to 23 days without trial. This can at times take weeks, during which the suspect is in detention, and are prevented from contacting a lawyer or family. Academics have also studied that Japanese judges can be penalized by a personnel office if they rule in ways the judicial office dislikes, and face biased incentives to convict. Using data on the careers and opinions of 321 Japanese judges, it was found that judges who engage in acquittals have worse careers. Article 38 of Japan's Constitution categorically requires that "no person shall be convicted or punished in cases where the only proof against a suspect is his/her own confession". In practice, this constitutional requirement takes a form of safeguarding known as the "revelation of secret" (Himitsu no Bakuro, lit. "outing of secret"). Because suspects are put through continuous interrogation that could last up to 23 days, as well as isolation from the outside world – including access to lawyers, the Japanese judiciary, and the public – it can be suggested that the court is well aware that confession of guilt can easily be forced. Consequently, the court (and the public) take the view that mere confession of guilt alone is never a sufficient ground for conviction. Many foreign people in Japan who are arrested cannot afford bail. Instead, for confession to be valid evidence for a conviction, the Japanese court requires confession to include the revelation of verifiable factual matter that only the perpetrator of the crime could have known about, such as the location of an undiscovered body or the time and place the murder weapon was purchased, a fact about the crime scene, etc. Furthermore, to safeguard against the possibility that the interrogator has implanted such knowledge into the confession, the prosecutor must prove that such revelation of a secret was unknown to the police until the point of confession. For example, in the 1948 Sachiura murder case, the conviction was initially secured by the confession of the location of the body, which was yet to be discovered. It later transpired that the police had likely known the location of the body, and this created a possibility that the confession of this information could have been forged and implanted by the investigating police. This resulted in the higher court declaring the confession unsafe and reversing the verdict. Activists claim that the Japanese justice system consider that prolonged interrogation of a