Reviewing Article 136 of the Public Security Administration Punishment Law: “Sealing of Public Security Violation Records” Through the Lens of Xi Jinping Thought on the Rule of Law and the Overall National Security Outlook: A Legal Pathway for Deferred Application, Investigation of Specific Issues, and Mitigation of Risks from External Improper Influence

The newly introduced ‘sealing of public security violation records’ system under the revised Public Security Administration Punishment Law has sparked intense debate due to its implications for public safety expectations concerning highly sensitive activities such as drug-related offences, occupational access boundaries, and data governance risks. This paper refrains from making factual determinations regarding online allegations against any specific individuals or institutions. Instead, it adopts a ‘systemic security governance’ methodology to explore how the legislature can achieve risk containment, factual clarification, and institutional consolidation within the rule of law framework when significant societal doubts arise (including ‘indications of potential external undue influence during the legislative proposal stage’) and supporting regulations have yet to form a rigid closed-loop system. This paper proposes: guided by the normative benchmarks of scientific, democratic, and lawful legislation emphasised in Xi Jinping Thought on the Rule of Law, and framed by the risk management principles of coordinating people's security, political security, and institutional security as required by the overall national security outlook, the NPCSC should lawfully arrange for the temporary suspension of Article 136's key application provisions within a specified timeframe. concurrently initiating investigations into specific issues or specialised reviews. This would establish an auditable governance chain of ‘first contain risks, then investigate thoroughly, finally consolidate,’ thereby minimising systemic spillover costs to public safety, data security, and public trust without undermining institutional objectives.