting career continues to flounder, Cordelia is sucked into and made princess of a medieval hell dimension called Pylea in the season two episode "Over the Rainbow". When presented with the opportunity to pass her visions over to a champion named the Groosalugg (Mark Lutz), Cordelia refuses and returns to L.A. with her friends in the season two finale.

In season three's "Birthday", Cordelia learns from the demon Skip (David Denman) that her visions are slowly killing her because human beings are not strong enough to control them. To save her life, Cordelia accepts Skip's offer to alter history so that she never met Angel in L.A., instead landing her big break as an actress. However, even in this alternate timeline, Cordelia feels compelled to help others and eventually crosses paths with Angel again, who received the visions in her place and is now insane. Unable to let her friend suffer, Cordelia has Skip return the timeline to normal, and agrees to become half-demon, with new powers, in order to harbor the visions safely. This season also sees Angel become a father, with Cordelia stepping in to mother the infant Connor until he is kidnapped into a hell dimension in the episode "Sleep Tight", only to emerge as a disturbed teenager (Vincent Kartheiser) in "The Price". In the episode "Waiting in the Wings", Angel realizes he has romantic feelings for Cordelia, but is prevented from voicing them by the return of Groosalugg. Cordelia dates Groosalugg for the remainder of the season, but Groo notices she loves Angel instead and decides to leave. In the season finale, Cordelia arranges to meet Angel to confess her feelings, but is prevented from doing so by Skip, who informs her that she has become a higher being. Cordelia accepts her duty, and leaves Earth for another dimension. In season four, Cordelia feels trapped in her position as a higher being, and so in the episode "The House Always Wins" she returns to Earth in an amnesiac state. In "Spin the Bottle", her memories are returned via a spell, along with a vision of a mysterious Beast (Vladimir Kulich). Afterward, she admits to Angel the feelings she once had for him. As L.A. succumbs to the apocalypse in season four's "Apocalypse, Nowish", Cordelia begins to behave out-of-character; she seduces Connor, murders Lilah (Stephanie Romanov) in the episode "Calvary", commands the Beast in "Salvage", and magically battles former friend Willow to keep Angel from his soul in the episode "Orpheus". In season four's "Players", the team realize that the now pregnant Cordelia is possessed, so Cordelia takes the unstable Connor on the run with her so they may give birth to their supernatural offspring, Jasmine (Gina Torres). In "Inside Out", Skip explains that Jasmine is his master, and a higher being who possessed Cordelia before her returning to Earth, manipulating events to be born in a new body of her own.

Cordelia falls into a post-natal coma for the remainder of season four. Following an eleven-episode absence, Cordelia returns to Angel in season five, in the 100th episode "You're Welcome". Having (apparently) awoken from her coma, Cordelia reunites with Angel Investigations, who she discovers have taken over Wolfram & Hart since their defeat of Jasmine. She chastises Angel for accepting W&H's "deal with the devil" and reminds him of his true mission and higher calling. Together, they face and defeat their old enemy, Lindsey McDonald (Christian Kane) who had been impersonating Doyle in an attempt to destroy Angel. In the episode's closing moments, Cordelia reiterates to Angel that she loves him and kisses him, shortly before he receives a phone call reporting that Cordelia died that morning in the hospital. When Angel turns around, Cordelia is gone. It is later revealed that this encounter - the Powers That Be repaying their debt to Cordelia - allowed Cordelia to pass one last vision over to Angel, giving him the knowledge he needs to bring down the Circle of the Black Thorn.

Between 2001 and 2004, Joss Whedon and Jeph Loeb developed a 4-minute pilot episode for Buffy the Animated Series, which was set during the show's first season. Had the series been picked up by a network, it would have featured Cordelia (voiced by Charisma Carpenter) in more high-school adventures. Following a 2008 leak of the pilot to YouTube, Loeb expressed some hope that the series may be resurrected in some form.

Literature
Cordelia also appears in comic books and novels based on the Buffy and Angel television series. The Cordelia Collection, Vol. 1 by Nancy Krulik is a novelization of the Buffy episodes "Out of Mind, Out of Sight", "Some Assembly Required" and "Homecoming". These episodes tell specific incidents in which Cordelia becomes targeted: by a scorned classmate, to become a zombie's bride and by hunters in a case of mistaken identity. She appears in numerous Angel novels as a member of Angel Investigations, but some feature Cordelia more prominently; in Not Forgotten she uncovers exploitation of child immigrants, while in Haunted she appears as a contestant on a supernatural-themed reality television show when she has a vision about another applicant. Cordelia appears in the majority of Angel comics, published by Dark Horse Comics during 2000–2002 and set between episodes of the television series. She appears less frequently in those by IDW Publishing between 2005 and 2011, mainly in stories set in and after the fifth season. Cordelia typically plays a minimal role in the Dark Horse Angel comics. However, issue seventeen was a "Cordelia Special", in which demonic items are stashed in Cordelia's apartment. In the Dark Horse Presents story "Lovely dark and deep", Cordelia lands a role as the star of a demonic movie. Cordelia appears in the IDW Publishing comic mini-series Angel: The Curse, set after season five, in flashback scenes. She subsequently reappears in the mini-series Angel: Old Friends, which sees Angel battle evil clones of his friends. Cordelia claims to be the genuine article, having returned from the dead, but Angel is unconvinced and kills her; his suspicions prove correct when her body immediately disintegrates like the other clones.

Angel: After the Fall, a canonical comic book continuation of the television series plotted by Joss Whedon and written by Brian Lynch, features the characters of Angel and all of Los Angeles condemned to Hell after the events of the series finale "Not Fade Away". Cordelia does not appear until the twelfth issue, in which she acts as a guide to Angel in his dying moments; it is revealed she serves in some capacity as a higher power now. The character departs in issue thirteen. Cordelia also appears in a dream sequence within the twentieth issue of Buffy's canonical continuation, Buffy the Vampire Slayer Season Eight, titled "After These Messages... We'll Be Right Back!". Buffy dreams of when she was in her first year at Sunnydale High; Cordelia's physical appearance is based on the art style of Loeb and Whedon's unproduced Buffy animated series.

Conception and casting
Cordelia was originally intended to serve as a dramatic foil to the series' main character Buffy Summers. Adapting the concept of the movie into a television series, Whedon decided to reinvent the character of Buffy. The shallow cheerleader of the 1992 Buffy film, as played by Kristy Swanson, had grown more mature and open-minded. Buffy now identified with the social outcasts, such as Willow and Xander. As a result, Cordelia Chase was created to embody the traits of that shallower Buffy. Despite portraying a shallow, valley girl stock character, actress Charisma Carpenter felt that Cordelia in early seasons was not "one-dimensional", nor was she "as superficial as people thought". At the same time, Carpenter was critical of her frequent role as the damsel in distress. Angel co-creator and executive producer David Greenwalt describes Cordelia in her Buffy years as "a somewhat shallow, somewhat vain, somewhat self-centered but [a] lively and honest character who spoke her mind". Indeed, even not when superhuman, she showed a lot of hardiness.

Charisma Carpenter had originally planned to read for the role of Buffy, but was late for her audition and instead tried out for Cordelia. Carpenter, who had dressed casually for the role of Buffy—who she believed "could really be herself"—felt unprepared to read for Cordelia because she "was definitely a character to dress for". Although she had only fifteen minutes to prepare for the character, the producers were "really responsive" to Carpenter's audition, and she left feeling confident she had got the part. After Carpenter's audition, actress Sarah Michelle Gellar, who had been offered the role of Cordelia before Carpenter, was asked to come back and audition for the part of Buffy. Bianca Lawson originally won the role of Cordelia Chase, but turned it down due to other contractual obligations. Lawson would later be cast as vampire slayer Kendra in the show's second season. Carpenter, proud of her own character's growth across the two series, did not envy Gellar for winning the role of Buffy over her.

Characteristics and analysis
Cordelia's representation of an assertive modern woman and her character arc in Buffy has been commented on in several academic texts, particularly in gender studies, such as "Praising Cordelia: Aggression and Adaptation Among Adolescent Girls", or Sex and the Slayer. In the latter, Dr. Lorna Jowett of the University of Northampton describes Cordelia's initial place in the series where "At first glance, Cordelia seems to have the 'normal life' Buffy often longs for. She is a familiar character from the teen drama: popular, a cheerleader, the center of cliques (power as status). Elizabeth Rambo notes how Cordelia's status is highlighted by her nickname, "Queen C", and Harmony's remark to her, "Cordy, you reign." Cordelia functions recognizably as the typical female victim of horror, often screaming and running away, and this makes her a perfect contrast for other female characters."

"Praising Cordelia" argues that both Buffy and Cordelia are representations of assertive and competitive young women, who "represent two kinds of aggressive adolescent girls". The article focuses on the competitive relationship between the characters. Buffy's initial friendship with Cordelia is compromised once Cordelia sees the attractive, socially competent Buffy as a threat to her. Even after Cordelia joins the Scooby Gang and becomes Buffy's friend, theirs is not a friendship of "mutual support, warmth, and intimacy" but rather one of "mutual antipathy". The authors opine that Cordelia, unlike Buffy, is a "representation of the archetypal 'feminine type'", one who conforms to the "pervasive stereotypes of femininity while, at the same time, dominating the other girls in the school" and commanding the attention of the boys. Describing her character arc in Buffy, Mary Alice Money views Cordelia as one of many transformed or redeemed Buffy characters, one who "reveals a previously unexpected vulnerability that nullifies some of their less attractive traits." Jowett argues that Cordelia's assimilation within the main group is due largely to her relationship with main character Xander, and she is rendered sympathetic to the audience once they witness her rebuff the peer pressure from her old friends. She is further endeared to the viewer when Xander betrays her because the scenes showing her pain are shown only to the viewer. After Cordelia is cheated on by Xander with Willow she chooses not to go back to him and instead retains her autonomy.

Others such as Susanne Kord and Elisabeth Krimer note how Cordelia is also a subversive representation of feminine stereotypes, describing "Although superficially, Cordelia conforms to the stereotype of the insensitive bitch", what she actually does is "offers her viewers the clandestine pleasures of female self-assertion". One of Cordelia's strongest traits, her honesty, is also highlighted in "Earshot", where Buffy temporarily develops telepathic powers and can hear the thoughts of her friends, who avoid her to hide these thoughts. For Cordelia however, "her thought processes and actual utterances are completely identical" and because of this, she embodies an "antithesis of female self-sacrifice" in these years but also "the opposite of the kind of hypocrisy that is typically attributed to women". Writer Jennifer Crusie interprets this as Cordelia's "lack of depth" becoming "her strength". She does not mean to argue that Cordelia is stupid, however, pointing out "Cordy's solipsism could easily be mistaken for stupidity, but it comes coupled with a keen intelligence and a fixity of purpose that makes her almost invincible." Jowett feels Cordelia's confidence is based in her wealth. Despite becoming more sympathetic as the series progressed, "bitchiness enhances Cordelia's comic appeal", as it offers viewers an opportunity to relish its honest truth-telling.

Development
In early seasons of Buffy the Vampire Slayer, Cordelia was often used both as comic relief and occasionally for the damsel in distress plot device, which would require series' heroine Buffy to save her. Any concerns that she was simply one-dimensional were alleviated for the actress when writers developed the character through her relationships with Xander and later Wesley, which led Carpenter to become more convinced of her potential. In an article about the psychology of characters in Buffy the Vampire Slayer, Steven C. Schlozman writes about how "Cordelia is wealthy and, at first glance, superficial, appearing to care most about her own popularity. However, as the show progresses, we learn that her mother has myalgic encephalomyelitis/chronic fatigue syndrome (ME/CFS) and her father was prosecuted for income tax evasion. She is a reluctant participant, baffled at her own loyal feelings and bewildered at her attraction to the unpopular Xander." He goes on to describe how Cordelia, and "all the characters of Buffy the Vampire Slayer are particularly compelling for their depictions of important adolescent themes." Discussing Cordelia's relationship with Xander, Carpenter says, "A lot of Cordy's conflict, and a lot of who she is, comes out around Xander. Because she is in love with him in spite of herself, or in spite of him. I have my best moments with [Nicholas Brendon]." However, her character's growing involvement with Buffy and her friends caused the actress some concern; "I wasn't sure how I felt about it, because I didn't want to lose my edge. I didn't want her to be nice; I didn't want her to change because that's who she is." Carpenter's challenge was to find a balance between the good and bad sides of Cordelia, and she explains, "That's why I enjoy playing her so much. She's got to be somewhat tolerable or why would they hang out with her? But I [try] not to lose her edge, her honesty." Carpenter claims that Cordelia's "rough edges" made for difficult experiences with fans, who expected her to be snobby like her character. Charisma continually pleaded to get to slay a vampire, which the writers let her do in her final Buffy appearance, "Graduation Day, Part Two".

Over the course of her appearances in Angel, Cordelia would develop enormously as a character. Describing this evolution, Carpenter comments, "When I first started playing Cordelia, she wasn't nice. She has really deepened and has a stronger sense of responsibility. She's a team player, which was not the case in the beginning." Carpenter cherishes what playing a multi-faceted character like Cordelia meant for her as an actress, describing "The road Cordelia has traveled, the journey she has taken up to now has been such a joy to play as an actress, because there have been so many chances to do so many different emotions. Heroic, vulnerable, just angry, possessed, funny – I get to be all those different things rolled into one. Getting this role, in hindsight... God I made a good decision, or they did." Cultural critic Jennifer Crusie points out how Cordelia was initially perfect for the transition to "selfish, superficial Los Angeles", which turned out to be her "trial by fire".

Executive producer David Greenwalt was very keen to acquire the character of Cordelia for the spin-off series, commenting, "I desperately wanted her to come to Angel because Angel being dark and broody, we need a big bright smile." At the same time, Whedon felt her presence was sorely missed in the fourth season of Buffy where "All of our characters got to the point where they were loving and hugging, and it was sort of like, where's Cordelia?", leading him to introduce Spike (James Marsters) to the cast to accommodate her absence. According to Marsters, his request for a salary equal to what he was paid on Buffy caused Whedon to remove Carpenter as a regular cast member.

Kelly A. Manners describes Cordelia as a "rich gal whose family ended up losing everything to the IRS. So in episode one of Angel, Cordelia showed up in LA trying to start a career as an actress because her family was in jail, actually." Crusie states that in mourning for Doyle Cordelia also begins "finding within herself a new level of humanity". Greenwalt discusses how Cordelia "is sort of forced to become a deeper character" when she starts to receive the visions of the suffering and helpless, "She's sort of living with one foot in the world of 'I want to be an actress' and with another foot in the world of 'I want to save and help people, and I have a deeper purpose and mission.'" Greenwalt felt that this development allowed Cordelia to develop from a "vainglorious high schooler to someone who's almost like a superhero"; this also provided Carpenter with the opportunity to stretch her potential as an actress. From the tenth episode, "Parting Gifts", Cordelia begins to actively function as a supernatural character in the series while the introduction of Wesley also contributes some added comic relief to the series. It is from this episode Cordelia is also forced to mature as she mourns the death of Doyle, whose visions serve as a painful reminder of him. The first-season finale saw Cordelia's visions inflict all the suffering of the human world upon her, and to effectively act this, Carpenter's acting coach showed her pictures of real human pain as motivation. The scene took over eight hours to film, and Carpenter was relieved when it was over. The experience saw Cordelia further resolve to help those in need, stating "I saw the world and there's so much pain. We have to help them." Carpenter explains, "Through the suffering of the world, and through her own experiences, she discovers what's important in life."

Carpenter pleaded to the producers to let her cut her hair in the second season of Angel, but they were dissatisfied with the darker tone and cut which created a "dark edge of Cordelia" which wasn't as "warm and effervescent as she usually is", so for the third season they wanted her to "go shorter and blonder". Angel third season demonstrates Cordelia's development into a full-fledged heroine. The episode "Birthday" saw her being offered the chance to live a life where she never met Angel, but her inner desire to help others sees her sacrifice this life and her humanity to become a half-demon who can better withstand the visions she carries. In "Billy", Cordelia begins to train alongside Angel to become a better fighter and learns quickly. Carpenter began to train extensively with the show's stunt co-ordinators both to learn how to fight and to handle weaponry. In the episode "Waiting in the Wings", both Angel and Lorne remark on what a fine woman Cordelia has finally become, with Cordelia noting she is more like a superhero than she ever expected to be growing up in Sunnydale. Also in this episode, she and Angel both realize they have fallen for one another, but their love goes unconsummated. Critically, Jennifer Crusie considers Cordelia's ascension to the heavens at the end of season three to be the "point that the Mutant Enemy Productions writers evidently lost their minds". She goes on to describe how Cordelia's compliance with Skip seems entirely out of character. Jes Battis also argues that a paradox is created when "the character who embraces her privilege (Cordelia) gets to become a higher being and exit Angel, and as an overwhelmingly positive force" where later Fred (Amy Acker), "the character who is conflicted about her privilege" in season five "ends up being possessed by a millennia-old demon".

Angel season four played with audience's expectations of the now heroic Cordelia by revealing her to be the season's Big Bad; it was later established that Cordelia had been possessed by a manipulative deity called Jasmine. The storyline was controversial with fans, and Carpenter has admitted hating how a possessed Cordelia seduced Angel's teenage son. Carpenter has said, "I'm in denial about that whole storyline. It was creepy." She tried to keep a positive attitude about the situation, though; director Terrence O'Hara commented that he thought Carpenter had "a lot of fun" playing a manipulative Cordelia in the episode "Orpheus" because she enjoyed coming up with Cordelia's new "schizophrenic madwoman" characterization. David Boreanaz was also unsettled by the incestuous pairing. At a 2004 convention, he admitted that the season four storyline "freaked him out." The episode "Inside Out" saw the height of this inversion of Cordelia's character, where she is seen urging Connor to murder an innocent girl in order to expedite the birth of the child they conceived together. In an effort to stop Connor, the Powers That Be send the spirit of Connor's mother Darla (Julie Benz) to convince him not to go through with it. The episode sees Carpenter dressed in black, while Benz appears in heavenly white as she becomes the voice of reason and morality. Steven S. DeKnight, who wrote and directed the episode, felt this was a brilliant role-reversal for both actresses as Carpenter is accustomed to playing the benevolent Cordelia where Darla is normally seen as a sinister vampire. Much of season four's storyline had to be adjusted due to Carpenter's real-life pregnancy; after Cordelia gives birth to Jasmine in the episode "Inside Out" she is left in a coma for the remainder of the fourth season. Crusie discusses what she felt were the flaws in the execution of the fourth season, "It's that she betrays the man she trusts above all others and who trusts her absolutely; it's that she seduces a boy she once diapered; it's that she dresses like a drag queen and talks like a Dynasty reject. It's that she's not Cordy, and what might have been fun to watch had we been let into the secret before the Beastmaster seduced Connor becomes the extended rape and death of a much-beloved character."

Matt Hills and Rebecca Williams also discuss the treatment of Cordelia (and Darla) in "Angel Monstrous Mothers and Vampires with Soul: Investigating the Abject in 'Television Horror'", from Reading Angel: The TV Spin-off With a Soul by Stacey Abbot. They see the send-offs of Cordelia, Fred and other characters as part of a pattern of highly gendered "elaborated abjection" seen in Angel. They also see Cordelia's possession in season four as part of a recurring pattern: "More so than other characters in [Buffy] and Angel, Cordelia has suffered or been threatened with bodily invasion and rape, either symbolically or literally" and recounts the demon impregnation in "Expecting", and similarly in "Epiphany", where she develops a gestating demon in her head and then told she must mate with the Groosalugg in "Through the Looking Glass". Cordelia even remarks on this, as Hills and Williams quote her as she remarks on her "status as a violated and devalued character"; Cordelia states, "If you ever figure out how to get us out of here, I want you to find me a dimension where some demon doesn't want to impregnate me with his spawn!" They liken the horror motif in these examples, and in "Inside Out", to what Barbara Creed called the 'monstrous womb' in her book The Monstrous-feminine: Film, Feminism, Psychoanalysis. Jes Battis also comments how, in comparison with the Fred-Illyria season five storyline, Cordelia's storyline is not as positive as Fred's rebirth, because Fred got to "'live on' through Illyria, whereas Cordelia is taken right out of the show and receives no interesting blue-haired reincarnation". Continuing, they say that in fact, there is no meaningful connection between the "real" Cordelia and Jasmine, as the Cordelia who did those bad things is killed the moment Jasmine is, "and the 'true' Cordy wakes up from her coma". Further illustrating the comparisons, "Fred/Illyria become a joined mother/daughter subjectivity, a dual being whose constituent essences are inseparable; Cordelia is never so intimately connected with her evil child and is remembered as the healthy, vibrant Cordy that everyone knew." Pointing out symbolic parallels in the subtexts of these gestations, Battis notes "Cordelia, a vocal advocate of her own privilege, creates a fully formed supernatural being, Jasmine, who attempts (shockingly) to control the world. Fred, on the other hand, who internalizes her own privilege and cannot express it except in terms of insecurity and awkwardness, has her body devoured from the inside by the demon Illyria."

For Angel fifth season, as with Buffy fourth, Spike steps in to replace Cordelia as a source of comedic dialogue within the series. It is also noted by critics that, in the fifth season, "it doesn't take long for Illyria to become a version of Cordelia, giving everyone the cold and honest truth whether they want it or not". Concerning Cordelia's last appearance in Angel fifth and final season, Joss Whedon says he used the 100th episode to reinforce the "mission statement" of the show, as well as assess where the characters are now compared to how they began. Whedon explains this episode presents an ideal opportunity to—through Cordelia, who was "there at the beginning"—ask of Angel, "Where are you now? Where were you when you started and where are you now and how do you feel about that?" The return to the show's "original concerns" is echoed by the flashback to Doyle's first season advertisement; Sara Upstone points out aerial images of Los Angeles reappear at the same time Cordelia tells Angel "You forgot who you are," bringing back the show's link to the city. Buffy Summers was originally intended to appear in the 100th episode to get Angel 'back on track', but Sarah Michelle Gellar had other obligations. Writer/director David Fury explains that since "we couldn't get Sarah" the episode was instead written for Cordelia. He adds, "This turned out to be a Godsend because Charisma was fantastic." In the original script, Fury wrote a conversation between Wesley and Angel while driving to the hospital that set up Cordelia as a possible vegetable. The scene was never shot because "the shock of seeing her up and around after a 9-month coma was enough. We just didn't want to tip it too soon," says Fury.

Reception
For her role as Cordelia Chase, as she appeared in the television series Angel, Charisma Carpenter has been nominated four times by the Saturn Awards. Carpenter earned back-to-back nominations in 2000 and 2001 for Best Genre TV Supporting Actress and Best Actress on Television, respectively. The actress did not receive any nominations in 2002, but again obtained two back-to-back nominations in 2003 and 2004 for Best Actress in a Television Series and Best Supporting Actress in a Television Series, respectively.

title: Cordelia Chase