Waseda University Repository

Developments in 2023 ̶ Academic Societies 13910.　Philosophy of LawThe Japan Association of Legal Philosophy held its 2023 Annual Conference at Doshisha University on 4-5 November 2023.Reports on Individual Themes:A:（1） “Justification of ‘Uncivil Disobedience’ by C. Delmas’s Natural Duty of Justice” Keisuke Yamamoto （Part-Time Lecturer, Seisen University）（2） “lex naturalis and ius naturale” Kenji Hirate （Professor, Gifu Kyoritsu University）B:（1） “On Regulation of Freedom of Expression: Concerning the Role of the Government” Akihiro Oe （Doctoral Course Student, University of Tokyo）（2） “The Significance of “Animal Welfare”: EU Farm Animal Welfare Legislation in Animal Law” Moe Honjo （Associate Professor, Nagasaki University）Workshops:Group 1: “Sex, Reproduction, and Law”（1） “Introductory Remarks on the Purpose of the Project” Hirono Ikeda （Professor, Yamagata University）（2） “Contractualization of Marriage and the Future of Child-Rearing Institutions” Kazuki Matsuda （Research Associate, Waseda University）（3） “Feminist Theories of the Body and Legal Institutions: Ashley X’s Case Study as a Clue” Yoshie Ogumi （Lecturer, Doshisha University）（4） “Yet Another, or Trans Justice Theory” Rokuro Ayabe （Assistant Professor, Nagoya College）140 Waseda Bulletin of Comparative Law Vol. 43Group 2: “Wherein Lies the Value of Diversity?”（1） “Introductory Remarks on the Purpose of the Project” Fumihiko Ishiyama （Professor, Chuo University）（2） “Diversity over Disability/Gender: Thinking from the Side of the Boundary Zones Where it Sticks out of Society” Takehiko Yoshioka （Professor, Saga University）（3） “The Possibilities and Limits of Diversity: a Multiculturalist Perspective” Seiko Urayama （Associate Professor, Seijo University）（4） “Diversity （Concept, Value, and Design）” Yoshiki Wakayama （Professor, Gakushuin University）Group 3: “Legal Philosophy and Positive Law/Legal Practice”（1） “Introductory Remarks on the Purpose of the Project” Yachiko Yamada （Professor, Chuo University）（2） “Through the Differentiation and the Maturation of Legal Thinking” Ryosuke Kikuchi （Associate Professor, Kyoto University）（3） “Are We Talking Past Each Other That Much?: the Relationship of Contemporary Justice Theory and Positive Law/Legal Practice” Kotaro Yonemura （Professor, Rikkyo University）（4） “The Distance Between Legal Philosophy and Positive Law/Legal Practice” Yachiko Yamada （Professor, Chuo University） （5） Comments Hiroshi Kamemoto （Professor, Meiji University） Itaru Shimazu （Emeritus Professor, Chiba University）Group 4: “Relational Egalitarianism”（1） “Introductory Remarks on the Purpose of the Project” Masami Sumiyoshi （Professor, Aoyama Gakuin University）（2） “The Contemporary Significance of the Debate over ’Distributive’ versus ‘Relational’ Egalitarianism: How Should Relational Egalitarianism Confront ‘Distributive Justice’?” Yuichiro Mori （Associate Professor, Hokkaido University）（3） “Doubts Towards Relational Egalitarianism from a Distributive Egalitarian” Daisuke Fujioka （Associate Professor, Asia University）Developments in 2023 ̶ Academic Societies 141（4） “A Defence of Relational Egalitarianism Divorced from Republicanism” Akira Inoue （Professor, University of Tokyo）Group 5: “The Role of Professionals: in Connection with Contemporary Democratic Theory”（1） “Introductory Remarks on the Purpose of the Project” Takehiro Ohya （Professor, Keio University）（2） “Professionals in Contemporary Governance” Naoya Nagaishi （Associate Professor, University of Tokyo）（3） “Professionals in Democracy” Yoshinori Seki （Professor, Shinshu University）（4） Comments Yo Matsuo （Professor, Nagoya University）Group 6: “The Problem of History in Legal Philosophy”（1） “Introductory Remarks on the Purpose of the Project” Ryuichi Nakayama （Professor, Osaka University）（2） “Between the Universal and the Particular: The Merits and Demerits of Kokutai in the Successions of Law” Taku Morimoto （Professor, Tohoku University of Community Service and Science）（3） “What It Means to Think about Law in East Asia” Yasunori Sugawara （Professor, Hokkai-Gakuen University）（4） “The Significance and Role of the Historical Content of Legal Thought in Western Legal Education: the ‘History of Legal Thought’ for What?” Shintaro Suzuki （Aichi Gakuin University）（5） “The Past and Future of Education and Research in the History of Legal Thought” Yasufumi Suzuki （Lecturer, Momoyama Gakuin University）11.　Comparative LawI.　The Japan Society of Comparative Law held its General Meeting and 

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ACTIVITIES OF ACADEMIC SOCIETIES: 10. Philosophy of Law

Developments in 2023 ̶ Judicial Decisions 691.　Constitutional LawX v. JapanSupreme Court Grand Bench, October 25, 2023.Case No. （Ku） 993, 202077 MINSHU 1792Summary: Article 3, paragraph （1） of the Act on Special Cases in Handling Gender Status for Persons with Gender Identity Disorder ［herein after the GID Act］, which requires the person to have “no reproductive glands” or “lost-function［ing］” glands to change the gender status, is unconstitutional under Article 13 of the Constitution.Reference: Constitution, Articles 13; Article 3, paragraph （1）, item （iv） of the Act of Special Cases in Handling Gender Status for Persons with Gender Identity DisorderMAJOR JUDICIAL DECISIONSJan.─Dec., 202370 Waseda Bulletin of Comparative Law Vol. 43Facts: Article 3 （1） of the GID Act provides that family court may make a ruling of a change in the recognition of the gender status of a person who is a Person with Gender Identity Disorder and who falls under all of the following items: A person （i） is not less than 20 years of age ［18 years after the 2022 Civil Code amendment］,（ii） is not currently married,（iii） currently has no child who is a minor,（iv） has no reproductive glands or whose reproductive glands have permanently lost function, and（v） has a body which appears to have parts that resemble the genital organs of those of the Opposite Gender. The plaintiff satisfies （i） through （iii）, but not （iv） and （v）. The Okayama Family Court and the Hiroshima High Court, Okayama Branch did not approve the plaintiff’s application on that basis.Opinion: Quashed and remanded1. Standard of review Article 13 of the Constitution provides that “all of the people shall be respected as individuals. Their right to life, liberty, and the pursuit of happiness shall, to the extent that it does not interfere with the public welfare, be the supreme consideration in legislation and in other governmental affairs.” It is obvious that freedom not to have one’s body invaded against one’s will （hereinafter simply referred to as the “Freedom from Having the Body Invaded”） is guaranteed by the same Article as an important right related to an existence in which the personality is respected. On the other hand, given that Legal Gender is treated as one of the basic attributes of an individual in various aspects of social life, and the situation in which persons with gender identity disorder are placed is as stated above, it should be said that for a person with gender identity disorder, having the gender status under laws and regulations handled in accordance with the person’s gender identity is an important legal interest combined with an individual’s right to existence in which the personality is Developments in 2023 ̶ Judicial Decisions 71respected. This does not depend on whether or not such a person with gender identity disorder is required to undergo gonadectomy surgery as treatment. Gonadectomy is a surgery to remove the testicles or ovaries and is an intense bodily invasion that involves risk to the life or body of the person and leads to an irreversible result. Accordingly, if a person is forced to undergo such gonadectomy surgery, it should be said that it falls under a material restriction on the Freedom from Having the Body Invaded. It can be said that the Provision restricts the Freedom from Having the Body Invaded in terms of forcing a person with gender identity disorder who does not require gonadectomy surgery as treatment to undergo the same surgery in order to realize an important legal interest in having gender status under laws and regulations handled in accordance with the person’s gender identity. Such a restriction should not be allowed unless it can be said to be necessary and reasonable in light of the importance of the Freedom from Having the Body Invaded, even taking into consideration that the Provision does not directly force persons with gender identity disorder in general to undergo gonadectomy surgery. It is reasonable to understand that whether the Provision conforms to Article 13 of the Constitution as a necessary and reasonable restriction should be determined by comparing the extent to which the restriction is required for achieving the purpose of the Provision, and the content and nature of the freedom restricted and the specific manner, extent, and other factors of the restriction.2. Applying the standard（1） Purpose of the Provision It is understood that the Provision is based on considerations such as the possibility of causing confusion in society due to the occurrence of problems related to parent-child relationships if a child should be born through the reproductive function of the previous gender of a person who had received a Ruling of Change in Recognition of Gender Status, or the need to avoid a sudden change in the manner of distinguishing between men and women based on biological gender, which has been long established. However, even if the Provision were not to exist, it is extremely rare 72 Waseda Bulletin of Comparative Law Vol. 43that the problems related to parent-child relationships occur due to the fact that a person who has received a Ruling of Change in Recognition of Gender Status has a child without the person having undergone gonadectomy surgery. It is possible to resolve some of the aforementioned problems related to parent-child relationships, including whether or not a legal parent-child relationship is established or how to enter the relationship in a family register, through the interpretation of laws and regulations, legislative measures, or other means. It should be said that the need for the restriction under the Provision, which was under consideration at the time of the enactment of the Act on Special Cases, has decreased due to changes in the circumstances that were the premise of the restriction.（2） Medical knowledge concerning the provision It is understood that the purport of the enactment of the Act on Special Cases is to, by the Ruling of Change in Recognition of Gender Status, enhance the effect of treatment given to and eliminate any social disadvantage suffered by persons who have problems in their social life due to their Legal Gender still being their biological gender even though they have received the necessary treatment for gender identity disorder. At the time of such enactment, gender reassignment surgery, including gonadectomy surgery, was positioned as a treatment in the final phase of the step-by-step care approach. Thus, it can be said that the imposition of a requirement that a person requesting a Ruling of Change in Recognition of Gender Status must undergo gonadectomy surgery was reasonably relevant also from a medical perspective in that persons who had received necessary treatment for gender identity disorder were subject to the requirement. However, after the enactment of the Act on Special Cases, medical knowledge of gender identity disorder has advanced, and awareness about the diversity of the symptoms exhibited by persons with gender identity disorder and the ways in which treatment therefore should be given have become generalized. Thus, the concept of a step-by-step care approach need no longer be adopted, and what kind of physical treatment patients require as treatment for gender identity disorder has come to be regarded as depending on each individual patient. Accordingly, deeming a person to have received the necessary treatment is no longer subject to whether the person has undergone gender reassignment surgery, and we have to say Developments in 2023 ̶ Judicial Decisions 73that the imposition of the above requirement is no longer reasonably relevant from a medical perspective. It can be said that, according to the aforementioned advances in medical knowledge, the restriction on the Freedom from Having the Body Invaded under the Provision becomes one that forces a person with gender identity disorder who does not require gonadectomy surgery as treatment to make a harsh choice between two options: the person abandons the Freedom from Having the Body Invaded and accepts gonadectomy surgery as an intense bodily invasion, or the person abandons an important legal interest in having gender status under laws and regulations handled in accordance with the person’s gender identity and decides not to receive a Ruling of a Change in Recognition of Gender Status. It also should be said that the imposition of such a restriction with no reasonable relevance from a medical perspective to achieve the purpose of the Provision as stated above has become excessive, taking into additional consideration that the number of countries that do not require the loss of fertility for a change in the recognition of gender status under laws and regulations has increased.3. Conclusion Comprehensively comparing the need, which has now decreased, for the restriction on the Freedom from Having the Body Invaded under the Provision with the extent of the restriction, which has increased in severity, it cannot be said that the restriction is necessary and reasonable. Article 3 paragraph （1） Item （iv） of the GID Act is unconstitutional. The Supreme Court decision of January 23, 2019 （ruled that the provision is constitutional） is changed. This case is remanded to the prior court for further examination on the argument related to the Item （v） provision.Editorial Note:1. Standard of review The standard of review used by the Supreme Court in this case, as the Supreme Court always likes to do, is a comprehensive consideration of the necessity and reasonableness （purpose and means） of the regulation. To the Anglo-American reader, it is best to think of it as the rational basis standard. It is a standard that favors the government. Unlike the U.S., where the constitutional discourses focus where to use strict scrutiny, it is 74 Waseda Bulletin of Comparative Law Vol. 43rare for the Supreme Court of Japan to use strict scrutiny, regardless of the field. Contrast the rulings presented in the previous issue, Vol. 42 pp. 57-64, which is an exceptional case using strict scrutiny. However, the Supreme Court has recognized that the legal interest to be regulated - the interest in having one’s gender treated in accordance with one’s gender identity under the law - is an important legal one that is tied to an individual’s personal existence. In addition, the Supreme Court clearly states that Article 13 of the Constitution guarantees the Freedom from Having the Body Invaded. As a result, the Supreme Court recognized that the requirement of surgery （invasion of the body） for the realization of gender identity is a restriction of rights （In the Supreme Court’s parlance, “a harsh choice between two options.”）.2. Medical knowledge The greater significance of this decision is that it acknowledges that the GID Act relies on the concept of “gender identity disorder” that has existed since ICD-9 - that it is a “disorder” and requires hormone therapy or surgery to bring the body into conformity with gender identity - and that it is already an inappropriate idea. This is a remarkable change that has not been seen in previous cases related to the GID Act. In stating the background of its decision （not directly cited in this paper）, the Supreme Court noted that psychiatric guidelines have been revised in Japan to recognize that the symptoms exhibited by persons with gender identity disorder are diverse and that the type of physical treatment required will vary from patient to patient. It also points out that the ICD-11 now defines so-called “GID” as “gender incongruence” where the gender assigned at birth differs from the gender identity, and that it is no longer appropriate to refer to it as a “disorder.”  The Supreme Court also noted that in 2017, the European Court of Human Rights held that making reproductive incapacity a requirement for gender reassignment for gender identity conformity is contrary to the European Convention on Human Rights （Although not explicitly mentioned, it certainly appears to be A.P., Garçon and Nicot v. France, 79885/12, 52471/13 and 52596/13）. The fact that an increasing number of countries, including EU, which Developments in 2023 ̶ Judicial Decisions 75do not make loss of reproductive capacity a requirement for changing the legal gender, in addition to requiring medically unnecessary surgery, appears to be considered as a factor that increases the excessiveness of this provision.3. Remaining problems The GID Act, which relies on the concept of “gender identity disorder” since ICD-9, is highly problematic. First, for the plaintiff in this case, even if item （iv） is declared invalid, item （v） stands. He/she should have a body which appears to have parts that resembles the genital organs of those of the Opposite Gender （hereinafter “Appearance Requirement”）. Would the Appearance Requirement also be unconstitutional?  In order to achieve this requirement, the male （in the physical sense） must first have his male genitalia removed. This is clearly a bodily invasion and is within the scope of the reasoning stated by the Supreme Court in this decision. It is noted that the plaintiff in this case also applied for gender reassignment from male to female. However, the Supreme Court remanded on the grounds that the lower court had not decided on the requirement. This, the dissenting opinions of three judges points out, would be nothing more than an unnecessary trouble. The Supreme Court should have declared that item （v） was also unconstitutional, at least as long as the surgery was mandatory. In the case of women （in the physical sense）, the requirement is generally considered to have been satisfied by the enlargement of the external genitalia due to hormone therapy. Does this fall within the scope of this ruling’s reasoning? Perhaps the majority opinion postponed its decision because it did not want to go through the trouble of collecting opinions on this point. The dissenting opinions suggests that hormone therapy can be considered the same as surgery, since medically speaking, some people do not need it and it has side-effects. Next, let us consider the item （i） to （iii）. In light of the majority opinion, it is a hurdle to say that （i）-（iii） are unconstitutional. This is because, while the Supreme Court has clearly stated that freedom from bodily invasion is guaranteed by Article 13 of the Constitution, it has not stated that it is guaranteed by the Constitution with respect to the legal 76 Waseda Bulletin of Comparative Law Vol. 43interest having the gender status under laws and regulations handled in accordance with the person’s gender identity, nor has it cited any other basis. And, looking at the decision as a whole, the Supreme Court seems to be treating the physical invasion, surgery, as a particularly heavy factor to be considered. If this is true, items （i）-（iii）, which do not involve the element of physical invasion, may be considered minor infringements of legal interests, which are not certainly guaranteed by the Constitution. In his dissenting opinion, Justice Uga Katsuya regarded the legal interest having the gender status under laws and regulations handled in accordance with the person’s gender identity as a fundamental human right guaranteed by Article 13 of the Constitution, and suggests that （i）-（iii） are also questionable. In fact, he had written his dissenting opinion from such a perspective in the case where item （iii） was in question （Decision November 30, 2021, 266 SHUMIN 185）. Since legal gender treatment is linked to personal survival, Justice Uga’s view is reasonable. At the time of this writing, this act is under consideration for revision. However, the coalition government of the Liberal Democratic Party and New Komeito is not expected to proceed smoothly with the removal of （iv）, let alone （v） requirement, due to strong opposition from the conservative faction. Some have argued that instead of removing （iv） or （v）, another requirement should be established. Whatever the requirement, it is unlikely that a requirement that satisfies the extreme right would satisfy the legal interest in aligning gender identity with legal gender. On the other hand, among the opposition parties, it is noteworthy that the Constitutional Democratic Party of Japan is proposing the deletion of item （iii） in addition to （iv） and （v）.

MAJOR JUDICIAL DECISIONS: 1. Constitutional Law

Nakamura, Nobuo

De facto director's liability to a company under case law in Japan.

TABLE OF CONTENTSArticleConsent in Smart Societies Ruben E. Rodriguez Samudio   1De facto director’s liability to a company under case law in Japan. Nobuo Nakamura   23Developments in 2023Major Legislation & Treaties1. Constitutional Law    452. Family Law    483. Law of Civil Procedure and Bankruptcy    544. Criminal Law and Procedure    585. Labor / Social Security Law    636. International Law and Organizations    66WasedaBulletinofComparativeLawVolume 43 Annual Report 2023Major Judicial Decisions1. Constitutional Law    692. Administrative Law    773. Family Law    854. Law of Civil Procedure and Bankruptcy    955. Criminal Law and Procedure    1006. Commercial Law    1037. Labor Law / Social Security Law    1078. International Law and Organizations    112Activities of Academic Societies1. Constitutional Law    1232. Administrative Law    1253. Law of Property and Obligations    1274. Family Law    1295. Law of Civil Procedure and Bankruptcy    1306. Criminal Law and Procedure    1317. Commercial Law    1348. Legal History    1359. Sociology of Law    13710. Philosophy of Law    13911. Comparative Law    14112. International Law and Organizations    149Activities of the Institute in 2023    155Members of the Institute    167

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MAJOR JUDICIAL DECISIONS: 8. International Law and Organizations

Vol.43Annual Report   2023INSTITUTE OF COMPARATIVE LAWWASEDA UNIVERSITY, TOKYO, JAPANWASEDABULLETINOFCOMPARATIVELAWVOL.43Annual Report2023INSTITUTEOFCOMPARATIVELAWWASEDAUNIVERSITYTOKYOJAPANWaseda Bulletin of Comparative Law                             Volume 43    2023ISSN 0285-9211Vol.43Annual Report   2023INSTITUTE OF COMPARATIVE LAWWASEDA UNIVERSITY, TOKYO, JAPANWASEDABULLETINOFCOMPARATIVELAWVOL.43Annual Report2023INSTITUTEOFCOMPARATIVELAWWASEDAUNIVERSITYTOKYOJAPANWaseda Bulletin of Comparative Law                             Volume 43    2023ISSN 0285-9211

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Developments in 2023 ̶ Academic Societies 1252.　Administrative LawI.　The Ad-Law-Forum held its 22nd General Meeting at Kansai University on July 22, 2023.Common Theme “The Enforcement of Administrative Law”Reports:（1） “Toward the Development of Legislation to Ensure the Enforcement of Public Administration: Focusing on the Draft Outline” Takao Hamanishi （Professor, Tsukuba Gakuin University）（2） “Current Status and Issues of Enforcement in Municipalities” Katsuhiko Itagaki （Professor, Yokohama National University）（3） “Relationship between Administrative Enforcement and Litigation Enforcement” Yuji Yasunaga （Associate Professor, Hiroshima University）（4） “Memorandum on the Link between the Implementation of the International Rules of the Economy and the National Laws” Kazumochi Komeyani （Attorney/ Visiting Professor, The University of Tokyo Graduate School of Public Policy）Discussion:II.　The Japan Tax Jurisprudence Association held its 113th General Meeting at Hokkaido University on June 24 and 25, 2023, with online participation also available. First Day:Report:（1） “Nature of Heavy Penalty Tax as Sanction” Kenzo Koseki （Professor, Asahikawa City University）（2） “Digitization of Tax Procedure and Protection of Taxpayer’s Rights” Naoto Noishiki （Professor, Kyoto Sangyo University）126 Waseda Bulletin of Comparative Law Vol. 43（3） “Problems of Sharing Economy Transactions in Taxation─Focusing on Relationship between Tax Law and Private Law─” Tomonori Taniguchi （Professor, Senshu University）（4） “DeFi Tax Treatment of the Transfer of Cryptocurrencies and Other Tokens─Decentralized Digital Society Using Blockchain and Smart Contracts” Junya Izumi （Associate Professor, Toyo University）Questions and Answers on Report （1）Second Day:Report:（5） “Estimating the Fair Market Value of Inherited Property and the Principle of Equality in Taxation: The Supreme Court Case on April 19,2022“ Riho Yokoi （Lecturer, Shimane University）Questions and Answers on Report （5）Symposium: “Legal Issues in Tax Law for Digitalisation ”III.　The Japanese Society for Tax Law held its 52nd General Meeting at Kokushikan University on October 14, 2023.“Aspects of “Asset” Taxation and Contemporary Issues”Report:（1） The Current Status and Future of Fixed Asset Taxes as Local Property Taxation─Including the Fluidization of Relationships between Humans and Territories─ Takahiro Tezuka （Professor, Hiroshima University）   Comments, Yuka Shiba （Professor, Sugiyama Jogakuen University）（2） What the Law or the Judiciary can Do for Property Valuation Akiyuki Asatsuma （Professor, Rikkyo University） Comments, Norihisa Yoshimura （Professor, Keio University）（3） Expatriation of Persons and TaxationDevelopments in 2023 ̶ Academic Societies 127 Kana Suminaga （Associate Professor, Seinan Gakuin University） Comments, Keiji Aoyama （Visiting Professor, Chiba University of Commerce）（4） Intangible Assets as a Source of Corporate Value and Tax Law Masao Yoshimura （Professor, Hitotsubashi University） Comments, Shigeki Minami （Attorney, Nagashima Ohno & Tsunematsu Tokyo Office）Question and Answer Session （Symposium）3.　Law of Property and ObligationsThe Japan Association of Private Law held its 86th General Meeting at Keio University on October 7 and 8, 2023. For reports and the symposium on commercial law, see the section on commercial law.Day One （October 7）:Reports:1. “A Study of Japanese Contract Law in Practice: Its Uniqueness in Contract Formation Without an Offer-and-Acceptance Paradigm” Ichiro Kobayashi （Professor, Hitotsubashi University）2. “The Incapacity Rule and the Rescission Right of Article 120 Paragraph 1 of the Civil Code” Tomoko Fukuda （Lecturer, Ibaraki University）3. “The Responsibility of the Defender in regard to Self-Defence in Civil Law” Kiyotaka Suzuki （Professor, Kyushu University）Day Two （October 8）:Symposium: “The Development of Digital Society and Shaping Private Law”Chairperson and Reporter: Kenichi Matsuo （Professor, Osaka University） 

ACTIVITIES OF ACADEMIC SOCIETIES: 2. Administrative Law

Developments in 2023 ̶ Academic Societies 1294.　Family LawThe Japan Society for Socio-Legal Studies on Family Issues held its 40th Annual Meeting at Aichi Gakuin University on November 11, 2023.Reports:Young Scholars’ Colloquium“The Meaning and Limit of the Intentional Element in Biological Parentage Law ～ with Clues from Recent Trends in French Law ～” Syuhei Yanaseko （Assistant Professor, Hiroshima Shudo University）Symposium “Family and Society during the Coronavirus Crisis”（1）  “A Society that includes <Life> and a System that evaluates <Care> - in an Era that Illness has Become Commonplace” Emiko Ochiai （Professor, Kyoto Sangyo University）（2）  “Visitation between Children and Non-Resident Parents under a Coronavirus Situation” Jun’ichi Abe （Associate Professor, Chuo University）（3）  “LGBTQ and Family during the Coronavirus Crisis - Amplified Vulnerabilities” Hiroyuki Taniguchi （Professor, Aoyama Gakuin University）（4）  “Terminal Care that Medical Workers offered to Coronavirus Infected Persons and their Families - What Could be Done at the Time?” Mayumi Nishimura （Visiting Researcher, Kyoto University）（5）  “Coronavirus Crisis and Family - from the Viewpoint of Law and Society”  Ayako Harada （Professor, Nagoya University） and Teiko Tamaki （Professor, Niigata University）

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ACTIVITIES OF ACADEMIC SOCIETIES: 10. Philosophy of Law

MAJOR JUDICIAL DECISIONS: 1. Constitutional Law

De facto director's liability to a company under case law in Japan.

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MAJOR JUDICIAL DECISIONS: 8. International Law and Organizations

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ACTIVITIES OF ACADEMIC SOCIETIES: 2. Administrative Law

ACTIVITIES OF ACADEMIC SOCIETIES: 4. Family Law

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