Consular Section invalidated C’s valid Chinese passport immediately on site by cutting off the passport’s right-hand corner and applying a cancellation mark.142 The country with which C has relations is China; however, by invalidating C’s passport, the Embassy of China in effect made it impossible for C to return to China. The official invalidation of the passport of a national who is overseas and the prohibition of his return means that the right to return to one’s country of origin, which is a core right of a national, is denied, and it can be interpreted that the authorities made it clear that they do not treat C as a national in practice. Therefore, it is possible that C became stateless, not being considered as a national by any State under the operation of its law. On the other hand, the Japanese government had considered C as a Chinese national even after his passport was cancelled, and it has placed China as his nationality on his (former) alien registration certificate and in various procedures. 5. Possible size of Category C (1) Current State of Japan’ Refugee Status Determination System As stated above, refugees and asylum seekers may, depending on the circumstances of individual cases, be at risk of not being treated as nationals by their State of origin and having their nationality lost arbitrarily. Even so, if recognized as a refugee in Japan, one can benefit from various advantages (protections) such as the following: (a) in principle, the status of a “long term resident” (valid for five years and renewable, according to recent practice) is granted; (b) a refugee travel document is issued (Refugee Convention Article 28, ICRRA Article 61-2-12); (c) the conditions for a permanent residence permit are relaxed; 143 (d) an assistance program including Japanese language education is offered at a facility for supporting long-term residents; 144 and (e) various difficulties are reduced in public life as a result of having Japanese law as the law applicable to the personal status of refugees. However, the number of refugee recognitions in Japan has remained at a quite low level for many years, varying from a few per year to some tens per year.145 Since the refugee 142 Later, C was recognized as a refugee by Japan in December 2001. For details of Case 6, see Sosuke Seki, “Chounan Jiken [Zhao Nan Case]”, Ito Kazuo Bengoshi Zaishoku 50 Shuunen Shukuga Ronbunshuu: Nihonniokeru Nanmin Soshouno Hattento Genzai [Collection of Papers in Celebration of Attorney Kazuo Ito’s 50 Years of Work: Development of Asylum Litigation in Japan and Where We Are Today] (Gendai Jinbunsha, 2010), pp.51-62. 143 For recognized refugees, the requirement for the period of residence is eased, and the requirement for ability to support oneself is waived. Ministry of Justice, “Eijuu Kyokanikansuru Gaidorain [Guidelines on Permission for Permanent Residence]”, at http://www.moj.go.jp/nyuukokukanri/kouhou/nyukan_nyukan50.html. 144 See Agency for Cultural Affairs, “Nanminni Taisuru Nihongo Kyouiku [Japanese Language Education for Refugees]”, at http://www.bunka.go.jp/seisaku/kokugo_nihongo/kyoiku/nanmin_nihongokyoiku/. 145 The total annual number of recognitions, including first instance and appeal, was 46 in 2005, 34 in 2006, 41 in 2007, 57 in 2008, 30 in 2009, 39 in 2010, 21 in 2011, 18 in 2012, 6 in 2013, 11 in 2014, 66