A review of Zero Dark Thirty includes this gem of a quote, one writer in effect overhearing arguably the first great modern non-fiction writer, George Orwell, talking about what we today call literary non-fiction, and what fictionalization he allows in a non-fiction story. .
There were few more minute observers of fact than George Orwell. As Timothy Garton Ash has written, if Orwell had a God it was Kipling’s “God of Things as They are.” Yet, as Garton Ash says of Orwell: “One of his most powerful early essays describes witnessing a hanging in Burma. But he later told three separate people that this was ‘only a story.’ So did he ever witness a hanging? He annotates a copy of “Down and Out in Paris and London” for a girlfriend: this really happened, this happened almost like this, but “this incident is invented.”’
Orwell was a polemicist trapped in a realist's body. That's what made his fiction so striking -- its consciousness of its own politics.
At the same time, note the assumption embedded in that quote or Orwell's. An essay will focus on a story. Of course! That's his attitude, and that's the forgotten Orwell -- the great storyteller.
Here's an example, from the story about a hanging::
We set out for the gallows. Two warders marched on either side of the prisoner, with their rifles at the slope; two others marched close against him, gripping him by arm and shoulder, as though at once pushing and supporting him. The rest of us, magistrates and the like, followed behind. Suddenly, when we had gone ten yards, the procession stopped short without any order or warning. A dreadful thing had happened — a dog, come goodness knows whence, had appeared in the yard. It came bounding among us with a loud volley of barks, and leapt round us wagging its whole body, wild with glee at finding so many human beings together. It was a large woolly dog, half Airedale, half pariah. For a moment it pranced round us, and then, before anyone could stop it, it had made a dash for the prisoner, and jumping up tried to lick his face. Everyone stood aghast, too taken aback even to grab at the dog..
In the end, it's not Orwell's rules that make him special. It's his writing.