The disdainful reviews meted out to [Ai no borei (Empire of Passion)] are surely related to the film's gravity of expression, by comparison with the sex and violence of Ai no corrida [In the Realm of the Senses]. Oshima has moved further back in time (the earlier film took place in the Thirties) to a Nineteenth-century setting…. But the dictates of Japanese formalism where period works are concerned have not inhibited Oshima's sense of outrage. There is a fury that burns like a bright diamond at the heart of Ai no borei, and Seki and Toyoji live passionately to their last gasp. As Oshima says, in their reluctance to rebel, there dwells a curious strength.
These lovers are unhinged by the ghost of the man they have conspired to kill, and Oshima [creates] an oneiric atmosphere, in which dream and actuality merge. He introduces an element of surrealism by forcing one to watch the murdered man's body tumble in slow-motion into a gigantic pit, engulfing the camera. Death and sexual ecstasy are intertwined. (pp. 218-19)
In the final analysis, the ghost story is only an idiom for Oshima. His prevailing interest is in the impossibility of free love in a social grid. Seki may be sufficiently swept away by passion to acquiesce in the murder of her husband, but as his ghost assails her, and she shelters behind a bank of protective fires, she exclaims to Toyoji that she wants to live "like a couple."… Guilt is ranged against desire, death against life. The lovers in Ai no borei … perish at the hands of a community that is insignificant beside their rage for experience. (p. 219)
Peter Cowie, "'Ai no borei' ('Empire of Passion')," in International Film Guide 1979, edited by Peter Cowie (copyright © 1978 by Thomas Yoseloff Ltd.), The Tantivy Press, 1979, pp. 218-19.