The Art Law Review: Japan

Introduction

The Japanese art market consists of the antiquities market, the modern art market and the contemporary art market. Products traded in the antiquities market are Japanese, Chinese and Korean antiques and traditional artworks, such as Ukiyo-e, lacquerware, swords and tools for tea ceremonies. Arts traded in the modern art market are Japanese and western-style paintings by past and present artists. Generally, artists of traditional and modern arts in Japan belong to one of the artists' circles, which regularly hold publicly sponsored exhibitions. There are over 100 artists' circles, each of which has close relationships with particular dealers. In the primary market, most works are sold to regular customers of those dealers by private sale. Art Tokyo Association, the organiser of Art Fair Tokyo, estimates that in 2020, the value of sales of antiquities and modern arts was ¥97.6 billion and ¥104.3 billion, respectively, each of which accounted for approximately 40 per cent of total art market sales (¥236.3 billion).2

In this century, a number of young artists, willing to create contemporary artworks freely, choose not to belong to a traditional circle. Contemporary art sales account for approximately ¥37.3 billion in value, which is less than 20 per cent of total art sales.3

The year in review

i 'After “Freedom of Expression?”' exhibition

Incidents related to the 'After “Freedom of Expression?”' exhibition highlight that freedom of artistic expression is not necessarily secure in Japan.4

The purpose of the exhibition held in August 2019 as part of 'Aichi Triennale 2019' organised by Aichi prefecture, was to display artworks that public bodies, galleries and organisers had previously refused to exhibit. The exhibits included a collage of photos of burning portraits of Emperor Showa, a girl's statue and an image of a Korean 'comfort woman'. However, three days after opening, the exhibition was shut down by the organiser following protests and the threat of terrorism. In reaction to the sudden suspension, many artists and citizens protested against the organiser and the Aichi governor. The organiser ultimately reopened the exhibition but only for a short period and with strict restrictions.

In May 2021, a human rights group in Aichi announced it would hold 'Our “After Freedom of Expression?”' exhibition, featuring some of the works from the original exhibition, in Tokyo, Nagoya and Osaka. However, the Tokyo exhibition was postponed after the gallery that was due to hold the exhibition withdrew because of an outpouring of calls and protests demanding its cancellation. The Nagoya exhibition commenced on 6 July 2021 but was cancelled only two days later after the venue received a package containing explosive materials from suspected terrorists. The Osaka exhibition gallery also stated that it would withdraw from hosting the exhibition. However, on 9 July 2021, Osaka District Court ordered it to provide the facility in response to a petition from the exhibition's executive committee.5 The Osaka exhibition was held under heavy police guard.

ii Government policy towards the arts

Recently, Japan's government has changed its arts policy, focusing on art's power to develop the economy. In April 2018, the Agency for Cultural Affairs published a report providing its opinion on the art market (the ACA Report).6 The ACA Report states that the Japanese market has been underdeveloped because museums have small budgets and vulnerable management structures, the business foundations of dealers, galleries and auction houses are weak, art fairs and international art festivals are not well known, and art reviews are not transmitted to the world. It proposes to: (1) create a 'leading museum'; (2) develop infrastructure for arts; (3) establish art fairs to invite the world's top artists; and (4) disseminate information on Japanese art overseas. The Agency suggests that the 'leading museum':

  1. purchase artworks from art fairs, artists, etc.;
  2. study and select the works to be retained; and
  3. sell the remaining pieces through auctions to revitalise the market.

However, the entire Japanese art world opposes this plan, which has also been criticised on social network services by many artists, curators and critics. The Japan Council of Art Museums, consisting of approximately 400 museums, stated that museums and non-profit organisations for social education for everyone should not deal directly in art market activities. Journals and academics have also criticised the plan.

Since 2019, the government has initiated various measures to revitalise the art market in line with the ACA Report. However, it has not implemented the concept of a leading museum. Moreover, this is not included in the budget for 2021. Thus, the government seems to have dropped this plan due to the art industry's opposition.

Art disputes

i Title in art

Private sale and auction

In private sales, a buyer acquires title to property from the seller when a contract of sale becomes effective unless otherwise agreed between the parties.7 In auction sales, most auction terms include a title retention clause, providing that title will transfer from the consignor to the buyer when the artwork is delivered to the buyer after the auction house confirms receipt of the price and commission from the buyer.

Title acquisition by good faith purchaser

A person who acquires the possession of an artwork from its previous possessor by sale, gift or exchange in good faith will obtain title to the artwork even if the last possessor is not the title holder.8 A transaction carried out under the usual circumstances is presumed done in good faith.9

In a recent case where an art gallery entrusted its Japanese paintings to an art dealer, the dealer put them up at an auction without the gallery's permission. Later, the dealer cancelled the auction request and sold them to the auction house. Upon learning of this, the gallery filed a lawsuit against the auction house, demanding the return of the artworks. The gallery argued that the auction house was not a good faith purchaser because it failed to confirm the seller's authority to sell. However, Tokyo District Court held that the auction house had been in good faith because it had previous transactions with the seller, the seller had guaranteed the right of possession, and there had been no other appropriate means of investigating the authority of the paintings that were not reported as stolen.10

ii Nazi-looted art and cultural property

In Japan, there is no legislation or case law related to Nazi-looted art. Cultural properties are often stolen. As at 2020, there were 145 missing stolen national treasures and cultural properties.

The most famous cultural property stolen and unreturned is the ancient Buddhist statue, an important cultural property designated by the government stolen by Korean thieves from Kannonji Temple in Tsushima Island, Nagasaki in 2012. The following year, the thieves were arrested in South Korea and the South Korean government seized the statue. However, it was not returned to Kannonji because a South Korean temple claimed that the statue had been stolen from it in the fourteenth century. The Korean temple brought a lawsuit against the South Korean government before the South Korean court, seeking restitution. In 2017, the court ruled that the statue should be given to the plaintiff, holding that it had been looted by Japanese pirates around 600 years ago.11 The South Korean government appealed this decision, and in December 2020 it asked Kannonji Temple to join the lawsuit. In November 2021, Kannonji decided to participate in the Korean appeal court proceedings.

iii Limitation periods

The Civil Code provides that a person who possesses any property of another person for 20 years shall be entitled to acquire the ownership under the acquisitive prescription.12 By this provision, the possessor of a stolen artwork may assert to own the work, proving its possession at two different points in time, one of which is more than 20 years previously and the other is 20 years later than the first point in time.13 The original owner may contest the possessor's ownership, if they prove that: (1) the possessor commenced its possession under an arrangement not to transfer titles, such as a contract of deposit, loan for use or lease;14 (2) the possessor concealed the possession or lost it at any time in the 20-year period; or (3) at any time after commencing the possession, the possessor manifested by words or conduct that the property was not their belonging.15 In a recent case, a possessor of a sword, designated as cultural property, asserted ownership because he had acquired it over 20 years ago. Sendai High Court denied his argument, holding that he had concealed possessing it, considering that he had received it knowing it had been stolen and had not shown it to anyone during the 20-year period.16

iv Alternative dispute resolution

An arbitration clause is often provided for in a contract for cross-border art transactions. If Japan is the seat of arbitration, the rules of the Japan Commercial Arbitration Association are chosen as the procedural rules.

Mediation is another commonly used method for dispute resolution. In Japan, the system of mediation has been incorporated into the court system for many years and, even in the case of litigation, judges are expected to act as mediator before rendering a judgment.17 In international commercial transactions, the system is gaining popularity as a prerequisite for commencing arbitration.

Fakes, forgeries and authentication

i Private sales

The handling of a fake would be subject to fraud, forgery and other criminal penalties.18 On 27 September 2021, the Metropolitan Police Department arrested an art dealer, who was a former director of the Contemporary Graphic Art Dealers Association of Japan, and a workshop artisan for violating the Copyright Act. For over 10 years, the dealer had the artisan produce more than 120 copies of fake prints of famous Japanese artists such as Ikuo Hirayama, Kaii Higashiyama and Tamako Takaoka, and traded them in major department stores and art galleries. The fakes remained undetected for a long time because of the difficulty in distinguishing authorised prints from unauthorised ones, both of which were reproductions, and the business practice of trading on trust between acquaintances.

Civil remedies may or may not be given to victims of fake artworks. A purchaser of a fake, believing it to be genuine, may rescind the contract and demand the seller to return the price on the ground of mistake if the parties had a common understanding that the purchaser took the work's authenticity as the basis of the contract.19

However, courts tend to reject assertions of a mistake by professional buyers. In one case where a UK antique dealer purchased a Chinese vase from a Japanese dealer, the parties agreed on the price based on the mutual understanding that it was an antique produced during the Qing dynasty (the eighteenth century). After the transaction, the buyer obtained Christie's and Sotheby's opinions that it was likely a twentieth century product. Tokyo District Court denied the buyer's claim for return of the price, taking into account that both antique dealers with expertise in Chinese arts had been aware of the difficulty in determining the ages of antiquities.20

On the contrary, courts incline to accept assertions by an amateur collector purchasing a fake from a professional art dealer.21 An experienced dealer may also breach a duty to disclose important information that would affect the customer's reasonable decision to purchase the artwork. Tokyo District Court so held when a company with no expertise in arts purchased Leonard Foujita and Renoir paintings from an art gallery.22 In the customary practice in the Japanese art market, a Foujita painting without Tokyo Art Club's authenticity certificate and a Renoir painting not included in the Wildenstein Institute's catalogue raisonné are traded at substantially lower prices than if proved to be genuine. In this case, the buyer was unaware of the above practice, and purchased the Foujita without a certificate and the unlisted Renoir. The Court held that the art gallery should have informed the buyer of the practice before the sale and ruled that the gallery should indemnify the buyer's damages.

ii Auction sales

In relation to auction sales, most auction terms contain either a warranty clause or a non-warranty clause concerning the work's authenticity. If the auction house or the seller warrants the authenticity, the buyer of a fake may demand return of the purchase price and the commission, provided that the buyer instigates this procedure within the time limit as set out in the terms. If the buyer did not take the required steps, the price would neither be returned under the warranty nor based on mistake.23 If the terms expressly provide that the seller gives no warranty as to authenticity, the seller and the auction house will not be liable for repayment of the price or damages other than those caused by gross negligence.24

Art transactions

i Private sales and auctions

In Japan, arts are mainly traded through private sales involving art dealers as consignee. Unlike in other major markets, public auctions are not popular.25 Under customary practice, a consignment sale by a dealer proceeds in the following manner. First, the owner agrees to sell the work to the dealer and designates the price required for the sale (the designated amount). After receiving the artwork from the owner, the dealer finds and negotiates with a potential buyer to sell the work as the seller. At the time the dealer sells the work to the buyer, the dealer purchases it at the designated amount from the owner. The balance between the sales price and the designated amount is the dealer's profit. In the above transaction, the dealer assumes the seller's liability against the buyer, and is under the consignee's duties as against the owner, including a duty of care, fiduciary duty and duty to account.26

Dealers operating in the primary market deal with artists directly to sell their works. In addition, dealers must discover, support, train and promote artists. In practice, the business relationship between a specific dealer and an artist is long-lasting and almost monopolistic. However, in most cases, the two parties enter into a transaction without a particular arrangement. Thus, the dealer is not obligated to purchase all the works from the artist, and the artist may sell the pieces to other dealers or customers. On the other hand, if they agree in writing that the dealer will handle all of the works, the agreement is interpreted as an exclusive transactional contract that bans the artist from selling their work through another dealer. In one recent case, Senju Hiroshi, a well-known Japanese painter, was required to pay damages for breaching his contract with the plaintiff gallery.27 He agreed to sell his works through the gallery to stabilise his works' price, except for 'cases where the artist must deliver directly for various reasons'. However, during the six years following this agreement, the artist sold over 700 pieces to four other dealers. Tokyo District Court ordered the artist to compensate the gallery's lost profits of approximately ¥230 million, holding that the terms of the agreement imposed an obligation on the artist to deal exclusively with the gallery. The Court also held that sales to other dealers did not constitute 'cases where the artist must deliver directly for various reasons'.

ii Art loans

Borrower's duty of care in art lending

Art lending in Japan is always based on a contract between the lender and the borrower. A gratuitous loan is also a contract. A person taking any goods on loan, either gratuitously or for consideration, shall exercise the utmost care as a prudent manager unless otherwise agreed with the lender.28 Moreover, upon completing the loan, the borrower must return the object in the same state as when they received it. If the loaned item is lost or damaged, the borrower shall restore it to its original condition or compensate for damages, unless caused by force majeure (i.e., factors not attributable to the borrower).29 Ordinary wear and tear resulting from deterioration over time are exempt from this obligation.30

Immunity from seizure for artworks on loan

Japan has a scheme to protect loaned artworks from seizure and attachment during the loan period for exhibition.31 Under the scheme, a foreign artwork borrowed for exhibition is protected from seizure, distress and attachment by a creditor of the lender or a party alleging ownership if the government designates such work. The government designates the piece if it considers it vital to show at the exhibition and not purported for sale.32 After the designation, the government shall give public notice of the work and the exhibition details. In 2020, over 400 pieces of art were borrowed from overseas museums under the scheme, including from the National Gallery, London, the National Portrait Gallery and the Courtauld Institute of Art.

Apart from the above scheme, works owned by a foreign nation, agency or state are protected from seizure, etc., by the Sovereign Immunity Act.33 If a foreign country requires a letter of confirmation concerning the sovereign immunity from the Japanese government as a condition to lending its work, the organiser of the exhibition may request the government to issue a certificate confirming that such nation is immune from civil jurisdictions concerning the work to be loaned.

iii Cross-border transactions

Export of cultural objects

An artwork designated as an important cultural property under the Law for Protection of Cultural Properties cannot be exported unless specifically permitted by the government.34 The permission is granted only when its export is necessary for international cultural exchange or other relevant purposes. Because of this export restriction, at the time of export of any cultural artworks, the exporter must obtain from the relevant governmental agency a written certificate confirming that the object is not an important cultural property.35

Art fairs and auctions in bonded areas

In 2020, the government amended the operation policy of the Customs Law to allow art fairs and auctions to be held in bonded areas. If the application for a bonded exhibition or storage space is approved, art from overseas may be traded therein without customs duties or VAT.36 On 1 October 2021, a Japanese auction company held the first auction of this type in the bonded area of Tokyo International (Haneda) Airport, resulting in total sales of ¥2.64 billion.

iv Art finance

Regulation of art finance

There is no legislation regulating art finance and related business, except for private trusts for art investment, which can be carried out only by an enterprise that obtains a trust business licence from the government.37

Anti-money laundering regulation

The anti-money laundering legislation in Japan comprises the Act on Punishment of Organised Crimes and Control of Crime Proceeds and the Act on Prevention of Transfer of Criminal Proceeds. Under the former Act, anyone who has accepted or received artwork in the knowledge that it was acquired through criminal means, shall be punished by imprisonment for not more than three years or a fine of not more than ¥1 million, or both.38 The latter Act imposes on certain specified business entities the duties to: (1) check the identity of customers and beneficial owners of corporate customers; (2) make and keep records of transactions; and (3) report anything suspicious relating to money laundering to the relevant governmental agencies.39 The specified business entities regulated under the Act include jewellery and precious metals traders; however, art dealers and art-based transactions are exempt from the regulation.

Artist rights

i Moral rights

The Copyright Act provides the right of disclosure, the right to authorship and the right of integrity as the moral rights.40 While the issues regarding the right of integrity are often argued in court cases, there have been few remarkable ones in recent years.

ii Resale rights

There are no provisions of resale rights in the Copyright Act at present. In 2019, the International Confederation of Societies of Authors and Composers, the international network of authors' societies, held its Regional Asia-Pacific Committee meeting in Tokyo. It resolved to call upon the government of Japan to promote the resale right and introduce the right in the Copyright Act and support international discussions within the World Intellectual Property Organization on the global recognition and implementation of the resale right throughout the world. However, there have been no significant developments in legislating resale rights. Considerable discussions will be necessary for legislation in view of the closed nature of the Japanese market where people put importance on the confidentiality of trade information.

iii Copyright

2018 Amendments to the Copyright Act

By the amendments of laws as a result of the Trans-Pacific Partnership Agreement, on 30 December 2018 the period of protection for copyright was extended from 50 years to 70 years after the author's death, in principle.41 Under the Berne Convention, copyright of a foreign artist's work is also protected for the same period unless the copyright law of the artist's country provides a shorter period of protection.42 This means that works of nationals of the Allied Powers of the Second World War (Australia, Canada, France, the United Kingdom and the United States) are protected for over 80 years post mortem auctoris because, under the Treaty of Peace with Japan agreed in San Francisco in 1951, the period between 7 December 1941 and the Treaty coming into force (28 April 1952; 3,794 days) is added to the period of protection. However, this amendment will not revive the copyright for works whose protection period had expired by 29 December 2018.

Contemporary art

In general, contemporary art is less likely to be protected by copyright than conventional arts because the former is more concerned with the concept of the work than with its exterior details. Copyright law does not protect ideas but an expression.

One recent case of Osaka High Court is a decision regarding a contemporary artist's copyright.43 The plaintiff, a contemporary artist, created a work in which he filled a water tank, closely resembling a public telephone box, with water and goldfish. The defendants exhibited a work in which they filled a tank converted from a public telephone box with water and goldfish. The plaintiff claimed that the defendants infringed his copyright (right of reproduction). The Court held that a telephone booth filled with water and goldfish was merely a form of an idea, and therefore could not be creative in itself. However, it decided that the plaintiff's work was copyrightable because having the telephone handset floating in the water generating air bubbles showed the creator's individuality and creativity. The Court then found that the defendants infringed the copyright because it relied on the plaintiff's work and reproduced all the creative parts.

Applied art

Applied arts (i.e., art for everyday use) hold a prominent position in the Japanese art world and market. However, the extent to which the Copyright Act protects this art is uncertain, as there are no specific provisions for applied art in the Act. According to case law, 'artwork' protected by the Copyright Act means, in principle, 'fine arts' for appreciation, and protected 'applied arts' are only pieces with sufficient aesthetic qualities. However, in a recent case concerning the copyrightability of a baby chair, the Intellectual Property High Court (the IP Court of Appeal) took a different view.44 The Court held that the copyrightability is determined based on whether a specific work contains an element that shows the creator's or designer's individuality and that the aesthetic should not be a criterion because it is too subjective. While the IP Court of Appeal suggests a change of criteria for the copyrightability of applied arts,45 some subsequent judgments have not followed this suggestion, but decided on the basis of the aesthetic quality of the works concerned.46 In a recent case, the copyrightability of octopus slide playground equipment in a park was in dispute.47 The plaintiff, who had made a slide in the shape of an octopus, claimed that the defendant's production of a slide in a similar form infringed the right of reproduction or adaptation. Tokyo District Court held that the question was whether 'the design has aesthetic characteristics that can be an object of appreciation of art, separated from the composition relating to the functions necessary to achieve a practical purpose'. The Court refused to grant copyright protection to the design of the octopus-shaped slide, holding that it had no aesthetic characteristics separated from its function as slide playground equipment for children. The IP Court of Appeal is now examining this decision.

Trusts, foundations and estates

The Legislative Council of the Ministry of Justice is now drafting a bill of the reformed Charitable Trust Act, intending to submit it to the Diet during the next session. A charitable trust under the existing law can be used solely to pay money for philanthropic purposes, and only trust banks licensed by the government can be trustees. However, under the new Act, if enacted, trusts will be allowed to carry out business promoting the arts, such as the operation of a museum, including the collection of admission fees and the sale of exhibition catalogues and other goods in a museum shop. Any institution or individual capable of proper management of such business may be a trustee.48 A new charitable trust will provide practical means for the maintenance and management of artworks owned by companies willing to use their collections in the course of their corporate social responsibility activities.

Outlook and conclusions

The post-2020 art market has seen new types of transactions in terms of sales methods and items sold. First, blockchain-based digital art transactions have emerged. Although not on the same scale as the Beeple work that sold for over US$69 million at Christie's, in March 2021 Japanese artist Aimi Sekiguchi sold a virtual reality non-fungible token (NFT) artwork online for ¥13 million. During 2021, several companies have set up NFT artwork marketplaces. Second, the trading of original and celluloid paintings of manga and anime is on the rise. In March 2021, publishing company Shueisha launched a business using digital transformation (DX) technology to sell manga art through its digital archives.49 During summer 2021, several NFT marketplaces opened for the sale of manga and anime celluloids. Trade in NFT-based blockchain game characters has also increased since 2020. Manga, anime and digital arts existed on the market before 2020; however, the DX technology, combined with the covid-19 pandemic, has encouraged this movement. The market size for manga, anime and digital arts may soon surpass the existing markets considering the number of enthusiasts of these subcultures, including comic readers, anime viewers and digital game users. Transactions using the DX technology can be made online rather than through dealers or auction houses. These transactions might become standard in the future art market and break through the conventional market practices.

Footnotes

1 Makoto Shimada and Taku Tomita are partners at SAH & Co.

2 Art Tokyo Association, Japanese Art Industry Market Research 2020, 9, 10.

3 id., 10.

4 Yuka Okamoto, et al., Aichi Triennale 'tenji chushi' jiken: Hyogen no fujiyu to Nihon (Iwanami, 2019).

5 Decision of Osaka District Court of 9 July 2021 (confirmed by the decision of Osaka High Court of 15 July 2021), LEX/DB.

6 Agency of Cultural Affairs, 'Ato shijo no kasseika ni mukete' (translation: 'Towards activation of Japan's Art Market'), 17 April 2018.

7 Civil Code (Law No. 89 of 1896), Articles 176 and 555.

8 id., Article 192.

9 Judgment of Tokyo District Court of 24 January 2012, LLI/DB.

10 Judgment of Tokyo District Court of 7 August 2019, LLI/DB Hanrei Times, Vol. 1472, p. 210.

11 Choe Sang-Hun, 'South Korea Can Keep Buddhist Statue Stolen From Japan, Court Says,' New York Times, 26 January 2017.

12 Civil Code, Articles 162(1) and 145.

13 id., Articles 162(1) and 186(1) and (2).

14 Judgment of Tokyo District Court of 31 July 2006, LLI/DB.

15 Judgment of Hiroshima High Court of 23 May 2012, LLI/DB.

16 Judgment of Sendai High Court of 14 July 2020, LLI/DB.

17 Civil Conciliation Act (Law No. 222 of 1951); Code of Civil Procedure (Law No. 109 of 1996), Article 89.

18 Criminal Code (Law No. 45 of 1907), Articles 167 and 246.

19 Civil Code, Article 95.

20 Judgment of Tokyo District Court of 30 September 2013, LEX/DB.

21 Judgment of Hiroshima High Court of 22 April 2003, LEX/DB.

22 Judgment of Tokyo District Court of 26 July 2012, Hanrei Jiho, Vol. 2162, p. 86.

23 Judgment of Tokyo District Court of 19 July 2017, LEX/DB.

24 Consumer Contract Act (Law No. 62 of 2000), Article 8(1).

25 Art Tokyo, Market Research 2020, 11 (which shows that the volume of auction sales accounted for only 6 per cent of total domestic sales in 2020).

26 Civil Code, Articles 108 and 643–647; Commercial Code, Article 552(2).

27 Judgment of Tokyo District Court of 27 September 2019, LEX/DB.

28 Civil Code, Article 400.

29 id., Articles 599 and 621.

30 Judgment of Nagoya High Court of 17 July 2007, Hanrei Jiho, Vol. 2025, p. 37.

31 Act on Facilitation for Exhibiting Overseas Works of Art, etc. to the Public in Japan (Law No. 15 of 2011).

32 Order for Enforcement of the Act on Facilitation for Exhibiting Overseas Works of Art, etc. to the Public in Japan (Cabinet Order No. 288 of 2011), Article 2.

33 Law No. 24 of 2009.

34 Law No. 214 of 1950, Article 44.

35 Customs Act (Law No. 61 of 1954 as amended), Article 70.

36 Basic Circular of the Customs Law, 43-2-2, 42-17.

37 Trust Business Act (Law No. 154 of 2004), Article 3.

38 Law No. 136 of 1999, Article 11.

39 Law No. 22 of 2007, Articles 4 and 6–8.

40 Law No. 48 of 1970, Articles 18–20.

41 id., Article 51.

42 id., Article 58.

43 Judgment of Osaka High Court of 14 January 2021, LLI/DB, Jurist Vol. 1556, p. 8.

44 Judgment of IP Court of Appeal of 14 April 2015, Hanrei Jiho, Vol. 2267, p. 91.

45 Judgment of IP Court of Appeal of 21 December 2016, Hanrei Jiho, Vol. 2340, p. 88 also seems to have relied upon the same criterion.

46 Judgments of Tokyo District Court of 27 April 2016 and IP Court of Appeal of 13 October 2016; judgment of Tokyo District Court of 21 April 2016, Hanrei Jiho, Vol. 2340, p. 104.

47 Judgment of Tokyo District Court of 28 April 2021, LLI/DB.

48 Ministry of Justice, 2018, Draft Summary on Review of Public Interest Trust Act, Sections 2-2, 4-1 and 9-3(3).

49 Shueisha Manga-Art Heritage: www.mangaart.jp.

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