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◆ Thai Legal Studies2026-07-31· Normative

Xiyuan Jilu and the Three Seals Code

Junlang Zeng, Xinhui Lu, KHUMSAT TEAVAKORN 任欣 路卫

原始摘要(英文原文)· Original abstract
This article presents a comparative study of the forensic examination and evidentiary provisions in Xiyuan Jilu (1247), a seminal work on forensic medicine from China’s Song Dynasty, and the Three Seals Code (1805), the foundational legal compilation of Thailand’s early Bangkok period. Though differing fundamentally in textual nature—the former being a specialized treatise on autopsy techniques, the latter a comprehensive legal archive—both texts offer valuable insights into how pre-modern Asian legal civilizations approached the problem of judicial evidence. Rather than claiming equivalence, this study uses their differences as analytical leverage to illuminate divergent institutional paths. Through textual analysis, the study reveals both commonalities and divergences. Both texts exhibit systematic approaches to judicial evidence and emphasize the importance of physical injuries in legal determination. However, they differ significantly in normative form, technical approach, and judicial philosophy. Xiyuan Jilu adopts a knowledge-based structure centered on morphological analysis to pursue objective truth, reflecting the Song Dynasty’s forensic empiricism. The Three Seals Code, by contrast, embeds evidentiary rules within a comprehensive legal framework, utilizing quantified compensation standards and emphasizing procedural justice grounded in Buddhist ethical principles. These differences illuminate the distinct paths through which East Asian and Southeast Asian legal civilizations developed their approaches to judicial evidence. The comparative analysis contributes to global legal history by demonstrating how divergent institutional, philosophical, and cultural contexts shaped the pursuit of judicial truth across pre-modern Asia.
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