Supreme Court First Petty Bench Decision of November 30, 1995, 49 Minshu 9-2972, 1557 Hanji 136, 901 Hanta 121. The Court reversed a lower court ruling on the liability of a commercial landlord with respect to the contracts of its commercial tenant. The commercial tenant's store appeared to be part of the landlord's supermarket and associated with it. By application Commercial Code Article 23, which imposes joint and several liability on those who authorize others to act under their trade name for obligations undertaken by such persons, the Court found liability on the part of the landlord's supermarket, which was the managing company, as a nominal seller.

Maibashi District Court Decision of January 25, 1995, 883 Hanta 278. In a case involving a claim of fraudulent transfer of a right to payment by a debtor in bankruptcy, the Court determined that the manager the defendant purchaser had dispatched to represent it at the litigation did not have authority to act as a "judicial representative" under Civil Procedure Code Article 79(1), which requires registration of employees authorized to perform judicial acts on behalf of a legal entity. Although the dispatched manager had been properly registered to perform "all judicial and extra-judicial acts on behalf of the employer" under Commercial Code Articles 38 and 40, the Court determined that the defendant’s registration of nineteen of its employees as managers solely for the purposes of performing certain activities in conjunction with the company’s loan business, was inconsistent with the requirements of a judicial representative under Civil Procedure Code Article 79(1). The Court therefore denied the right of the manager to act as a representative of the entity for the purposes of litigation, and ruled in favor of the plaintiff.