A topic from AEG's L5R CCG Rules forum, copied for Oracle of the Void from a copy of the forum saved in October 2015, so pages it didn't save are missing. Players' names are left out; the rules officials are named. Rulings are as they stood on these dates; later rulings, the rulebooks and the Rules Archive may differ.
A player, 19 June 2012
Can the performing unbowed Nonhuman for Duel of Serpents battle ability be a Nonhuman follower at the battlefield?
Duel of Serpents Open: If another player has higher Family Honor than you, bow your performing Nonhuman or Spirit: Gain 3 Honor. Battle: Choose your performing unbowed Nonhuman or Spirit and target an enemy card without attachments: Bow it.
Thanks,
Justin
Ben Higgins (rules official), 20 June 2012
Can the performing unbowed Nonhuman for Duel of Serpents battle ability be a Nonhuman follower at the battlefield?
Thanks,
Justin
Yes. Any Nonhuman or Spirit card capable of performing actions may be bowed to satisfy the cost of Duel of Serpents. As per the Glossary entry on Perform: "Only Personalities and Followers may perform actions; no other card type may be chosen as a performer. "