On 23 June 2009 , the Beijing procuratorate ( a government officer who investigates crimes ) approved Liu Xiaobo 's arrest on charges of `` suspicion of inciting subversion of state power , '' a crime under Article 105 of the Law of the People 's Republic of China . On 23 June 2009 , the Beijing procuratorate approved Liu Xiaobo 's arrest on charges of `` suspicion of inciting subversion of state power , '' a crime under article 105 of China 's Criminal Law .