817-2 and following)89 was granted by the family court, the court also determined E’s nationality as stateless.90 E is currently an adopted child of a Japanese national. In the future, E plans to apply for naturalization to obtain Japanese nationality based on Article 8(ii) of the Nationality Act (simplified naturalization), which simplifies the normal requirements for naturalization for an adopted child of a Japanese citizen when the child has had a domicile in Japan for one year or more.91 3. Possible Size of Category A (1) Possible cases of conflict of nationality laws Cases 1 and 2 show a traditional pattern of statelessness where there is a clash of provisions for the acquisition of nationality by birth. For example, in the past when the Nationality Act of Japan followed paternal jus sanguinis, the so-called Amerasian children, who were born in Japan from a Japanese mother married to an American soldier, were stateless.92 Also, as Brazil followed the jus solis principle in the past, children born in Japan from parents with Brazilian nationality sometimes became stateless.93 The granting of Japanese nationality by birth, according to the Nationality Act, is based primarily on jus sanguinis, but it also follows jus solis to complement it, thereby preventing statelessness to some extent. However, in addition to the cases mentioned above, a child born in Japan may become stateless by a clash of laws regarding the acquisition of nationality by birth. The following four general patterns can be found in such cases, namely, for the acquisition of nationality, the country concerned requires: (a) residency, (b) that the parents are nationals of the country, (c) registration in case of births outside of the country, or (d) paternal lineage following the jus sanguinis principle. 89 “Special Adoption is a form of adoption established by a ruling of a family court, by which the legal relationship between a child and his or her natural relatives is extinguished, and a stable relationship is established between the child and his or her adoptive parent similar to that between a real parent and child, when there is a special need for the welfare of the minor, in principle below the age of 6. For this purpose, the person to be an adoptive parent, needs to have a spouse, be 25 years old or above in principle, and the couple must jointly make the adoption. Also, divorce is prohibited in principle.” Homepage of the Courts, at http://www.courts.go.jp/saiban/syurui_kazi/kazi_06_09. 90 Yokohama Family Court, Yokosuka Branch, adjudication on 10 November 2015 (Heisei 27 Nen (Ka) No. 203), unpublished. It was kindly made available by Tazuru Ogawa, Representative of the Board of Directors, Across Japan, which is a general incorporated association. 91 Asahi Shimbun, 9 January 2016 evening edition, “Mukokusekino Akachan Sukueru: Youshiengumi Sureba Nihon Kokusekini Michi [Stateless Baby Can Be Saved: Road to Japanese Nationality Through Adoption]” (reported by Eri Goto), at http://www.asahi.com/articles/ASHDV4W4JHDVUHMC002.html. It was widely reported that there is a way for a stateless child to acquire Japanese nationality at an early stage through Special Adoption, and it drew much attention. 92 Also see Abe Report, supra note 2, p.32. 93 Also see Arakaki Report, supra note 2, p.56. 48