Hui-neng 惠能(638-713), who succeeded Hung-jen as the Sixth Patriarch, was not an advocate as sitting as the path to enlightenment. With him, we have a distinction between tso-ch'an which attains enlightenment through sitting, and tso-ch'an which attains enlightenment without sitting. Hui-neng had a different interpretation of what tso-ch'an means. He said that when there is no mind, or no thoughts arising, that is called "sitting" (tso). When you see internally that the self-nature is not moving, that is Ch'an.

This was different from the sitting tso-ch'an of Bodhidharma. The Sixth Patriarch took his inspiration from the Samadhi of One Act, described in the Manjusri Sutra mentioned above. The method is to put your mind steadfastly on the One Dharma Realm 一法界, in which there is no differentiation into forms. Quoting from the Vimalakirti Sutra 維摩詰經, he also said, "The straightforward mind is the Path." Its meaning is that all forms are equivalent to one form. Any time, any place, whether walking, standing, sitting or lying down, there is no situation that is not an opportunity to practice tso-ch'an. In this view sitting was not only not necessary, but could be a hindrance.

Fundamentals of Tso-ch'an

As we saw above, tso-ch'an was practiced in China long before the appearance of Ch'an. The earlier masters practiced according to methods in the Hinayana sutras, which emphasized the techniques collectively known as samatha-vipasyana. Generally speaking, these were methods for achieving samadhi through three aspects: regulating one's body, regulating one's breathing, and regulating one's mind.