unable to have Japanese law applied in their legal actions affecting their civil status, as Article 12 of the 1951 Refugee Convention, which provides that “The personal status of a refugee shall be governed by the law of the country of his domicile (or residence)”, is not considered to apply to them.161 Thus, persons falling within Category D are similar to those falling within Category C [Consulate denial I (Refugees)] in the sense that they are possibly not recognized as nationals by the purported countries of nationality, but they differ in the sense that the former cannot benefit from the application of Article 12 of the 1951 Refugee Convention designating the law of the country of residence for refugees’ personal status. Thus, persons falling within Category D often face difficulties in procedures related to their legal actions changing their personal status such as marriage or recognition of their children as they are requested to submit certificates issued by their countries of purported nationality. This category of persons may have an easier time with the municipal offices in the areas where settled refugees are concentrated, which may accept documents such as written statements that the persons concerned are settled refugees. However, when it comes to municipal offices without experiences of dealing with this category of persons, they may be simply denied processing of their applications for lack of the required documents. Furthermore, as under the current implementation of the relevant legal provision, persons in this category are not considered able to benefit from facilitated naturalization. In order to acquire Japanese nationality, they must fulfill the normal naturalization requirements; i.e., they cannot naturalize unless they turn 20 and qualify themselves as financially stable, and so on. (2) Possible size of category D This category includes (i) so-called “settled refugees” (i.e., Indochinese refugees), (ii) persons granted special permission for residency on humanitarian grounds,162 and (iii) persons who arrived in Japan via third country resettlement. “Settled refugees” under (i) above cumulatively amount to 11,319 persons, as stated in sub-section (1) above. 163 Persons who have been granted special permission for 161 However, there are some cases including divorce cases, where the law of Japan, the place of habitual residence, was recognized as the applicable law, providing that the family court should give considerations similar to Convention refugees when deciding on the applicable law. 162 “Persons granted special permission for residency on humanitarian grounds” are persons whose application for refugee status was rejected (including on appeal) but who were granted the status of mid- to long-term resident on humanitarian grounds; they include individuals with Special Permission to Stay, and change of residential status to “Long-term Resident”, “Designated Activities”, etc. 163 The total number of Indochinese refugees accepted into Japan from 1978 to the end of 2005 was 11,319 (Ministry of Foreign Affairs, 19 October 2016, “Kokunainiokeru Nanmin Ukeire [Refugee Acceptance in Japan]”, at http://www.mofa.go.jp/mofaj/gaiko/nanmin/main3.html. 75