In this special topic of "Mental Law for Handling Cases" in the column "Trial Business Backbone of Shanghai Courts", Xi Shaojun, an advanced individual in the juvenile court work of the people's court, the backbone of the trial business of the Shanghai court, and the fourth-level senior judge of the civil trial division (environmental resources trial division and enforcement tribunal) of the Shanghai High People's Court, is invited to introduce the trial ideas and key points of juvenile off-campus sports injury cases.
At present, the physical fitness and physical training of minors have become the focus of attention of parents, schools and all walks of life, and the advocacy and popularization of national fitness sports have been integrated into daily life.
However, sports and risks are accompanied, and tort disputes caused by minors being injured in off-campus sports activities such as trampoline, rock climbing, equestrian, and skiing are frequent, and handling such disputes requires not only a reasonable judgment of the specific circumstances of the sports venues' performance of safety and security obligations, but also the need to explore and improve the safety guarantee system for minors from the perspectives of operators, guardians, and supervisors, so as to provide judicial safeguards for minors to safely carry out off-campus sports activities and the high-quality development of national fitness. This paper focuses on the analysis of common problems and dispute resolution paths in sports injury disputes among minors from the dimension of operator responsibility.
01
Characteristics of Minors' Extracurricular Sports - "Three Highs"
Minors' extracurricular sports activities are no longer limited to traditional common sports such as ball games, swimming, and roller skating, but have been extended to more diversified sports activities such as trampoline, rock climbing, equestrian, and skiing.
First, it is risky and challenging
There are risks associated with sports, but the degree of risk varies from sport to sport and facility. For example, the current rise of extreme sports is relatively risky and may pose a threat to the personal safety of athletes. For example, equestrian, skiing and other sports are also more risky, and even professional athletes may be injured or have other serious consequences during training or competition.
Second, high professionalism and strong technology
In the physical education course, the minors are exposed to the basic training of sports - walking, running and jumping. The form and content of extracurricular sports are more abundant, and with the development of socio-economic and cultural development, the scope of sports is constantly expanding, and the corresponding difficulty is also increasing. Therefore, minors often need to choose professional venues, wear professional protective gear, and receive professional guidance when participating in these risky sports. For example, ball games, trampolines, and figure skating require high skills and require a certain learning and practice process, while some novel sports combine and innovate a number of traditional sports, which require participants to master and familiarize themselves with them step by step.
3. Pay attention to high standards and security requirements
This characteristic is determined by the first two characteristics, namely the high risk of sports and the professionalism. In order to minimize the risk of sports and improve the safety factor during sports, sports venues and sports facilities providers need to fulfill their safety and security obligations in accordance with statutory or agreed care standards, such as providing sports facilities that meet the standards and have perfect functions, removing obstacles in the sports venues in a timely manner, and setting up safety management personnel to maintain sports order and stop improper behavior.
02
Cases involving injuries caused by minors in off-campus sports
Key Points of the Trial - "Three Searches"
Injuries in juvenile extracurricular sports may have the consequences of injuries and need to be taken seriously. In the event of a sports injury, it may also be difficult to clarify the responsible entity, the cause of the injury, or the attribution factors. In this regard, we need to do "three searches":
1. Find the whole responsible entity
After a minor is injured in extracurricular sports, the first point is to clarify the subject of responsibility, and two issues should be paid attention to at this time.
1. Determination of operators, managers, and organizers
Usually, off-campus sports injuries of minors occur in specific sports venues or in the course of participating in sports training and events. Article 37 of the Tort Liability Law of the People's Republic of China in 2009 (hereinafter referred to as the Tort Liability Law of 2009) defines the scope of tort liability for breach of security obligations as "managers of public places such as hotels, shopping malls, banks, stations, entertainment venues or organizers of mass activities", that is, "managers of public places or organizers of mass activities". There are shortcomings in the narrow scope of this subject, which is not conducive to protecting the interests of those who should be protected. Therefore, the subject of tort liability for breach of security obligations stipulated in Article 1198 of the Civil Code of the People's Republic of China (hereinafter referred to as the "Civil Code") has been greatly expanded on the basis of Article 37 of the Tort Liability Law of 2009 to provide that it is "the operator or manager of a hotel, shopping mall, bank station, airport, stadium, entertainment venue and other business premises or public place, or the organizer of mass activities".
Therefore, when it is necessary to pursue the responsibility of the operator in the case of injury to minors outside of school, the venue operator, the event organizer, the training service provider, etc. should generally be the main body of responsibility. In most cases, the identities of venue providers and training service providers are competing, and in some cases, different aspects of sports activities are completed by different entities performing their duties and division of labor, so it is necessary to determine the specific scope of the responsible subjects according to the cause of injury, the content of duties, etc.
2. Determination of the direct infringer
Paragraph 2 of Article 1198 of the Civil Code stipulates that if a third party's conduct causes damage to others, the third party shall bear tort liability; Where operators, managers, or organizers fail to fulfill their security obligations, they shall bear corresponding supplementary liability. After the proprietor, manager or organizer bears supplementary liability, it may recover compensation from a third party. In some off-campus sports injury cases, where a minor participant is injured while engaging in adversarial sports, group activities, or being collided with others or under the influence of external forces, the "third party" who commits the infringement and causes the harmful consequences is the direct infringer and shall participate in the litigation as the subject of responsibility.
In particular, Article 1188 of the Civil Code stipulates that if a person with no or limited capacity for civil conduct causes damage to others, the guardian shall bear tort liability. Where guardians perform their guardianship duties, their tort liability may be reduced. Where a person with property who lacks or has limited capacity for civil conduct causes harm to others, compensation is to be paid from his or her own property; The guardian shall compensate for the shortfall. Therefore, if the "third person" is a minor, his guardian must be a co-defendant.
2. Find the cause of the injury
Because minors have more daily learning and life trajectories, they will participate in sports activities both inside and outside the school. Therefore, many sports injuries fail to fix the fact of injury at the first time due to minor injuries, urgent medical treatment, and failure to obtain the contact information of the other party, which leads to disputes over the cause of injury in subsequent litigation. At this time, we can use three "means" according to the actual situation, give full play to the positive role of "technology + tradition" and "self-reliance + police force" to restore the facts, and try to make up for the shortcomings of not fixing the facts in time.
1. Direct restoration of monitoring data
At present, the monitoring facilities are popular, and the data recorded by the surveillance video has the advantages of directness, objectivity, and clarity, and should be retrieved at the first time through burning, transmission, reproduction and other ways to maximize the traces.
2. Eyewitnesses and clue collection methods
In practice, the surveillance data may be objectively restricted by the shooting angle, storage time, facility failure, etc., and the cause of the injury cannot be completely restored. At this time, direct evidence such as witness testimony can also reflect the circumstances of the incident to a certain extent, and even have its own advantages in judging tort liability. For example, the dialogue and facial expressions of personnel, emergency response, disposal, background information outside the monitoring period, the order around the site, and the implementation of customary management measures that cannot be reflected in the monitoring may have important reference value for the identification of the cause of injury and even the final determination of the proportion of responsibility.
3. Methods of intervening in the investigation by the public security organs
After a sports injury occurs, consumers may encounter obstacles in the process of negotiation with the operator, and it is difficult to grasp private information such as monitoring data and information on direct infringers. In this case, efforts to fix the basic facts may be done through methods such as promptly reporting the case and having the public security organs intervene in the investigation, so as to lay a good foundation for the restoration of subsequent incidents and the determination of responsibility.
3. Identify the factors of responsibility
In the tort liability for breach of security obligations, there should be a causal relationship between the breach of duty by the obligor and the damage caused by the protected person. Due to the different types of infringement, the nature and requirements of the causal elements are also different.
1. Direct causation or equivalent causation
In the case of asserting the fact that the breach of the security obligation directly caused the injury, the requirement for causation is that there is a direct causal relationship or a substantial causal relationship, and the breach of the security obligation is the cause of the damage.
For example, in a skating injury case, 5-year-old Chen fell while receiving one-on-one figure skating training at the defendant's ice rink, and Guo, an ice rink worker behind Chen, hit Chen, who had not yet gotten up, because of a reverse slip, and Guo also pressed on Chen's body during the fall, causing the sole skate blade to scratch Chen's fingers. In this case, the breach of the security obligation was the cause of the fact of the damage to the protected person, and there was a direct causal link between the breach and the consequences of the damage.
2. Indirect causation
Among the tort liabilities for breach of security obligations, there is a category of tortious acts that belong to the category of prevention and suppression. For those who claim the existence of such acts, the requirement of causation is relatively low, and the causal relationship constituted by the tort liability should be indirect causation, that is, the breach of the security obligation is only the indirect cause of the damage, and it is not required to be the direct cause.
For example, Mei, a 12-year-old student, was participating in a barrier-breaking exercise in the defendant's sports hall when she walked in the opposite direction on the turntable and fell on the ground ocean ball from the gap between the levels, resulting in an injury to her arm. The investigation found that Mei violated the rules and stayed for a long time, and the staff did not guide and stop it during the reverse activities, and the operator assumed the corresponding tort compensation liability based on the management defects.
03
The operator's obligation to ensure safety
Reasonable limits and basis for segregation of liability
Where the liability of business operators is premised on the implementation of conduct that violates the obligation to provide safety safeguards, and some minors participate in extracurricular sports and form a contractual relationship with the corresponding venues or institutions such as consumer services, the standards agreed in the contract are an important basis for judging whether the perpetrator has fulfilled the obligation to ensure safety. Of course, the safety guarantee obligation is a legal obligation at the level of tort liability law, and the judgment of whether the safety guarantee obligation is violated and its reasonable limit are closely related to the corresponding care standards, and it is necessary to combine the two major factors of sports risk and the characteristics of minors to compare and evaluate.
1. How to determine whether the obligor has violated the security obligation
Judging whether the obligor has fulfilled the security obligation can be grasped from four aspects.
1. Statutory Standards
Where the law has direct provisions on the content of security safeguards and the conduct that must be performed by persons with security safeguards, judgments shall be made in strict accordance with the clear provisions of laws and regulations.
For example, according to the "Sports Law of the People's Republic of China", "Regulations on National Fitness", "Measures for the Administration of Permits for the Operation of High-Risk Sports Projects" and other provisions, the operation of high-risk sports projects shall apply for an administrative license from the competent sports department of the local people's government at or above the county level, and meet the following conditions: (1) the relevant sports facilities meet national standards; (2) Social sports instructors and rescue personnel who have reached the required number and obtained national vocational qualification certificates; (3) Have safety assurance systems and measures such as a responsibility system for production safety posts, safety operation procedures, emergency response plans, and safety inspection systems for sports facilities, equipment, and equipment; (4) Other conditions provided for by laws and regulations. This provides a more comprehensive and systematic legal judgment standard. Violation of this standard and causing sports injuries to minors constitutes a breach of the duty to ensure safety.
Regarding the specific application of the corresponding statutory standards, the following two points need to be noted:
First, the "high-risk sports" stipulated in the provisions have their own established scope, rather than the subjective empirical judgment of individuals. On May 1, 2013, the General Administration of Sport of China and other departments jointly issued the Announcement on the Catalogue of the First Batch of High-Risk Sports, which included swimming, alpine skiing, freestyle skiing, snowboarding, diving, and rock climbing in the management scope of high-risk sports. Therefore, the high-risk sports mentioned in the legal provisions are limited to the above-mentioned scope, which is objective and determined, which is different from the subjective judgment of consumers on the degree of sports risk in daily life.
Second, the "national standard" is divided into mandatory and recommended. The "standards" adjusted by the Standardization Law of the People's Republic of China refer to the technical requirements that need to be unified in the fields of agriculture, industry, service industry and social undertakings. Standards include national standards, industry standards, local standards, group standards, and enterprise standards. Among them, national standards are divided into mandatory standards and recommended standards, and industry standards and local standards are recommended standards. Therefore, even national standards are mandatory and recommended, and the implementation effect of the two is different. Mandatory standards must be enforced, while recommended standards are encouraged. The Standardization Administration of the People's Republic of China has successively issued and revised various parts of the "Opening Conditions and Technical Requirements for Sports Venues", involving swimming, bungee jumping, rock climbing, roller skating, skiing, skating, shooting, diving, rafting, paragliding and other sports venues.
For example, skating venues are required to be equipped with non-slip walkways, seats, and railings, and safety protection facilities with a height of not less than 1 meter around the venue, and ice skating equipment and protective gear. Therefore, if a minor is injured in ice skating activities due to the failure of the skating venue to provide facilities and equipment that meet national standards, it shall bear the corresponding tort liability for compensation.
2. Special Standards
Special standards shall be applied for the obligation to ensure the safety of minors, that is, if there is a danger of temptation to children in a field of business activity or a field of social activity, the manager of a public place or the organizer of a mass event must perform the highest obligation to ensure safety.
The safeguard obligations that should be fulfilled include: (1) eliminating the danger and avoiding the occurrence of sports injuries to minors; second, to isolate the danger so that minors cannot come into contact with the corresponding danger; Third, take other measures to ensure that no harm is caused to minors. Failure to implement these safeguards is considered a breach of the security obligation.
For example, the Law of the People's Republic of China on the Protection of Minors (hereinafter referred to as the "Law on the Protection of Minors") stipulates that public places where minors gather for concentrated activities shall comply with national or industry safety standards, and appropriate safety protection measures shall be taken. Facilities that may have safety risks shall be maintained regularly, and safety warning signs shall be set up in conspicuous positions and the appropriate age range and precautions shall be indicated; When necessary, special personnel shall be arranged to supervise them. Large-scale shopping malls, supermarkets, hospitals, libraries, museums, science and technology museums, amusement parks, stations, docks, airports, tourist attractions, and other such venues shall set up security alert systems for searching for lost minors. After receiving a request for help, the site operating unit shall immediately activate the security alarm system, organize personnel to conduct a search, and report to the public security organs. When emergencies occur in public places, priority shall be given to the rescue of minors.
3. Good stewardship standards
This criterion is closely related to the degree of specialization in the occupational field. In tort law, the duty of care of ordinary people is based on the care of a person with considerable knowledge and experience in a certain field or matter. However, the good manager standard does not investigate whether the operator actually has the knowledge and experience of such care, and the level of care that he has always used in the transaction, but only needs to be measured according to his profession, and the degree of care used should be higher than that of ordinary people.
For example, in a case involving equestrian training, 13-year-old Li was registered as an equestrian rider after professional training at the club, and was hospitalized after accidentally falling off his horse during a training session. A month after being discharged from the hospital, Li resumed training, but accidentally fell from the horse again and was trampled by the horse during the obstacle exercise. During the trial, the plaintiff Li pointed out that the coach did not require and remind him to wear armor, while the defendant club said that only cross-country obstacles were required to wear armor in equestrian sports, and whether to wear it in other situations was up to the rider to decide and bear his own risk. This controversy has practical significance for applying the special standards for minors and the standards for good managers. Because the "Equestrian Riding Instructions" posted in the defendant's venue contained a reminder of "do not wear armor, do not ride a horse", and it is generally recommended that underage players wear armor in equestrian show jumping competitions, and one factor that cannot be ignored is that Li had an experience of being trampled by a horse because he did not wear armor before resuming training. Coaches and venue managers should pay attention to the protective role of protective gear to avoid the recurrence of similar accidents. Therefore, for Li's second fall from a horse and injury, there was a gap between the defendant's level of guidance and management and the standard of care that he should have met, which violated the statutory and agreed safety and security obligations.
4. General Standards
This criterion mainly refers to the obligation to inform about hidden dangers, as well as the general protection of invitees entering the field of business or social activities.
For example, 7-year-old Shi went to a basketball hall to participate in an experience class, and Shi hit the edge of the wooden door frame in the gym during the training organized by the coach, resulting in a forehead injury, and immediately sought medical attention for adhesive treatment. The investigation found that the door frame of the impact was difficult to identify due to the painted pattern, and the frame was sharp, and the coach did not explain it to the students and their parents during the exercise. It can be seen that the basketball hall did not isolate or inform about this imperceptible hidden danger, which did not meet the general standard of care.
2. The specific types of tort liability for breach of security obligations
Tort liability for breach of security obligations can be divided into four specific types.
1. Defective facilities and equipment
The facilities and equipment of sports activity business venues shall be maintained and overhauled on a regular basis to keep them in good and safe operating condition and meet safety standards. If the requirements for ensuring safety are not met, and there are defects or flaws, causing harm to minors, the proprietor shall be liable for damages to the infringed party.
For example, when the ice surface is damaged or uneven in the skating place, it should be warned, isolated, and overhauled in a timely manner, and whether it has the conditions to continue to be open should be assessed.
2. Service Management Defects
The safety and security obligations in the management of sports venue services mainly include the following three aspects:
(1) Strengthen management and provide a safe environment for consumption and activities
When providing services, the stadium shall ensure that the service content and service process are safe, and there must be no potential safety hazards or unreasonable risk factors that exceed the inherent risks of the sport. These requirements are concentrated in the organization, management and service of operators.
(2) Adhere to service standards to prevent damage
In the operation and management of sports venues, sports venues should usually have safety guarantee systems and measures such as a responsibility system for safety production posts, safety operation procedures, emergency response plans, and safety inspection systems for sports facilities, equipment and equipment. If there are rules and regulations that are not followed, orders are not followed, and there is a large gap between the set service standards or safety requirements, resulting in sports injury accidents, it shall be found to have service management defects.
For example, in one case, Liu, who was only 5 years old, went to an extreme sports hall to experience the "high-altitude extreme escape project", the large air cushion laid on the ground was about 1.8 meters high, and the bottom jump platform was 1.4 meters away from the air cushion. After investigation, it was found that the "High-altitude Extreme Escape Risk Notice" posted in the extreme sports hall contained "safety warnings": "The following groups of people participating in this project are prone to internal organ damage, fractures and even irreversible physical injuries due to physical conditions such as incomplete bone development or osteoporosis, please follow the following regulations: minors under the age of 7 are prohibited from experiencing the ...... of this project" It can be seen that the venue staff did not understand and determine whether the participating children met the age of the experience as required, and not only did not stop the experience of those who did not reach the age, on the contrary, he took the initiative to assist in the completion of high-risk activities, which clearly violated the activity rules and service standards set by himself, and bore unshirkable responsibility for Liu's injury.
(3) Necessary reminders, explanations, advices, and assistance obligations
In business or social activities, if there are unsafe factors that may cause injury or accidents, warnings shall be given, consumers or participants shall be reasonably explained to possible dangers, and operators or organizers shall actively rescue the dangers that have occurred or are occurring, so as to avoid the occurrence or expansion of damages.
For example, the Law of the People's Republic of China on the Protection of Consumer Rights and Interests stipulates that business operators shall ensure that the goods or services they provide meet the requirements for protecting the safety of persons and property. For goods and services that might endanger the safety of persons or property, consumers shall be given a truthful explanation and clear warning, and the methods for using the goods or receiving services correctly and the methods for preventing harm from occurring shall be explained and marked.
It should be pointed out that at present, many sports venues will prompt and explain by posting admission instructions, signing notices, etc., but mainly from the perspective of operators, risk warnings, and the content of the prompts is formatted, one-sided, and mere formalities. There is a serious mismatch between this kind of reminder and the duty of reminder and notification that business operators should perform in accordance with law, and it should be clarified and corrected. In this regard, the common prompt questions in sports venues are as follows:
First, the content of the prompt is highly homogeneous and not specific enough. Generally, the activity facilities provided in the sports venues have a certain degree of risk, but the specific activity methods, risk levels and precautions are different, and the operator should give special reminders in this regard. Many stadiums provide notices that are highly homogeneous, with similar versions and mostly standard terms. The most common is to generalize with the expression "sports are risky", which suggests that the content is too general and principled. Another example is that important reminders such as age restrictions are not conveyed to minors and their guardians and companions through eye-catching and effective channels, resulting in a lack of specific and adequate risk notification.
The second is that the notification channel is unreasonable and the logo is not significant. During the trial of similar cases, it was found that some venues gave reminders and notices in various forms such as playing videos, written notices, on-site explanations, and posting signs after minors entered, and although they played a positive role in preventing risks and reducing harm, some of the notification channels were unreasonable and the signs were not significant. For example, only posting exercise rules in closed activity venues, without prompting and explaining them at the entrances, exits, observation areas, and other places where guardians stay, leads to information asymmetry for guardians, making it difficult to help assess exercise risks and select appropriate activities through prompt information. For another example, many reminders are in Chinese and English forms, with very small fonts and dense packs, and important and key information is scattered in many entries, which is not prominent and eye-catching, and is difficult to quickly identify, which weakens the effectiveness of the notice.
3. Defects in the service object
Legally, special standards apply to the protection of minors, requiring operators of sports venues and sports organizers to do everything in their power to take all measures to protect minors from tempting dangers in the venue. For example, the Law on the Protection of Minors sets out requirements for the production and sale of products intended for minors, and also clearly stipulates the safety and security obligations of public places and accommodation operators. When receiving minors in sports activity venues, they shall ask about the contact information of their parents or other guardians and the identity of the accompanying persons, and where there are restrictions on age or height, a sign prohibiting or restricting entry shall be set up in a conspicuous position, and where it is difficult to determine whether they are minors, they shall be required to present their identification documents. If special protection is not provided according to the age and characteristics of the service recipients, causing sports injuries to minors, it may be found to constitute a special protection defect.
4. Prevent and stop defects
If an operator or organizer who has a security obligation to others fails to fulfill its obligation to prevent and stop the infringement of others, causing damage to the protected person, it also gives rise to tort liability for violating the security obligation, which is a specific type and is often associated with supplementary tort liability. Supplementary liability in tort law refers to the tort liability of two or more actors who violate their statutory obligations and commit acts of harm to one infringed party, or where different actors cause the same damage to the rights of the infringed party based on different acts, and each actor incurs tort liability with the same content, and the several claims enjoyed by the infringed party have a sequential requirement, and the claim right with the order of the first claim is exercised first, and when the claim cannot be realized or cannot be fully realized, the other claims are exercised.
It should be noted that the scope of liability of the supplementary liable person is not the part that the directly responsible person cannot compensate, but the "corresponding" part, that is, it should be "corresponding" to the degree of fault of the obligor and the causal force of the act, and shall not bear the liability for compensation beyond the corresponding part.
For example, 6-year-old Xu went to the children's playground in the mall accompanied by his mother. When Xu was sliding down the rainbow slide, 3-year-old Shen suddenly appeared under the slide and climbed up, hitting Xu. Xu's mother, who was sitting at the mouth of the rainbow slide, immediately called the police and took the child to seek medical treatment, and then sued Shen and the amusement park for joint liability. During the trial, the monitoring was found that a staff member was standing and walking around facing the exit of the slide, Shen's grandparents were chatting with people at the mouth of the slide, and Shen suddenly walked on the mat at the mouth of the slide alone and went backwards, colliding head-on with Xu who was sitting on the bottom of the slide, and the two were injured. In this case, the on-site staff failed to evacuate Shen in time and eliminate hidden dangers, which was negligent. However, Shen's reverse climbing behavior occurred suddenly, and his caretakers did not pay attention to it, and a guard had been set up at the entrance of the slide, so the children's playground party should only bear the supplementary liability for compensation commensurate with its ability to prevent and stop and the degree of on-site management defects.
epilogue
Minors' active participation in sports can not only shape a healthy body and improve physical fitness, but also cultivate perseverance and enterprising will. Therefore, it is not possible to "choke on food" simply because there are sports risks and injuries that may lead to "choking" and unduly reduce or restrict minors' opportunities to exercise. Of course, sports safety is no small matter. This paper comprehensively analyzes and sorts out the common characteristics, causes and treatment modes of juvenile sports injury accidents at this stage, in order to better understand the development trend, frequent causes and improvement paths of such accidents. In the trial of similar cases and disputes, it is necessary to take "sports risk" as the center and "safety and security capacity" as the radius, find all responsible entities, find the cause of injury, find out the attribution factors, do a good job of "dual positioning" of attention standards and types of responsibility, implement the "should do" of safety and security measures, create space for the "promising" of sports safety and rule of law awareness, and realize the two-way interaction of "dispute resolution" and "source prevention", so as to provide high-quality safety guarantees for the healthy growth of minors. Fundamentally reduce the rate of sports injuries and accidents among teenagers, and truly enable minors to gain a sense of security, pleasure and accomplishment in sports.
About the Author:
Xi Shaojun, LL.M. from Nanjing University, is currently a fourth-level senior judge of the Civil Division (Environmental Resources Division and Enforcement Division) of the Shanghai Higher People's Court. He was awarded the advanced individual in the juvenile court work of the people's court, the model of women's meritorious service in Shanghai, the backbone of trial business and the model of case handling in Shanghai court, and was awarded the third-class individual merit in the Shanghai court system. A number of cases presided over by the trial have been selected as "Three Hundred" excellent cases and excellent judgment documents of Shanghai courts.
Contributing Department of the High Court丨Cadre Training Division, Civil Trial Division (Environmental Resources Division, Enforcement Division)
Author: Xi Shaojun
Statement丨Please indicate that it is from the official account of "Shanghai High Court".