on the part of the tortfeasor, infringement of some legally recognised right, and a causal link between the tortfeasor's action and the infringement in question. As this leaves room for a broad and potentially unrestricted scope of tort liability, Japanese tort law gradually developed based on case law, including cases on pollution. Statutes outside the Civil Code also regulate specific types of torts, such as the Law on the Compensation of Losses arising from Car Accidents enacted in 1955, the 1973 Law on the Remedies of Harm Caused to Human Health by Pollution, and the 1994 Law on Product Liability. The standard of proof in Japanese tort litigation is that of "proof of a high degree of probability", a higher standard than the balance of probabilities utilised for tort liability in common law jurisdictions but lower than the reasonable doubt standard used in most legal systems for criminal trials, which the Japanese Supreme Court described in the leading case Miura v. Japan (a case on liability for medical malpractice): Contemporary Japanese product liability law forms a distinct area of tort liability in which litigation may proceed under Article 709 of the Civil Code or the Product Liability Act of 1994. Under the Product Liability Act, which defines "products" as including any "movable item that is manufactured or processed"; manufacturers bear strict liability where a plaintiff proves the existence of: A defect in the product, Damage to life, body, or property, and A causal link between the defect and damage in question. Under Japanese tort law, plaintiffs may seek compensation for both economic and non-economic damages, and there is no statutory cap on damages; however, punitive damages are forbidden on public policy grounds. Japanese courts regard the compensation of plaintiffs as the paramount purpose of damages under tort law, regarding punishment and deterrence as the exclusive domain of criminal law.Daisuke Mori & Shuichi Takahashi & Yasuhiro Ikeda, 2017. "Compensation, punishment, and deterrence: a survey on the purpose of tort damages in the case of a defective car accident in Japan," Asia-Pacific Journal of Regional Science, Springer, vol. 1(2), pages 589–624, October. DOI: 10.1007/s41685-017-0059-8 Punitive damages awarded against tortfeasors by arbitral tribunals or foreign courts are unenforceable in Japan. Additionally, Japanese civil procedure does not allow for class actions and does not recognise mass tort liability. As a result of the structure of Japan's tort system, the country experiences a significantly lower