In Silas Hsiu-liang Wu, The Memorial Systems of the Ch'ing
dynasty, Harvard Journal of Asiatic Studies, 27:7-75 ( 1967),
pp. 61-62, there is a list, following TCHT, 82: 10b-11, of offi-
cials qualified to present tsou-che-type memorials, and his list
serves to indicate the diffuse scattering of this right directly to
communicate with the emperor throughout many offices. It
should be noted that this TCHT passage states that the higher
nobles of the tsung-shih (imperial house) had the right to me-
morialize. (On types of nobles, see IV, 3, d.) Just how many
of the twelve ranks of the imperial house had the right is not
clear. There is evidence that the phrase used, tsung-shih wang-
kung, covers just the first six. There is also a list of persons
qualified to present tsou-che-type memorials "by themselves" in
Rikubu seigo chükai (Terminology of the six boards, annotated;
Kyoto, 1940), pp. 3-4. The text in this book is that of Liu-pu
ch'eng-yü chu-chieh, a handbook partly prepared in the late
Ch'ing period. This list gives the first four grades of the im-
perial house as qualified as well as the first three grades of non-
imperial nobles.

A definitive understanding of who could memorialize is still
beyond us. Rikubu diverges from the TCHT list in that (a) it
states that tsung-ping (brigade generals in green standard
units), provincial treasurers, and provincial judges lack the
right to "memorialize by themselves" -- TCHT says they have it;
(b) Rikubu omits taotais, while TCHT says that taotais, like
certain censors, have a partial right to memorialize in that they
may present memorials in which they yen-shih (discuss state
matters). From Rikubu, p. 8, we learn that besides yen-shih
there were two kinds of memorials: hsieh-en (expressing thanks
for an imperial favor) and ch'i-ch'ing (to make a request [from
the emperor]). The latter clearly was that main category of
executive memorials making specific proposals.

One should also note that all officials had the right to memo-
rialize if they were "being oppressed in a way out of accord with
the rules of moral propriety" by their superiors ( TCLL, 4:16;
Philastre, I:135). However low his rank, an official speaking
to the emperor at an audience was said to be "memorializing."
An official without the full right to memorialize could ask one
who had it to memorialize on his behalf (tai-tsou). Finally we
should keep in mind that the realization of the legal right to
memorialize partly depended on changing policies or fashions.

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