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Shen Buhai (Chinese: 申不害; pinyin: Shēn Bùhài; Wade-Giles: Shen Puhai, d. 337 BC) was a Chinese bureaucrat who was the Chancellor of Han under Marquis Zhao of Han from 351 BC to 337 BC. Shen was born in the State of Zheng; he was likely to have been a minor official for the State of Zheng. After Han conquered Zheng in 375 BC, he rose up in the ranks of the Han officaldom. He was an innovator of administrative bureaucracy and was often linked with the Legalists. He is credited with writing the Shenzi. Shen Buhai successfully reformed the bureaucracy in the State of Han; his reforms would later be copied by other states. He died of natural causes while in office.

Shen was chiefly concerned with government administration through the use of bureaucracy. His system required a strong ruler at the center. Shen Buhai believed that the ideal ruler should remain distant from his officials, keeping his innermost thoughts secret and maintaining an independence of thought. According to Shen, the ruler needed to be the loneliest person in the world.

To Shen Buhai, the greatest threat to a ruler's power came from within. He believed that threats from powerful, independent ministers to usurp power were more dangerous than threats from external forces. Shen championed the concept of Shu (術 administrative methods/techniques). Shen advocated for maintaining checks against the power of officials, and in equality among the officials.

He touted the primacy of finding the right person for the job (xingming 刑名). He evaluated officials based on skill, achievement and seniority. He also encouraged routine assessments of officials.

Shen Buhai promulgated his own concept of wu wei, which caused some scholars to link him with Taoism. In Shen's case, he believed that rulers maximized power by exercising power as little as possible. He also encouraged rulers to limit their scope, leaving the details of administration to capable ministers. Some modern scholars argued that Shen's legalism was more a blend of Taoism and Legalism than just purely the conceptual Shu school of Legalism.

Shen Buhai was criticized by both Confucians and Legalists. Unlike the Confucians, he never mentioned virtue; unlike the Shang Yang wing of the Legalists, he never mentioned Fa (Law). The Confucian Xun Zi strongly criticized Shen Buhai's emphasis on secrecy and lack of trust in ministers. The legalist Han Fei criticized Shen for paying too much attention to methodology at the expense of laws.

Although Shen Buhai was later linked inseparably with the Legalists, it was Hanfei who merged the ideas of Shen Buhai with those of Shang Yang. In 141 BC, under the reign of Emperor Wu of Han, Shen Buhai's name was listed with other legalist thinkers whose ideas were officially banned from the government; from that point on, scholarship on the ideas of Shen Buhai went into a steep decline.

Shen Buhai was known for his cryptic writing style. He was credited with writing a now extinct two chapter text, the Shenzi (申子). During the Han Dynasty, the compilation was organized into two outer chapters, and six inner chapters, but the admeasurement might be different as time goes by. The last mention of this work occurred in 1616, some scholars believe his work did not survived. During the Qing Dynasty, three major attempts were made to reconstruct the contents of this work. The only traces of this work remain in surviving texts which quote from the Shenzi in Qunshu Zhiyao, compiled in 631, and Yilin, compiled around 786.

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