de gouvernement, avoids judicial review as it is too politically sensitive. While the scope of the concept has been reduced over time, there are still acts that the courts do not have jurisdiction over, such as matters that are deemed to be unseverable from France's diplomatic acts, like the President's decision to conduct tests of nuclear weapons or to sever financial aid to Iraq. Other acts include the President's decision to dissolve Parliament, award honors, or grant amnesty. Such actes de gouvernement need to be politically-based and also concern domains in which the courts are not competent to judge, e.g. national security and international relations. Japan The postwar constitution gave the Supreme Court of Japan the power of judicial review, and the court developed its own political question doctrine (; tōchikōi). The Supreme Court of Japan was in part trying to avoid deciding the merits of cases under Article 9 of the post-war pacifist constitution, which renounces war and the threat or use of force. Issues arising under Art. 9 include the legitimacy of Japan's Self-Defense Force, the U.S.-Japan Security Treaty, and the stationing of U.S. Forces in Japan. The Sunagawa case is considered the leading precedent on the political question doctrine in Japan. In 1957, in what was later known as the "Sunagawa incident," demonstrators entered a then U.S. military base in the Tokyo suburb of Sunagawa. By their entry into the base, demonstrators violated a special Japanese criminal law based on the U.S.-Japan Security Treaty. A Tokyo District Court found that the U.S. military's presence in Japan were unconstitutional under Art. 9 of the Constitution and acquitted the defendants. The Supreme Court overturned the district court in a fast-track appeal, implicitly developing the political question doctrine in the ruling. The Court found it inappropriate for the judiciary to judge the constitutionality of highly political matters like the U.S.-Japan Security Treaty, unless they expressly violate the Constitution. On the Security Treaty, the Court saw "an extremely high degree of political consideration" and "there is a certain element of incompatibility in the process of judicial determination of its constitutionality by a court of law which has as its mission the exercise of the purely judicial function." It therefore found that the question should be resolved by the Cabinet, the Diet, and ultimately by the people through elections. The presence of U.S. forces, moreover, did not violate Article 9 of the