On the fourth day of the sixth month of 822, Saichō died. His most influential lay patrons, Minister of the Right (udaijin) Fujiwara no Fuyutsugu, Vice Councilor (chūnagon) Yoshimine no Yasuyo, Provisional Vice Councilor (gonchūnagon) Fujiwara no Mimori, and Vice Controller of the Left (sachūben) Ōtomo no Kunimichi, submitted a petition to the Emperor requesting approval of the Shijōshiki (Regulations in Four Articles). Seven days after he died, Saichō’s request was granted. …
Saichō’s death had presented Fuyutsugu and Saichō’s other supporters with a chance to press for approval of the Shijōshiki. In addition, it had presented the court with an opportunity to grant Saichō’s request as a token of its grief at his passing. Thus the court was able to honor Saichō without allowing the Tendai School an undue advantage over the Nara schools. Approval of Saichō’s requests during his lifetime would have been the equivalent of court recognition of Tendai superiority.
Saichō: The Establishment of the Japanese Tendai School, p162-163