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            long-term  contracts. When  a fixed-term  contract  has  been  repeatedly  renewed,
            the employer’s refusal to renew the contract for another term is considered as dismissal,

            because the employee had reasonable expectation that the contract would be extended,
            so that the employer must have a just cause for refusing to renew the contract. 27

                    It is very difficult to dismiss an employee before expiry of the contract period,
            unless the employer has a compelling reason to do so. Even the choice not to renew

            a fixed-term contract at the time it expires can, in some situations, require an employer
            to have objectively reasonable grounds for the non-renewal that do not offend generally

            accepted social norms. For example, a non-renewal may be difficult for a contract with
            substantially similar terms to a permanent employment, or if the fixed-term employee
            reasonably expects their employment to continue because the employer had repeatedly

            renewed their contracts in the past. Nevertheless, compared to regular employees,
            the non-regular employees are more vulnerable in times of crises and are the first
            in line to lose their jobs.



                                            VI. Conclusion



                    The Japanese economy faces serious challenges. Economic recession, rising
            unemployment, aging population, and now pandemics are only some of the problems

            that may affect its future. The challenges Japan is facing are universal, but he manner
            in which these challenges are dealt with differs from nation to nation. The impression
            is that the general feeling in Japan is not really about fighting against COVID-19,

            but rather as adjusting to the new conditions imposed by pandemics by making attempts
            to reshape the working environment.

                    COVID-19 has forced businesses to reduce their economic activity, particularly
            in the service industry. The consequence is the labor demand is also shrinking.

            The crises caused by the pandemics has created problems for both employers and
            employees. Employers were forced to adopt more flexible arrangements to adjust to



                    27  The Supreme Court 22 July 1974 (Toshiba Yanagicho Factory) Minshu Vol. 28, No. 5, (1974) 927; see
            also, the Supreme Court 4 December 1986 (Hirata v. Hitachi Medico Co.) Rodo-hanrei No. 486 (1986) 6.



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