2017 Zhonghe apartment fire

2017 Zhonghe apartment fire
Firefighters outside the apartment building.
LocationZhonghe District, New Taipei City, Taiwan 4–5F, No. 65, Section 2, Xingnan Road
Date22 November 2017 20:37–21:14 (UTC+8)
TargetRevenge against a fourth-floor resident
Attack type
Arson Mass murder
WeaponGasoline and a cigarette lighter
Deaths9
Injured2
PerpetratorLi Guohui
MotivePersonal dispute with a fourth-floor resident

On the night of 22 November 2017, a fire was started at 20:37 in a Subdivided flat in the Nanshijiao area of Zhonghe District, New Taipei City, Taiwan.[1][2][3][4] The arsonist, 49-year-old Li Guohui, had a dispute with a fourth-floor resident and sought revenge by pouring gasoline in storage areas on the third and fourth floors and igniting it with a lighter.[5][6] The blaze spread through 28 rooms on two floors, killing nine people, causing minor smoke inhalation injuries to two others, and leaving 18 residents in need of temporary accommodation.[3][4][5][7]

Background

The building was located in Nanshijiao, Zhonghe District, near Huaxin Street, commonly known as "Little Burma", where many returned overseas Chinese from Southeast Asia had settled. The community largely consisted of descendants of the Kuomintang in Burma, refugees from the 1967 anti-Chinese riots in Myanmar, and their families. Attracted by nearby factories and relatively low housing prices, Chinese people in Myanmar residents formed communities around Huaxin Street, Xingnan Road Sections 1 and 2, and Zhongxiao Street.[8][9][10] Residents cited inexpensive living costs, convenient transportation via Nanshijiao Station, and a familiar cultural environment as reasons for living there. Consequently, illegal construction led to the widespread development of subdivided rental apartments, attracting many migrant workers and people employed outside the district.[11]

The landlord of the apartment was Lian Qiuxiang, aged 56 at the time of the fire. Although she owned no property under her own name, she controlled numerous rental properties in Zhonghe District, Yonghe District, and Tucheng districts.[12] The building involved in the fire was completed in 1976 and was reported for illegal alterations in 2007. Authorities classified it as a Category D ordinary illegal structure. In 2015, Lian acquired the second through fourth floors of an apartment building for 39 million New Taiwan dollars from a real estate broker surnamed Liu. Ownership of the property was registered under her children's names. Together with an illegally added fifth-floor rooftop structure, the building contained 51 rooms across four floors. Studio apartments and Rooming house were rented for around NT$5,000 per month, with individual units measuring only about 3 ping (roughly 10 m²). The fourth floor covered approximately 40 ping..[12][13][14][15][16]

The building's wooden construction, highly flammable interior materials, lack of fire compartmentation, high fire load, and inadequate escape routes—a single central corridor with the only staircase located at the ignition point—created severe fire hazards.[17][18] Illegal partitioning and rooftop additions by previous owners, combined with cramped spaces, contributed to a chimney effect that accelerated the spread of smoke and flames.[19] Numerous undocumented migrant workers were also living in the building, resulting in a complex population.[20] According to tenant Liu Qingzong, cooking inside the rooms was prohibited.[18]

The perpetrator, Li Guohui, was an unemployed ethnic Chinese from Myanmar who suffered from substance abuse involving amphetamine and was 49 years old at the time of the incident.[5][21] According to the New Taipei City Fire Department， Li had previously committed two arson attacks. On 21 May 2017, after failing to collect a debt from a friend, he set fire to a residence on Lane 109, Huaxin Street, using two gasoline-filled bottles and oil-soaked ropes. On 21 June, he burned two motorcycles parked near the eventual fire scene.Although neither incident caused casualties, after the cases were transferred to the New Taipei District Prosecutors Office, Li repeatedly failed to appear when summoned. Despite arrest warrants being issued, police did not apprehend him.[22][23]

The November 2017 fire was Li's third arson attack. Following an argument with fellow Burmese resident Hu Jinfu, who lived on the fourth floor, Li sought revenge. After purchasing gasoline at a filling station, he stored a plastic bottle filled with gasoline in the stairwell. On the evening of the incident, he poured gasoline into storage areas on the third and fourth floors and ignited it with a lighter.[5][6][23] Before committing the crime, Li changed his appearance. He initially wore a camouflage T-shirt and a red vest, but after fleeing the scene he stole clothing from a nearby residence and changed into a pink polo shirt before being arrested.[24]

Incident

The New Taipei City Fire Department received reports of the fire at 20:37 on 22 November. The Emergency Rescue Command Center dispatched ten units from the Fifth and Seventh Brigades, the Special Search and Rescue Brigade, the Emergency Response Team, and the Emergency operations center, while activating the mass casualty incident mechanism.[17]A total of 34 fire engines, 27 ambulances, and 178 firefighters were sent to the scene,[2] arriving at 20:42.[3]One resident on the fourth floor continuously called for help from a window, throwing personal belongings and furniture outside and at one point appearing ready to jump.[25] The fire was brought under control at approximately 21:02 and completely extinguished twelve minutes later.[3]Firefighters used ladders to rescue the resident in time.[2][26]

Investigations showed that the fire damaged five rental rooms on the third floor over an area of about 15 ping (approximately 50 square metres), while fourteen rooms on the fourth floor covering about 25 ping (approximately 83 square metres) burned, accounting for 62.5% of that floor's area. Another fourteen rooms on the fifth floor were heavily smoke-damaged.[26]

The blaze affected 28 rooms across two floors. While clearing the fourth-floor rear area, firefighters discovered two charred bodies, one lying in the corridor and the other at the far end of the floor.[27]After several days of DNA identification and coordination with the New Taipei City Police Department and Labor Affairs Department, one victim was confirmed to be Hu Jinfu, the fourth-floor resident with whom the perpetrator had previously argued.[28] Seven severely injured victims were pronounced dead on arrival at hospitals, most of whom died from respiratory failure caused by smoke inhalation.[29] Two others suffered minor smoke inhalation ,[2][3][4][5] while 18 residents from 14 households were temporarily housed at the Hongren Hotel on Jingxin Street by the Zhonghe District Office.[7][30]

Aftermath

After learning of the fire, then Mayor of New Taipei City Eric Chu visited the scene that evening to express support for firefighters and to receive updates on rescue efforts and post-disaster arrangements.[29] Nine victims were sent to Taipei Medical University Shuang-Ho Hospital , Taipei Tzu Chi Hospital, Cardinal Tien Hospital in Xindian, and Cardinal Tien Hospital in Yonghe. Social workers stationed at these hospitals assisted victims' families and provided necessary support.[30][31] Residents from the first and second floors were temporarily accommodated in nearby hotels by the Zhonghe District Office for up to five days.[7]

Deputy Mayor Hou Yu-ih convened an emergency meeting on 23 November, instructing police to strengthen the "building sweep operation" and calling for inspections of residences rented to students, migrant workers, low-income households, and buildings with complicated occupancy. Inspections focused on fire safety equipment and public safety violations, with illegal structures referred for further action.[32] In addition to immediate condolence payments of NT$10,000 for each deceased victim and NT$5,000 for each injured person, the city government provided NT$200,000 to each bereaved family and an additional NT$100,000 to the families of foreign migrant workers. Funeral expenses were fully covered by the New Taipei City Government.[33]

Eric Chu and Hou later visited bereaved families at Banqiao Funeral Home on 23 November and 1 December. Hou instructed the Department of Social Welfare and the Funeral Management Office to provide full assistance and arranged with the Indonesian Economic and Trade Office in Taipei to repatriate the remains of two Indonesian victims for burial.[34][35] Volunteers from the Tzu Chi Foundation visited the scene, brought food and bread to firefighters and police officers, and provided emergency assistance and relief funds to victims and their families.[36][37]

Police immediately established a special task force. Hou stated that the fire was unlikely to have been caused by electrical malfunction, noting that the walls were blackened with soot and that the origin did not appear to be inside a room. Suspecting arson, he ordered investigators to review surveillance footage.[22][23][38] At 03:00 on 23 November, police arrested Li Guohui at the intersection of Huaxin Street and Xingnan Road Section 2. Li falsely claimed that he had purchased gasoline to refuel a vehicle, but investigators discovered that he did not own one.[22][23][38]

Prosecutors charged Li with public endangerment and murder and transferred him to the New Taipei District Prosecutors Office. Following questioning, prosecutors requested detention, and the New Taipei District Court approved the request early on 24 November.[15][39]

Landlord Lian Qiuxiang was investigated on suspicion of public endangerment and negligent homicide. She was transferred to The New Taipei District Prosecutors Office on the afternoon of 23 November and was released on NT$50,000 bail later that evening.[23][39] On 24 November, officials accompanied structural engineers back to the scene for inspection. The Public Works Department imposed a NT$300,000 fine and requested judicial authorities to freeze her assets.[40] Lian was later sentenced by the New Taipei District Court to two years' imprisonment for negligent homicide. On appeal, the Taiwan High Court reduced the sentence to one year and ten months, and the Supreme Court upheld the ruling, making the sentence final.[41]

The tragedy prompted a surge of reports concerning illegal structures. Between 23 and 24 November, the city's Demolition Squad received 194 complaints through phone calls and emails.[42] The Public Works Department announced that it would begin forcibly demolishing 205 registered rooftop additions on 8 December. Continued inspections led some owners to remove illegal structures voluntarily, reducing the number of pending cases to 124.[43]On the first day of the demolition campaign, the first case addressed was the illegal rooftop additions at Nos. 387-3 and 389-3 Jingxin Street, near Nanshijiao in Zhonghe District, which, like the fire site, were located in the surrounding area..[44]

On the same day, legislator Lin Chun-hsien proposed amendments to the Building Act to establish a "Whistleblowing", converting fines for illegal structures—ranging from NT$60,000 to NT$300,000—into rewards for tenants who report unsafe Rental housing, thereby encouraging reporting and providing legal protection.[45]

Trials

  • 7 June 2018: The New Taipei District Courtsentenced Li Guohui to death and deprived him of civil rights for life for murder.[46]
  • 14 May 2019: The Taiwan High Court overturned the original ruling but again sentenced Li to death and lifelong deprivation of civil rights.[47]
  • 31 July 2019: The Supreme Court（Taiwan） overturned the judgment and remanded the case to the High Court.[48]
  • 31 March 2020: Upon retrial, the High Court again sentenced Li to death and lifelong deprivation of civil rights.[49]
  • 23 July 2020: The Supreme Court once again overturned the ruling and ordered another retrial.[50]
  • 14 April 2021: In the second retrial, the Taiwan High Court again imposed the death penalty and lifelong deprivation of civil rights.[51]
  • 23 December 2021: The Supreme Court（Taiwan） for a third time overturned the High Court ruling and remanded the case for further proceedings.[52]

References

  1. ↑ "中和出租套房火警 九死" [Fire in Zhonghe Rental Unit Kills Nine]. bcc.com.tw. Archived from the original on 2017-12-01. Retrieved 2026-06-20.
  2. 1 2 3 4 "中和出租套房火警 釀8死1命危[更新]" [Fire at Zhonghe Rental Unit Leaves 8 Dead, 1 Critically Injured [Updated]]. CNA. Archived from the original on 2017-11-22. Retrieved 2026-06-20.
  3. 1 2 3 4 5 "中華民國內政部消防署全球資訊網->【22日新北市中和區興南路出租套房火災，9人死亡、2人輕傷送醫】(結報)". nfa.gov.tw (in Chinese (Taiwan)). 2013-05-14. Archived from the original on 2017-12-01. Retrieved 2026-06-20.
  4. 1 2 3 "中和大火 9死2傷名單" [List of 9 Dead and 2 Injured in Zhonghe Fire]. Archived from the original on 2017-12-01. Retrieved 2026-06-20.
  5. 1 2 3 4 5 "火6分鐘害9命！和好友爆口角 竟縱火燒公寓" [Fire claims 9 lives in just 6 minutes! Apartment set ablaze following a heated argument with a friend.]. 東森新聞. Archived from the original on 2017-12-01. Retrieved 2026-06-20.
  6. 1 2 林煒傑 (2017-11-23). "縱火殺9命！緬甸籍華僑曾二度縱火　買汽油犯案畫面曝光" [Arson kills nine! Footage reveals Myanmar-born ethnic Chinese man—who had previously committed arson twice—buying gasoline for the crime.]. www.ettoday.net (in Traditional Chinese). Retrieved 2026-06-20.
  7. 1 2 3 民間全民電視公司 (2017-11-23). "中和火災受災戶18人 安置旅社心酸哽咽" [18 victims of the Zhonghe fire, now sheltered in a hostel, choke up with emotion as they recount their ordeal.]. 民視新聞網 (in Traditional Chinese). Retrieved 2026-06-20.
  8. ↑ "華人在緬甸出現的歷史" [The History of the Chinese Presence in Myanmar]. library.taiwanschoolnet.org. Archived from the original on 2016-09-16. Retrieved 2026-06-20.
  9. ↑ "什麼是「臺灣心。緬甸情」？" [What is "Taiwan's Heart, Myanmar's Spirit"?]. library.taiwanschoolnet.org. Archived from the original on 2016-09-16. Retrieved 2026-06-20.
  10. ↑ 民間全民電視公司 (2017-11-23). "緬甸一條街！ 臨近中和惡火公寓" ["Myanmar Street"—near the Zhonghe apartment building where a deadly fire broke out.]. 民視新聞網 (in Traditional Chinese). Retrieved 2026-06-20.
  11. ↑ "中和"緬甸街"多移工 便宜出租套房普遍" [Zhonghe’s "Burma Street" has a large population of migrant workers, making affordable studio rentals commonplace.]. 公視新聞網 PNN (in Traditional Chinese). 2017-11-23. Retrieved 2026-06-20.
  12. 1 2 自由時報電子報 (2017-11-24). "中和大火／10年前被檢舉違建...沒事" [Zhonghe Fire: Reported for Illegal Construction 10 Years Ago... Nothing Happened]. 自由時報電子報 (in Chinese (Taiwan)). Archived from the original on 2025-04-30. Retrieved 2026-06-20.
  13. ↑ 中時新聞網 (2017-11-23). "影》違法隔間年收300萬租金 檢警究責約談女房東" [[Video] Illegal partitions generate 3 million in annual rent; prosecutors and police summon landlady for questioning.]. 中時新聞網 (in Chinese (Taiwan)). Retrieved 2026-06-20.
  14. ↑ 聯合新聞網. "中和火警公寓隔間圖曝光！房東打通樓隔成28間 月入10萬起" [Floor plan of the partitioned apartment involved in the Zhonghe fire revealed! Landlord knocked through walls to create 28 units, generating monthly income starting at NT$100,000.]. 聯合新聞網. Archived from the original on 2018-10-21. Retrieved 2026-06-20.
  15. 1 2 中央通訊社 (2017-11-23). "中和大火案嫌犯緬甸華僑 今年曾兩度縱火" [Suspect in Zhonghe Arson Case—an Ethnic Chinese from Myanmar—Had Set Fires Twice Earlier This Year]. 中央社 CNA (in Chinese). Retrieved 2026-06-20.
  16. ↑ 自由時報電子報 (2017-11-24). "中和大火／10年前被檢舉違建...沒事". 自由時報電子報 (in Chinese (Taiwan)). Archived from the original on 2025-04-30. Retrieved 2026-06-20.
  17. 1 2 柳名耕 (2017-11-24). "中和9死／縱火男辯「有聲音叫我做」恐再犯　檢方聲押獲准" [Zhonghe Arson (9 Dead): Suspect Claims "Voices Told Me to Do It"; Prosecutors Secure Detention Order Amid Risk of Reoffending.]. www.ettoday.net (in Traditional Chinese). Retrieved 2026-06-20.
  18. 1 2 聯合新聞網. "中和惡火／起火點在樓梯間 阻斷逃生路" [Zhonghe Fire / Blaze Started in Stairwell, Blocking Escape Route]. 聯合新聞網. Archived from the original on 2017-12-09. Retrieved 2026-06-20.
  19. ↑ 自由時報電子報 (2017-11-23). "中和大火9死2傷 消防局分析：6大不利原因害命" [Zhonghe Fire Leaves 9 Dead, 2 Injured; Fire Department Identifies 6 Fatal Factors]. 自由時報電子報 (in Chinese (Taiwan)). Archived from the original on 2025-04-30. Retrieved 2026-06-20.
  20. ↑ 陳豐德 (2017-11-23). "中和9死／木造隔間套房4千元1間！　租客：多逃逸移工" [Zhonghe Fire (9 Dead): Wooden-Partitioned Units Rented for 4,000 Yuan—Tenants Include Many Undocumented Migrant Workers]. www.ettoday.net (in Traditional Chinese). Retrieved 2026-06-20.
  21. ↑ 中時新聞網 (2017-11-23). "中和九死火警 李嫌坦承吸安毒稱：有人叫我點火" [Zhonghe Fire That Nearly Claimed Nine Lives: Suspect Confesses to Meth Use, Claims Someone Ordered Him to Start the Blaze]. 中時新聞網 (in Chinese (Taiwan)). Retrieved 2026-06-20.
  22. 1 2 3 自由時報電子報 (2017-11-23). "中和縱火犯半年3度縱火 檢警傳喚、拘提不到釀慘劇 - 社會 - 自由時報電子報" [Zhonghe Arsonist Sets Fires Three Times in Six Months; Failure to Appear After Summons and Arrest Warrant Leads to Tragedy]. 自由時報電子報 (in Chinese (Taiwan)). Archived from the original on 2025-04-30. Retrieved 2026-06-20.
  23. 1 2 3 4 5 聯合新聞網. "台版劏房悲歌 中和暗夜惡火奪9命始末整理" [A Tragedy of "Subdivided Units" in Taiwan: A Detailed Account of the Deadly Late-Night Fire in Zhonghe That Claimed Nine Lives]. 聯合新聞網. Archived from the original on 2018-07-10. Retrieved 2026-06-20.
  24. ↑ 聯合新聞網. "中和火警命案 縱火嫌犯李國輝曾變裝逃亡" [Fatal Fire in Zhonghe: Arson Suspect Li Guo-hui Disguised Himself While Fleeing]. 聯合新聞網. Archived from the original on 2018-07-10. Retrieved 2026-06-20.
  25. ↑ 中時新聞網 (2017-11-23). "不要跳!圍觀民眾救受困男一命 - 社會" [Don't jump! Bystanders save the life of a trapped man.]. 中時新聞網 (in Chinese (Taiwan)). Retrieved 2026-06-20.
  26. 1 2 聯合新聞網. "中和大火釀9死2傷 多名死者國籍不詳" [Zhonghe fire leaves 9 dead and 2 injured; nationalities of several victims unknown.]. 聯合新聞網. Archived from the original on 2017-12-10. Retrieved 2026-06-20.
  27. ↑ 王致凱 (2017-11-23). "違建斷逃生路！中和暗夜惡火奪9命　25隔間套房全面燃燒" [Illegal structure blocks escape route! Deadly late-night fire in Zhonghe claims 9 lives; 25 partitioned rental units engulfed in flames.]. www.ettoday.net (in Traditional Chinese). Retrieved 2026-06-20.
  28. ↑ "中和大火2焦屍身分出爐　各為男緬甸華僑、女台中人" [Identities of the two charred bodies from the Zhonghe fire have been confirmed: a male ethnic Chinese from Myanmar and a female from Taichung.]. 蘋果日報 (in Chinese (Taiwan)). Archived from the original on 2017-12-09. Retrieved 2026-06-20.
  29. 1 2 中央通訊社 (2017-11-23). "中和大火 舊違建木造隔間濃煙斷生路" [Zhonghe Fire: Wooden Partitions in Old Illegal Structure Trap Victims in Thick Smoke]. 中央社 CNA (in Chinese). Retrieved 2026-06-20.
  30. 1 2 中時新聞網 (2017-11-23). "中和縱火案釀9死 市府致贈罹難者救助金" [Zhonghe Arson Attack Leaves 9 Dead; City Government Presents Relief Funds to Victims' Families]. 中時新聞網 (in Chinese (Taiwan)). Retrieved 2026-06-20.
  31. ↑ 自由時報電子報 (2017-11-23). "中和大火 最完整、最新傷亡名單出爐" [Zhonghe Fire: Most Complete and Up-to-Date Casualty List Released]. 自由時報電子報 (in Chinese (Taiwan)). Archived from the original on 2025-04-30. Retrieved 2026-06-20.
  32. ↑ 新北市政府 (2017-11-23). "侯友宜：加強清查隔間套房 維護民眾生命財產安全" [Hou Yu-ih: Intensify inspections of subdivided rental units to safeguard public life and property.]. 新北市政府. Retrieved 2026-06-20.
  33. ↑ 新北市政府 (2017-11-23). "中和興南路火災 市府致贈罹難者救助金20萬元 外籍移工部分協助家屬來台並發放10萬元慰問金及協助喪葬事宜" [Regarding the fire on Xingnan Road in Zhonghe, the city government has provided 200,000 NTD in relief funds to the families of the deceased. For foreign migrant workers, the government is assisting family members in traveling to Taiwan, providing 100,000 NTD in condolence payments, and helping with funeral arrangements.]. 新北市政府. Retrieved 2026-06-20.
  34. ↑ 張曼蘋 (2017-11-23). "中和9死家屬怒求「判嫌死刑」　侯友宜安慰：最好關到死" [Families of the 9 victims of the Zhonghe fire angrily demand the death penalty for the suspect; Hou Yu-ih offers comfort, saying, "Ideally, he should be locked up until he dies."]. www.ettoday.net (in Traditional Chinese). Retrieved 2026-06-20.
  35. ↑ 中時新聞網 (2017-12-01). "中和縱火案焦屍確認身分 侯友宜慰問家屬" [Identity of Charred Body from Zhonghe Arson Case Confirmed; Hou Yu-ih Offers Condolences to Family]. 中時新聞網 (in Chinese (Taiwan)). Retrieved 2026-06-20.
  36. ↑ 中央通訊社 (2017-11-23). "中和大火 慈濟慰問關懷" [Tzu Chi Offers Comfort and Support Following Zhonghe Fire]. 中央社 CNA (in Chinese). Retrieved 2026-06-20.
  37. ↑ 慈濟基金會. "中和無情火 有情共度難關" [A Merciless Fire in Zhonghe; Compassion Helps Weather the Crisis Together] (in Chinese (Taiwan)). Archived from the original on 2017-12-10. Retrieved 2026-06-20.
  38. 1 2 中央通訊社 (2017-11-23). "中和大火案嫌犯緬甸華僑 今年曾兩度縱火 | 社會". 中央社 CNA (in Chinese). Retrieved 2026-06-20.
  39. 1 2 中央通訊社 (2017-11-24). "中和大火被告羈押 檢：迅速縝密偵查" [Suspect in Zhonghe fire case remanded; prosecutors pledge swift, meticulous investigation.]. 中央社 CNA (in Chinese). Retrieved 2026-06-20.
  40. ↑ 中時新聞網 (2017-11-25). "奪命公寓現任房東 遭重罰30萬" [Current Landlord of Deadly Apartment Fined Heavily (300,000 Yuan)]. 中時新聞網 (in Chinese (Taiwan)). Retrieved 2026-06-20.
  41. ↑ 焦點判決編輯部 (2022-12-01). "法規範評價——最高法院111年度台上字第2323號判決". 元照出版公司 (2022:12): 1–3 – via lawdata.com.tw.
  42. ↑ 陳豐德 (2017-11-24). "9死燒出安全疑慮！　新北拆除大隊2日獲報近200件違建" [Fatal fire sparks safety concerns; New Taipei’s demolition squad received reports of nearly 200 illegal structures in just two days.]. www.ettoday.net (in Traditional Chinese). Retrieved 2026-06-20.
  43. ↑ 聯合新聞網. "強拆頂樓出租套房 新北：拆違建沒終止日" [Forced Demolition of Rooftop Rental Units; New Taipei: No End Date for Demolishing Illegal Structures]. 聯合新聞網. Archived from the original on 2017-12-09. Retrieved 2026-06-20.
  44. ↑ 聯合新聞網. "拆除大隊機具開進雅房 新北違建住戶：我們來不及搬" [Demolition crew machinery moves into the subdivided rental unit; New Taipei illegal structure residents say: "We didn't have time to move out."]. 聯合新聞網. Archived from the original on 2017-12-09. Retrieved 2026-06-20.
  45. ↑ 聯合新聞網. "違建頻火災 立委提案訂「吹哨者條款」" [Frequent fires in illegal structures prompt lawmaker to propose "whistleblower clause."]. 聯合新聞網. Archived from the original on 2017-12-09. Retrieved 2026-06-20.
  46. ↑ "臺灣新北地方法院 107 年重訴字第 11 號刑事判決" [Criminal Judgment No. 11 (Year 107) of the New Taipei District Court, Taiwan]. law.judicial.gov.tw (in Chinese (Taiwan)). Archived from the original on 2021-05-10. Retrieved 2026-06-20.
  47. ↑ "臺灣高等法院 107 年上重訴字第 24 號刑事判決" [Criminal Judgment No. 24 (Year 107, Shang-Chong-Su) of the Taiwan High Court]. law.judicial.gov.tw (in Chinese (Taiwan)). Archived from the original on 2021-05-10. Retrieved 2026-06-20.
  48. ↑ "最高法院 108 年台上字第 1845 號刑事判決" [Supreme Court Criminal Judgment No. 1845 (Tai-Shang-Zi) of the 108th Year]. law.judicial.gov.tw (in Chinese (Taiwan)). Archived from the original on 2021-05-10. Retrieved 2026-06-20.
  49. ↑ "臺灣高等法院 108 年上重更一字第 2 號刑事判決" [Criminal Judgment No. 2 (Year 108, Shang-Chong-Geng-Yi) of the Taiwan High Court]. law.judicial.gov.tw (in Chinese (Taiwan)). Archived from the original on 2021-05-14. Retrieved 2026-06-20.
  50. ↑ "最高法院 109 年台上字第 2309 號刑事判決" [Supreme Court Criminal Judgment No. 2309 (Tai-Shang-Zi) of the 109th Year (2020)]. law.judicial.gov.tw (in Chinese (Taiwan)). Archived from the original on 2021-05-14. Retrieved 2026-06-20.
  51. ↑ "臺灣高等法院 109 年上重更二字第 5 號刑事判決". law.judicial.gov.tw (in Chinese (Taiwan)). Archived from the original on 2021-05-14. Retrieved 2026-06-20.
  52. ↑ "最高法院 110 年度台上字第 3445 號刑事判決" [Supreme Court Criminal Judgment No. Tai-Shang-Zi 3445 of the Year 110 (2021)]. law.judicial.gov.tw (in Chinese (Taiwan)). Archived from the original on 2021-12-29. Retrieved 2026-06-20.
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