Exhibit 8.2

                                                              5th December, 2003


China Life Insurance Company Limited
16 Chaowai Avenue
Chaoyang District
Beijing 100020
China

Dear Sirs,

[NAME IN CHINESE CHARACTERS] China Life Insurance Company Limited (the Company)

We act as Hong Kong counsel for the Company, a joint stock limited company
incorporated in the People's Republic of China (PRC), in connection with the
proposed offering of its H shares and American depositary shares representing
such H shares (ADSs).

We have reviewed the section headed "Taxation--Hong Kong" on pages 219 and 220
of Amendment No. 2 to the Registration Statement on F-1 dated 5th December, 2003
(the F-1) for the purposes of the public filing of the F-1 with the United
States Securities and Exchange Commission. We have also reviewed such Hong Kong
laws and regulations as we consider necessary for the purpose of giving this
opinion. We have not examined any other documents or carried out any searches or
enquiries for the purpose of this letter.

This opinion is given only as to the laws of the Hong Kong Special
Administrative Region of the PRC as in force at the date of this opinion. We
have made no investigation and no opinion is expressed or implied as to the laws
of any other jurisdiction, including the United States. This opinion is being
given to you solely for use in connection with the proposed offering of ADSs in
the United States.

Based on and subject to the foregoing, we confirm that the statements as set out
in the section headed "Taxation--Hong Kong" on pages 219 and 220 of the F-1,
represent our opinion.

We hereby consent to this opinion being publicly filed as an exhibit to the F-1
with the United States Securities and Exchange Commission on 5th December, 2003,
and to the reference to us under the heading "Taxation--Hong Kong" in the F-1.
In giving such consent, we do not hereby concede that we are within the category
of persons whose consent is required under Section 7 of the Act or the rules and
regulations of the Commission thereunder.

Yours faithfully,

/s/ Allen & Overy

Allen & Overy