Washington International Law Journal


Etsuro Tutsuka


Despite international condemnation, Japan has done little to recognize its responsibility for forcing over 200,000 "Comfort Women" into sexual slavery for the Japanese Imperial Army during the Second World War. However, in a landmark April 1998 decision, a Japanese court ordered Japan to compensate three Korean "Comfort Women." This was the first time that a Japanese court found in favor of foreign plaintiffs in a postwar compensation case. The court held members of the Diet negligent under the State Liability Act for failing to enact a compensation law for the "Comfort Women." Although the judgment will almost certainly be overturned, it should have widespread political impact. The court's extensive fact-finding regarding "Comfort Women" will be hard to challenge and should bolster the movement to have the Japanese Govemment compensate and restore dignity to the "Comfort Women" victims.

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