Theories behind Change of Land Expropriation Institutions in Cross-Strait: An Analysis from Historical Institutionalism Approach

Abstract

Rapid urbanization in developing countries has led to an increasing demand for urban construction land. As a result, many farmers’ lands have been expropriated by local governments, exacerbating the imbalance between land supply and demand. This issue is particularly pronounced in Chinese Mainland, where land expropriation institutions have operated at a suboptimal level for an extended period. While existing research has explored the current practices and potential avenues for the optimization of the horizontal aspects of land expropriation institutions in Chinese Mainland, there remains a dearth of academic inquiry from a historical developmental and comparative analytical perspective. To address this gap, this article uses the analytical framework of historical institutionalism and combines it with the comparison case method and in-depth interviews to analyze the fundamental path, logic, and dynamic mechanism behind land expropriation institutional change in Cross-Strait and provide insights for similar developing countries. Research shows that Cross-Strait land expropriation institutions have gone through five different stages of development, and finally evolved in the direction of narrowing the scope of expropriation and increasing the compensation for expropriation. Cross-Strait land expropriation institutions show a triple logic in terms of change types, change paths, and change processes: in terms of change types, there are compulsory changes and mutual games between induced factors and actors pushing for compulsory changes; in terms of change paths, there are patterns of displacement, drift, conversion, and layering; and in terms of gradual change processes, path dependence characteristics become apparent within Cross-Strait land expropriation institutions. The synergistic interaction among the institutional milieu, ideas, and actors constitutes the dynamic mechanisms for the change of land expropriation institutions in Cross-Strait.

1. Introduction

In any era and country, land stands as a vital resource for development. In the ancient Stone Age, tribes frequently engaged in conflicts over land resources through warfare. After the formation of nation-states, a sense of civic consciousness gradually emerged among people, and in order to avoid conflicts, when those in positions of superiority sought to acquire the land from those of lesser standing, primitive seizure methods gave way to a more rational approach of gradual exchange [1]. As a result, the institution of land expropriation came into being and has become a necessary means for modern states to reconcile conflicts between the public interest and the rights and interests of individuals. At the same time, land expropriation has become one of the key instruments of land governance [2]. However, as urbanization takes center stage in developing countries, the demand for urban construction land continues to surge. This trend has led to a significant number of instances where farmers’ land is subject to expropriation by local governments. Given that land expropriation 1 encompasses the redistribution of land value appreciation, the establishment of the expropriation institution, and the execution of land expropriation procedures, the mishandling any aspect of this process by local authorities or the misalignment of the expropriation institution with the rapid pace of urbanization could result not only in land-related disputes but also in adverse effects on local development. For developing countries with swift urbanization, a prominent concern and challenge in land management and expropriation lies in determining the most effective approach to providing land that accommodates urbanization in ways that fuel economic growth and promote human settlement [3].

Notably, among these developing countries, the Chinese Mainland is probably one of the fastest urbanizing countries. The level of urbanization (the proportion of urban population to the total population) in Chinese Mainland increased from 17.92% in 1978 to 52.57% in 2015. It is projected to further increase by 70% by 2030 and 80% by 2050, potentially reaching the urbanization levels seen in developed countries [4]. However, in contrast to the rapid urbanization levels in the Chinese Mainland, the effectiveness of its land expropriation institution has persistently remained low due to the continuous increase in the demand for land for urban construction, giving rise to a pronounced contradiction between land supply and demand. Moreover, certain local governments, in their pursuit of substantial land revenues and overall local economic growth, have unscrupulously expropriated farmers’ land in violation of the law, further intensifying the conflicts between the rural population and local authorities [5]. Against this backdrop, Chinese Mainland academics hold varying perspectives on the land expropriation institution, which can be broadly classified into four categories: the abolitionist theory, the comprehensive reductionist theory, the market value compensation theory, and the overall integrationist theory. Regarding the abolitionist theory, this viewpoint posits that the land expropriation institution itself is inherently unreasonable. It holds that land functions as a production factor, and its allocation should solely rely on market mechanisms. Advocates of this stance argue that government-led land expropriation constitutes a deprivation of farmers’ property rights and a violation of the Constitution [6]. Moving on, the second perspective is the Comprehensive Reductionist Theory. According to this school of thought, expropriation is necessary when the market fails in the allocation of land resources. The private sector, they argue, cannot supply adequate land for the public good, thus requiring the government intervention. However, land for the non-public good can be supplied through the market without government expropriation. Scholars of this school of thought support the retention of the expropriation institution but call for a narrowing of its scope to the public interest [7]. The third perspective is the Market Value Compensation Theory. Scholars subscribing to this viewpoint contend that a significant flaw in the expropriation institution is that the government compensates the farmers according to the original land use value, while the government receives the proceeds of the appreciation of the value of the land. Therefore, this group proposes a substantial increase in the compensation standard for land expropriation, suggesting even compensation for farmers based on market value [8]. The fourth perspective is the Overall Integrationist Theory. Scholars aligned with this view regard land expropriation as a legitimate government power. They argue that academia should prioritize the function of the expropriation institution rather than its specific form. They assert that the current expropriation institution based on the public ownership of land is the foundation of the rapid development of urbanization in the Chinese Mainland. These scholars call for the maintenance of the expropriation institution without dramatic modifications [9]. In general, these perspectives concentrate on the current practices, issues, and potential avenues for optimization at the operational level of the land expropriation institution. However, they lack scholarly research from the historical development and comparative analysis perspectives. Examining the change of the land expropriation institution through the lenses of historical development and comparative analysis not only aids in analyzing the direction and fundamental path of institutional change, but also clarifies the logic and principles of institution transformation. Furthermore, this approach highlights potential directions for optimizing the land expropriation institution in the future.

In light of this, this article presents a comparative exploration of Taiwan’s land expropriation institutions to address the following questions. First, how many stages of development have the land expropriation institutions in Cross-Strait 2 gone through, and what is the general direction of change? Second, what kind of logic has been followed in the changes of land expropriation institutions in Cross-Strait? Third, what are the incentives for the change of land expropriation institutions in Cross-Strait? In order to answer the above questions, this article employs historical institutionalism as the analytical approach, utilizes in-depth interviews, and conducts a comparative case analysis to observe the process of generation, survival, and change of land acquisition institutions in Chinese Mainland and Taiwan from a broad historical perspective, so as to provide certain theoretical references and values for the change of land acquisition institutions in similar developing countries.

There are two reasons for the selection of Taiwan and Chinese Mainland as the subjects of comparison for land expropriation institutions. Firstly, following the concept of most similar systems design, Taiwan and the Chinese Mainland share numerous commonalities, including their belonging to the same nation and a shared history, language, and culture. However, a crucial divergence emerges in the foundation of property rights within their respective land institution—public ownership in the Chinese Mainland and private ownership in Taiwan. Consequently, a comparative analysis between the two regions facilitates an exploration into whether the logic and fundamental trajectory of change in the land expropriation institution markedly diverge within a nation featuring distinct political systems. Secondly, from a historical perspective, Taiwan, as a developed region, has encountered land expropriation conflicts currently unfolding in the Chinese Mainland amidst rapid urbanization. Yet, guided by Sun Yat-sen’s principle of “equal land rights”, Taiwan authorities have ingeniously localized and assimilated European and American experiences. This strategic assimilation has culminated in the establishment of an inclusive system governed by the Spatial Planning Act. This comprehensive system encompasses various aspects including land policy, land acquisition, land administration, land regulations, land registration, land tax framework, land finance, land price assessment, land rezoning, cadastral surveying, and property management [10]. Given the comprehensive and multifaceted land institution arrangement in Taiwan, its utilization as a comparative benchmark yields theoretical insights and practical policy cues for the reform of the land expropriation institution in the Chinese Mainland and even other developing countries in Asia. This approach seeks to address the rapid urbanization with a more sustainable approach to land expropriation.

2. Theoretical Analysis and Research Methods

The objective of this article is to study the land expropriation institutions in both the Chinese Mainland and Taiwan. The land expropriation institution serves as a typical political system. According to North in 1990, institutions are the rules of the game in a society, or formally, the rules developed by human beings to influence human interactions. By definition, institutions include formal rules (e.g., constitutions, laws, written regulations) and informal rules (codes of conduct, norms, and practices) [11]. Historical institutionalism, as one of the three major theoretical schools of new institutionalism, is renowned for its elucidation of differential political phenomena or outcomes by tracing the emergence, development, and impact of institutions. Over the course of approximately four decades, historical institutionalism has undergone substantial development and refinement to establish a systematic and mature analytical framework for institutional analysis.

2.1. The Main Viewpoints of Historical Institutionalism

Historical institutionalism became a research avenue initiated by Thelen and Steinmo’s research paper on comparative political activity [12]. These scholars contended that the analysis of institutions is about exploring the relationship between actors as historical objects and vehicles. While institutions wield the power to mold and confine political strategies, they emerge as conscious or unintentional results of political strategies, political conflicts, and choices [13]. In terms of research topics, historical institutionalism focuses on institutional dynamism and change, along with the interaction between ideal innovation and institutional limitations. Therefore, at its core, this research approach centers on institutional change and explores the causes and consequences of such change from a structural and historical perspective. Specifically, the main arguments of historical institutionalism can be summarized as follows:

First, historical institutionalism draws upon elements from both structural functionalism and behavioralism, offering a comprehensive perspective that acknowledges the influence of the institutional milieu at a structural level and considers the significance of actors. On one hand, from a structural perspective, historical institutionalism argues that any institution forges structural relationships and undergoes structural changes in interaction with a number of factors. These factors include basic institutional arrangements, such as politics, economics, and culture—comprising the specific environments confronting institutions in the process of development and change. Termed as institutional environments, their structural interactions with institutions contribute to the generation of institutions [14]. Therefore, a thorough examination of the macro-institutional landscape becomes necessary in the discourse on Cross-Strait land expropriation institutions. On the other hand, historical institutionalism posits that attention must also be accorded to actors. Instead of being purposeless executors of historical nullification, actors are dynamic individuals inspired by certain motives, values, and preferences [15]. In other words, the formation and change of institutions do not unfold in a unidirectional process dominated by “structure-environment”, but result from a bi-directional interaction between the institutional milieu and actors.

In addition, it is important to recognize that ideas are also a key element of historical institutionalism. Ideas serve as abstract representations of the material world in an individual’s cognition, encompassing practical experiences, value concepts, thoughts, and cognition, among other factors [16]. Despite the great importance of ideas, they remain inert on their own and require the agency of actors to shape policies and create institutions. Historical institutionalists introduced “ideas” into institutional analysis, arguing that ideas constitute the very heart of institutional change, and alterations in the ideas embraced by actors exert an influential impact on such change. Institutions are the vessels of ideas, and ideas can guide the behavioral patterns of individuals and collectives through the reconstruction or consolidation of their conceptions of self-interest and ultimately realize the synergistic evolution of “institutional milieu-actors-ideas”.

Second, from a historical perspective, historical institutionalists generally categorize the study of institutions into two main branches. One category is the study of path dependence, which mainly explores the matter of how institutions endure over time. The other is the analysis of critical juncture, which mainly deals with how institutions come into existence throughout history. The two types of analysis have their own strengths, but they complement each other and together constitute the dual sides of the historical institutionalism coin. The pioneer in the use of the concept of path dependence in political science was Krasner, who, in rational choice, explained how institutions are influenced by history. Krasner pointed out that the development of history embodies path dependence and regarded path dependence as the branching tree model of sequential development, in which the institutions forged in the past serve as constraining factors for present-day choices. The preferences of the actors are subject to the institutional structure and exert a palpable influence on the subsequent institutional changes and reconfigurations [17], due to the operation of an institutional increasing returns mechanism during the course of institutional change. As time elapses and political actors continue their engagement within the established system, the accrued benefits bestowed upon these actors by the system amplify. Consequently, the impediments associated with overhauling the entrenched system escalate in tandem. In contrast, the cumulative sunk costs linked to the system surge. As a result, the existing system engenders a robust impetus for survival, and the range of options for future institutional change has been limited and blocked in a specific path, making it difficult to retrace steps or undertake comprehensive system reconstruction until the emergence of the critical juncture [18].

Another concept that complements path dependence is punctuated equilibrium. Over the course of the long-term development of the institution, there arise critical junctures during which critical changes in the institution take place. These changes will give rise to a fresh equilibrium state. This newly established equilibrium is upheld by the institution for a certain duration. Subsequently, another critical juncture emerges, accompanied by a transformation that propels the institution into yet another phase of equilibrium. This cycle pattern endures in a similar manner. Each critical junction represents a strategic situation in which actors engage in complex political struggles, such as conflict and cooperation, which determines the direction of institutional change [19]. Worth noting is that during the period of stable equilibrium between the two critical junctures, the institution will feed back the operational principles into the cognitive patterns of the actors through the reproduction mechanism of self-reinforcing sequences [20]. This process facilitates the institution’s long-term sustainability. It is important to note that there are many possibilities for innovation, change, and renewal of institutions in terms of critical junctures, depending on the strength of path dependence and the size of historical turning points.

Finally, in terms of modes of institutional change, historical institutionalists have summarized several patterns, with a primary focus on gradual change: displacement, conversion, layering, and drift, each of which is briefly described below. Displacement is the replacement of well-established regulations with new rules. Displacement may not necessarily be an immediate, dramatic change but manifest as a gradual, unhurried process, especially when the introduction of a new institution directly challenges the role of the established institution. Conversion, on the other hand, signifies the continuation of an established institution infused with a new interpretation and implementation, which can also be perceived as the reinterpretation of an existing institution to fulfill a new purpose. Conversion occurs mainly as a result of the discrepancy between the institution and reality. Actors take advantage of the ambiguities within the rules to reapply the established institution to regulate the new reality. Layering is the process by which new formal rules are affixed to preexisting ones, thereby reshaping the normative function of the established rules. Established rules remain intact, but the gradual accumulation of new components may also fundamentally alter the system’s role. Drift takes place when the established institution persists, yet its role and normative capacity wane as the external environment changes. Drift occurs when actors fail to proactively uphold the institutional role in response to environmental changes [21]. With reference to the implications of these patterns of institutional change, their relative positions can be categorized along a spectrum that spans from “change” to “continuity” based on the extent of modifications applied to the established rules. This categorization is depicted in Figure 1.

2.2. The Applicability of Historical Institutionalism to Cross-Strait Land Expropriation Institutions

This article employs historical institutionalism as an analytical framework to examine the changes in the Cross-Strait land expropriation institutions, and this approach proves applicable in three ways. Firstly, historical institutionalism focuses on institutional change in the political sphere. It places central importance on the construction and enhancement of political institutions as the focal point of analysis. Considering that the land expropriation institution is a type of land institution, a political system with a very broad scope, the integration of historical institutionalism into the study of Cross-Strait land expropriation institutional changes is well-founded. Secondly, positioned as a middle-range theory, historical institutionalism centralizes its analysis on intermediate-level institutions. Its primary focus pertains to the interplay between institutional arrangements within the state and public policy, as well as the efficacy of intermediate-level institutional configurations [22]. The land expropriation institution, situated as an integral element within the broader Chinese institutional framework, profoundly shapes the behaviors and interests of multiple stakeholders, such as the central government, agricultural workers, and local governments. Therefore, the land expropriation institution qualifies as an intermediate-level institution under the macro-institution within the scope of historical institutionalism. Finally, the perspective on institutional change expressed in the theoretical elements of historical institutionalism, such as institutional milieu, actors, ideas, and critical junctures, is intrinsically compatible with the reality of change observed in the land expropriation institution. For instance, the Cross-Strait land expropriation institutions emerge within a specific external environment, operating under established institutional structures in the process of change and undergoing critical junctures of change in stages.

Having elucidated the applicability of historical institutionalism to the analysis of this topic, this paper constructs a theoretical framework to explain the change dynamics in the Cross-Strait land expropriation institutions based on its theoretical perspectives. This theoretical framework consists of three analytical orientations: macro-institutional milieu as the structural driving force of institutional formation, ideas as the mid-political variable, and actors as the subjects of institutional change, as shown in Figure 2.

2.3. Research Methods

To address the research questions of this article, a combination of qualitative research methods has been used, combining the comparison case method with in-depth interviews. The selection of qualitative research methods stems from the recognition that mainstream quantitative statistical methods are applicable to multiple cases (in an attempt to establish overarching principles that apply to a wide range of cases). Qualitative research methods take precedence when the sample size for comparison is limited because comparisons based on the focal theme can highlight the complexity and uniqueness of the cases [23]. At the same time, as Lijphart points out, the comparative method is a means of uncovering empirical relationships between variables, wherein an exhaustive comparative scrutiny of a small cohort of cases can yield more insightful results than a superficial statistical analysis conducted across numerous instances [24]. Having thus substantiated the adoption of qualitative research methods, the subsequent elucidation will delve into their practical application.

On the one hand, comparison stands as a foundational cognitive mode for the identification and analysis of issues, with controlled comparison at the bedrock of the social sciences. The comparison case method, however, confronts the task of analyzing and explaining a single case. This involves extracting select cases from complex environments, analyzing and comparing cases in relatively discrete contexts, and integrating various factors to explain these cases have become the main work of comparative case studies [25]. Amid the various comparative case studies, prominence is accorded to single-country case studies and cases involving two or more countries. With regards to the application of the comparative case study method, this paper undertakes a comparison between the land expropriation institutions in the Chinese Mainland and Taiwan. This comparison covers the contents and characteristics of the Cross-Strait land expropriation institutions in each period, as well as the key actors involved in the process of institutional change and the concepts they champion. The analysis will specifically focus on the contents and characteristics of the Cross-Strait land expropriation institutions during different periods, along with the primary actors and their associated concepts throughout the institutional change process. The objective is to present the similarities and differences in the directions and trajectories of change within the land expropriation institutions of these two regions. In the process of comparison case and analysis, the specific materials for analysis consist of regulations, documents, and expert interviews related to land expropriation institutions in the Chinese Mainland and Taiwan. In the context of the Chinese Mainland, pertinent materials include the Agrarian Reform Law of the People’s Republic of China, the Regulations on Land Requisition for National Construction, the Measures for Land Expropriation for National Construction, and the Land Administration Law of the People’s Republic of China. For Taiwan, the pertinent information includes documents such as the Land Law, the Equalization of Land Rights Act, the Land-to-the-Tiller Act, and the Land Expropriation Act.

On the other hand, the researcher employed the in-depth interview method to comprehensively gather information. Qualitative researchers commonly conduct research by interview method, engaging in thorough discussions with relevant people to obtain valuable information [26]. In-depth interviews are based on a quasi-structured or unstructured discussion led by the interviewer with open-ended questions and informal probing. Unlike large-scale social surveys, in-depth interviews extract and reinterpret information by allowing the respondent to express their statements to gain a profound understanding of their thoughts. In line with the requirements of this study, a comprehensive comprehension of the development of the Cross-Strait land expropriation institutions was imperative. Hence, the researcher conducted interviews with experts specializing in land institution studies and landless farmers, and social activists to obtain more comprehensive insights into institutional change. Specifically, the researcher interviewed a total of six professors engaged in the study of the land expropriation institution, six landless farmers, and two social activists, while the specific implementers of the Cross-Strait land expropriation process refused to be interviewed, making it impossible for the researcher to collect their voices. The professors and social activists used the same interview outline, which centered on the political and economic background of the change in the land expropriation institutions, the game of change, and the resistance of the landless farmers, while the landless farmers’ interviews focused on the land expropriation institutions, the land expropriation implementation process, and the level of satisfaction.

Regarding interviews, the researcher chose to conduct in-depth interviews with fourteen interviewees between February and April 2023. This process involved a combination of face-to-face and Internet phone calls to procure firsthand research materials. All interviews were conducted in Chinese, following the principle of anonymity, and the basic information of the interviewees is shown in

Table 1. Basic information of the fourteen interviewees.

Category	Number	Gender	Background	Number	Gender	Background
Professors	P1	Male	Professor, Beijing, Chinese Mainland	P4	Female	Associate Professor, Taiwan
	P2	Male	Professor, Jiangsu, Chinese Mainland	P5	Male	Professor, Taiwan
	P3	Female	Associate Professor, Chongqing, Chinese Mainland	P6	Male	Professor, Taiwan
Landless Farmers	F1	Male	Chongqing, Chinese Mainland	F4	Female	Hsinchu, Taiwan
	F2	Female	Chongqing, Chinese Mainland	F5	Female	Kaohsiung, Taiwan
	F3	Female	Jiangsu, Chinese Mainland	F6	Male	Taichung, Taiwan
Social Activists	S1	Male	Taipei, Taiwan	S2	Male	Kaohsiung, Taiwan

below. Interview durations ranged from 50 to 80 min per participant, with an average of about 65 min each, and the interview materials were organized into a transcript within 24 h of each interview. The researcher named these three categories by their initials, P1-6, F1-6, and S1-2, and then used content analysis to analyze the interview data.

The reasons for and criteria of selecting these three categories of individuals are as follows: (1) Professors were chosen because they could provide comprehensive insights into the finer details of this study. As experts in the field, they possess a deeper understanding of the historical context and political-economic background of the land expropriation institution’s evolution. The selection of these six professors was based on their prominence in the field of Cross-Strait land expropriation, evidenced by numerous highly-cited papers, with two of them having practical experience as advisers to local governments involved in land acquisition. It is important to note that the researcher contacted multiple professors, and ultimately, six agreed to be interviewed. (2) Landless farmers are the direct beneficiaries and affected parties in the land expropriation process. Their experiences, perspectives, and emotions can help us comprehend the disparities between the land expropriation institution and its implementation. Farmers may provide information regarding issues related to forced expropriation, compensation, resettlement, or unfair treatment, indirectly shedding light on one of the reasons behind the evolution of land expropriation. The selection of these six landless farmers was based on their direct involvement in contentious land expropriation events in the context of Cross-Strait disputes. (3) Social activists are typically active advocates and activists who are deeply involved in issues related to land expropriation. They have a keen understanding of the motivations, goals, and aspirations behind land protests, which can help explain why people engage in land expropriation protests and opposition activities, as well as the types of changes they are seeking. The selection of these two social activists was based on their respective participation in land protest movements in both southern and northern Taiwan, with one of them having been involved in the Da-Pu incident. It is important to emphasize that the researcher contacted eight social activists, but only two agreed to be interviewed.

3. Evolutionary Trajectory and Characteristics of the Cross-Strait Land Expropriation Institutions

The land expropriation institution encompasses a series of institutional structures concerning the non-agricultural use of land. It involves a range of various institutional elements, including the scope of land expropriation, land expropriation procedures, and safeguard mechanisms. Only by clarifying the specific changes and developmental stages of Cross-Strait land expropriation institutions, and by defining the changes in land expropriation scope, procedures, and compensation, can we summarize the characteristics of each stage and the overall direction of Cross-Strait land expropriation institutions from a historical development perspective. Therefore, in this section, drawing on the concept of “critical juncture” in historical institutionalism, the researcher uses significant historical events and landmark policy documents as critical junctures to explore the development trajectories of land expropriation institutions in Chinese Mainland and Taiwan separately. To achieve this goal, this section will be divided into three subsections for separate investigations. Firstly, the first subsection will delve into the historical development trajectory of land expropriation institutions in Chinese Mainland, which will help us understand the fundamental changes in land expropriation institutions in that region. Secondly, the second subsection will focus on the evolution of land expropriation institutions in Taiwan, allowing for comparisons and contrasts with the Chinese Mainland situation. Lastly, the third subsection will conduct a comparative analysis of the characteristics of land expropriation institutions at different stages on both sides of the Cross-Strait, thereby highlighting the commonalities and differences between these two regions. Through the analysis within these three subsections, a comprehensive understanding of the historical evolution of land expropriation institutions in Cross-Strait can be achieved, providing a solid foundation and context for the subsequent discussion on the logic of institutional change in Cross-Strait land expropriation. This is because, from the perspective of historical institutionalism, a systematic account of its historical development trajectory serves as a crucial prerequisite for revealing the underlying logic behind institutional change.

3.1. The Historical Development Trajectory of Land Expropriation Institutions in Chinese Mainland

This article divides the developmental history of Chinese Mainland land expropriation institutions into five stages: inception, exploration, development, stabilization, and innovation, using significant historical events and landmark policy documents as critical junctures.

In its inception stage (1950–1957), the institutional framework for land expropriation in Chinese Mainland emerged. A pivotal event during this period was the introduction of the Agrarian Reform Law of the People’s Republic of China on 30 June 1950. This marked the first instance where “land expropriation” was defined, along with the identification of the four circumstances for its implementation. Land expropriation activities during this period were primarily aimed at consolidating the newly established state power and realizing peasant land ownership. However, the institutional framework lacked details regarding the expropriation entities, procedures, compensation standards, and related elements [27]. To address these gaps, the Government Administration Council intervened by issuing the Regulations on Urban and Suburban Land Reform on 21 November 1950, which set out the principles of compensation for land expropriation, stipulating that privately owned agricultural land was expropriated by the State for urban development and other purposes, and appropriate resettlement and equitable compensation were to be provided to landless peasants. By 1953, the land reform in Chinese Mainland was essentially completed, followed by the formulation of its first relatively comprehensive land expropriation law, the Measures for Land Expropriation for National Construction (MLENC). This document precisely outlined the boundaries of land expropriation, the expropriation process, the authorizing bodies, and the compensation standards. It laid the foundational groundwork for the establishment of the Chinese Mainland land expropriation institutions. The institutional arrangements in the MLENC fully highlight the central role of farmers in land expropriation activities undertakings. They placed considerable emphasis on the rights of the expropriated farmers to participate in and supervise all aspects of land expropriation, fully respect the preferences of the farmers, and effectively safeguard the legitimate rights and interests of those subject to expropriation. A typical case is the expansion of the East China Textile Engineering College in Shanghai. In November 1952, in order to expand its campus, the East China Textile Institute expropriated 6.93 hectares of land in Hejiajiao Township, Xinjing District, of which 3.426 hectares were privately owned by peasants, involving ninety-four families. The land acquisition working group fully emphasized the importance of farmers in the process of land acquisition, held many meetings for the expropriated farmers to express their opinions spontaneously, and satisfied the farmers’ demands to the maximum extent. In the end, fifty-eight households were paid compensation only, twenty-five households were taken care of for work, six households were redeployed for land, and five households were taken care of in cash [28].

The exploration stage of Chinese Mainland land expropriation institutions (1958–1981) was marked by significant transformations in the socio-economic landscape. By the close of 1956, the comprehensive socialist transformation of agriculture, handicrafts, and capitalist industry and commerce in the region had been accomplished. While rural areas had witnessed substantial progress in the establishment of agricultural cooperatives, ushering in a shift from individual land ownership to collective land ownership among peasants [29]. Changes in the institutional milieu have led to corresponding adjustments in the land expropriation institutions, as evidenced by changes in the agricultural land titling system. In 1958, a notable milestone in this stage was the official revision of the MLENC. The revised version generally adhered to the institutional framework of the creation stage. However, noteworthy adjustments were introduced regarding the expropriating entities, compensation for expropriation, resettlement methods, and approval authority. For instance, the expropriated individuals shifted from farmers to collective organizations (cooperatives or people’s communes), and the resettlement method was refined from agricultural resettlement or job transfer to local agricultural resettlement. However, the change in the subject of expropriation also introduced new conflicts of interest. For example, in the case of expropriation in Hengshui City, Hebei Province, there was a dispute over whether compensation for arable land should be initially distributed within the villagers’ group based on the principle of member-sharing, and then re-adjusted and redistributed to the existing collective arable land, or whether it should be directly distributed based on the actual area of land expropriated [30]. This disagreement has resulted in conflicts over the distribution of interests.

The development phase of the Chinese Mainland land expropriation institutions (1982–1997) unfolded against the backdrop of pivotal shifts catalyzed by the “Reform and Opening Up” initiatives introduced during the Third Plenary Session of the Eleventh Central Committee of the Communist Party of China in 1978. This period witnessed a progressive alignment of social and economic development with a heightened demand for land for various construction projects. The original framework, embodied by the Measures for Land Expropriation for National Construction (MLENC), found itself unable to adapt to the evolving social landscape. Against this background, the State Council promulgated in May 1982 the Regulations on Land Requisition for National Construction (RLRNC). Amidst the intensifying conflicts arising from land usage, the RLRNC expanded the scope of land requisition to include economic, cultural, and national defence construction, as well as the establishment of social and public utilities, and added a compulsory provision on the procedure of land requisition. For instance, the cadres and people of the requisitioned community shall obey the needs of the state, and shall not impede or obstruct the construction of the requisitioned land. The RLRNC has also made adjustments to the guarantee mechanism, namely, the standard land compensation fee of three to six times the average annual output value of the three years preceding the expropriation, the standard resettlement subsidy of two to three times the annual output value of each mu of land, and the resettlement of the remaining labor force. Thus, RLRNC’s construction of the principle of expropriation, compensation standards, resettlement methods, expropriation procedures, and other institutional elements still indicates notable advancements in Chinese Mainland expropriation institutions. In 1986, this progress culminated with the formal promulgation of the Land Administration Law of the People’s Republic of China by the Standing Committee of the National People’s Congress. This landmark legislation further clarified on the basis of jurisprudence that the land use unit retains the right to utilize the expropriated land while the ownership is vested in the state.

The period of stabilization of the land expropriation institutions in the Chinese Mainland (1998–2014) witnessed significant developments. As China’s reform and opening-up gathered momentum and the market economy took root, escalating demand for construction land led to a worrisome decline in arable land [31]. To further fortify land administration and safeguard arable resources, the Standing Committee of the National People’s Congress revised the Land Administration Law in 1998. The amendments laid down a resilient framework for the land expropriation institutions. Regarding authorization, the responsibility for approving the expropriation of agricultural land in the Chinese Mainland shifted to the State Council, which has clarified the legal consequences for unlawful expropriation. In terms of land expropriation procedures, the government formulates compensation and resettlement plans, subsequently seeking feedback from the affected landowners. Safeguard mechanisms have been implemented as well. Based on the original usage, the compensation rate for expropriated land is set at 6–10 times the average value of the land’s first three years. Provisions have been established, including a resettlement approach for surplus labor force from enterprises. Concurrently, this revision introduces a land use control system and a land use planning system. In 2010, the Ministry of Land and Resources issued the Notice on Further Improving Land Expropriation Management Work (NFILEMW). This NFILEMW, for the first time, incorporated a unified annual value and comprehensive land price per area into the expropriation compensation standard, ensuring consistent compensation rates for the same location. At the same time, a dynamic adjustment mechanism for land expropriation compensation standards and an advance deposit system for compensation payments were introduced, guaranteeing prompt and full compensation payments to farmers whose land was expropriated. However, compensation alone is not sufficient; the livelihoods of land expropriatees are also crucial. As stated by interviewee F2, “although we, the expropriated people, have received one-time compensation from the government, we generally have lower educational qualifications and reduced competitiveness in the job market. Consequently, most of the jobs we find after losing our land are in the manufacturing or service industries, typically with lower wages. We strongly hope that the government will provide us with employment guidance and training”.

The innovation phase of the Chinese Mainland land expropriation institutions (2015–present) emerged against the backdrop of rapid economic and real estate development during the first decade of the 21st century. The substantial demand for land for construction, driven by rapid urbanization, ignited a series of conflicts over land expropriation, which directly impacted the stability and sustainable development of rural society [32]. For example, some farmers, considering only their own interests, make exorbitant demands without regard for the broader perspective, which poses challenges to the government’s land acquisition efforts and exacerbates conflicts between the two parties. According to interviewee F3, “in a village in a certain county of Jiangsu Province, as the industrial cluster area gradually took shape, some farmers, in order to obtain higher compensation, have illegally erected plastic greenhouses on agricultural land, while others have haphazardly expanded the compensation area on the rooftops of their houses, demanding compensation multiples of the original amount from the government”. The Opinions on Pilot Work for Rural Land Expropriation, Collective Operated Construction Land Market Entry, and Homestead Institution Reform was introduced in 2015, marking a new phase of pilot efforts to reform land expropriation institutions. From 2015 to 2019, the No. 1 central document was issued annually for five consecutive years, outlining the reform of the land expropriation institutions. In August 2019, the newly revised Land Administration Law elevated the reform experience to a legal level. It narrowed the scope of land expropriation to six cases, including military and diplomatic affairs, government-organized infrastructure construction, government-organized public utilities, government-organized poverty alleviation, relocation with guaranteed resettlement, and piecemeal development and construction. This move largely eliminated the ambiguity of public interest, providing much-needed clarity. In terms of land expropriation procedures, the post-land expropriation announcement has been changed to a pre-land expropriation announcement, accompanied by arrangements for consultation and consideration of opinions from the landowners being expropriated. The provision regarding the determination of the compensation standard for the original use has been abolished, and the compensation standard is now determined based on the comprehensive land value of the area, incorporating elements of residential compensation and social security. To enhance the presentation of this information, a concise overview of amendments to the Land Administration Law is presented as

Table 2. Comparison of land expropriation after the Amendment to the Land Administration Law.

	Land Administration Law	Amendment to Land Administration Law (2019)
land expropriation procedure	The post-land expropriation announcement	pre-land expropriation announcement, arrangements for consultation and consideration of opinions from the landowners being expropriated
land expropriation compensation	Determine compensation standards based on the original purpose of use	Abolish the provision of determining compensation standards based on the original purpose of use, establish compensation standards based on “comprehensive land prices by district”
land expropriation scope	Broad in scope, characterized by ambiguity	Emphasizing public interest, narrowing the scope to: military and diplomatic affairs, government-organized infrastructure construction, government-organized public utilities, government-organized poverty alleviation, relocation with guaranteed resettlement, and piecemeal development and construction

below.

3.2. The Evolution of Land Expropriation Institutions in Taiwan

This article divides the developmental history of Taiwan’s land expropriation institutions into five stages: inception, transition, development, stabilization, and refinement, using significant historical events and landmark policy documents as critical junctures.

The inception stage of Taiwan’s land expropriation institutions (1946–1953): During the formative years, the implementation of land expropriation in Taiwan unfolded in tandem with the land reform from 1949 to 1953, and the foundations of these institutions were etched into documents such as the Land Law and the Land-to-the-Tiller Act.

The National Government of Nanjing orchestrated the promulgation and enforcement of the Land Law and the Land Law Enforcement Law in 1946 to promote land reform and land expropriation. After the Civil War in 1949, the KMT retreated to Taiwan, ushering in an era marked by extensive land reform initiatives orchestrated by the KMT authorities. This included measures such as rent reduction, public land reclamation, and equitable distribution of land ownership to tillers [33]. Among them, the Land-to-the-Tiller Act was officially embraced by Taiwan in January 1953, which mandated that on the basis of the ownership relationship of the existing lease, the landlord can only retain the paddy fields 3 Jia or the dry fields 6 Jia (1 Jia is equal to 0.9699 hectares), and the rest is handed over by the authorities to the tenant farmers for rent cultivation by means of expropriation compensation. In the scope of expropriation, landlords were exempted from cultivated land, but were required to relinquish any surplus leased cultivated land. Additionally, landlords were compelled to cede the infrastructure such as premises, grain yards, fruit trees, bamboo groves, and other structures for the benefit of tenant farmers, which were then redistributed among the current cultivating peasants. Regarding compensation, landlords were entitled to 70% of their compensation in the form of land bonds issued by the authorities, payable over a decade with an annual interest rate of 4%. The remaining 30% was allocated as shares in public utilities. The landmark implementation of the Land-to-the-Tiller Act policy in 1953 heralded a monumental juncture in Taiwan’s land expropriation history, with the acquisition of nearly 140,000 hectares of farmland by the Taiwan authorities in that year [34].

The transition phase of Taiwan’s land expropriation institutions (1954–1976): On 26 August 1954, the Taiwan Legislative Yuan announced the Implementation Rules for Urban Average Land Right (IRUALR), which, in conjunction with the revised 1946 Land Law, established Taiwan’s inaugural framework for land expropriation compensation regulations. On 19 January 1956, the Taiwan Provincial Government issued a significant edict—the Implementation Rules for the Urban Average Land Right Implementation Ordinance in Taiwan Province, which mandated the completion of status declaration work before the end of June 1956. On August 1, the imposition of land value tax, and then on September 1, the enforcement of land price tax, ushered in a new era of land valuation regulations in urban areas of Taiwan. Throughout this process, the Taiwan authorities encountered hurdles in the implementation of the initially proposed regulations, as well as the practice of expropriating land based on self-reported land values by landowners. For instance, acquiring land at inflated prices strained the financial resources of local governments, whereas acquiring land at lower prices often gave rise to property disputes or underutilization, creating additional challenges after expropriation. A typical case is that the Taiwan authorities, in order to promote industrialization and urbanization, constructed a coastal industrial zone on the southwestern coast of Kaohsiung and expropriated thousands of hectares of agricultural land in Dalinpo and Fengbutou at a lower price, and there were incidents of land resistance by farmers [35]. Therefore, a total of three revisions were undertaken between 1956 and 1968 to refine these regulations. By 1964, the land value declaration rate across Taiwan had surged to 97.06%, with one-third of regions reaching 100%. Real-time land values were publicly disclosed, serving as a reference for land expropriation. This development marked a significant step toward streamlining the overall procedure during this period.

The developmental innovation phase of Taiwan’s land expropriation institutions (1977–1998): In January 1977, driven by KMT authorities, the Legislative Yuan of Taiwan amended the IRUALR to be the Equalization of Land Rights Act (ELRA). The ELRA introduced eight key modifications from the original IRUALR. In the domain of land expropriation, certain amendments were made to achieve optimal land utilization. Specifically, regulations were set to restrict the use of vacant land and to enhance the processes of Land readjustment and zone expropriation 3. Section-based expropriation, according to Taiwan’s Land Law, involves the complete expropriation and reorganization of all land within a specified area, transitioning land ownership from public to private hands. This method aims to ensure rational land use across the entire region, mitigate the formation of land monopolies, and promote policy-oriented expropriation. Section-based expropriation falls under the category of policy-driven expropriation, where government authorities intervene to regulate land privatization rights, plan and coordinate privately owned land, and ensure rational utilization of private land. Simultaneously, in a bid to minimize resistance against expropriation based on market value and safeguard the interests of those subject to expropriation, compensation mechanisms shifted from landowners self-reporting land values to government-prepared estimates of land valuations. Additionally, noteworthy enhancements were made in cash compensation and a corresponding reduction in the ratio of compensation bonds, as compared to the previous stage. However, under the Average Land Right Ordinance, there existed other relevant regulations, such as urban planning laws, construction codes, national housing ordinances, and tourism development ordinances. These varying regulations introduced complexities in the execution process. Furthermore, divergent protocols for land expropriation procedures and compensation criteria frequently gave rise to conflicts during the expropriation proceedings. As interviewee F4 said, “according to the relevant agreement on land expropriation at that time, my family had experienced two land expropriations, the first of which took place at the end of the last century, when Taiwan, as one of the Four Asian Tigers, was developing very quickly, but at that time, the Hsinchu government’s expropriation process was in a mess, and it seemed that there was not a unified implementation plan, and that the amount of compensation was not too much”.

The stabilization phase of Taiwan’s land expropriation institutions (1999–2011): With the rapid urbanization process, the ELRA found itself increasingly unable to adequately balance the interests of both expropriators and the expropriated, as evidenced by the frequent disputes during land expropriation in Taiwan. In response to the grievances of farmers who had lost their land, Taiwan authorities pushed for the establishment of the Land Expropriation Act in 1999. This act aimed to harmonize the disparate land expropriation regulations, streamline expropriation procedures, standardize compensation criteria, and formulate a specialized law for land expropriation (Land Expropriation Act). With its official enactment on 2 February 2000, the Land Expropriation Act was officially brought into effect, explicitly its supremacy in cases where variances exist between other laws and this act with regard to expropriation procedures or compensation standards. Furthermore, the act classifies land expropriation based on the nature of the undertaken project, spatial scope, and required land-use duration. It is structured into two main categories: general-purpose land expropriation (referred to as General Expropriation) and special-purpose land expropriation. The former applies to individual instances where the state requires expropriation for public projects or when government agencies must individually expropriate private land for the implementation to implement national economic policies. The latter includes zone expropriation, associated expropriation, and reserved expropriation, constituting a broader concept of land expropriation. In this regard, “interviewee S2 mentioned that the frequent land protests around 2010 were a result of the fact that although zone expropriation can be an option to receive land in lieu of monetary compensation, allowing the original landowner to participate in the overall development of the land and enjoy the benefits of increased land value, improved public facilities, and a better quality home environment after development. However, according to the Land Expropriation Act, the local government can carry out zone expropriation as long as it deems it necessary, which is a compulsory expropriation, and it inevitably leads to public protests”.

The refinement phase of Taiwan’s land expropriation institutions (2012–present): In 2001, the Miaoli County government in Taiwan applied for a new urban plan to embark on an urbanization initiative. Within this plan, the total area of the Zhunan Keda Pu urban planning zone covered a total expanse of 154 hectares, out of which approximately 136 hectares were designated for development through the zone expropriation approach. This affected the lives of nearly a thousand landowners, among whom a remarkable 98% sought compensation through alternative land acquisition channels. However, the land expropriation process in 2010 was marred by forced demolitions that sparked strong public resistance. Confronted with this widespread outcry, Taiwan authorities undertook a period of contemplation and introspection. As a result, in 2011, amendments to specific provisions of the Land Expropriation Act were drafted. These amendments were officially promulgated and effectuated in 2012, and the act has since remained unchanged. Central to this amendment was a shift in the compensation standard for expropriated land. The previous method, which announced the land’s current value and added 40%, gave way to a new framework based on market value. Additionally, the expropriating party was now required to provide reasons for the public interest and present a resettlement plan for the expropriated individuals. Furthermore, to further safeguard the rights of the expropriated, the amendment stipulated that those receiving cash compensation for zone expropriation could exercise the option of receiving alternative land instead. As a result, the amendment to the Land Expropriation Act not only addressed the expectations of various sectors of Taiwan society for land expropriation institutions reform, but also aimed to reshape forthcoming land expropriation in closer alignment with the principles of public interest and necessity.

In a broader context, Taiwan’s current land expropriation institutions can be categorized into two types: general expropriation and zone expropriation. The concept of general expropriation pertains to instances where government authorities expropriate private land and above-ground structures for specific project purposes. In these cases, the compensation offered is exclusively in the form of monetary payment. On the other hand, zone expropriation comes into play when there is a requirement to establish or expand urban plans. This often involves large-scale expropriation covering entire areas. Following the process of reorganization and planning, a certain portion of the land is made available for expropriated individuals, who are then given the choice between cash compensation or alternative land. The preceding analysis has examined the historical development of Cross-Strait land expropriation institutions. To enhance the presentation of this information, a concise overview of the relevant regulations of Cross-Strait land expropriation institutions is presented as

Table 3. Comparison of the main regulations of the Cross-Strait land expropriation institutions.

Phase	Documents Related to Chinese Mainland Land Expropriation Institutions
Initial phase (1950–1957)	In 30 June 1950, the Agrarian Reform Law of the People’s Republic of China was promulgated. In 21 November 1950, the Regulations on Urban and Suburban Land Reform were promulgated. In 1953, the Measures for Land Expropriation for National Construction were promulgated.
Exploratory phase (1958–1981)	In 1958, the Measures for Land Expropriation for National Construction were revised.
Development phase (1982–1997)	In 1982, the Regulations on Land Requisition for National Construction were promulgated. In 1986, the Land Administration Law of the People’s Republic of China was officially promulgated and implemented.
Stabilization phase (1998–2014)	In 1998, the Land Administration Law was amended. In 2010, the Notice on Further Improving Land Expropriation Management Work was issued.
Innovation phase (2015-present)	In 2015, the Opinions on Pilot Work for Rural Land Expropriation, Collective Operated Construction Land Market Entry, and Homestead Institution Reform was introduced. In August 2019, the Land Administration Law was revised.
Phase	Documents Related to Taiwan’s Land Expropriation Institutions
Initial phase (1946–1953)	In 1946, the Land Law and the Implementation Law of the Land Law were enacted and implemented. In January 1953, the Land-to-the-Tiller Act was officially passed.
Transition phase (1954–1976)	In 1954, the Implementation Rules for Urban Average Land Right were promulgated.
Developmental innovation phase (1977–1998)	In 1977, the Equalization of Land Rights Act was revised from the Implementation Rules for Urban Average Land Right.
Stabilization phase (1999–2011)	In 2 February 2000, the Land Expropriation Act was officially implemented.
Refinement phase (2012–present)	In 2012, the Land Expropriation Act was revised.

below.

3.3. Comparative Analysis of the Characteristics of Land Expropriation Institutions at Various Stages of Cross-Strait

The preceding analysis has provided a comprehensive examination of the development of Cross-Strait land expropriation institutions. This section proceeds with a comparison of the characteristics of land expropriation institutions across different developmental stages.

Firstly, a comparative analysis of the characteristics of the initial stage of Cross-Strait land expropriation institutions: During the initial phase of the Chinese Mainland’s land expropriation institutions, authorities in the Chinese Mainland explored an array of constituent elements within the land expropriation system, considering a dual perspective of domestic and international situations. The primary objective was to forge a bedrock of institutional safeguards for advancing national economic development and ensuring the underpinning bedrock of political stability. This initial phase of the land expropriation institutions exhibits three fundamental characteristics. (1) In terms of the scope and objectives of land expropriation, it is inherently aligned with the principles of the public interest, primarily aimed at advancing the collective welfare and fostering rapid national development. (2) With regard to safeguard mechanisms, it establishes compensation standards based on the original land use. Land owned by landlords and industrial and commercial proprietors was subject to mandatory uncompensated expropriation, whereas privately owned land of individual farmers subject to expropriation received fair and reasonable compensation. This approach facilitated the implementation of various resettlement methods, including agricultural and vocational resettlement. During this phase, the central government aimed to minimize the compulsory nature of land expropriation, emphasizing its “negotiability” and recognizing the “importance” of farmers. (3) Owing to the relatively early stage of development of the Communist Party’s political authority during this phase, the approval authority for agricultural land expropriation remained notably decentralized to the county-level governments. Consequently, the approval process for agricultural land expropriation retained a relatively lenient disposition.

Comparatively, the initial stage of land expropriation institutions in Taiwan differed from the characteristics of their mainland counterpart. (1) Land expropriation institutions in Taiwan assumed the role as essential means and tools for the KMT to implement its land policies. This strategic emphasis was driven by the KMT’s imperative to not only enact land reform and expropriation in alignment with Sun Yat-sen’s Three Principles of the People, but also to consolidate their political foothold on the island. In terms of the scope and objectives of land expropriation, the KMT authorities in Taiwan were chiefly oriented towards their political survival and influence. (2) In terms of compensation mechanisms for land expropriation, Taiwan diverged from the Chinese Mainland by retaining a more substantial “compulsory” element within its expropriation framework. It did not resort to uncompensated expropriation of landlord-owned land. Instead, Taiwan accommodated landlord interests by providing compensation to landlords in the form of physical land bonds and ownership shares in state-owned enterprises. (3) With regards to the procedural implementation of land expropriation, Taiwan opted for a comparably moderate and peaceful approach in contrast to the more forceful methods observed on Chinese Mainland, with a blend of administrative and economic methods to foster a conducive environment for farmers’ land acquisition while affording landlords opportunities for benefit.

Secondly, the comparative analysis of the transitional characteristics of the Cross-Strait land expropriation institutions: During the transitional phase of the Chinese Mainland land expropriation institutions, three fundamental characteristics were similarly unveiled. (1) The predominant position of farmers in land expropriation diminished, leading to a near-complete loss of influence. Those subject to expropriation shifted from being primarily farmers to part of collective organizations, which then became the recipients of compensation. (2) Compensation mainly took the form of land compensation, accompanied by a decline in compensation standards. Simultaneously, there emerged a more standardized resettlement method that primarily focuses on local agricultural resettlement. (3) The central government undertook a dual approach, whereby it delegated its original approval authority to provincial-level governments while consolidating the approval authority at the provincial level by withdrawing it from county-level governments. This consolidation centralized the approval power for land expropriation at the provincial administrative level.

During the transitional phase of the land expropriation institutions in Taiwan, four distinct characteristics were evident. (1) The practical inadequacy of relevant land expropriation regulations posed challenges in simultaneously balancing the public interests and the rights of those subject to expropriation. Frequent amendments were necessary to address this imbalance and ensure equitable outcomes. (2) Emphasis was placed on the primary position of those being expropriated. This was manifested through the implementation of a pre-expropriation declaration of land value by the expropriated parties themselves. The real-time price of land was clarified, highlighting the objective neutrality of the expropriation process. (3) Land expropriation institutions remained the substantive means and tools for the KMT to implement land policies. Fourthly, during this period, the scope of land expropriation was extensive, accompanied by simplified procedures and relatively low compensation for land expropriation.

Thirdly, a comparative analysis of the characteristics of the developmental stages of Cross-Strait land expropriation institutions reveals the following features. The developmental phase of the Chinese Mainland land expropriation institutions can be broadly observed in four key aspects: (1) The scope of expropriation expanded, accompanied by a relative increase in ambiguity concerning expropriation criteria and public interest aspects compared to the preceding phase. (2) In terms of safeguard mechanisms for expropriation, compensation standards were elevated, and with and a greater variety of resettlement methods. (3) The compulsion within the expropriation procedures was heightened, wherein regulations stipulated that those subjected to expropriation should willingly adhere to the nation’s land requirements for construction, refraining from causing obstruction or hindrance. (4) The process of legal institutionalization deepened as the developmental phase of the Chinese Mainland land expropriation institutions progressed from regulations and measures to the stage of laws.

In contrast, the developmental innovation phase of Taiwan’s land expropriation institutions exhibits distinct characteristics in comparison to the land expropriation institutions in the Chinese Mainland. (1) During this innovative development phase, emphasis was placed on land management and utilization efficiency. Measures were implemented to restrict vacant land use, and the pioneering zone expropriation mechanism effectively reduced the potential landlord resistance during the expropriation process. (2) Notable improvements were made in the safeguards within the expropriation mechanisms, with careful consideration of the rights of those being expropriated. This includes a significant increase in cash compensation and a reduction in the compensation ratio through bonds.

Fourth, the stable phase characteristics comparison of Chinese Mainland land expropriation institutions: In terms of the scope of land expropriation, this phase exhibited a broader scope compared to the developmental stage, signifying a shift from the gradual fading of the public interest to arrangements that seriously compromised the very principle of public interest as a basis for expropriation. Regarding the procedures for land expropriation, the level of compulsion was further intensified, leading to a near-complete diminishment of the primary status of those being expropriated. In relation to compensation for land expropriation, there was an increase in compensation standards, coupled with a reduction in measures such as job placements and household transfers and an enhancement of social security provisions.

Compared to the developmental innovation phase of Taiwan’s land expropriation institutions, the transition into the stable phase of this system reveals minimal changes in the characteristics of land expropriation purposes and scope. Instead, there is an increase in the level of legal formalization, achieved through the integration of various expropriation regulations under the Land Expropriation Act as the overarching law. This results in the establishment of a unified land expropriation procedure, further safeguarding the primary status of the expropriated parties.

Finally, the innovation phase of the Chinese Mainland land expropriation institutions has demonstrated the following characteristics. (1) In terms of the expropriation process, in contrast to the previous period where the displaced farmers nearly relinquished their primary position, this phase of the land expropriation institutions has reintroduced an emphasis on the primary status of displaced farmers. This is manifested in the mandate to fully consider farmers’ opinions prior to land approval and the streamlining of expropriation procedures post-land approval, aiming to alleviate the burdens on farmers. (2) Regarding the scope of expropriation, the land area subject to expropriation has been curtailed. (3) The compensation mechanism has been optimized, eschewing the previous provision tying compensation standards to the original land use. Instead, compensation standards are ascertained based on the comprehensive land price of the area, with additional provisions related to residential compensation and social security.

The refinement phase of Taiwan’s land expropriation institutions can be delineated by three core characteristics. (1) The land expropriation procedures have gained greater standardization and stringency, including the preliminary procedures for land expropriation (mandatory public hearings and the statutory precedence of negotiated prices), implementation procedures (application, review, and execution), and oversight procedures (remedies and supervision). (2) In terms of land compensation, the principles and standards have been clarified and enhanced, accompanied by a diversification of compensation methods. For instance, beneficiaries of cash compensation due to zone expropriation can opt for compensatory land, thus mitigating conflicts and rent-seeking tendencies in the compensation process. (3) Land expropriation must prioritize public interest and necessity, leading to a substantial contraction of the expropriation scope. To vividly illustrate the changes and differences in the characteristics of Cross-Strait land expropriation institutions,

Table 4. Comparison of the characteristics of the Cross-Strait land expropriation institutions.

Phase	Characteristics of Chinese Mainland Land Expropriation Institutions
Initial phase (1950–1957)	The scope and objectives of land expropriation generally aligned with the public interest. The compulsion of land expropriation was weakened, and the negotiation aspect was emphasized while highlighting the significance of farmers.
Exploratory phase (1958–1981)	The dominant position of farmers disappeared. Mainly adopting land compensation, with relatively standardized resettlement methods. Centralization of approval authority to provincial governments.
Development phase (1982–1997)	The expropriation scope became broader. Compensation standards were raised. The compulsion of the expropriation process increased.
Stabilization phase (1998–2014)	The scope of land expropriation became even broader. Compulsory measures were further intensified. Compensation standards had been somewhat raised.
Innovation phase (2015–present)	Emphasizing the primary status of the farmers whose land is expropriated. Reducing the expanse of land expropriation.
Phase	Characteristics of Taiwan’s Land Expropriation Institutions
Initial phase (1946–1953)	The politicization of the land expropriation institutions was evident. The methods of expropriation were relatively peaceful. The compensation mechanism took into account the interests of landowners.
Transition phase (1954–1976)	Emphasizing the primary position of the expropriated parties, but facing challenges in balancing the interests of both public welfare and the expropriated individuals. Wide expanse of expropriation scope, simplified procedures, and relatively low compensation for land expropriation.
Developmental innovation phase (1977–1998)	Pioneering zone expropriation mechanism. Improvement in expropriation safeguard mechanisms.
Stabilization phase (1999–2011)	Further ensured the primary status of the expropriated parties. Enhanced the degree of legalization. Specified the expropriation procedures.
Refinement phase (2012–present)	The expropriation procedures are more standardized and stringent. The compensation principles and standards have been improved. The scope of expropriation has significantly narrowed down, emphasizing the public interest and necessity of expropriation.

is prepared for reference.

In general, land expropriation institutions in Chinese Mainland and Taiwan can be categorized into five stages of development. Regarding changes in land expropriation institutions in Chinese Mainland, the status of peasants in land expropriation activities has undergone the developmental trajectory of “establishment of an important position→loss of the right to speak→return to an important position”, and the scope of land expropriation has followed a developmental path from “broad→broader→narrower”. The compensation standards have continuously improved, and the compensation schemes have gradually diversified. In Taiwan’s land expropriation institutions, the status of the expropriated has become increasingly consolidated. The scope of expropriation has also followed a developmental process of “broad→broader→narrower”, with expropriation procedures gradually standardizing and compensation standards continually upgrading.

4. The Triple Logic of Change Types, Change Paths, and Change Processes in Cross-Strait Land Expropriation Institutions

After analyzing the developmental history of land expropriation institutions in Cross-Strait, it was found that the overall process consists of three recurring phases: institutional generation, institutional continuity, and institutional change. Behind these phases lie the stabilizing mechanistic and regular logical factors, which are the key to explaining the logic of institutional change. Therefore, in this context, the analysis of the logic of land expropriation institutional change can be approached from three aspects: types of change, change paths, and change processes. To achieve this goal, this section will be divided into three subsections. Firstly, since different types of change govern the evolutionary directions of land expropriation institutions on both sides at various development stages, the first subsection will delve into the types of institutional change in land expropriation institutions in Cross-Strait, utilizing concepts from historical institutionalism such as critical junctures, induced factors, and compelling agents. Secondly, the second subsection will focus on discussing the change paths of land expropriation institutions in Cross-Strait. This will aid in understanding the degree of upheaval and relevant patterns during the change process. Lastly, the third subsection will employ the concept of path dependence to elucidate the strong historical inertia in the process of institutional change. Through the analysis of these three aspects: change types, change paths, and change processes, a comprehensive understanding of the logic of land expropriation institutional change in Cross-Strait can be attained.

4.1. Cross-Strait Land Institutional Change Typologies: Critical Junctures, Induced Factors, and Compulsory Changes

Different types of institutional change reflect different social, political, and economic factors at the time of Cross-Strait, and critical junctures, induced factors, and compulsory subjects of change by means of historical institutionalism not only help to understand in depth the evolution and motivation of land expropriation institutions, but also provide important references to the subsequent institutional development, reform, and social participation.

Different types of changes have exerted their dominance over the evolution of Cross-Strait land expropriation institutions at different developmental stages. Based on the previous analysis, the initial and exploratory stages of Chinese Mainland land expropriation institutions unfolded in the political and economic contexts framed by the burgeoning CPC regime and the planned economy. These two periods (1950–1981) were characterized by strategic imperatives aimed at consolidating authority and safeguarding the fruits of the revolution. This era witnessed the implementation of a series of regulations by the CPC to strengthen the power of the party and maintain a seamless integration of party and governmental functions; the Communist Party of China (CPC) Central Committee became the body in charge of all affairs, with the State Council assuming the role of executing the directives set forth by the CPC Central Committee. Therefore, the land expropriation institutions in the initial and exploratory stage essentially materialized the CPC’s will in the institutional field, and the corresponding institutional change was a compulsory response, directly orchestrated by the resolute mandate of the CPC Central Committee.

The year 1978 marked a critical juncture in the transformation of land expropriation institutions in the Chinese Mainland. It was during this year that Deng Xiaoping propelled the CPC and the Chinese Mainland towards a momentous historical shift with far-reaching significance. This juncture also emerged as a significant period for the transformation of land expropriation institutions. In Fengyang’s Xiaogang Village, Anhui Province, a groundbreaking initiative was undertaken by 18 farmers. They embarked on the implementation of the household contract responsibility system, thereby reclaiming a portion of the property rights of rural land. This transformative act substantially altered the production relations of the rural society, rendering the existing farmland expropriation mechanisms inadequate for the evolving rural land tenure relationships [36]. In order to adapt to this change, the CPC, with Deng Xiaoping as its core, restructured the land expropriation institutions. This marked the onset of the developmental phase for these institutions. It is noteworthy that during the developmental stage (1982–1997), the backdrop of a planned economy persisted and the central government continued to play a dominant role in the construction of the institutions, but the difference arose due to the fact that farmers have acquired partial property rights to rural land. This endowed them with an increasingly awakened awareness of their land rights. When farmers perceive encroachments upon their land rights and interests, it often leads to instances of land disputes and resistance, which makes the landless peasants gradually become a causative factor driving institutional change. Within this context, alterations to land expropriation institutions in the development stage are the product of the nesting of compulsory change and induced factors.

The stabilization and innovation phases of land expropriation institutions in Chinese Mainland: “Interviewee P1 noted that in the late 1990s and early 2000s, the process of urbanization in the Chinese Mainland led to an expanding scope of land expropriation. Displaced farmers, in response, began to make use various non-institutionalized methods to assert their interests. They sought to bypass the grass-roots government by means of land struggles and directly inputting their demands into the political system. Their goal was to exert pressure on the central government to improve the land expropriation institutions in a top-down way, thus realizing institutional export and pressure relief.” As a result of these efforts, the central government was compelled to improve the institution of land expropriation, thus realizing institutional output and pressure relief. “Interviewee P2 said that the struggle of landless farmers constitutes merely one aspect of systemic change. He mentioned that local governments in some economically developed regions had drew inspiration from the experiences of Taiwan, Europe, and the United States. They embarked on a journey of innovation and crafted a series of beneficial institutional systems in the practice of land expropriation. These pioneering models gradually diffused to the national level. These innovations have ultimately become useful supplements to the established Chinese Mainland land expropriation institutions. Notable illustrations include the ‘Nanhai model’ characterized by dividend-sharing in Guangdong Province, and the ‘land for social security’ approach observed in Jiaxing, Zhejiang Province.” Therefore, the change of the land expropriation institutions in the stage of stabilization and innovation can be understood as a “product” stemming from the intricate interplay between landless peasants, who serve as a catalytic force for change and certain local governments and the central government, which assume pivotal roles as actors driving compulsory change.

In contrast to Chinese Mainland, Taiwan’s land expropriation institutions, regardless of the time period, adhere to a blend of compulsory and induced changes. However, notable differences arise in terms of the induced factors between the initial exploratory and developmental innovative stages from 1946 to 1998 and the stable and refined stages from 1999 to the present. A discernible trend emerges, indicating a progressive escalation in the prominence of induced factors. During the initial stage, Taiwan witnessed a limited number of land expropriation cases conducted under the Land Act, which defined uncomplicated expropriation procedures and relatively modest compensation standards.

The inception, exploration, and developmental innovation stages of Taiwan’s land expropriation institutions were deeply intertwined with the backdrop of the KMT’s challenging circumstances during the Chinese Civil War and its subsequent retreat to Taiwan, which marked the onset of an era dominated by authoritarian rule. Following their migration to Taiwan, the KMT sought to solidify its political power and recalibrate the wealth distribution of Taiwan society. Employing the authoritative might of the ruling elite, the KMT initiated a series of land reforms using land expropriation as a policy instrument that brought about profound changes to the socio-economic structure. Given Taiwan’s framework as a capitalist society, where the majority of land was held in private ownership, Taiwan authorities encountered staunch opposition from the landlord class and their representatives during the enforcement of compulsory land acquisition from landlords. In the end, Taiwan authorities conceded certain concessions to the landlords amid the land reform process. Although the landlords experience the expropriation of their land, they were granted compensation from peasants in the form of land payments and shares in well-operated state-owned enterprises. Strategic conversion of land capital into industrial and commercial capital led many landlords to transition into entrepreneurs, investing in emerging industries. As the grip of the ruling regime grew stronger, the KMT administration recognized the incompatibility of the existing land expropriation institutions with Taiwan’s circumstances at the time. For instance, offering to buy high-priced land at the reported market values led to fundraising challenges for local governments when the prices were inflated, while undervalued land often led to property disputes or inefficient land utilization, presenting further post-acquisition complexities. In response, during the transition phase of Taiwan land expropriation institutions, the KMT initiated three amendments to the IRUALR. However, with the development of urban construction and the economy in Taiwan’s political and economic landscape, a surge in loosely organized and fragmented land disputes began to emerge [37]. As a result, in 1977, Taiwan underwent a comprehensive revision of the IRUALR in eight aspects, leading to the enactment of the ELRA. Regarding compensation mechanisms, the shift was made from prior landlords reporting land values to government-led advance estimation of land values. This alteration resulted in a notable increase in cash-based payments, accompanied by a reduction in the issuance of bonds. Moreover, an innovative segmental expropriation mechanism was introduced. Throughout the initial three stages of Taiwan’s land expropriation institutions, the enforcing authority of compulsory changes rested with the Taiwan authorities, while the induced factors consisted of those entities subject to expropriation.

However, under the ELRA, there exist provisions related to land expropriations in several legislative acts, including the Urban Planning Act, the Construction Act, the Housing Ordinance, and the Development of Tourism Ordinance. This intricate web of regulations often poses challenges to the effective implementation of these provisions due to the disparities and discrepancies among them. “As Interviewee P4 stated, the disagreement between land expropriation regulations and the lack of clarity in the expropriation process creates impediments to proper protection of the rights and interests of those who have lost their land. Although the KMT authorities optimized the compensation for land expropriation, as Taiwan embarked on its transition to democracy in the 1990s, the resistance of the expropriated population has undergone a significant evolution. What began as a stance of stoicism and concessions under the influence of public power has gradually transformed into a network of socially-mobilized, organized group actions of resistance.” In 1999, the Taiwanese used both institutionalized and non-institutionalized ways to assert their interests. They utilized methods such as group land protests and the appointment of public opinion representatives to express their demands. Under the pressure of public opinion, the Taiwan authorities then promoted the formulation of land expropriation regulations to harmonize the divergent perspectives entrenched within existing expropriation laws and regulations and to reaffirm the central standing of the expropriated individuals. In this stage, Taiwan’s public representatives also acted as a causative factor to push for institutional change. The 2010 Tai Po protests serve as a compelling illustration. In this instance, the participation of social movement organizations and opposition parties, alongside expropriated landowners and representatives of public opinion, is conspicuously evident.

“As interviewee S1 said, the essence of land expropriation is the use of power by the executive to forcibly deprive the people of their property rights without regard to their wishes, and then offer them certain compensation. However, there are many people who are unwilling to give up their landed property. In order to protect the private property of this group of people, we, as social movement organizations, are obliged to stand up to oppose it.” Meanwhile, “interviewee F5 also said that Kaohsiung government wants to expropriate our farmland for the construction of a highway. Many farmers have taken action to protest against the highway’s faulty route, which destroys the environment and ruins, etc., and the Environmental Protection Evaluation Commissioners also believe that the development should not be carried out, but the Kaohsiung government insisted on expropriation based on the relevant regulations. Finally, we jointly expressed our demands to public representative Lin Dai-Hua, hoping that the government should come up with a better compensation plan. Moreover, Lin Dai-Hua believes that Taiwan’s existing land expropriation institutions are indeed inappropriate, and she will report to the Legislative Yuan”. From this, the land expropriation institutions in the refined stage can be understood as the end product of the interactive game between the land expropriated individuals, public representatives, social movement organizations, opposition parties as the induced factors, and the Taiwan authorities as the compulsory change actors.

To strengthen the comparative analysis, it should be noted that the induced factors in the change of the Cross-Strait land expropriation institutions are not the same. Since Taiwan adopts a Western-style democratic system with bottom-up governance, Taiwan’s people can not only express their demands in a non-institutionalized way, but also express their dissatisfaction with land expropriation through feedback to public representatives’ opinions and by turning to the opposition party because of a more complete mechanism for expressing interests. In contrast, the causal factors in the land expropriation institutional change in Chinese Mainland are the landless farmers and the local government. This difference between Cross-Strait is caused by the difference in political systems, which makes the land governance paths in these two places different.

In general, in terms of the change patterns of the Cross-Strait land expropriation institutions, except for the initial and exploratory stages of the land expropriation institutions in Chinese Mainland, which were mandatory changes controlled by the will of the CPC Central Committee, the rest of the stages of the land expropriation institutions are the products of the game between the induced factors and the mandatory change subjects. However, due to the difference in political systems between the Cross-Strait, the induced factors in the process of institutional change in Chinese Mainland are only the landless farmers, while the induced factors in the process of institutional change in Taiwan have been enriched along with the process of democratization; and in addition to the landless farmers, public representatives, the social movement organizations, and the opposition parties have gradually become the actors in the process of institutional change.

4.2. Cross-Strait Land Institutions Generally Follow Gradual Change Paths: Layering, Displacement, Drift, Conversion

Understanding the patterns of change in the various phases of the Cross-Strait land expropriation institutions can help to reveal the logic of change and the complexity behind it. Such an understanding can not only assist academic research and policy analysis, but also help to improve the land expropriation institutions to make it more equitable, sustainable, and responsive to social needs. In terms of patterns of institutional change, historical institutionalists have summarized several patterns, with a primary focus on gradual change: displacement, conversion, layering, and drift.

Since its inception, the change of land institutions in Chinese Mainland has been a gradual process and under this framework of change, three main patterns have emerged: displacement, drift, and conversion. First of all, displacement refers to the removal of existing rules and their replacement with new ones, and displacement runs through the entire change in the land acquisition institution of the Chinese Mainland. Displacement may not involve an immediate and radical change, but may manifest as a gradual and measured progression, especially when the introduction of a new system directly challenges the role of the established one. This phenomenon is observed in the changes in compensation rates, resettlement methods, and expropriated individuals in the Chinese Mainland [8]. In terms of compensation standards for land expropriation, the Chinese Mainland has successively adopted the method, including total production value, the multiples of production value approach, and the comprehensive land value approach for specific regions, and the compensation standards have been raised over the years. Concerning expropriation resettlement, the resettlement method has changed from a monotonous to a diversified one, and the resettlement standard has continued to rise. With respect to expropriated individuals, with the changes in rural land property rights, individual farmers, village collective organizations, and farmers together with village collectives have successively become expropriated individuals and beneficiaries of compensation, and the position of peasants in expropriated land activities has undergone a developmental sequence at the institutional level, characterized by a transition from “establishment of the main status → loss of the right to speak → return of the main status” at the institutional level.

Second, the solid stage of Chinese Mainland land expropriation institutions showed the pattern of drift. Drift refers to the fact that the established institution still exists, but as the external environment changes, its functionality and regulatory capacity gradually weakens. This phenomenon was driven by the swift growth of the real estate industry during that period. With the escalation of land and housing prices, farmers’ expectations for overall compensation also surged. However, the Chinese Mainland persisted in the multiplier of production value method to calculate compensation standards. This divergence between compensation standards and farmers’ expectations gave rise to a considerable gap, ultimately triggering destabilizing factors such as mass incidents. These occurrences were a result of the mismatch between institutional configurations and the original intentions of the architects of the expropriation system. Consequently, the outcomes of the institutions deviated from the original intentions of the land expropriation institutional designers.

Finally, conversion refers to changing the outcome of the institution by adjusting the way the institution is implemented, and it is also the actor’s reinterpretation of the existing institution to serve a new purpose. Although Chinese Mainland land expropriation institutions have formed a relatively systematic and scientific institutional framework after going through five phases, they are still ambiguous, leading to an ambiguous space between the institutions and their implementation. This gap provides room for innovation among those who implement the institutions and also serves as an excuse for local governments to expand their powers. On one hand, local governments such as Jiaxing have changed the traditional compensation and resettlement methods, adopting means like “land for social security” and “residence-based compensation” to innovate the land expropriation institutions. On the other hand, some local governments have misinterpreted or even violated the provisions of the established land expropriation institutions based on considerations of land finance and local economic development, and have gone to great lengths to illegally expropriate rural land by means of unauthorized expropriation and leasing in lieu of expropriation, which ultimately resulted in the infringement of the legitimate rights and interests of farmers.

Compared to the change patterns observed in the Chinese Mainland land expropriation institutions, the change patterns of the Taiwan land expropriation institutions stand out with greater distinction. Aside from displacement, drift, and conversion, Taiwan’s land institutions also involve layering. Firstly, displacement similarly runs through the entire process of the Taiwan land expropriation institutions change. The displacement pattern is also evident in the compensation methods, compensation standards, and the changing status of those subject to expropriation within the Taiwan land expropriation institutions. Regarding compensation methods, the evolution in Taiwan’s land expropriation institutions has advanced from initial practices that involved compensating landowners through land value assessments, tangible land bonds, and allocations of state-owned enterprise shares, culminating in the availability of alternatives, such as the choice between receiving developed land or a monetary compensation equivalent to 40% of the expropriated land’s value. In terms of compensation standards, Taiwan has successively adopted institutions involving prior self-reported land values by landowners, government estimation of land value prior to expropriation, and post-expropriation government compensation based on market value, with a consistent augmentation of compensation standards over time. Concerning resettlement during expropriation, the approach has also transitioned from a single standard to a diversified framework. In terms of those subject to expropriation, the evolution has shifted from an initial stage that aimed to balance the interests of landowners to a gradual progression that emphasizes and ensures the primary status of those subjected to expropriation. The standing of those subject to expropriation has progressively risen and solidified throughout the course of land expropriation activities.

Secondly, the drift of Taiwan land expropriation institutions is primarily evident in the developmental innovation stage from 1977 to 1998. In 1977, the Taiwan Legislative Yuan brought about an amendment to the IRUALR, transforming it into the ELRA, and introduced measures to regulate the utilization of vacant land, facilitate land re-subdivision, and innovative segmental expropriation for optimal land use. Despite these advancements, there remained discrepancies within the ELRA due to related provisions in laws such as the Urban Planning Act and the Development of Tourism Ordinance. These incongruities in regulations posed execution challenges. The diverse procedures for land expropriation led to inconsistencies in compensation items and standards. Consequently, this divergence led to frequent resistance during the land acquisition process. This institutional outcome deviated from the original intentions set forth by Chiang Kai-shek and Chiang Ching-kuo, based on the Three Principles of the People. During this 21-year period, the KMT authorities failed to adequately respond to changing circumstances.

Thirdly, the pattern of conversion is predominantly observable in both the developmental innovation stage as well as the stabilization stage of Taiwan land expropriation institutions. The period from 1977 and 1999 was marked by the absence of the Land Expropriation Act in Taiwan. In the absence of overarching legislation, certain local governments in Taiwan, driven by the desire for expedient expropriation and in support of the development of the KMT’s local factions, occasionally indulged in practices that favored expropriating parties, sometimes leading to rent-seeking behaviors. During the period from 2000 to 2012, even with the enactment of the Land Expropriation Act, the rapid urbanization and considerations related to land financing and local economic development occasionally led certain local governments to misinterpret the provisions outlined in the regulations pertaining to land expropriation. The lack of well-defined parameters regarding the criteria of public interest and necessity also contributed to a blurry boundary between the institutions and its implementation. This ambiguity served as a pretext for local governments to expand their sphere of authority. The emergence of the conversion mode can be attributed to the discrepancy between the established system and the prevailing reality. Actors exploit the ambiguity inherent in the rules to reinterpret existing institutional norms to align with new realities they face.

Finally, the logic of layering finds its embodiment in the stabilization and refinement phase of Taiwan land expropriation institutions from 1999 to the present. Layering refers to modifying, refining, and supplementing the existing institution through additional clauses or amendments without introducing an entirely new institution. Instead, it focuses on altering the structural functions of the existing institutions to ensure adaptability and increased efficacy [38]. An important milestone in this progression occurred on 2 February 2000, when Taiwan officially implemented the Land Expropriation Act, which served as a consolidation of various pre-existing land acquisition regulations. In February 2002, the Taiwan Legislative Yuan introduced Article 36–1 to the Land Expropriation Act. By the year 2012, Taiwan underwent another series of amendments and supplements to the Land Expropriation Act. These successive rounds of revisions further bolstered the protections accorded to the rights of those subject to expropriation and aligned land acquisition more closely with the principles of public interest and necessity. This, to a certain extent, optimized the structural functions of the existing institutions.

In order to strengthen the comparative analysis, it should be emphasized that compared with the three patterns of change in the land expropriation institutions in Chinese Mainland, Taiwan has an additional pattern of change in layering. Layering is a modification, refinement, and supplementation of the existing system, which is able to optimize the structural functions of the old system to a certain extent. Layering is a pattern of institutional change that can achieve a smooth transition of the system and alleviate social and economic instability. The emergence of the layering pattern of change not only indicates that Taiwan’s land expropriation institutions are undergoing a gradual process of change at this stage, but also implies that the institutions have already been perfected, with only a small part of them being modified and supplemented.

Overall, in the process of institutional development, displacement, drift, layering, and conversion are intricately interwoven, collectively guiding the progressive change of land expropriation institutions. It is worth noting that these patterns of transition do not exist in isolation; they frequently intersect and collectively steer the progressive evolution of these institutions. Importantly, no single transition mode can be universally applied; each pattern has its advantages, disadvantages, and contextual suitability. Therefore, when considering the future trajectory of land expropriation institutions, be it in the context of the Cross-Strait or various other developing nations, it is essential to comprehensively take into account the political, economic, and social conditions both within and outside the system.

4.3. Path Dependence: The Historical Inertia That Sustains the Continuity of Land Expropriation Institutions

Historical institutionalists posit that in the process of institutional change, mechanisms of increasing returns and self-reinforcement come into play. Once an initial institution embarks on a certain path, it gains considerable inertia [15]. Cross-Strait land expropriation institutions, since their inception stage, unmistakably exhibited clear features of path dependence, as their institutional changes have been marked by substantial historical inertia.

In the wake of the establishment of the People’s Republic of China, the Chinese Mainland chose to extract resources from the vast rural areas to facilitate smooth industrialization. The foundational principles of agriculture serving industry, rural areas serving cities, and land expropriation serving national economic development became deeply embedded in the land expropriation system. Despite the changing times and the rapid growth of the Chinese Mainland economy, while such notions might no longer be explicitly stated in the present text of land expropriation institutions, analogous ideas regarding land acquisition persist at the core of Chinese Mainland land expropriation institutions. These ideas occasionally resurface in land acquisition practices across various regions. As historical institutionalists suggest, ideas construct institutions, and once the ideas entrenched in institutions become solidified, the corresponding institutional elements will also become locked in place [39]. For instance, since their inception, methods like the total output value approach and the output value multiplier approach, though no longer congruent with the changing institutional milieu, have continued to be employed in land expropriation activities in the Chinese Mainland for nearly 30 years. Moreover, the resettlement method primarily centered around local agricultural resettlement has endured for over fifty years in the history of land expropriation in the Chinese Mainland, often intertwined with the dual urban-rural household registration system [40].

In contrast to the Chinese Mainland, when the KMT retreated to Taiwan in its early stages, it aimed to consolidate its political power and ensure stability. The KMT utilized the coercive force of the ruling class to execute large-scale land expropriation from the landlord class. This strategic move altered the socio-economic structure. In other words, the KMT employed land expropriation as a policy tool, bringing an end to the traditional landlord economy in Taiwan and weakening the socio-economic foundation of the existing rural landlord class. This laid the groundwork for Taiwan’s subsequent industrial and commercial development. “As mentioned by Interviewee P6, the mindset of the KMT political elites at that time viewed land expropriation institutions as means by which the administrative authorities to achieve political objectives. For instance, they utilized land requisition to support the development of Taiwan cities and local areas. This perspective persisted until the gradual transformation towards democratization. This shift was driven by electoral pressures, whereby the KMT found the need to to broaden its voter base as much as possible. As a result, the governing authorities had to incorporate various societal demands and progressive values into their policy considerations, such as the notions and needs of land justice and housing justice”.

According to North, there exist two variants of path dependence. Institutional change can either follow the correct path and a trajectory of virtuous cycles or proceed along an incorrect path, becoming entrenched in an ineffective state [41]. The innovation stage of land expropriation institutions in the Chinese Mainland involved a reconstruction of the existing institutional framework, leading to a series of beneficial complementary arrangements. This has become the starting point for a new round of path dependence in institutional change, with the potential to propel the Chinese Mainland’s land expropriation institutions onto a trajectory of virtuous cycles. Meanwhile, during the consolidation stage in Taiwan, land expropriation institutions were integrated under the Land Expropriation Act, consolidating multiple regulations. This act underwent minor revisions and supplements in 2012, evolving into a more comprehensive and contextually appropriate land expropriation institution aligned with the realities of Taiwan. As a result, starting from the consolidation stage, Taiwan land expropriation institutions have embarked on a new round of path dependence.

In summary, differences can be observed in the types of institutional change in Cross-Strait land expropriation institutions. The initial stage of Chinese Mainland land expropriation institutions involved enforced change orchestrated by the CPC Central Committee. The subsequent stages of development, consolidation, and innovation emerged as outcomes of the interplay between compulsory change and induced factors. In contrast, Taiwan’s land expropriation institutions, regardless of the period, have followed a logic that intertwines both compulsory and induced changes, with induced factors demonstrating greater diversity compared to those in the Chinese Mainland. Furthermore, in terms of the change trajectory, the Cross-Strait land expropriation institutions change has primarily exhibited a progressive nature. In terms of the patterns of change, the Chinese Mainland exemplifies the elements of displacement, drift, and conversion, whereas Taiwan incorporates an additional layering logic not as prominently present in the Chinese Mainland. Ultimately, the change of Cross-Strait land expropriation institutions is characterized by pronounced characteristics of path dependence.

5. Institutional Milieu, Ideas, and Actors Serve as Dynamic Mechanisms for the Change of Cross-Strait Land Expropriation Institutions

Historical institutionalism synergizes the theoretical strengths of Structural Functionalism and Rational Choice and is able to explore the origins of institutional change under stable institutional arrangements. In order to explore the causal factors of institutional change, this section will draw on the analytical framework of historical institutionalism and analyze it in three subsections. Firstly, the first subsection will discuss the institutional milieu, which is regarded as a contextual factor influencing the formation and development of institutions and can be used to explain the causes behind institutional change. Secondly, the second subsection will focus on the promotion of perceptions on the land expropriation institution, because institutional change is usually accompanied by perceptions first, and changes in perceptions become an important driving force for institutional change. Finally, the third subsection will discuss the promotion of actors in Cross-Strait land expropriation institutions, because ideas cannot act by themselves, but need actors to create institutions and promote institutional change. Through the analysis of these three subsections, we can have a more comprehensive understanding of the dynamic mechanisms of the Cross-Strait land acquisition system change.

5.1. “Background-Institution” Structure: Institutional Milieu Determines the Choice of Land Expropriation Institutions

Historical institutionalists posit a temporal causal relationship between institutional formation and change. The institutional milieu, including macro-level contextual factors, is considered to influence the formation and development of institutions. These factors are employed to explain the causes behind particular institutional patterns [42]. In the case of the Chinese Mainland, following the founding of New China in 1949, the CPC aimed to solidify its authority by establishing stability within the vast working and peasant classes. To achieve this goal, they pursued compulsory expropriation of land from the landlord class, industrial and commercial owners. The acquired land was then distributed equally among landless and land-poor peasants, setting a precedent for the land expropriation system in New China. However, by the late 1950s, the deterioration of Sino-Soviet relations and resultant disruptions in the industrialization process in the Chinese Mainland led to a period of stagnation. This industrial stagnation also rendered cities unable to absorb new labor, posing the potential for social unrest if landless peasants were to be transferred to urban areas. In response to this predicament, adjustments were made to the agricultural land expropriation institutions, including the reduction of compensation standards for land expropriation. Additionally, the main resettlement method shifted towards local agricultural resettlement.

By the onset of the 1978 reform and opening-up, the economic framework of public ownership had undergone disruptions, with the restoration of partial ownership rights for farmers over rural land. The development of the non-public sector created a substantial demand for land, leading to an expansion of land acquisition scope. The distinct public interest characteristics became relatively blurred, and the coercive nature of land acquisition gradually emerged. From the 1990s through the 2010s, the government assumed a dominant position in economic development, fostering what could be termed a “government-led” economic system. “As Interviewee P3 mentioned, within this government-led economic system, the liberalization of factor markets catalyzed the activation of pivotal resources, such as land and other tangible assets previously controlled by the government. This led to enhanced liquidity and marketability of these resources. Consequently, under the government-led economic system, the government capitalized on its monopoly over primary markets by auctioning acquired land to businesses and industries, yielding substantial revenue. This, in turn, incentivized some local governments to expand the scope of land acquisition and intensify the coercive nature of the acquisition process.” Lastly, during the innovation phase of land expropriation institutions, the growth rate of the Chinese Mainland’s GDP experienced a decline. Economic growth shifted from rapid to medium-high speeds, accompanied by an intensification of the aging population. The issues related to agriculture, rural areas, and farmers gained prominence on the central government’s agenda. In response, the CPC Central Committee introduced development strategies like rural revitalization, positioning the effective protection of farmers’ interests as a central concern within the current land expropriation institutions.

However, in the case of Taiwan, in 1946, faced with successive defeats in its internal conflict with the CPC during the Chinese Civil War, the KMT initiated land reform in some areas of the Chinese Mainland. This strategic employment of land expropriation aimed to rally support from the rural class and reverse the tides of battle. Following the KMT’s defeat in 1949, dual objectives came into play: preventing the Communist Party’s influence from permeating Taiwan and sustaining the ongoing rivalry against the CPC as the leading Chinese revolutionary force. The KMT authorities in Taiwan extended the legacy of modern Chinese political elites by devising modernization plans to save the nation [43]. They used land expropriation as a political tool to initiate a peaceful land reform in Taiwan. By 1974, a critical year in the transformation of Taiwan’s land institutions, the political and economic situation in Taiwan underwent a drastic change. Economically, the repercussions of the fourth Arab-Israeli War reverberated across, causing the economic growth rate to plummet from 12.8% in 1973 to 1.1% in 1974. This economic upheaval, in turn, triggered a substantial 47.5% increase in urban consumer prices, impacting the livelihoods of the people [44]. On the political front, Taiwan’s foreign relations underwent substantial recalibrations, accompanied by a change in regional leadership that ushered in a period of successive political power under a strongman regime. In this context, Chiang Ching-kuo, then Premier of Taiwan, proposed the Ten Major Construction Projects. This initiative, funded with a budget of TWD 19.47 billion, sought to demonstrate the political influence of the strongman regime through the implementation of consequential public policies. As Taiwan’s political and economic situation gradually stabilized, the Taiwanese economy began to soar. To ensure land supply to accommodate economic development requirements, the authorities innovatively introduced a zoned expropriation mechanism, enhancing the security of expropriation assurances. Moving into the late 1990s, it underwent a significant metamorphosis into a democratic society, yielding profound changes in the political and social environment. The burgeoning of the public’s citizenship consciousness was accompanied by both institutionalized and non-institutionalized ways of expressing interests. Through collective land protests and representation by elected officials, citizens conveyed their demands and aspirations. Under the pressures of a democratic electoral system, incumbent leaders tend to court voter favor through public expenditures or championing reforms in the lead-up to elections. Therefore, in the years preceding Taiwan’s second and fifth direct leadership elections, the KMT took steps to either enact or revise the Land Expropriation Act. These actions aimed to clarify land acquisition procedures and reinforce the primary status of those subject to expropriation, furthering their efforts to secure voter backing. This view is also supported by interview data, “such as interviewee F6, who said that my family’s agricultural land was expropriated by the Taichung City Government, but the government gave sufficient compensation. Although some friends complained that they did not want to move away from the land on which they depended for their livelihoods, they finally recognized and appreciated the efforts of the KMT legislators as they sent them to the door to apologize and promise to optimize the expropriation process”.

Overall, institutional evolution mirrors the changing institutional milieu, which in turn exerts a substantial impact on the direction and trajectory of institutional transformations. An analysis of the evolution of Cross-Strait land expropriation institutions underscores the pivotal role played by the institutional milieu in its driving mechanisms. Despite the inherent limitations in value judgments resulting from the institutional milieu-driven changes in land expropriation institutions, it remains undeniable that these changes have made substantial contributions to economic development and social stability in Cross-Strait.

5.2. “Variable-Institution” Structure: Ideas Influence Land Expropriation Institutions Arrangements

Ideas serve as abstract mappings of the material world in individual minds, encompassing practical experiences, value concepts, cognitive thinking, and more. With the incorporation of recent theoretical perspectives such as cognitive analysis, discourse analysis, and rhetorical analysis, scholars of historical institutionalism have come to acknowledge the profound influence of culture, cognition, and ideas on institutions and institutional change. Historical institutionalism scholars believe that idea analysis offers a reasonable explanation for endogenous institutional change, beyond the realms of structure and agency [45].

The transitions of Cross-Strait land expropriation institutions are often closely linked to a preceding shift in ideas, where changes in ideas become a crucial driver for institutional changes. After the initiation of reform and opening-up in the Chinese Mainland, a noticeable shift in ideological orientation transpired within the CPC, marked by a transition from a focus on class struggle to a heightened emphasis on economic development [46]. This realignment led to economic development becoming the paramount priority for both central and local governments. Other matters were expected to follow the principle of economic prioritization, including land expropriation. In tandem with this shift in ideas, adjustments were made to agricultural land expropriation in the Chinese Mainland in 1982, with a strong emphasis on the compulsory nature of land acquisition. Furthermore, changes in the perceptions held by the affected population directly influence the transformation of the land expropriation institutions. As the reform and opening-up continued to deepen, societal viewpoints were gradually emancipated, resulting in diverse values. Safeguarding individual legitimate interests became not only a crucial aspect of the rule of law but also a widely accepted ideological concept within society. Consequently, ideological shift gave rise to a growing population of displaced farmers who took on confrontational roles within the political system. These farmers adopted non-institutionalized methods to articulate their interests and exert pressure on the government. Ultimately, this mounting pressure forced the central government to adjust the land expropriation institutions by raising compensation standards for land acquisition and aligning with the goal of safeguarding the immediate interests of the displaced farmers.

After the KMT retreated to Taiwan, its political elites drew lessons from their failures. They believed that the military defeats were not solely attributable to military factors but rather stemmed from their failure to address the survival needs of the tenant farmers and hired laborers, who constituted over 80% of the population on the Chinese Mainland. This perspective was influenced by a discourse on land reform prevalent during the Cold War era, as proposed by Ladejinsky. According to this discourse, communism could incite poor landless peasants to rise against the government, necessitating top-down land reforms in underdeveloped nations. These reforms were believed to stabilize the political situation and promote economic development; otherwise, there was a risk of grassroots revolutions led by communist parties [47]. On the other hand, the KMT political elites adhered to the “Premier’s legacy” and Principles of People’s Livelihood to reform towards the goal of allocating land to those who cultivate it in order to stabilize and develop Taiwan’s economy and, in accordance with the Three Principles of the People, eventually unify China. For more than four decades, land expropriation was one of the means by which the KMT political elites promoted their policies and achieved their political goals. It was not until the end of the 20th century that Taiwan transitioned into a democratized society, with democracy, freedom, and human rights gradually as fundamental values of Taiwan society. The rule of law became the governing philosophy of the government, as democracy and human rights gained consensus in Taiwanese society. “As Interviewee P5 pointed out, land ownership tends to take precedence in Taiwanese society, reflecting the value that land means wealth. In general, the government resorts to expropriation as a last resort, pursued only after all other avenues are exhausted for land acquisition. Moreover, if those subject to expropriation are dissatisfied with the procedures and compensation, they can voice their grievances to the Taiwan authorities through accountability mechanisms and protests to safeguard their interests.” During this era, the political elites of the KMT, under the pressures of democratic accountability and elections, attach great importance to the legitimate demands of the populace for land justice and residential justice. Therefore, under the impetus of Taiwan authorities, the Taiwan Legislative Yuan’s revisions to the land expropriation institutions aimed for more standardized land acquisition procedures and a substantial reduction in acquisition scope. This shift underlines a renewed focus on the public interest and necessity of land expropriation. It is evident that ideas serve not only as overarching societal trends that trigger changes in power dynamics but also as guides for the behaviors of specific actors.

5.3. “Behavior-Institution” Structure: Actors Driving the Change of Land Expropriation Institutions

From a macro perspective, ideas offer insights into the mechanisms behind institutional change, whereas actors offer explanations from a micro perspective. Ideas are important, but ideas are foundational, they remain inert without the intervention of politicians or similar figures who translate these concepts into policies and the establishment of institutions. Historical institutionalists assert that institutions serve as frameworks that both shape and govern the scope of actors’ behavior; however, it is the demands and pressures brought about by actors that drive the need for institutional adjustments. Ultimately, the interaction between institutions and actors propels institutional change.

Firstly, the political form in the Chinese Mainland is characterized by a fully controlled political system under the leadership of the CPC. With deep integration into state power, the party assumes dominance over the country’s political direction, shapes the national political processes, and holds authoritative control over the distribution of political values and resources [48]. In this political system, the CPC establishes itself as the steward of power, exercising authority across a multitude of domains. As the conduit of state power, the CPC Central Committee wields considerable control over the creation and development of most national institutions. It holds the capability to determine the inclusion of a particular institution into the government agenda and the direction in which that institutional transformation should proceed [49]. Therefore, in line with the aforementioned political logic, the CPC’s top echelon can be regarded as the pivotal actors shaping the formation and evolution of land expropriation institutions in the Chinese Mainland. Changes in institutional content mirror their will. Secondly, as displaced farmers embroiled in grassroots resistance face the high costs of formalized protest and contend with the political culture in China, expressing their own interest-driven demands through formal mechanisms becomes a formidable challenge, rendering them a vulnerable group before the state’s official power. Entering the new century, as expropriation expanded and compulsion encroached upon farmers’ core interests, displaced farmers have had to frequently resort to non-formalized methods means, such as protests and sit-ins, to voice their interests. For example, “interviewee F1 mentioned, I went to sit quietly outside the government office with other villagers only when our petitions yielded no results. It wasn’t a protest; we just wanted to express our dissatisfaction with the land compensation. With so many children in my family, I had to think about their future.” Confronted with pressure from grassroots protesters, the political system had to respond by reforming land expropriation institutions. Finally, local governments, as the implementers of the system, embarked on a considerable number of spontaneous innovations within the land expropriation framework driven by developmental and pressure-induced dynamics, which, upon successful diffusion, paved the way for the reform of the land expropriation institutions.

In the context of Taiwan, firstly, before the democratic transition, the region operated martial law, characterized by a fully controlled political system under the rule of the KMT. Power was tightly integrated between political parties and administrative agencies. The KMT’s grassroots party branches and local factions established patron-client relationships, and their authority extended from the central authorities to grassroots village chiefs [50]. In terms of land expropriation institutions, the KMT’s political elites played a pivotal role in shaping Taiwan’s land expropriation institutions, often driving compulsory changes in land expropriation institutions in response to developmental policy needs. It was only with Taiwan’s formal embrace of democratic practices, modeled on Western frameworks, that local county and city leaders and regional officials started facing direct elections by the voters. As a result, the political landscape shifted from the KMT’s fully controlled political system to a dualistic opposition structure between the KMT and the Democratic Progressive Party (DPP). Secondly, before Taiwan’s democratization, due to the limited level of legal formalization and the cultural literacy of the population, displaced individuals at the grassroots level often resorted to methods like protests and demonstrations to express their grievances concerning land expropriation. This was particularly frequent during the rapid urbanization of Taiwan in the 1980s and 1990s. Lastly, following Taiwan’s democratization, grassroots individuals who had lost their land gained the ability to utilize both formalized and non-formalized means to voice their interests. Established mechanisms such as elected representatives allowed them to communicate their interests to local governments and authorities. Simultaneously, methods like marches and demonstrations, often coordinated by opposition parties and social movement organizations, were used to hold authorities accountable. Therefore, the post-democratization era witnessed the involvement of opposition parties, elected representatives, and social movement organizations compelling Taiwan authorities to further refine land expropriation institutions.

In conclusion, the driving factors from the three dimensions mentioned above not only exert individual influence on institutional change but also intersect and intertwine. Institutional milieu, ideas, and actors form a logical chain of causality, collectively constructing the dynamics of change in Cross-Strait land expropriation institutions. The institutional milieu influences relevant institutional actors, subsequently altering their perceptions and behavioral patterns. Consequently, this dynamic interplay, marked by innovation and diffusion, resistance and response, fuels the intricate process of institutional change.

6. Conclusions

This paper utilizes the analytical framework of historical institutionalism, combining the comparative case study method and in-depth interviews. After elucidating the trajectory and direction of change in the land expropriation institutions in Cross-Strait, it systematically analyzes the logic of change and the dynamic mechanisms of land expropriation institutions in both regions. This serves as theoretical insight and policy guidance for land expropriation institution reforms in developing countries in Asia. It also aims to address the rapid urbanization process with a more sustainable approach to land expropriation.

After analysis, concerning the first research question: How many stages of development have the land expropriation institutions in Cross-Strait gone through, and what is the general direction of change? The researcher has made the following findings. Cross-Strait land expropriation institutions can be categorized into five stages of development. In Chinese Mainland, the land expropriation institutions have gone through the stages of initial, exploratory, development, stabilization, and innovation. On the other hand, Taiwan’s land expropriation institutions have undergone stages of initial, transition, developmental innovation, stabilization, and refinement. Regarding changes in land expropriation institutions in Chinese Mainland, the status of landless farmers in land expropriation activities has undergone the developmental trajectory of “establishment of an important position→loss of the right to speak→return to an important position”, and the scope of land expropriation has followed a developmental path from “broad→broader→narrower”. The compensation standards have continuously improved, and the compensation schemes have gradually diversified. In Taiwan’s land expropriation institutions, the status of the expropriated has become increasingly consolidated. The scope of expropriation has also followed a developmental process of “broad→broader→narrower”, with expropriation procedures gradually standardizing and compensation standards continually upgrading.

Regarding the second research question: What kind of logic has been followed in the changes of land expropriation institutions in Cross-Strait? Researchers have found that Cross-Strait land expropriation institutions show a triple logic in terms of change types, change paths, and change processes: in terms of change types, there are compulsory changes and mutual games between induced factors and actors pushing for compulsory changes; in terms of change paths, there are patterns of displacement, drift, conversion, and layering; and in terms of gradual change processes, they show obvious path dependence characteristics. However, it is worth noting that differences exist in the patterns of change pathways for Cross-Strait land expropriation institutions. In the case of Chinese Mainland, the change patterns involve displacement, drift, and conversion, while in Taiwan, an additional layering pattern is added to the aforementioned three.

As for the third research question: What are the incentives for the change of land expropriation institutions in Cross-Strait? Institutional milieu has had a significant impact on the direction and trajectory of changes in the land expropriation institutions in Cross-Strait, with perceptions influencing the specific arrangements of the land expropriation institutions; actors drive change in land expropriation institutions. Institutional milieu, ideas and actors not only exert individual influence on institutional change but also intersect and intertwine. Institutional milieu, ideas, and actors form a logical chain of causality, collectively constructing the dynamic mechanisms of change in Cross-Strait land expropriation institutions.

In general, this paper presents two main innovations: First, it is innovative in that it shifts the focus from the discussion of current practices, problems, and potential optimization paths of the land expropriation institutions in Chinese Mainland, which is common in existing studies [6,7,8,9], to the logic of historical development and institutional change. While some studies have touched upon the historical development of land expropriation institutions in Chinese Mainland, they tend to overlook the deeper underlying patterns behind the evolution of this institution. Additionally, although the academic community in Cross-Strait has extensively analyzed Taiwan’s land policies and land reform experiences, there is a lack of literature that systematically traces the developmental trajectory of Taiwan’s land expropriation institutions and delves into the logic of their changes. In response, this study systematically explicates the logic of change and the dynamic mechanisms behind the evolution of land expropriation institutions in Cross-Strait, aiming to fill this research gap. Second, in terms of theoretical contributions, this paper employs the analytical framework of historical institutionalism. This methodology can enhance our understanding and explanation of the evolution and stability of land expropriation institutions in various countries and regions, as well as the interplay between these institutions and political and economic factors. Furthermore, the application of historical institutionalism, with its concepts of institutional environment, critical junctures, and path dependence analysis, can facilitate the examination of why land expropriation institutions take different forms in different countries or regions, when they undergo reforms, and why some reforms face greater challenges. This holds significant relevance for scholars researching land expropriation institutions.

Future research can delve into the potential policy diffusion effect between the Chinese Mainland and Taiwan concerning land expropriation institutions. In decisions involving policy transfer, the consideration of the institutional and normative “fit” remains crucial. Once the criteria for “fitting” are met, the scope of transferrable policy components can be remarkably wide, including policy norms, principles, goals, tools, and instruments. This would aid certain Asian developing countries in adapting the developmental experiences of land expropriation institutions from both Chinese Mainland and Taiwan to their local context, leveraging “Asian values”. Additionally, since this study has clarified the logic of change in land expropriation institutions in both regions, the cost-effectiveness of institutional change and land governance issues during the transition process should also be worth exploring.

Finally, it is essential to emphasize that this study has certain limitations. On one hand, the researchers did not interview the implementers involved in the land expropriation process, which limits the scope of the available data. On the other hand, interviewees may have had biases during the interview process, also contributing to the study’s limitations.