[Article / Copyright] Supreme Court, Reiwa 3 (Ju) 1112, “Music school case” (Yoshinobu Hisamura, Patent, February 2024)
Updated: Oct 15
Article information
Article type: Publication review
Display and classification checked: 2026-09-30
Categories: Copyright
Topics: Attribution of copyright use
Published on this website: 2026-09-29
[Article / Copyright] Supreme Court, Reiwa 3 (Ju) 1112, “Music school case” (Yoshinobu Hisamura, Patent, February 2024)
The Supreme Court did not regard students’ performances as being under the music school’s control, for these reasons:
(1) Purpose: Students seek to “acquire and improve performance skills”; playing assigned pieces is merely a “means” to that end.
(2) Autonomy: Students play of their own volition; teachers’ instruction merely “assists” them (it is not compulsion).
(3) Consideration: Tuition is “consideration for teaching skills,” not “consideration for performing the music itself.”
Moving away from the “karaoke doctrine”
The Club Cat’s Eye Supreme Court decision (karaoke doctrine) had treated even karaoke sung by snack-bar customers as use attributable to the proprietor.
JASRAC sought to apply this reasoning to music schools, but the Supreme Court rejected the analogy as “involving different facts and being inappropriate” (translation of quotation).
A prominent view is that this judgment ended the karaoke doctrine and declared a break with the doctrine that had functioned for many years.
Originally posted on LinkedIn: https://www.linkedin.com/feed/update/urn:li:activity:7510495120484425728/
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This log starts on 30 September 2026. Display and classification checks are distinct from a review of the legal analysis.
2026-09-30 — Presentation update: added the article type, this change log and a link to consultation options. The existing article text was preserved.
2026-10-01 | Name notation: replaced verified Japanese-script personal names with Roman-letter forms in this English article and its navigation. Legal analysis and original publication date unchanged.
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