Hiroo Sono's Website

The Multiple Worlds of gNihon-hoh

[Forthcoming in the Proceedings of the CAPI Colloquium, "The Multiple Worlds of Japanese Law: Disjunctions and Conjunctions"(University of Victoria, 3 April 2001) to be published from University of Victoria]

Hiroo Sono*

A. Introduction

Among the three worlds of Japanese legal studies (gJapanese lawh, gJapanisches Rechth, and gnihon-hoh) identified by Luke Nottage[1], gnihon-hoh stands out as having a distinct character: it is multi-layered. I will start out in Part B by explaining what I mean by this. This perspective is important in assessing whether gJapanese lawh and gJapanisches Rechth have had limited impact on gnihon-hoh. Today, we all know better than to compare Japanese businesspeople / business practices with U.S. lawyers/law when we compare attitudes toward contracts in the two countries[2]. Taylor and Nottage are both well aware of this [3]. But they seem to make a similar mistake by comparing wrong gworldsh. After assessing the interaction of the gworldsh of Japanese legal studies (maybe too) optimistically in Part C, I will then cast a critical light on the autism that plagues gnihon-hoh in Part D. Nonetheless, I will try to end in an upbeat mood.

Before I proceed, I must mention my background. I live in the world of gnihon-hoh, and gminpo [Civil Code]h in particular. I have had several encounters with the world of gJapanese lawh, but mostly that produced in the United States. I also regretfully confess that the world of gJapanischesRechth has been truly foreign to me. Thus, I must almost totally exclude reference to gJapanisches Rechth in the following comments.

B.The Anatomy of gnihon-hoh

1. Primary and Secondary gnihon-hoh

Taylor and Nottage mention the world of gnihon-hoh, they are referring to the body of academic literature on law in Japan written in the Japanese language. This is gacademich in the sense that it may have no immediate practical consequences. However, there is another layer of gnihon-hoh, which is the law as it is practiced in Japan. I use the term gpracticeh broadly. It encompasses the activities of actors such as legislatures, the legal profession, bureaucracy, and even private citizens in so far as they have practical legal consequences on peoplefs lives. It includes both the formal and informal enforcement of law. This layer of gnihon-hoh is the gprimary nihon-hoh. The academic gnihon-hoh is gsecondary nihon-hoh. (gPrimaryh and gsecondaryh as used in, e.g., gcases are primary materialh, and glaw reviews are secondary material.h)

2. Secondary gNihon-hoh with an Internal Standpoint

The ultimate objective of gsecondary nihon-hoh as a collective is to influence the actors in the world of gprimary nihon-hoh. However, individual works may not necessarily be intended to affect the actors. For example, the extensive comparative law articles written by virtually every Japanese legal academic are rarely intended to be used by practitioners. (If they are, they have problems with their presentation.) They are mostly intended to serve as building blocks and to give insights for further studies, which in turn will affect the actors[4]. In this sense, it is useful to distinguish two sub-layers of gsecondary nihon-hoh.

A typical example of the first sub-layer is the bulk of kaishakuron papers. They are characterized by their immediate concern of influencing gprimary nihon-hoh. In other words, they have ginternal standpointsh[5]. These are addressed directly towards the legislators, judges, attorneys, prosecutors and other legal professionals. This can be attested by the fact that academics do not hold a monopoly in this field of writing. Contributors to this sub-layer include many practitioners (judges, attorneys, prosecutors, corporate legal department (homubu) staff members, etc.). This sub-layer may be named gapplied legal studiesh, or gjitsuyo hogakuh[6], but in this paper, I will simply refer to it as gsecondary-internal nihon-hoh.

Many residents of the gworld of Japanese lawh will consider this literature boring. To some degree, I share that sentiment. However, subjective tastes aside, there are many jobs out there that are boring but indispensable. Somebody must do this. If lawyers donft, who will?

3. Secondary gNihon-hoh with an External Standpoint

In contrast to applied legal studies (gsecondary-internal nihon-hoh), the second sub-layer can be named gbasic legal studiesh. Although the final goal of basic legal studies is also to affect various actors of gprimary nihon-hoh, these studies do so only indirectly. Rather, this sub-layer intends to exert direct influence on gapplied legal studiesh, which in turn will influence gprimary nihon-hoh. A typical example, but not the only one, is the so-called kisohogaku. It consists of traditional interdisciplinary subjects such as legal philosophy, legal history, legal sociology/law and society, comparative law, and the new gLaw-andh areas such as Law and Economics, Law and Negotiation, Law and Feminism, etc. Another example of basic legal studies is the descriptive analysis of case law, which tries to identify the state of specific areas of law (e.g., Ichiryushafs gSogo Hanrei Kenkyu [Comprehensive Case Studies]h series)[7]. These studies are all philosophical or empirical in approach. The boundary between the basic and the applied may be blurred at times (just in the way the American gRestatementsh of various areas of US law are not always mere restatements), but their immediate concern is to understand, interpret, and explain the function of law. In that sense, they have an gexternal standpointh. For them, law is a subject of observation. Hence I will refer to this sub-layer as gsecondary-external nihon-hoh.

C. Interaction

1. hJapanese Lawh as Secondary-External

we compare the multiple worlds of gnihon-hoh classified above with the world of gJapanese lawh posited by Taylor and Nottage, it is apparent that gJapanese lawh in most cases have no intention to influence gprimary nihon-hoh. It is secondary in nature and external in standpoint. Given this characteristic, it is understandable that gJapanese lawh delivers very little gkaishakuronh[8], which is essentially internal in its standpoint[9].

Of course, gJapanese lawh may have its own practical agenda: i.e., to influence, for example, gprimary U.S. lawh or to provide practical legal advice to Americans interacting with Japan. Titles such as gDoing Business in Japanh[10] and gLaw and Investment in Japanh[11] tailor also to this market, which flourished in the 1980s. Also, many gJapanese lawh writings, although driven by their general interest in Japan[12], are written in a fashion to affect the gprimary U.S. lawh. However, their practical message portion is not directed to the world of gnihon-hoh[13]. Thus, gJapanese lawh intersects with gsecondary nihon-hoh only to the extent that they share the external standpoint. And even then, they do not completely overlap because they have different purposes.

2. Little Impact?

If so, the question of what impact gJapanese lawh has had on gnihon-hoh should be asked primarily with regard to gsecondary-external nihon-hoh. The contention by Taylor and Nottage thatgJapanese lawh has had little impact on gnihon-hoh does not distinguish the multiple worlds of gnihon-hoh. When the right question is asked, a whole new picture emerges[14].

First of all, works of gJapanese lawh, especially those that are translated into Japanese, have been extensively quoted in gsecondary-external nihon-hoh. Mark Westfs work on sokaiya [corporate racketeers][15] takes up substantial time in Kyushu Universityfs corporation law lectures. Haley and Ramseyerfs work on litigation rates are standard references, profiled for instance in a popular textbook on the Japanese judicial system[16]. As a result, they presumably have influence over gsecondary-internal nihon-hoh, and may eventually have impact on gprimary nihon-ho", too.

One might say that these are exceptions and that most gJapanese lawh literature is ignored. Maybe so. But then, secondly, how many gsecondary-external nihon-hohhave significant impact on gsecondary-internal nihon-hoh or gprimary nihon-hoh? I am not proud about this, but my gsecondary nihon-hoh writings have had little impact on any other sub-world of gnihon-hoh[17]. I would also say that very few Japanese scholars have had or will have a direct impact on gprimary nihon-hoh in their lives. With regard to the limited impact gsecondary nihon-hoh actually has had on gprimary nihon-hoh in particular, Makoto Ibusuki attributes this to the tendency among many Japanese scholars to write about the gidealh with little regard to actual practice[18]. However, writing about the gidealh may have been true in the 19th century and up until 1960s, when an important role of legal scholars was to guide the courts. In those days, arguably, Japan adhered closely to the civil law tradition of gprofessorial lawh[19]. However, since then, the courts and the bar have grown strong and their expertise has expanded. Accordingly, the role of professors has diminished. Even their presence in various government councils (shingikai) is largely symbolic, and they are no longer power players in the field of policy-making or law-making[20]. (I hereby sadly report the death of professorial law tradition in Japan!) Today, no scholar in good conscience can write about law disregarding its practice. (However, I admit that Ibusukifs point may hold true to the field of criminal law, in which he specializes as a criminal procedure professor.) Thus, I speculate that the reason that we have little influence is not in our attitude, but in the strength and resources that legal practitioners have already gained. In other words, the world of gprimary nihon-hoh is becoming increasingly independent. The relative qualitative dilution of Japanese scholars may be an additional reason.

If this is so, the impact that gJapanese lawh has had on gnihon-hoh is quite remarkable. Also consider the quantity of gJapanese lawh in comparison to that of gsecondary nihon-hoh. gJapanese lawh has a much higher batting average[21]. So my point here is: patience, please!

D.The Autistic gnihon-hoh

1. Globalization and the gWorldsh

So far, I have proceeded on a very conservative assumption that gprimary nihon-hoh is the main concern and problem for Japan. To put my assumption in general terms, primary laws are matters of each jurisdiction, and each sovereign nation state. Yet this view is increasingly obsolete in the age of globalization. The problem of ggaikokuho jimu bengoshi (foreign law solicitors)h has attracted a lot of attention from non-Japanese, for example, and many gJapanese lawh articles were written to influence gprimary nihon-hoh on this issue. There, the standpoint of gJapanese lawh no longer remained external.

Moreover,there is a growing body of gprimary global/transnational lawh. In that world, we all share ginternal standpointsh, and legal studies (secondary law) of various countries start to converge[22]. At a regional level, this is most vividly seen in Europe today.

2. Autistic gnihon-hoh

The question I pose at this point is whether gnihon-hoh is ready for this. I must answer in the negative. But I believe early diagnosis will lead to cure. I will give one symbolic example, although I should mention that my expertise limits my analysis to the area of private law.

In November 1998, two major symposia were held consecutively in Tokyo and Kyoto commemorating the 100th anniversary of the Japanese Civil Code (Minpoten). These centennial symposia were entitled gLegislation and Private Law in the 21st Century: Private Law in the Age of Internationalizationh. Four panelists were invited from France, Germany, the United States (Richard Hyland), and the Netherlands (or rather E.U.: Ewoud Hondius). Incidentally, there were no Japanese. Further, both in Tokyo and Kyoto, time ran out with questions directed almost exclusively to the French and German panelists, who come from countries that had tremendous historical influence on all sub-worlds of gnihon-hoh. (Some were really gboringh microscopic black-letter-law questions, such as gtell me about the concept of property damagesh.) Admittedly, this was at an occasion of the 100th anniversary of the Civil Code, and black-letter-law questions may have been welcomed, but my impression is that gsecondary nihon-hoh (or secondary minpo) is taking the Code approach too seriously[23]. The panelists from E.U. and the United States, who were there to offer to look to the future,[24] were virtually ignored.

In addition to this backward looking mentality, the frustration I felt with the symposium was its autistic nature. It strikes me as odd that in a symposium dealing with the gPrivate Law in the Age of Internationalizationh, the topic of international unification or harmonization of law, or topics dealing with lex mercatoria, were not included. The most important instrument in this context is, of course, the UN Convention on Contracts for the International Sales of Goods (Vienna Sales Convention or CISG). It took effect in January 1988, and as of March 2001, nearly 60 countries are parties to it. CISG is starting to serve not only as a positive law applicable to international sales contracts, but also as a common framework of dialogue for lawyers who come from different legal traditions. The UNIDROIT Principles of International Commercial Contracts (1994) are also serving similar functions. They are a set of legal principles to be used in international commercial contracts in arbitration and possibly in courts. On the legal education front, the Willem C. Vis International Commercial Arbitration Moot, which takes place in Vienna every spring, has become an important vehicle in educating future lawyers in this field.[25] We are therefore witnessing an emergence of a supranational legal community. But when we look at Japan, we find that it is one of the only two major trading nations that have not even ratified CISG (the other being the U.K.). So "primary nihon-ho" is not at all ready to take on the challenges of globalization.

Neither is "secondary nihon-hoh ready. It is still obsessed with what we can hlearnh from other countries. Little is done to jointly build primary global law[26]. This is all the more shocking when we consider that Japan, with its scarce resources, cannot survive without international trade. The closing talk at the symposium given by an eminent Japanese civil law scholar, who is now a Supreme Court Justice, did mention CISG but in a very shocking way. He referred to CISG as an example of gDevelopment of European Contract Lawh. Then he maintained that as such, it should be given more attention as a subject of comparative law, together with Lando Commissionfs gEuropean Principles of Contract Lawh and the UNIDROIT Principles. However, CISG, as well as the UNIDROIT Principles are not gEuropeanh developments; they are attempts in harmonization of (primary) international contract law. It is not gtheirh problem; it is gourh problem. Hopefully, things have improved in the two or three years since the incident, but the perception within gsecondary nihon-hoh may remain seriously distorted.

3. Demystification and Globalization

I conclude with a brief note about the impact gJapanese lawh may have on the self-image of gnihon-hoh in the age of globalization. The greatest contribution of the recent gJapanese lawh literature is the message of gdemystificationh (as in the works by John Haley, Frank Upham, Mark Ramseyer and the younger generation)[27]. If Japan is no longer a mysterious society, gnihon-hoh can no longer be excused from the responsibility to contribute towards building primary global law. I have a dream that one day the worlds of gnihon-hoh will converge not only with gJapanese lawh or gJapanisches Rechth, but also with the world of the global legal community.

** Associate Professor of Law, Kyushu University. LL.M.1989, Hokkaido University; LL.M. 1990, University of Michigan Law School. I am grateful to the participants of the CAPI Colloquium gThe Multiple Worlds of Japanese Law: Disjunctions and Conjunctionsh (University of Victoria, April 3, 2001) for the helpful comments I received at the colloquium and at the online discussion which took place before and after our face-to-face encounter. I would also like to note that I had only limited access to Japanese law materials (both in the Japanese and English language) during the preparation of this essay. Citations remain arbitrary.

[*1] Luke Nottage, Japanisches Recht, Japanese Law, and Nihon-ho: Towards New Transnational Collaboration in Research and Teaching (in this volume)[an earlier version is here(lukeppr.htm)]. He develops on Veronica Taylor, Spectres of Comparison (in this volume)[an earlier version is here(sympo99taylor.pdf)]. I suspect that the worlds of Japanese legal studies are not limited to these three. For instance, judging from the nationalities of foreign students studying law in Japan (and especially in the case of Korea and Taiwan, judging from the history of pre-WW2 colonization), I imagine that Korea, China, and Taiwan have substantial amount of literature on law in Japan.

[*2] Whitmore Gray, The Use and Non-Use of Contract Law in Japan: A Preliminary Study, 17Law in Japan 98 (1984).

[*3] For example, see, Veronica Taylor, Continuing Transactions and Persistent Myths: Contracts in Contemporary Japan, 19 Melb. U. L. Rev. 352 (1993), Luke Nottage, Economic Dislocation and Contract Renegotiation in New Zealand and Japan: A Preliminary Empirical Study, 27 Victoria U.Wellington L. Rev. 59 (1997); Planning and Renegotiating Long-Term Contracts in New Zealand and Japan: An Interim Report on an Empirical Research Project, 1997New Zealand L. Rev.482; Bargaining in the Shadow of the Law and Law in the Light of Bargaining: Contract Planning and Renegotiation in the US, New Zealand, and Japan, in Interaction of Legal Cultures: Pre-publications of the Workshop on Changing Legal Cultures 113 (J. Feest & V. Gessner eds., O?ati International Institute for the Sociology of Law, 1998).

[*4] The conventional and increasingly contemporary criticism against Japanese universities as being givory towersh has little appreciation of this division of labour or the collective and multi-layered nature of academic research, and its autopoietic nature (cf.Gunther Teubner, Law as an Autopoietic System (Blackwell,1993)). Legal studies, in particular, are often naively denounced as being guseless for practice (jitsumu no yaku ni tatanai)h. However, those studies that have immediate impact on gprimary nihon-hoh are only tips of icebergs. Of course, I do not mean to give the academic community license to do whatever they please. I personally believe that even when a research has no immediate practical consequence, researchers should always be conscious of its relevance to real life situations, no matter how remote the relevance may be. Otherwise, scholarship will remain a self-satisfactory project.

[*5] I do not know if this is the same as H.L.A. Hartfs terminology.

[*6] Jurisuto,presumably the largest commercial legal journal in Japan, proclaims itself to be a gjitsuyo hogaku zasshih [applied legal studies journal].

[*7] Yuhikakufs gMinpo Kozahseries published in the 1980s (Eiichi Hoshino et al. eds.) has a standpoint that is even external to gsecondary-external nihon-hoh. They are collections of works that analyze the history and state of gminpo gakusetsu [academic commentary on civil law]h.

[*8] However, there are examples of gJapanese lawh literature containing case analyses from external standpoints. Among those with some flavor of black-letter-law are, for example, Mark Ramseyer, Japanese Antitrust Enforcement After the Oil Embargo, 31 Am. J. Comp. L. 395 (1983), Mark Ramseyer, Odd Markets in Japanese History (Cambridge University Press, 1996); Frank Bennett, Jr., Legal Protection of Solar Access under Japanese Law, 5 UCLA Pac. Basin L. Rev. 107 (1986), Clash of the Titles: Japanfs Secured Lenders Meet Civil Code Section 395, Netherlands Intfl L. Rev. 281 (1991), Procedure, Precedent, and Business Practice under the Japanese Civil Code, paper presented to the August 1995 meeting of the Research Committee on the Sociology of Law (Tokyo); Mark West, The Pricing of Shareholder Derivative Actions in Japan and the United States, 88Nw. U. L. Rev. 1436 (1994); and Curtis Milhaupt, A Relational Theory of Japanese Corporate Governance: Contract, Culture, and the Rule of Law, 37Harv. Intfl L.J. 41 (1996). Frank Bennettfs articles cited above may even have internal standpoints, though. So does Luke Nottage,Form and Substance in US, English, New Zealand, and Japanese Law: A Framework for Better Comparisons in the Law of Unfair Contracts, 27Victoria U.Wellington L. Rev 247 (1996).

[*9] Tom Ginsburg, In Defense of gJapanese Lawh (in this volume) offers an alternative (and not mutually exclusive) explanation. His explanation covers the reason why one U.S. variant of gJapanese lawh literature is more theoretical than gJapanisches Rechth scholarship. My explanation doesnft. However, to me, it rather suggests not a flaw in my theory but the rather puzzling purpose of gJapanisches Rechth world, as I understand it from Nottage, supra note 1. I must leave this for further exploration in the future.

[*10] Doing Business in Japan (Zentaro Kitagawa ed., Mathew Bender, 1980).

[*11] Law and Investment in Japan: Cases and Materials (Yukio Yanagida et al. eds., Harvard University Press, 1994).

[*12] A typical example that shows the authorfs joy is Mark West,Legal Rules and Social Norms in Japanfs Secret World of Sumo, 26J.Legal Stud. 165(1997).

[*13] I will leave this as gyour problemh for the time being, but will revisit it in Part D to conclude that it is gour problemh after all.

[*14] It would also depend upon how one defines gimpacth or ginfluenceh. In my definition, a view has gimpacth or ginfluenceh if it is considered to be relevant in the academic discourse. Whether people agree or not is a different matter.

[*15] Mark West, Information, Institutions, and Extortion in Japan and the United States: Making Sense of Sokaiya Racketeers, 93Nw. U. L. Rev. 767 (1999), (translated as Naze Sokaiya wa nakunaranainoka ? Yusuri to kabunushi Sokai no ho to keizaigaku [Why Donft Sokaiya Go Away? The Law and Economics of Blackmail and Shareholdersf Meetings](Kenichi Osugi trans.), 1145Jurisuto 60; 1146Jurisuto 114; 1147 Jurisuto 97 (1998)).

[*16] Setsuo Miyazawa et al., Tekisuto Bukku Gendai Shiho [A Textbook onContemporary Judicial System], (4th ed., Nihonhyoronsha, 2000). Haley and Ramseyerfs works are available in Japanese. A translation of John Haley, The Myth of the Reluctant Litigant, 4J.Japanese Stud. 359 (1978) appears in 902Hanrei Jiho 14 (1978); 907Hanrei Jiho 13 (1979) (Shintaro Kato trans.) and Mark Ramseyer has his ownHo to Keizaigaku: Nihon-ho no Keizai Bunseki [Law and Economics: Economic Analysis of Japanese Law](Kobundo, 1990).

[*17] One modest exception is a piece I wrote on the relationship between private law and competition law. Hiroo Sono gfDokkinho ihan koi no shihojo no koryokuronf Oboegaki: Keshohin hanbai tokuyakuten keiyaku no kaiyaku jirei wo sozai ni [A Memorandum on gThe Validity of Contracts in Violation of Antimonopoly Lawh: With Reference to Cosmetic Distributorship Cancellation Cases], 38Kanazawa Hogaku 263 (1996).

[*18] Makoto Ibusuki, A Response from a Nihon-ho Scholar: Why do We See Only the Trees, Not the Wood? (in this volume).

[*19] As outlined in Ginsburg, supra note 9.

[*20] See,e.g., Tom Ginsburg, A Change in System? A New Perspective on Japan's Administrative Procedure Law (in this volume). The gHosei Shingikai[Legislative Council]h, which dates back to the gHoten Chosakai [Code Research Commission]h in the late 19th century, and the current gShiho Seido Kaikaku Shingikai [Judicial Reform Council]h may be exceptions. On the former, see generally,EiichiHoshino,Hosei Shingikai,in9 Minpo Ronshu [Essays on Civil Law] (Yuhikaku, 1999). On the latter, see briefly Luke Nottage, Reformist Conservatism and Failures of Imagination in Japanese Legal Education (in this volume) and Noboru Kashiwagi, New Graduate Law Schools in Japan and Practical Legal Education (in this volume).

[*21] Then, why is it that gJapanese lawh scores better? It probably is because they make more interesting and provocative points. Why Japanese donft write that way is a question Ibusuki eloquently answers using the metaphor of gthe wood and the treesh (supra note 18). Luke Nottage prefers another: gFoxes and Hedgehogsh (<http://www.iue.it/LAW/res/nottage/Foxes2new.html>, forthcoming in Council Brief, the newsletter of the Wellington District Law Society), abridged as Kitsune to Harinezumi [Foxes and Hedgehogs],1636Toki no Horei 4 (2001). This probably is what I mean when I say gsecondary-internal nihon-hoh builds up the bulk of secondary nihon-ho. In addition, the gtatewarih mentality (or territorial protectionism) of scholars maybe another cause. It takes certain amount of courage to cross boundaries. Two prominent exceptions among civil law scholars are Zentaro Kitagawa and Masanobu Kato. Kato even has a book on Tenno-sei!Masanobu Kato, Tenno [The Emperor] (Ministry of Finance Printing Bureau, 1994).

[*22] Taylor, supra note 1, argues that Japanese law will increasingly be linked to other jurisdictions and cross-border transactions (e.g., in areas such as e-commerce; the activities of multinationals; the rise of multilateral and international law, and the regional transfer of law through legal aid development). Thus, she maintains that Japan is no longer legally insulated, and that Japanese legal studies can occur both inside and outside national boundaries. See also generally Luke Nottage,Practical and Theoretical Implications of the Lex Mercatoria for Japan: CENTRALfs Empirical Study on the Use of Transnational Law, 4/2Vindobona L.J.132(2000); forthcoming also inRevue Juridique polynesi?nne and (translated in)Kokusai Shoji Homu.

[*23] Eiichi Hoshino,Minpo no Susume [A Recommendation of Civil Law] (Iwanami Shoten, 1999) is exemplary of this trend.

[*24] When Japan was commemorating the passing of one century, EU was looking into the new millennium. Ewoud Hondiusf paper was entitled gFinding the Law in a New Millennium: Prospects for the Development of Civil Law in the European Unionh. Richard Hyland was also forward looking. He prepared an excellent paper entitled gPerspectives on Private Law Codification in America in the 21st Centuryh which he was not given time to present, even in part.

[*25] Hiroo Sono & Luke Nottage,Uin Baibai Joyaku (CISG) to hogaku kyoiku: Dainanakai Willem C. Vis Mogi Kokusai Shoji Chusai Taikai Sankaki[The Vienna Sales Convention (CISG) and Legal Education: Chronicle of Participation in the Seventh Annual Willem C Vis Commercial Arbitration Moot Competition], 67Hosei Kenkyu745(2001); Uin Baibai Joyaku (CISG) to Hogaku Kyoiku [The Vienna Sales Convention (CISG) and Legal Education], 1186Juristo24 (September 2000). See also Luke Nottage, Educating Transnational Commercial Lawyers for the 21st Century: Towards the Vis Arbitration Moot in 2000, 66-1Hosei Kenkyu F1-30, 66-2Hosei Kenkyu F1-32 (available through <http://www.law.kyushu-u.ac.jp/~luke/visteam.html>).

[*26] Takashi Uchida has been making this point for quite a while. I vividly recall his breathtaking gstirringh at the 1998 Nihon Shiho Gakkai [Japan Association of Private Law] Symposium on gObligation Law Reformh which took place a few weeks before the Centennial Symposium mentioned in the text. Most recently, see,Takashi Uchida, Keiyaku no Jidai [The Age of Contract] 277-279 (Iwanami Shoten, 2000).

[*27] I have quoted Haley and Ramseyer's work elsewhere in this essay. Accordingly , I will cite one work by Upham here:Frank Upham,Law and Social Change in Postwar Japan (Harvard University Press, 1987).