Due to amendments to Japan’s Hague Convention Implementation Act effective April 1, 2020, it has become easier and faster to enforce a return order.

The left-behind parent can petition for direct enforcement immediately after a return order becomes final, without first pursuing indirect (payment-based) enforcement(Article 136, Section1-2, 1-3, the amended Hague Implementation Act)..

In a direct enforcement proceeding, court enforcement officers are authorized to physically ensure the child’s return if necessary. Previously, left-behind parents had to petition for indirect enforcement first, and could only petition for physical enforcement later.

These changes have significantly improved the effectiveness of Hague return orders.

According to statistics from the Hague Convention Division of the Ministry of Foreign Affairs, following the aforementioned amendments of the Act, between April 2020 and May 1, 2025, there were nine cases that were enforced, of which 86% were successful. 
It can be said that the enforcement rate is high.

This indicates that the new enforcement mechanisms are achieving their goal of promptly restoring children to their habitual residence.”

While holding that the petition for a habeas corpus order be granted, the Justices of the Supreme Court decided to remand the case to the lower court for further examination, particularly with a view to ensuring the appearance of the child before the court.