pacifist Constitution, because it did not involve forces under Japanese command. Thereafter, the political question doctrine became a barrier for challenges under Art. 9. Under the "clear mistake" rule developed by the Court, it defers to the political branches on Art. 9 issues so long as the act is "not obviously unconstitutional and void." Other notable cases on the political question doctrine in Japan include the Tomabechi case, which concerned whether the dissolution of the Diet was valid. In the Tomabechi case, the Court also decided against judicial review by implicitly invoking the political question doctrine, citing the separation of powers as justification. In addition, the Court announced that in political question cases not related to Art. 9, the clear mistake rule does not apply and judicial review is categorically prohibited. Switzerland In 2007, the Republic of China filed a lawsuit before a Swiss civil court against the International Organization for Standardization, arguing that the ISO's use of the United Nations name "Taiwan, Province of China" rather than "Republic of China (Taiwan)" violated Taiwan's name rights. On 9 September 2010, a panel of the Federal Supreme Court of Switzerland decided, by three votes to two, to dismiss the suit as presenting a political question not subject to Swiss civil jurisdiction. Taiwan The Judicial Yuan on 26 November 1993 interpreted that the delimitation of national territory would be a significant political question beyond the reach of judicial review. International Court of Justice, and the European Court of Human Rights In international courts, the International Court of Justice has dealt with the doctrine in its advisory function, and the European Court of Human Rights has engaged with the doctrine through the margin of appreciation. Court of Justice of the European Union Within European Union law, the Court of Justice of the European Union has never explicitly addressed the political question doctrine in its jurisprudence, yet it has been argued that there are traces of the doctrine present in its rulings. References Further reading Piazolo, Michael: Verfassungsgerichtsbarkeit und politische Fragen, die Political Question Doktrin im Verfahren vor dem Bundesverfassungsgericht und dem Supreme Court der USA. Munich 1994 (german text) Civil procedure Legal doctrines and principles