Other cases which lead to the loss of Japanese nationality are when a Japanese national obtains foreign nationality by being born abroad, but fails to reserve his right to Japanese nationality in the designated period of time (presently three months) (Article 12); and when the Japanese national with foreign nationality renounces Japanese nationality by notifying the Minister of Justice (Article 13). Both provisions are intended to avoid dual nationality, but also prevent statelessness. The Nationality Act does not allow Japanese nationals to become stateless by renouncing Japanese nationality.92 On the other hand, actual application has invited cases that do not always prevent statelessness, as the following incidences illustrate. Some have been attempted to be rectified through lawsuits. Children Born out of Wedlock Article 2(1) of the Nationality Act reflects the principle of bilineal jus sanguinis for the child’s nationality at birth: “A child shall be a Japanese national when the father or the mother is a Japanese national at the time of its birth.” This “father or mother” refers to the legal, not the biological parent. The child obtains Japanese nationality if the mother or the legal father has Japanese nationality regardless of the place of birth. However, the accepted view is that if the child is born out of wedlock between a Japanese father and a mother of foreign nationality, the father must acknowledge paternity during pregnancy for the child to obtain Japanese nationality at the time of birth. Since the 1980s, babies born out of wedlock to non-Japanese mothers of irregular immigration status and Japanese nationals increased. In this case, the jus soli laws or priority to the father’s bloodline in the mother’s country often engendered statelessness 92 Ibid., pp.382. A Tokyo District Court Ruling (March 30, 1981) has stated that “Prevention of statelessness is more important than the prevention of dual nationality. When the two are in conflict and one must be chosen, prevention of statelessness must be given priority”. In fact, it is reported that there is a case in which the Japanese nationality of a three-year old girl was renounced when her name was expunged from the family registry of a Japanese man with whom her mother (non-Japanese) was once legally married. The erasure from the family registry was required by the Immigration authorities to legalize the residence status of her real father of Filipino nationality. Without having an opportunity to have her relationship with the Filipino father confirmed by a family court of the Philippines, however, she has been left effectively stateless. See Fusae Ohshita, “Kokuseki to Koseki to Zairyu Shikaku (Nationality, Family Registry and Residence Status)”, JInken to Seikatsu (The Human Rights and Life), Vol.28 (2009), pp.35-36. 36