While agreeing that rule of law without democracy is the most likely path to political reform in the short term, I suggest that in the long run democracy will be necessary to solve some of the divisive social issues that have arisen in China as a result of economic reforms and social changes. I also suggest that Pan's understanding of rule of law is overly simplistic and that his faith in the miraculous power of rule of law to put an end to corruption, resolve pluralistic conflicts and produce a just and harmonious society is wildly exaggerated. Finally, I expand the scope of Pan's proposal to explore various possible administrative law reforms and legal reforms more generally required to realize rule of law in China, while suggesting that ultimately their success turns on issues of power that exceed the limits of the law.