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Same-Sex Marriage in Japan: Prospects for Change

Published online by Cambridge University Press:  23 February 2021

Frank K. UPHAM
Frank K. UPHAM*
Affiliation:
NYU School of Lawuphamf@mercury.law.nyu.edu BY INVITATION
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Abstract

This article examines why Japan is a prominent exception to the global trend towards recognition of same-sex marriage and evaluates the prospects for change. It does so through an analysis of five cases brought on Valentine's Day – 14 February 2019. Unlike many jurisdictions where religious opposition to same-sex relationships has been intense and sometimes violent, Japan has a history of relative tolerance towards LGBT individuals. Nonetheless, despite the creation of civil partnership ordinances in some localities, national legislation seems unlikely, and a group of lawyers filed suit in five district courts across Japan. The litigation was brought under the State Redress Act and is based on tort rather than directly on constitutional doctrine. It claims that marriage equality is constitutionally required and that the failure of the government to recognize same-sex marriage constitutes a tort that has harmed the LGB plaintiffs and entitles them to compensation. This article analyzes the nature of the cause of action founded on the State Redress Act, and examines the arguments, which are based more on the plaintiffs’ suffering than on their desire for self-expression. Subsequently, it presents and evaluates the possible outcomes

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Article
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Asian Journal of Comparative Law , Volume 15 , Issue 2 , December 2020 , pp. 195 - 224
Copyright
Copyright © The Author(s), 2021. Published by Cambridge University Press on behalf of the National University of Singapore.

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Footnotes

*

Wilf Family Professor of Property Law, New York University School of Law. Because this area of law is new to me, I am indebted to more people than I can thank appropriately. I owe special thanks, however, to Bruce Aronson, Chao-ju Chen, Weitseng Chen, Hikaru Iwaki, Liam Kantor, Takeharu Kato, Sam Kramer, Takayuki Obata, Taro Tanaka, and Kenji Yoshino.

+

The terms ‘LGBT’ and ‘LGB’ are used at different points in this article, as the argument about gays is distinct from that on transgender issues. The term ‘LGB’ is therefore used where I intend to refer specifically to the gay, lesbian, and bisexual communities, but not the transgender community. The term ‘gay/gays’ is also used at times to generally encompass lesbian, gay, and bisexual, but not transgender, individuals.

References

1. Ellison, Ralph, Invisible Man (Random House 1952) 1Google Scholar.

2. See 同性婚人権救済弁護団 (Douseikon jinken kyūsai bengodan) [Same-Sex Marriage Human Rights Relief Lawyers Group], 同性婚: だれもが自由に結婚する権利 (Douseikon: daremo ga jiyū ni kekkon suru kenri) [Same-sex Marriage: Everyone has the Right to Marry] (Akashi Shoten 2016) 84: ‘The background to why there have not been many social movements or judicial battles in favor of same sex marriage as in the West is this lack of existence – “sonzai shinai mono” – aspect of Japanese homophobia.’

3. One of the most recent affluent democracies to recognize same-sex marriage, and the first to do so in East Asia, was Taiwan where the Constitutional Court (the Judicial Yuan) announced on 24 May 2017 that limiting marriage to heterosexual couples violated both the freedom to marry and the right to equality. The Court gave the government two years to correct the unconstitutionality, and on 17 May 2019, the Legislative Yuan passed a statute recognizing same-sex marriage. Another exception to the general trend is South Korea, which has a large and influential Christian minority (29%, as compared to 46% who are Buddhist). See ‘These South Korean women went abroad to get married. Then one spoke out at home, and the backlash began’ (The Washington Post, 22 Mar 2020) <www.washingtonpost.com/world/asia_pacific/south-korea-same-sex-marriage-gay-lesbian/2020/03/22/2890df14-61f6-11ea-912d-d98032ec8e25_story.html> accessed 3 Jun 2020; Thomas Maresca, ‘In Korea LGBT activists push for marriage equality’ (UPI, 13 Nov 2019) <www.upi.com/Top_News/World-News/2019/11/13/In-South-Korea-LGBT-activists-push-for-marriage-equality/8641573630204/> accessed 3 Jun 2020.

4. ‘Same sex marriage lawsuits to be filed on Valentine's Day by 13 couples nationwide’ (The Mainichi, 4 Feb 2019) <https://mainichi.jp/english/articles/20190204/p2a/00m/0na/022000c> accessed 3 Jun 2020. Suits were originally filed in Osaka, Nagoya, Sapporo, and Tokyo. On 5 September 2019, a fifth suit was filed in Fukuoka: Magdalena Osumi, ‘LGBT couples speak of their suffering in lawsuit seeking marriage for all in Japan’ (Japan Times, 15 Apr 2019) < www.japantimes.co.jp/news/2019/04/15/national/lgbt-couples-speak-suffering-lawsuit-seeking-marriage-japan/> accessed 3 Jun 2020.

5. This statement must be qualified by the fact that boundaries delineating racial, ethnic, and sexual identities are fluid and malleable. For one striking illustration of the precarious nature of these definitions and boundaries, see ‘A Little White Lie’ (OTB Productions LLC, 2015) <www.littlewhiteliethefilm.com/> accessed 3 Dec 2020.

6. One possible factor that is beyond the scope of this article is that Japanese are generally less sexually active than most other societies, and this has an effect on sexual minorities as well as the general population. For an exploration of the relationship between sex and law in Japan, see West, Mark, Lovesick Japan: Sex/Marriage/Romance/Law (Cornell University Press 2011)Google Scholar.

7. Michael Goodrich, The Unmentionable Vice: Homosexuality in the Later Medieval Period (ABC-Clio 1979). Reviewed by Charles T Wood in ‘Speculum: A Journal of Medieval Studies’: (1980) 55 Journal of the Medieval Academy of America 121.

8. Gary P Leupp, Male Colors: The Construction of Homosexuality in Tokugawa Japan (UC Press 1997).

9. ibid 1–5.

10. Anna Fifield & Yuki Oda, ‘It's Fine to be Gay on Japanese TV – If You're Outlandish and Outrageous’ (The Washington Post, 25 Mar 2015) <https://www.washingtonpost.com/world/its-fine-to-be-gay-on-japanese-tv--if-youre-outlandish-and-outrageous/2015/03/24/b3c3ac00-ce77-11e4-8730-4f473416e759_story.html> accessed 24 Nov 2020.

11. Eric Prideaux, ‘Is this really just good fun?’ (The Japan Times, 19 Mar 2006) <https://www.japantimes.co.jp/life/2006/03/19/to-be-sorted/is-this-really-just-good-fun/#.XPA-KdNKjX8> accessed 4 Dec 2020.

12. Fifield & Oda (n 10).

13. For a survey of Japanese attitudes as of 2019, see ‘LGBT意識行動調査2019’ (LGBT ishiki kōdō chōsa 2019) [LGBT Awareness Movement Survey 2019] <www.daiko.co.jp/dwp/wp-content/uploads/2019/11/191126_Release.pdf> accessed 4 Dec 2020 (hereinafter ‘2019 LGBT Survey’). For American attitudes, see Obergefell v Hodges 574 U.S. 1118 (2015). See also ‘Vast majority of Americans know someone who is gay, fewer know someone who is transgender’ (Pew Research Center, 28 Sep 2016) <https://www.pewforum.org/2016/09/28/5-vast-majority-of-americans-know-someone-who-is-gay-fewer-know-someone-who-is-transgender/> accessed 4 Dec 2020.

14. ibid, 2019 LGBT Survey.

15. Jonathan Rauch, Gay Marriage: Why It is Good for Gays, Good for Straights, and Good for America (Henry Holt & Co 2004) 82–83. The same survey in 2008 showed that 76% of schools did not mention sexual orientation at all; 4% portrayed it as 異常な者 (ijō na mono) [abnormal]; 10% presented it in a negative light; and only 6.5% presented it in a positive light.

16. ibid 10.

17. The two Diet members are Otsuji Kanako and Ishikawa Taiga: see ‘参院選で石川大我さんが当選し、初のオープンリー・ゲイの国会議事員が誕生しました (Saninsen de Ishikawa Taiga-san ga tōsen shi, hatsu no ōpunrī gei no kokkaigijiin ga tanjō shimashita) [Ishikawa Taiga's appearance on the Upper House election ballot and the birth of the first openly gay National Diet member]’ (Out Japan, 22 Jul 2019) <www.outjapan.co.jp/lgbtcolumn_news/news/2019/7/13.html> accessed 4 Dec 2020. Otsuji describes their situation: ‘For many politicians, same-sex marriage is a topic to avoid. Another contributing factor is Japan's culture of shame. Coming out is considered shameful in Japanese culture, so if one comes out, it's not encouraged or looked upon favorably by others. For East Asia in general, there is an attitude of “don't rock the boat”. Homophobia is invisible here and we have to fight this silent avoidance.’ See also Stephanie Anderson, ‘8 things ‘Gaycation’ taught us about Japanese LGBTQ+ culture’ (SBS Australia, 16 Aug 2017) <www.sbs.com.au/topics/pride/fast-lane/article/2016/11/16/8-things-gaycation-taught-us-about-japanese-lgbtq-culture?cid=inbody%3Atransgender-man-in-japan-launches-appeal-against-enforced-sterilisation> accessed 4 Dec 2020.

18. Rauch (n 15) 86.

19. Hifumi Okunuki, ‘Japan's courts don't share Sugita Mio's views on supporting LGBT people, precedents show’ (Japan Times, 30 Jul 2018) <www.japantimes.co.jp/community/2018/07/30/issues/japans-courts-dont-share-mio-sugitas-views-supporting-lgbt-people-precedents-show/> accessed 17 Dec 2020. For a statement of the official LDP position on gender issues, see ‘性的指向・性同一性（性自認）の多様性って？～自民党の考え方～ (Seitekishikō, seidōissei (seijinin) no tayōsei tte? ～jimintō no kangaekata～) [What is the diversity of gender identities, sexual orientation and gender dysphoria? The thoughts of the Liberal Democratic Party]’ (Jimintō) <https://jimin.jp-east-2.storage.api.nifcloud.com/pdf/pamphlet/20160616_pamphlet.pdf> accessed 17 Dec 2020. According to a survey conducted by the Japan Alliance for LGBT Legislation at the time of the House of Councillors elections in 2019, all the major political parties said that LGBT issues need to be actively addressed as a human rights issue. In addition, six out of eight major political parties have included the enactment of a legal system that guarantees the human rights of LGBT people in their manifestos and pledges. See ‘【参議院選挙2019・政党】LGBT・性的指向・性自認をめぐる課題に関する各党の政策と考え方についての調査結果報告〔各政党〕([Sangiinsenkyo 2019, seitō] LGBT, seitekishidō, seijinin wo meguru kadai ni kansuru kakutō no seisaku to kangaekata ni tsuite no chōsa kekka koukoku [kaku seitō]) [House of Councillors Election 2019: Announcement of the survey results for each party's thoughts and policy plans on topics relating to LGBT, sexual orientation, and sexual acceptance]’ (LGBT Hou Rengōkai, 10 Jul 2019). The Japanese government's official diplomatic position on sexuality as a protected status is at least superficially positive. Japan is one of the members of the UN LGBT Core Group and it supported two recent UN Human Rights Council resolutions on LGBT rights.

20. As of 1 April 2020, there were 47 municipalities recognizing same-sex couples, and 945 couples had received a partnership certificate as of 20 April 2020. See ‘パートナーシップ制度導入47自治体に港区など13市区町新たに開始 (Pātonāshippu seidodōnyū 47 jichitai ni minato-ku nado 13 shiku machi arata ni kaishi) [47 municipalities in 13 wards have begun plans anew to introduce partnership systems]’ (Tokyo Shimbun, 14 Apr 2020) <https://news.line.me/issue/oa-tokyoshimbun/s8liks6kdnn0?utm_source=Twitter&utm_medium=share&utm_campaign=none> accessed 4 Jun 2020; ‘全国パートナーシップ制度導入済み自治体状況 (zenkoku pātonāshippu seidō dōnyū sumi jichitai jōkyō) [The state of partnership systems across the country]’ (Jichitai ni Pātonāshippu wo Motomeru Kai, 1 Apr 2020) <www.facebook.com/partnership.lgbt/posts/682269599208044> accessed 4 Dec 2020; ‘地方自治体の動静パートナーシップ認知事件（2020年4月20日時点）(chiho jichitai no dosei patonashippu ninchi jiken (nisennijunen shigatsu hatsuka jiten)) [Count of regional municipalities which have recognized same-sex partnerships (as of 20 April 2020)]’ (Nijiro Diversity, 20 Apr 2020) <https://nijiirodiversity.jp/partner20200420/> accessed 4 Dec 2020.

21. Magdalena Osumi, ‘Justice Ministry overturns deportation order for gay Taiwanese man without visa’ (Japan Times, 22 Mar 2019) <www.japantimes.co.jp/news/2019/03/22/national/justice-ministry-overturns-deportation-order-gay-taiwanese-man-without-visa/#.XO76StNKjX8> accessed 4 Jun 2020.

22. The full name of this organization is ‘Japan Alliance for Legislation to Remove Social Barriers based on Sexual Orientation and Gender Identity’. See LGBT Law Association <http://lgbtetc.jp/> accessed 24 Nov 2020.

23. As of April 2020, there were 2 gay men, 6 transgender individuals, 1 lesbian, and one other person of a sexual minority holding local office: ‘統一地方選で、5名のLGBTの候補者が当選を果たしました(Tōitsu chihō senkyo kohansen de 5 mei no LGBT no kohōsha ga tōsen wo hatashimashita) [5 LGBT candidates win seats in the second half of the regional elections]’ (Out Japan, 22 Apr 2019) <https://outjapan.co.jp/lgbtcolumn_news/news/2019/4/12.html> accessed 4 Dec 2020. See also ‘Politicians launch group to promote LGBT-friendly policies’ (Kyodo News, 6 Jul 2017) <https://english.kyodonews.net/news/2017/07/0800a856879a-politicians-launch-group-to-promote-lgbt-friendly-policies.html> accessed 4 Dec 2020.

24. The lack of LGB legislators need not equate to lack of legislative action. Nor should we assume that LGB politicians or individuals will necessarily advocate for same-sex marriage.

25. Michael Dorf & Sidney Tarrow, ‘Strange Bedfellows: How an Anticipatory Countermovement Brought Same-Sex Marriage into the Public Arena’ (2014) 39 Law & Social Inquiry 449, 450. For a complementary perspective on the Japanese situation, see Mark McLelland, Queer Japan from the Pacific War to the Internet Age (Rowman & Littlefield 2005) 174: ‘Many gay men and lesbians, once they had come out to a small group of friends, were more interested in pursuing social activities than in agitating for widespread reform.’ While organized movements have proliferated since 2005, the basic lack of urgency remains widespread.

26. Julie Bindel, ‘The truth behind America's most famous gay-hate murder’ (The Guardian, 26 Oct 2014) <www.theguardian.com/world/2014/oct/26/the-truth-behind-americas-most-famous-gay-hate-murder-matthew-shepard> accessed 13 Dec 2020. Ironically, despite the iconic nature of Shepard's murder as a hate crime, there is a competing interpretation that claims that it was primarily a drug-related robbery-murder. See Stephen Jimenez, The Book of Matt: Hidden Truths about the Murder of Matthew Shepard (Steerforth 2013).

27. Jude Sheerin, ‘Matthew Shepard: The murder that changed America’ (BBC News, 26 Oct 2018) <www.bbc.com/news/world-us-canada-45968606> accessed 13 Jul 2020.

28. Among the many works advocating marriage equality, Rauch (n 15) is particularly striking for its emphasis on the importance of normalization of the LGB community.

29. Obergefell v Hodges, 135 S. Ct. 2584 (2015) <https://www.supremecourt.gov/opinions/14pdf/14-556_3204.pdf> accessed 17 Dec 2020.

30. The depth of humiliation was tragically marked by the suicide in 2016 of a gay student at Hitotsubashi University after a friend disclosed his sexuality on social media. Consistent with the theory of Dorf and Tarrow, the suicide sparked at least some recognition of LGBT issues on the Hitotsubashi campus. See ‘一橋大学生転落死「彼は自分だったかも」裁判知った2人、居場所作りのサークル (Hitotsubashi daigakusei tenrakushi ‘kare wa jibun datta kamo’ saiban shitta futari, ibashodzukuri no sakuru) [2 students form social group for sexual minorities at Hitotsubashi University after suicide]’ (The Mainichi, 28 Feb 2019) <https://mainichi.jp/articles/20190228/ddm/041/040/133000c> accessed 13 Jul 2020.

31. The defendants had repeatedly targeted gay men at that location because they thought the victims would be too ashamed to report the incident to the police. See Nagayasu Shibun, ‘Sexual Minorities in Japan: The Myth of Tolerance’ (Nippon, 21 Oct 2016) <www.nippon.com/en/currents/d00253/> accessed 4 Dec 2020.

32. This not to say that there was no opposition in Taiwan, or that religious institutions were not involved. In fact there was opposition, primarily from the small Christian community and from those who felt that same-sex marriage violated Confucian values. See eg Lee, Po-Han, ‘LGBT Rights Versus Asian Values: De/reconstructing the Universality of Human Rights’ (2016) 20 International Journal of Human Rights 978CrossRefGoogle Scholar.

33. ‘Petition for Human Rights Relief’ (translated by the Lawyers for LGBT & Allies Network, Lawyers for the Equal Marriage Petition, 2015) < http://llanjapan.org/> accessed 4 Dec 2020.

34. See Rauch (n 15).

35. Obergefell v Hodges (n 29).

36. ibid 6–7.

37. The Japanese Constitution, art 13 provides: ‘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.’ Art 13 is sometimes phrased as the 人格権 (jinkaku ken) [right of personality], and at other times as the 自己決定権 (jiko kettei ken) [right of self-determination].

38. See Obergefell v Hodges (n 29) 8.

39. Rauch (n 15).

40. For a thorough discussion of the similar role that courts played in pre-war Japan, see Colin Jones, Living Law in Japan: Social Jurisprudence in the Interwar Period (Columbia University Press 2017).

41. Two examples of the many insightful explications of this interpretation are Matsui, Shigenori, ‘Why Is the Japanese Supreme Court So Conservative?’ (2009) 88 Washington University Law Review 1375Google Scholar; Law, David, ‘The Anatomy of a Conservative Court: Judicial Review in Japan’ (2009) 87 Texas Law Review 1545Google Scholar.

42. Supreme Court, 31 Jan 1977, 268 Rōdō Hanrei 17.

43. ibid.

44. See Daniel Foote, ‘Judicial Creation of Norms in Japanese Labor Law: Activism in the Service of Stability’ (1995) 43 UCLA Law Review 635.

45. Supreme Court, 19 Feb 1952, 6 Minshū 110.

46. Supreme Court, 2 Sep 1987, 41 Minshū 1423. For an account of the contemporary social status and the process of divorce in Japan, see Allison Alexy, Intimate Disconnections: Divorce and the Romance of Independence in Contemporary Japan (University of Chicago Press 2020).

47. For the history of this development see Frank Upham, Law and Social Change in Postwar Japan (Harvard University Press 1987) ch 4, 124–165.

48. 労働基準法 (roudoukijun hou) Law No 49, 1947.

49. The Japanese Constitution, art 24 provides: ‘Marriage shall be based only on the mutual consent of both sexes and it shall be maintained through mutual cooperation with the equal rights of husband and wife as a basis. With regard to choice of spouse, property rights, inheritance, choice of domicile, divorce and other matters pertaining to marriage and the family, laws shall be enacted from the standpoint of individual dignity and the essential equality of the sexes.’

50. Upham (n 47) 132–133.

51. 性同一性障害者の性別の取扱いの特例に関する法律 (Seidō issei shōgaisha no seibetsu no toriatsukai no tokurei ni kan suru hōritsu) [Japan-Act on Special Cases in Handling Gender for People with Gender Identity Disorder] (promulgated by the National Diet, 16 Jul 2003, effective 16 Jul 2004, updated 25 May 2011) Law No 111 (2003) and 53 (2011).

52. The Supreme Court upheld the law against attacks on both the requirement of surgery and the exclusion of married persons. The affirmation of constitutionality was not unequivocal, however, especially as to the requirement of surgery. The majority opinion cautioned that ‘it is necessary to constantly examine the constitutionality of the provision,’ and two Justices wrote a concurring opinion warning that although they could not say it presently violates art 13, they ‘cannot deny there is a doubt of unconstitutionality’. See Thisanka Siripala, ‘Japan's Supreme Court Upholds Surgery as Necessary Step for Official Gender Change’ (The Diplomat, 5 Feb 2019) <https://thediplomat.com/2019/02/japans-supreme-court-upholds-surgery-as-necessary-step-for-official-gender-change/> accessed 4 Dec 2020.

53. Tokyo District Court, 20 Jun 2002, 830 Rōdō Hanrei 13.

54. ibid 20-21.

55. ibid 21.

56. Shizuoka District Court Hamamatsu Branch, 8 Sep 2014, 2243 Hanrei Jihō 67.

57. ibid.

58. ibid.

59. ibid.

60. ibid.

61. Tokyo District Court, 30 Mar 1994, 859 Hanrei Times 163; Tokyo High Court, 16 Sep 1997, 986 Hanrei Times 206.

62. Their interpretation by the average Japanese person, however, may differ from that of observers in countries where religion and sexuality play a larger role in politics and morality. For an American, for example, conflict between conservative Christians and openly gay persons would be expected. For most Japanese, for whom religion and sexuality are generally invisible private matters, both parties to the dispute may appear bizarre. As one anonymous observer put it to the author, ‘The average Japanese at the time wouldn't understand why the gays love each other, but equally would have had no clue as to why Christians are so excited about it. For average Japanese the reaction would be “why the fuss?”’

63. 859 Hanrei Times 163 (n 61).

64. 地方自治法 (Chihō-jichi-hō), Law No 67 of 1947.

65. Tokyo High Court, 16 Sep 1997, 986 Hanrei Times 206, 214.

66. ibid.

67. State Redress Act, art 1, para 1. The 国家賠償法 (kokka baishō hō) [State Redress Law, or Law Concerning State Liability for Compensation] (promulgated by the National Diet, 27 Oct 1947) Law No 125, implements art 17 of the Japanese Constitution: ‘Every person may sue for redress as provided by law from the State or a public entity, in case he has suffered damage through illegal act of any public official.’

68. 行政事件訴訟法 (gyousei jiken soshouhou) [Administrative Case Litigation Act, Law No 139 of 16 May 1962.

69. Supreme Court, 14 Sep 2005, 59[7] Minshū (Judgement concerning whether or not the Public Offices Election Law was in violation of Art 15(1) and (3), Art 43(1), and the proviso of Art 44 of the Japanese Constitution for the reason that it completely precluded Japanese citizens residing abroad from voting in national elections at the time of the general election of members of the House of Representatives held on 20 October 1996) <https://www.courts.go.jp/app/hanrei_en/detail?id=1264> accessed 14 Dec 2020.

70. The former art 733(1) provided: ‘A woman may not remarry unless six months have passed since the day of dissolution or rescission of her previous marriage.’

71. Valentine's Day Litigation Complaint (Marriage for All Japan, 2019) 56 (copy on file with author).

72. ibid (emphasis added).

73. ibid.

74. ibid.

75. ibid.

76. Jonathan Soble, ‘Japan's Top Court Upholds Law Requiring Spouses to Share Surname’ (New York Times, 16 Dec 2015) <www.nytimes.com/2015/12/17/world/asia/japan-court-ruling-women-surnames.html> accessed 4 Jun 2020. For an extensive discussion of the social impact of requiring the same surname and its relationship to the pre-war ie system see Etsuko Toyoda, ‘Japan's Marital System Reform: The Fūfubessei Movement for Individual Rights’ (2020) 18 [13] Asia-Pacific Journal/Japan.

77. Supreme Court Grand Bench, 16 Dec 2015, 69 Minshū 8, 2586.

78. ibid (emphasis added).

79. ibid.

80. ibid (emphasis added).

81. ibid.

82. Valentines’ Day litigation complaint (n 71).

83. Ben Dooley, ‘Japan's Support for Gay Marriage is Soaring But Can It Become Law?’ (New York Times, 27 Nov 2019) <https://www.nytimes.com/2019/11/27/world/asia/japan-gay-marriage.html> accessed 15 Dec 2020.

84. Supreme Court Second Petty Bench Decision, 23 Jan 2019 <http://www.courts.go.jp/app/files/hanrei_jp/274/088274_hanrei.pdf> accessed 5 Dec 2020.

85. Supreme Court, 14 Sep 2005, 59 Minshū 7.

86. ‘90年代のゲイブームを牽引した大塚隆史さん、LGBTを語る「一過性で終わらせないために、すべきことがある」 (90 nendai no geibumu wo kennin shita Otsuka Takashi san, LGBT wo kataru ‘ikkasei de owarasenai tame ni, subeki koto ga aru’)’ [Otsuka Takashi, the man behind the gay boom of the 90s, tells us of the future of the LGBT movement: ‘This will not end passively; we must do something about it’] (Huffington Post, 2 Apr 2016) <www.huffingtonpost.jp/2016/04/01/takashi-otsuka-lgbt_n_9596618.html> accessed 13 Aug 2020.