There appears to be a division between studies on treatises of Ottoman political philosophy written in the nineteenth century and studies on those produced in the sixteenth, seventeenth and eighteenth centuries. While the earlier texts are evaluated in terms of classical Islamic and Ibn Khaldunian concepts, the nineteenth century ones are assessed in terms of how they engage with modernity. However, there are examples produced in the nineteenth century that transcend this binary approach and call for a different evaluation. One of them is Ottoman statesman Mahmud Nedim Pasha’s (1817-1883) political credo, Ayine-i Devlet. Being written following the enthronement of Abdülaziz in 1861, Ayine-i Devlet was Mahmud Nedim’s advice for the Sultan in which he discussed the reasons for what he saw as the acceleration of the Empire’s decline over the last decades. Although so far it has been represented as a text that demonstrated its author’s anti-reformist tendencies, Ayine-i Devlet is, in fact, a self-conscious reinterpretation of a Khaldunian understanding of political power in a modern context. Mahmud Nedim was particularly influenced by Ibn Khaldun in his approach to the political relations between the bureaucracy and the Sultan as well as in his periodization of historical stages of the Ottoman Empire. Since Mahmud Nedim’s main emphasis was on the fallacies of newly fledgling modern bureaucracy, his criticism at times even gains a Weberian character, resulting in a remarkable treatise in which an interpretation of Ibn Khaldun in the 1860s heralded several issues modern sociologists would begin discussing not until half a century later. This paper discusses Mahmud Nedim’s political views on the Ottoman dynasty, autocracy, bureaucracy, history and the rule of law by demonstrating that they have their roots in classical Ottoman political philosophy and Khaldunian concepts as well as reflecting on their modern nature. This discussion is conducted through an analysis of the comparison of the political and administrative system Mahmud Nedim draws between the nineteenth-century Europe and the different stages of the Ottoman Empire according to his own periodization of Ottoman history.