A Reexamination of the 1877 Instruction of the Council of StateA Reexamination of the 1877 Instruction of the Council of StateThe Takeshima Documents Study Group

Abstract
In October 2018, the Takeshima Documents Study Group was founded by volunteers
as a part of a research project of the Japan Institute of International Affairs to scrutinize
the Instruction of the Japanese Council of State on March 29, 1877 ( 明 治 10 年 太 政 官 指
令 , hereinafter referred to as “the 1877 Instruction of the Council of State”), in which theCouncil stated that, with respect to the Shimane Prefectureʼs / Ministry of Home Affairsʼ
inquiry on “Takeshima and the other island ( 竹島外一島 )” in the Sea of Japan, “there is no
relation to Japan.” As a result of surveys and discussions over three years, the Study Grouppublished a report and concluded that present-day Takeshima was not included among theisland(s) declared “there is no relation to Japan” in the Instruction. After its publication,
historical materials corroborating the findings of the Study Group were found. In light of
the impact that one of the major grounds of the South Korean claim over the Takeshima
is clearly refuted, the JIIA has decided to update the introductory chapter of the report,
thereby introducing the newly found materials which were made in the same period as the1877 Instruction of the Council of State. This paper is an English translation of the updated
introductory chapter.

I

Backgroundn October 2018, the Takeshima Documents Study Group was founded by volunteers as
a part of a research project of the Japan Institute of International Affairs to scrutinize
the March 29, 1877 Instruction of the Japanese Council of State (明治10年太政官指令,
hereinafter referred to as “the 1877 Instruction of the Council of State”), in which theCouncil stated that, with respect to the Shimane Prefectureʼs / Ministry of Home Affairsʼ inquiry
on “Takeshima and the other island ( 竹 島 外 一 島 )” in the Sea of Japan, “there is no relation
to Japan.” After conducting sur veys and discussions over a period of three years, the Study
Group published a report on March 31, 2022 and concluded that present-day Takeshima was notincluded among the islands determined to have “no relation to Japan” in the 1877 Instruction.
This paper is an English translation of the introductory chapter.
Historical materials corroborating the findings of the Study Group were confirmed after
its publication. This paper is updated to include these newly-confirmed materials, which wereprepared in the same period as the 1877 Instruction of the Council of State.
The views and opinions expressed in this paper are those of the authors and the Takeshima
Documents Study Group and do not necessarily reflect the views or positions of the Japan
Institute of International Affairs.

1. Introduction―Why it is necessar y to reexamine the 1877 Instruction of theCouncil of State
Takeshima, also known as the Liancourt Rocks in English and Dokdo in Korean, is an uninhabitedisland located in the Sea of Japan approximately 211 km nor th of the Japanese mainland
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The Takeshima Documents Study Groupand 217km east of the Korean Peninsula at 37°14' north latitude and 131°52' east longitude.
Takeshima is comprised of two main islands, Higashijima (Mejima) Island and Nishijima (Ojima)Island, and numerous small islands. The total land area of Takeshima is approximately 0.2 square
kilometers. The two main islands are precipitous volcanic islands, and cliffs abut the coastline on
all sides. They have scarce vegetation and drinking water resources. Approximately 88km westnorthwest of Takeshima lies the Korean island of Ulleungdo, and approximately 158km southsoutheast of Takeshima are found the Japanese Oki Islands (see the map below).

Source: O f fice of Policy Planning and Coordination on Territor y and Sovereignty,
Cabinet Secretariat, website
The territorial dispute over Takeshima is one of the biggest concerns in Japan–South Korea
relations. After WWII, South Korea requested the Allied nations (including the United States)
to explicitly stipulate that Japan renounces Takeshima as a part of “Korea” in the peace treaty
with Japan. The United States denied the South Korean request in a letter from Dean Rusk, theUnited States Assistant Secretary of State for Far Eastern Affairs, that stated “...[a]s regards theisland of Dokdo, otherwise known as Takeshima or Liancourt Rocks, this normally uninhabitedrock formation was according to our information never treated as part of Korea and, since about
1905, has been under the jurisdiction of the Oki Islands Branch Office of Shimane Prefectureof Japan. The island does not appear ever before to have been claimed by Korea.” In the San
Francisco Peace Treaty, Takeshima was affirmed as a territory of Japan. In January 1952, South
Korea issued the Presidential Proclamation of Sovereignty over Adjacent Seas and establishedthe “Syngman Rhee Line” in the Sea of Japan, encompassing Takeshima within the Line. Then, in
1954, the South Korean government deployed a Coast Guard unit on Takeshima, and thus ensued
the illegal occupation of Takeshima by South Korea.

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A Reexamination of the 1877 Instruction of the Council of State

Chronological Histor y of Ulleungdo and Takeshima
Year

Events1417

The Joseon Dynasty adopted the “Empty Island” policy on Ulleungdo and the Japanesestarted fishing activities on and around the island.

17th century

Merchants in Yonago conducted abalone fishing and sea lion hunting on Ulleungdo(known as “Takeshima” at the time) with permission from the Edo Shogunate. Later,
the merchants star ted a similar business on present-day Takeshima (known as“Matsushima” at the time), located on the route from Oki to Ulleungdo. Later, passage
to Takeshima was also permitted by the Edo Shogunate.

1696

The Edo Shogunate prohibited the passage of merchants in Yonago to Ulleungdo,
also known as “Takeshima” at the time. However, passage to present-day Takeshima(known as “Matsushima” at the time) was not prohibited.

As a result of some inaccuracies in latitudinal and longitudinal charting by a European
Late 18th century ship, a non-existent island known as Argonaut started being depicted between the
Korean Peninsula and Ulleungdo, also known as Dagelet, in European maps.
A German doctor named Philipp Franz von Siebold, who had stayed in Japan,
published a “Map of Japan” (1840) in Europe. Siebold designated Argonaut asMid-19th century “Takasima” and Ulleungdo (Dagelet) as “Matsusima” on his map. As a result,
Ulleungdo started being called “Matsushima” in European maps, and such maps were
imported to Japan.
1877

The Japanese Council of State stated in the 1877 Instruction of the Council of State
that, with respect to the inquiry on “Takeshima and the other island” (the other island
being “Matsushima”), “there is no relation to Japan” (the main topic of this paper).

1905

The Japanese government incorporated Takeshima into Shimane Prefecture at therequest of Nakai Yōzaburō, who had conducted sea lion hunting on present-day
Takeshima. The name “Takeshima” was given to present-day Takeshima because
Ulleungdo was called “Matsushima” at the time (hereinafter “Takeshima” refers topresent-day Takeshima when touching upon history after 1905).

1951

The San Francisco Peace Treaty was signed. It was decided that Japan would retain
Takeshima.

1952

South Korea issued a declaration concerning maritime sovereignty and establishedthe “Syngman Rhee Line” in the Sea of Japan, asserting fishery jurisdiction within theLine. The Line encompassed Takeshima so a territorial dispute over Takeshima arose.
In 1954, the South Korean government started its illegal occupation of Takeshima.

2. South Korea has invoked the 1877 Instruction of the Council of State tojustify its territorial claim over Takeshima
After the outbreak of the dispute over Takeshima, Japan and South Korea exchanged views via
attachments to their notes verbales, but this ended in South Koreaʼs complete defeat as it wasnever able to produce any valid grounds for its possession during the exchange of views, andwas unable to refute “The Japanese Governmentʼs views on the Korean Governmentʼs views ofJanuary 7, 1959, concerning Takeshima” (July 13, 1962, the so-called Fourth Japanese View).
With regard to the display of state authority1 over present-day Takeshima, Japan has a clear upper
1

International trials on territorial disputes have sought rational solutions based on indications of“peaceful and continuous display of State authority.” This means a state wins the case if it has exercisedsovereignty and that exercise has not been contested by other countries. If both parties have conducted
such activities, it comes down to which party presents the stronger evidence or grounds.

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The Takeshima Documents Study Group

hand: ① the Japanese government was involved in the economic activities of Japanese nationals
on the island in the 17th century and ② Japan implemented a variety of administrative measures
after its incorporation into Shimane Prefecture in 1905. The South Korean government could
not have been able to show any proof that it has exercised sovereignty over the island but South
Korea has, nonetheless, refused to even admit the existence of a dispute over Takeshima andrejected Japanʼs proposals to refer the case to the International Court of Justice in 1954, 1962, and2012.
This inability to legitimize the South Korean claim based on Korean sources was what
motivated them to turn to the use of Japanese sources. The 1877 Instruction of the Council ofState was a suitable target for the Korean side in adopting this approach.
The 1877 Instruction of the Council of State was an instruction issued by the Council ofState2 to the Ministry of Home Affairs in 1877. In March 1877, the Council of State instructed
the Ministry of Home Affairs to “understand that, with respect to the inquiry on Takeshima andthe other island, there is no relation to Japan” in response to an inquiry from said Ministry titled“Inquiry on the Incorporation of Takeshima and the Other Island in the Sea of Japan into theLand Register.” The instruction was conveyed to Shimane Prefecture, which originally issued theinquiry, via the Ministry of Home Affairs. At the time, the Ministry of Home Affairs was taking
initiative to compile a land registry. Shimane Prefectureʼs original inquiry was sent to the Ministryof Home Affairs after two land register incorporation supervisors of the Ministry had sent a letter(Otsu No.28) to the prefecture to propose to do so (see the figure below).

Examination Process of Inquir y on “Takeshima and the Other Island”
October 5, 1876

October 16, 1876

2

Two land register incorporation super visors of the Ministr y of Home
Affairs sent a letter (Otsu No.28) to Shimane Prefecture to propose that theprefecture conduct an investigation on Takeshima (Ulleungdo) and send
the Ministry an inquiry over whether the prefecture should incorporate theisland into its land register.
Sakai Jirō, Vice-Governor of Shimane Prefecture, sent an inquir y on
“Takeshima and the other island” to Ōkubo Toshimichi, Minister for Home
Affairs (“Inquiry on the Incorporation of Takeshima and the Other Island in

Dajoˉkan or the Council of State was a Japanese state organ in the late 19th centur y under whose
command ministries operated. It was set up in 1868 and re-formed as the Cabinet in 1885.

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A Reexamination of the 1877 Instruction of the Council of State

March 17, 1877

March 20, 1877
March 29, 1877
April 9, 1877

the Sea of Japan into the Land Register”).
Maejima Hisoka, Vice-Minister for Home Affairs, sent an inquiry (Shimachi
No. 664) to the Council of State to get its approval for the Ministr y ʼ s
judgment that “there is no relation to Japan.”A Council of State of ficial drafted an approval document for the 1877
Instruction of the Council of State (Draft No. 20).
The 1877 Instruction of the Council of State was sent from Iwakura Tomomi,
Minister of the Right, to Maejima Hisoka, Vice-Minister for Home Affairs.
Maejima Hisoka, Vice-Minister for Home Affairs, instructed Sakai Jirō, ViceGovernor of Shimane Prefecture, to “understand that, with respect to theinquiry on Takeshima and the other island, there is no relation to Japan.”

The first time the 1877 Instruction was referenced in Japanese or Korean academia was ina paper by Hori Kazuo (later a professor at Kyoto University). 3 Based on an interpretation of
the 1877 Instruction that “Takeshima” refers to present-day Ulleungdo and “the other island”
to present-day Takeshima, he argued that “the Dajōkan (the Council of State), the highest
government organ in Japan at that time, formally declared, on the basis of the reports of both
Shimane Prefecture and the Ministry of Home Affairs and treating Takeshima/Ulleungdo andMatsushima/Tokdo as an integral whole, that these two islands were not Japanʼs territory.”In the Edo era (1603–1867), present-day Takeshima was called “Matsushima” in Japan,
whereas Ulleungdo was called “Takeshima” or “Isotakeshima.” In the 19th century, inaccuracies
in the latitudinal and longitudinal charting of Ulleungdo resulted in the island being depicted asconsisting of two separate islands on maps subsequently produced in Europe: Dagelet Island,
whose location was thought to be the same as present-day Ulleungdo, and non-existent Argonaut
Island, which was thought closer to the coast of the Korean Peninsula. A doctor named Philipp
Franz von Siebold created a “Map of Japan” (1840) based on the knowledge he had acquired
during his stay in Japan. Siebold believed that Argonaut and Dagelet Islands were “Takeshima”
and “Matsushima,” respectively, and drew up a map based on this understanding. Western maps
thereafter followed suit. In the latter half of the 19th century, Japan imported Western maps andstarted calling Ulleungdo “Matsushima.” Experts in Japan and Korea share the view that “theother island” was an island called “Matsushima.” Thus, the controversy comes down to which“Matsushima” the 1877 Instruction of the Council of State refers: the “Matsushima” of the Edo era(present-day Takeshima) or that of the late 19th century (Ulleungdo)? The arguments of both the
Korean government and Professor Hori are premised on the hypothesis that the Council of State
maintained its Edo-era recognition of “Matsushima.”3

堀和生「一九〇五年日本の竹島領土編入」『朝鮮史研究会論文集』24 (1987.3) pp. 97–125. Hori Kazuo,“Japanʼs Incorporation of Takeshima into Its Territory in 1905,” Korea Observer, Vol.28 No.3 (September1997), p.477–525. The latter is an English translation of the former. The citation is taken from the latter.

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Takeshima

ROK

Oki Islands

The Takeshima Documents Study Group
ShimanePref.

Chart 1: Early Names

Takeshima /Isotakeshima
UtsuryoIslandROK

ImaginaryIslandMatsushima

Matsusima (Siebold)
Utsuryo Island

Takasima (Siebold)Takeshima
ROK*The island now known as
Takeshima came to be called“Lyanko Islands,” so named
after the French ship,
Liancourt, that discovered
the island.

Oki Islands

Chart 1: Early Names

ShimanePref.

Takeshima
Lyanko Islands(common name)Oki Islands

Chart 2: Names in the late 19th century

ShimanePref.

Source:O f fice of Policy Planning and Coordination on Ter ritor y andImaginary(Siebold)
MatsusimaIslandSovereignty,
CabinetSecretariat, website
Utsuryo Island
Takasima (Siebold)Takeshima

The 1877 Instruction of the Council of State had a remarkable impact on Korean academia as
Lyanko Islands
ROK(commona plain indication of the “falsehood
the Japanese governmentʼs view that Japanese possession” of name)*The island now known as
Takeshima cameTakeshima
to be calledover present-day
wasestablishedin the 17th centur y (Edo period). The ROK
Oki Islands“Lyanko Islands,” so named
government
adoptedthe 1877 Instruction as a part of its official views, in particular in “Dokdo,
after theFrench ship,
Liancourt, that discovered
BeautifultheIslandof
Korea,” a pamphlet issued by the South Korean Ministry of Foreign Affairs.
island.
It is also
used as an indispensable partof South Korean “Dokdo education.” For instance, theShimaneChart 2: Names in the late 19th century
Pref.Years 5–6: Social Studies (6–2)” , the governmentMinistr y of Educationʼs “Primar y School
designated elementar y school textbook first published on August 15, 2019, introduces the1877 Instruction to “inform of the truth those who believe the false claim that Dokdo has been
Japanese territory since ancient times.” The 1877 Instruction plays an important role in Korean
public diplomacy on Takeshima as well.
As the 1877 Instruction exclusively concerns the Japanese sideʼs perception, it is necessary
for South Koreans to present separate evidence to the effect that present-day Takeshima has been
Korean territory since the premodern period. Nonetheless, the 1877 Instruction has come tohave the power to make not only Koreans but also some Japanese experts believe Korean claimthat Takeshima is Korean territory. This likely has a lot to do with the visual impact of a map
titled Simplified Map of Isotakeshima ( 磯竹島略図 ) (see the map below). This is stored among
the Koˉbunroku ( 公文録 ) (Compilation of Official Documents [exchanged between the Council ofState and ministries]) at the National Archives of Japan as one of the documents attached to theinquiry that Shimane Prefecture submitted to the Ministry of Home Affairs. Some researchers inJapan and South Korea argue that it is obvious that “the other island” mentioned in “Takeshima
and the other island” by the Ministry of Home Affairs and the Council of State refers to presentday Takeshima since this map depicts “Isotakeshima” (Ulleungdo) and “Matsushima” (present-day
Takeshima), leaving no room for further argument. They maintain that the Japanese government
adhered to the Edo-era recognition of “Matsushima.”

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A Reexamination of the 1877 Instruction of the Council of State

Simplified Map of Isotakeshima
Source: National Archives of Japan Digital Archive

3. Examination and Conclusions of the Takeshima Document Study Group

Did “the other island” of “Takeshima and the other island” in the 1877 Instruction of the Councilof State refer to present-day Takeshima? Over the past three years, the Study Group has
scrutinized the texts of all the documents stored together with the 1877 Instruction in Koˉbunroku,
sur veyed other relevant documents and maps at the time, and examined historical facts thatshould be considered. After the Study Group issued a report in March 2022, new documents wereconfirmed. Consequently, the Study Group has concluded that the 1877 Instruction has nothing
to do with present-day Takeshima. To put it differently, the Japanese government at the time did
not maintain the Edo-era recognition that “Matsushima” referred to present-day Takeshima when
it issued the 1877 Instruction, as opposed to the arguments put forth by Professor Hori and South
Korea. The grounds for the Study Groupʼs judgment are summarized as follows.
① The main text of the inquir y from the Ministr y of Home Affairs to the Council of State
started with “with respect to the inquiry on the jurisdiction over Takeshima...,” examined only
Takeshima, and did not refer to “the other island” or “Matsushima” at all (“the other island”
appeared only in the title of the inquiry).
② The Simplified Map of Isotakeshima and other documents submitted by Shimane Prefecture
to the Ministry of Home Affairs were attached to the inquiry from the Ministry to the Councilof State simply to explain Shimane Prefectureʼs inquiry. They were not used in the inquiry as abasis for the Ministryʼs judgment that “there is no relation to Japan.” In addition, documents on
the exchanges between the Japanese and Korean governments in the 17th century on Ulleungdo(there is not even a single reference to “Matsushima” in the documents) were attached to theinquiry from the Ministry as grounds to conclude that “there is no relation to Japan” and theCouncil of State approved the Ministryʼs judgment.
③ “Matsushima” in the official maps made by the Japanese government at the time referred toDagelet Island, i.e., Ulleungdo.
④ After the issuance of a repor t by the Study Group, one of its members confirmed an
official document that clearly shows that the Ministry of Home Affairs at the time considered“Matsushima” to be Ulleungdo: a reply letter sent from Ōkubo Toshimichi, Minister for Home
Affairs, to the governor of Nagasaki Prefecture, who had proposed to develop “Matsushima”
as the island was rich in forestry and fishery resources. It has become clearer than ever that
the South Korean argument does not hold water. Ōkubo dismissed the governorʼs proposal,
explicitly stating that the Ministry had “found that there is no relation to Japan” with respect
to “Matsushima” as a result of careful examination of the documents related to the exchanges
between the Japanese and Korean governments in the 17th century when Shimane Prefecture
sent an inquiry on “the island.” As mentioned above, it was “Takeshima” that the main text of the54
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The Takeshima Documents Study Groupinquiry from the Ministry of Home Affairs referred to in the case of Shimane Prefectureʼs inquiry.
Consequently, it has become crystal clear that the Ministry and the Council of State consideredboth “Takeshima” and “the other island (Matsushima)” to be Ulleungdo when the Council issued
the 1877 Instruction.
⑤ Moreover, the members of the Study Group confirmed several other documents that show
Japanese government officials around 1876 and 1877 recognized Ulleungdo as “Matsushima.”
Each point is explained in detail below.

4. Analysis of original documents (Chapter 2)

Chapter 2 (“The ʻInstruction of the Council of Stateʼ and the Genroku Japan–Korea Negotiations”
by Tsukamoto Takashi, former professor at Tokai University) analyzes documents concerning
the “Inquiry on the Incorporation of Takeshima and the Other Island in the Sea of Japan into theLand Register” in Koˉbunroku, focusing mainly on its texts. The author points out that the approval
document of the 1877 Instruction of the Council of State stated that the Council should endorse
the proposal by the Ministry of Home Affairs in its inquiry. Therefore, the author asserts that the
texts of the Ministryʼs inquiry need to be scrutinized to consider whether the 1877 Instruction of
the Council of State decided “there is no relation to Japan” vis-à-vis present-day Takeshima.
Analyzing the structure of the inquiry by the Ministry of Home Affairs, he revisits documentson the Japan–Korea negotiations over Takeshima at the time (Ulleungdo) in the Genroku period(excerpts from the Takeshima Kiji ( 竹島紀事 ), a record from Tsushima Domain), highlighted by
the Ministry as Reference Materials No. 1 to No. 4 and used as a basis for its judgment. He thenpoints out that there is no mention of present-day Takeshima in the reference materials selectedby the Ministry. In the Genroku Japan–Korea negotiations, present-day Takeshima was not partof the negotiations. The negotiations came about when Japanese merchants ran into Korean
fishermen on Takeshima at the time (Ulleungdo). As the Japanese side was concerned withpossible interactions between Japanese and Koreans on the island, the Edo Shogunate requested
that the Joseon Dynasty prohibit Korean fishermen from traveling to Ulleungdo. The sameproblem did not apply to present-day Takeshima, where no Korean fishermen had shown up.
Moreover, seeing how the inquiry from the Ministry of Home Affairs to the Council of State
starts with “[a]s we have investigated the attached documents submitted by Shimane Prefectureon the subject of jurisdiction over TAKESHIMA (Ulleungdo), THIS ISLAND [...] (emphasis
added by the author),” we should note that the judgment by the Ministry that “there is no relation
to Japan” solely concerns “Takeshima.” Subsequently, the Council of State endorsed the judgmentof the Ministry of Home Affairs, which only considered “Takeshima” (Ulleungdo), so the 1877
Instruction of the Council of State did not decide “there is no relation to Japan” with respect topresent-day Takeshima.
On the other hand, the Summary of Background Information ( 原由の大略 ) and the Simplified
Map of Isotakeshima were documents attached to Shimane Prefectureʼs inquiry. The documents
submitted by the Ministry of Home Affairs to the Council of State include these documents, but
the author points out that these were attached simply as part of Shimane Prefectureʼs original
inquir y and were not referenced during the examination by the Ministr y of Home Affairs to
render a judgment. They were attached just to show why the Ministry had submitted the inquiry
and what the inquiry was about.
Shimane Prefecture submitted the Summary of Background Information and the Simplified
Map of Isotakeshima to show that, in exchange for Korean recognition that Takeshima at the time
(Ulleungdo) belonged to Japan, the Edo Shogunate prohibited passage to the island by Japanesemerchants and granted fishing and hunting rights to Korea. This understanding was the basis of
Shimane Prefectureʼs request to incorporate into the prefecture “Takeshima” (Ulleungdo) and“Matsushima,” “the other island” on route to “Takeshima.” However, the Ministry of Home Affairs
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A Reexamination of the 1877 Instruction of the Council of State

did not share the prefectureʼs understanding and thus did not approve its request. While the
Ministry continued to use the title of the inquiry, “Takeshima and the Other Island,” it examined
only “Takeshima” and concluded that “it appears that there is no relation to Japan.” This was
because the Ministr y believed that both “Takeshima” and “the other island (Matsushima)”
referred to Ulleungdo and it was sufficient to examine only that one island.

5. Perceptions of Shimane Prefecture (Chapter 3 and 4)
Chapter 3 onward examines the background and surrounding circumstances of the 1877
Instruction of the Council of State. Chapters 3 and 4 focus on the perceptions of Shimane
Prefecture. Chapter 3 essentially highlights Sakai Jirō, the top decision-maker in Shimane
Prefecture on the “Inquiry on the Incorporation of Takeshima and the Other Island in the Sea ofJapan into the Land Register,” while Chapter 4 mainly discusses the Shimane Prefecture file “1876Land Register.”
Chapter 3 (“ʻThe Instruction of the Council of Stateʼ in Light of the Histor y of the SanʼinRegion” by Sugihara Takashi, special advisor to the Shimane Prefecture Takeshima Archive),
focuses on Sakai Jirō, who served as Vice-Governor of Shimane Prefecture at the time, while
examining the 1877 Instruction of the Council of State based on sources related to the historyof the Sanʼin region to be found in Shimane Prefecture. It shows that ① a request to develop“Takeshima” (1871) submitted by Fuji Shigechika (born in Fukuoka Prefecture), who served
as Vice-Governor of Oki and Hamada Prefectures in 1869–1870, indicates his perceptionthat “Takeshima” and “Matsushima” refer to the same island. Sakai Jirō then asked Fukuoka
Prefecture about Fuji around the same time that the “Inquiry on the Incorporation of Takeshima
and the Other Island in the Sea of Japan into the Land Register” was submitted to the Ministry ofHome Affairs in 1876, and the author points out the possibility that he may have wanted to know
about Fujiʼs perception of equating “Takeshima” with “Matsushima.” Moreover, ② (a) when Sakai
Jirō (then Governor) received a request to develop “Matsushima” (actually Ulleungdo) fromŌya Kensuke and another person in 1880, he asked the Ministry of Home Affairs if the policy
regarding the island had changed since the 1877 Instruction of the Council of State to “establish
it within the countryʼs territory” and (b) Sakai Jirōʼs subordinate Shimizu Seitarōʼs Oki no Kuni
Chishi Ryaku (Simplified Geographical Records of Oki Province) only mentions “Takeshima”
when introducing the geography of Oki Province. This leads the author to argue that “Takeshima”
and “Matsushima” may have been used interchangeably (meaning that they were the sameisland). Based on this, he writes that Sakai used the phrase “Takeshima and the other island”
in the “Inquiry on the Incorporation of Takeshima and the Other Island in the Sea of Japan into
the Land Register” to make sure that the inquiry would concern an island whose existence wascertain. Although he knew that he had been asked to inquire with the Ministry of Home Affairs
about the “Takeshima” land register, the existence of Argonaut Island as “Takeshima” was unclear
and often drawn with dotted lines at the time, while “Matsushima” in the same position as Dagelet
Island was drawn with solid lines. By adding “the other island” in his inquiry, Sakai avoided thesituation where Shimane Prefecture inquired only about a non-existent island.
Chapter 4 (“Incorporation into the Shimane Prefecture Land Register and the ʻInquiry on
the Incorporation of Takeshima and the Other Island in the Sea of Japan into the Land Registerʼ”by Uchida Teruko, temporar y staff member at the Shimane Prefecture Takeshima Archive),
analyzes the “1876 Land Register,” a document file prepared in Shimane Prefecture as the
Ministr y of Home Affairs conducted the land register incorporation project, and examines
historical facts related to Shimane Prefectureʼs inquiry to the Ministry of Home Affairs dated
October 16, 1876, which served as the prelude to the 1877 Instruction of the Council of State.
In particular, the author focuses on a visit to the prefecture made by land register incorporation
supervisors (Sugiyama Eizō and Tajiri Kenshin) from the Land Register Division, Geography
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Bureau, Ministr y of Home Affairs. She then points out that Sugiyama Eizō was from Tottori
Prefecture and had served as an official of Tottori Prefecture until 1873 (Oki belonged to Tottori
Prefecture at the time). Moreover, when Tottori Prefecture was asked to check the “Compendiumof Japanese Geography, First Draft” (out of “Takeshima” and “Matsushima” it only mentions
the former in the part about Oki) drafted by the Geographical Record Division of the Central
State Council in 1873, the Prefecture advised after much deliberation that both “Takeshima” and“Matsushima” ought to be mentioned, which was accepted by the Geographical Record Division
as they added a reference to “Matsushima” in the revised “Compendium of Japanese Geography.”
The author points out that Ōtsuka Shōzō from the former Tottori Prefecture, who was involvedin this, still belonged to Shimane Prefectureʼs Tottori Branch Office (Tottori Prefecture wasincorporated into Shimane Prefecture in August 1876) when Sugiyama visited the prefecture.
Moreover, she writes that documents referenced in Shimane Prefectureʼs inquiry, including “theold documents of the Ōya and Murakawa families,” merchants in Yonago who conducted abalone
fishing and sea lion hunting on Ulleungdo in the 17th century, and old maps were produced in
the area of Tottori Prefecture and that the Tottori Branch Office must have been involved in thedrafting of the Summary of Background Information and the Simplified Map of Isotakeshima.
Moreover, Sugiyama was in Toyooka Prefecture right before arriving in Shimane Prefecture,and the Governor of Toyooka at the time was Miyoshi Kanesuke. Miyoshi had previously served
as Vice-Governor of Tottori Prefecture, being in charge also when the aforementioned revisions
to the “Compendium of Japanese Geography” were discussed. After returning to Tokyo from
Shimane Prefecture, Sugiyama and Tajiri sent a document dated October 5, 1876 and basedon verbal discussions during their visit, requesting that Shimane Prefecture investigate oldsources about “Takeshima” and make an inquir y to the Ministr y of Home Affairs (Otsu No.
28). This document was shared by Shimane Prefecture with Hyogo Prefecture (which had justbeen reorganized from Toyooka Prefecture) on the following day, October 6. Considering thesefacts, she points out that Miyoshi and others in former Toyooka Prefecture were interested in“Takeshima” and likely brought it up also when Sugiyama was in Toyooka Prefecture.
While Otsu No. 28 makes mention of only “Takeshima,” the title of Shimane Prefectureʼsinquiry to the Ministry of Home Affairs mentions “Takeshima and the other island.” The authordraws attention to the fact that “the other island” only appears in the title, and the main text only
talks about “Takeshima.” The appendices thought to be based on documents held by the former
Tottori Prefecture and drafted by prefectural officials―Summary of Background Information and
Simplified Map of Isotakeshima―clearly mention both “Takeshima” and “Matsushima.” In thisregard, she points out that the authors of the main text and the appendices were likely not thesame, as well as that “Takeshima and the other island” may have been inserted into the title inconsideration of the appendices. She then goes on to argue that, since there is no indication that
Shimane Prefecture asked the central government about the interpretation of the 1877 Instructionof the Council of State after its issuance and the prefecture asked the Ministr y of Home
Affairs about any changes to the “last Instruction” after receiving Ōya Kensukeʼs “Matsushima
Development Request” (“Matsushima” here meaning Ulleungdo) in 1881, it seems that people in
Shimane Prefecture also thought that both “Takeshima” and “Matsushima” referred to Ulleungdo.
Meanwhile, Watanabe Kōki, the director of the Records Department at the Ministry of Foreign
Affairs, wrote that “[a]lthough it is said that Matsushima and Takeshima refer to the same island,
namely what the Koreans call Ulleungdo, the governor of the former Tottori Prefecture argued
that they are definitely two islands.” He pointed out that this means a certain governor of theformer Tottori Prefecture thought “Takeshima” and “Matsushima” referred to different islands.
As we consider that the main text of the inquiry, the Summary of Background Information, andother appendices were drafted by different people, it is likely that not all the officials in Shimane
Prefecture (especially those from the former Tottori Prefecture) shared the understanding that
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A Reexamination of the 1877 Instruction of the Council of State“Takeshima” and “Matsushima” were the same island.
Considering Chapters 3 and 4 as a whole, it is suggested that not all Shimane Prefecture
officials involved in the drafting of its inquiry, including those from the former Tottori Prefecture,shared the same understanding on what island(s) the prefecture had inquired about in the“Inquiry on the Incorporation of Takeshima and the Other Island in the Sea of Japan into theLand Register.” We also cannot deny the possibility that Shimane Prefectureʼs inquiry itself could
be the product of a compromise of the two views that “Takeshima” and “Matsushima” were
the same island (main text of the inquiry) and that they are separate (appendices). As pointed
out in Chapter 3, maps printed in the West and by Japanese government organizations such as
the Japanese Imperial Army and Navy treated “Takeshima” as “E.D.” (existence doubtful). On
the other hand, mentions of “Takeshima” were overwhelmingly more numerous than those of“Matsushima” in old documents in Japan. One way to think about this is that “Takeshima” and“Matsushima” did refer to the same island, but the old documents clearly said that they wereseparate and, as the existence of “Matsushima” had been visually confirmed on the sea route
between Nagasaki and Vladivostok, some continued to insist that “Matsushima,” a large andresource-rich island different from Ulleungdo, must exist.

6. The nature of “1877 Instruction” as a government document (Chapter 4,
cont.)
Chapter 4 also examines the relevant regulations of the Council of State on inquiries fromvarious ministries as well as regulations on the selection of documents in the Koˉbunroku and the
Dajoˉruiten ( 太政類典 , Precedents and Rules of the Council of State).
The Council of State was asked by other ministries to make decisions on various matters
ranging from important to trivial ones. For instance, listed in the Koˉbunroku right before thedocuments on the “Inquiry on the Incorporation of Takeshima and the Other Island in the Sea
of Japan into the Land Register” are those concerning the “Inquiry on the Transfer of Land from
Nagasaki Hospital to the Pharmaceutical Inspection Office ” and the “Inquir y on Relocation
Payments to Purchase Foreign National Residences in Yamate, Yokohama.”
Recognizing that they were making decisions about various matters of differing importance,
the Coordination Bureau (Secretariat) of the Council of State proposed to categorize official
documents based on their importance, saying “[w]e believe that governmental affairs range fromthe important to the trivial and this holds true in documents. We currently have so many pending
documents that we fear troubles and complications might occur unless they are categorizedaccording to importance.” [A rule on documents approved by the Council of State on February
14, 1877, titled “Official Documents Shall be Divided into the Four Categories of Laws ( 法律 ), Regulations ( 行 政 規 則 ), Bylaws ( 訓 條 ) and Replies ( 批 文 ).”] According to the rule,
instructions ( 指令 ) of the Council of State are distinguished from laws and regulations such as“ordinances ( 布告 ), directions ( 達 ) and ministerial ordinances ( 布達 ),” and are described ingeneral as “[i]n addition to instructing ministries that have asked about unregulated matters,
instructions of the Council of State ordinarily include instructions in response to legal queries andother minor matters, with dozens of documents being transacted on a daily basis, thereby shifting
the responsibilities of the ministries.” [ibid.] A red stamp that says “Hibun (Replies)” can be foundoutside the top row of the inquiry of the Ministry of Home Affairs discussed in this report. Thisis defined as “providing directions to those who ask questions about laws, regulations, and bylaws
or about unregulated matters.”
As such, the assertion of a Korean researcher that the “1877 Instruction is an extremely
legally binding document as it is an official document issued by the Council of State (the prime

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The Takeshima Documents Study Group

minister today) as the highest political decision-making organ in Japan at the time”4 is erroneous.
As suggested by the fact that the document was categorized as “Replies,” the 1877 Instruction wasa response to an inquiry from the Ministry of Home Affairs/Shimane Prefecture (an interaction
between government agencies) and neither a law nor a regulation. Of course, this does not denythat the 1877 Instruction of the Council of State is indicative of the judgment and perception of
the Council of State and the Ministry of Home Affairs, but it is necessary to discuss what theirperception was in light of their decision to respond to the inquiry with a reply ( 批文 ).

7. Perceptions of the Ministr y of Home Af fairs and the Council of State (1)(Chapter 5) : Analysis of maps published by central government agencies

Chapter 5 (“ʻTakeshima and the Other Islandʼ from the Perspective of the Parties Concerned―Ministry of Home Affairs and Council of State” by the Takeshima Documents Study Group)
examines the perceptions of the Ministry of Home Affairs and the Council of State by looking
into maps issued by central government agencies. It points out that the discussions about the“Inquiry on the Incorporation of Takeshima and the Other Island into the Land Register” were
held around the same time that perceptions about “Takeshima” and “Matsushima” were changing
in Japan. Against this background, it is noted that determining the scope of “Takeshima and theother island” in the 1877 Instruction of the Council of State requires considering maps publishedby central government agencies at the time.
Checking maps published by government agencies such as the Army, the Navy, and theGeographical Record Section of the Department of the Council of State in the five years between
1872 and 1877, “Matsushima” on all the maps showing “Matsushima” in the figure below refers
to Dagelet Island (Ulleungdo). Examining the maps made by the Geographical Record Section of
the Council of State, the Section perceived Argonaut Island to be “Takeshima” and Dagelet Island
to be “Matsushima” around 1873–1874. Then, as shown in the figure below, it became common for
Argonaut Island to not be drawn or to be drawn with dotted lines, and its non-existence became
widely accepted. “Matsushima” consistently refers to Ulleungdo on all the maps published by
Japanese government agencies.
Considering the above, it is clear that “the other island” in the 1877 Instruction of the Councilof State, or “Matsushima,” refers to Ulleungdo. In addition, while the Japanese government
perceived “Takeshima” to be Argonaut Island in 1873–1874, by the time that the 1877 Instruction
was issued, the non-existence of Argonaut Island had become widely accepted. In this regard, it
is likely that government agencies such as the Ministry of Home Affairs and the Council of State
considered both “Takeshima” and “the other island (Matsushima)” in the 1877 Instruction to refer
to Ulleungdo, as indicated by a passage in Kitazawa Masanariʼs report Takeshima Ko
ˉshoˉ (A Studyof Takeshima) showing that the majority of officials in the Ministry of Foreign Affairs believed“Takeshima” and “Matsushima” were the same island around 1876.

4

송휘영「17 세기 일본의독도 인식과 ‛ 고유영토론’」『일본의 독도 영유권 주장의 허상』( 동북아역사재단 , 2018) [ 宋彙榮「17 世紀 日本の独島認識と ʻ 固有領土論 ʼ」『日本の独島領有権主張の虚像』（東
北アジア歴史財団 , 2018 年）Song Hwi-Yeong, “Japanese Perception of Dokdo in the 17th century andassertion of inherent territory,” Myth of Japan’s territorial claim over Dokdo (Northeast Asian History
Foundation, 2018)] p.106.

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A Reexamination of the 1877 Instruction of the Council of State

Perceptions about “Takeshima” and “Matsushima” on Maps Made by Japanese
Government Agencies in the Early Meiji Period
Present-day
Takeshima

Argonaut Island

Dagelet Island

Take I.

Matsou I.

Not depicted on
the map

The Complete Map of Korea ( 朝鮮全図 )Takeshima

Matsushima

Outside of thearea covered by
the map

Map of East Coast of Korea ( 朝鮮東海岸図 )Argonaut Island

1875 Ver.:
Dagelet Island
1876 Ver.:
Matsushima

Olivutsa andMenelai

Map of East Asia ( 亜細亜東部輿地図 )Takeshima

Matsushima

Not depicted on
the map

The Complete Map of the Land and Sea
Not depicted onof Japan and Adjacent Areas of Korea andthe map
Sakhalin ( 大日本海陸全図聯接朝鮮全国並樺太 )Matsushima

Olivutsa andMenelai

The Complete Map of Japan ( 大日本国全図 )Not depicted on

Not depicted on Not depicted on
the map
the map

The Complete Map of Japan ( 大日本国全図 )Takeshima

Matsushima

The Complete Map of Japan ( 大日本全図 )Not depicted on

Not depicted on Not depicted on
the map
the map

The Complete Map of Japan ( 日本全図 )Takeshima
Matsushima(with dotted lines)

Carte du L’Empire du Japon(made by a cartographer of the Geographical Record
Division of the Council of State and possibly exhibitedat the International Exposition in Vienna in 1873)(made by General Staff Office, Imperial Japanese Army, (with dottedin 1875)
lines)(made by Hydrographic Bureau, Ministry of the Navy,in 1875 and revised in 1876)(made by General Staff Office, Japanese Imperial Army, (with dotted lines)
in 1875)(made by Hydrographic Bureau, Ministry of the Navy,in 1875)(made by Geographical Record Section, Historiography the map
Bureau, Council of State, in 1876 as an exhibit for theInternational Exposition in Philadelphia) (the exhibition
was canceled because the map was not completed intime)(made by the Geographical Record Section,
Historiography Bureau, Council of State, probably
around 1876 to show the locations of lighthouses)(made by General Staff Office, Japanese Imperial Army, the map
in 1877)(made by Ministry of Education, in 1877)

Not depicted on
the map

Not depicted on
the map

8. Perceptions of the Ministr y of Home Af fairs and the Council of State (2) :Exchanges between the central government and the governor of Nagasaki
Prefecture
The report of the Takeshima Documents Study Group concluded that present-day Takeshima
was beyond the scope of “Takeshima and the other island” in the 1877 Instruction of the Councilof State. After the publication of the report, two new documents were confirmed as a result ofinvestigation and research by Shimane Prefecture, and Fujii Kenji wrote an article about them.
These documents not only support the conclusion of the report but also prove that the Ministryof Home Affairs and the Council of State perceived both “Takeshima” and “Matsushima” to be
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The Takeshima Documents Study Group

Ulleungdo in the process of examining the inquiry on “Takeshima and the other Island.”One of these documents is a reply letter dated August 18, 1877 from Ōkubo Toshimichi,
Minister for Home Affairs, to Kitajima Hidetomo, Governor of Nagasaki Prefecture.5 In theletter, Ōkubo denied Kitajimaʼs request expressed in his letter dated July 13, 1877 to develop“ Matsushima ” under the jurisdiction of Nagasaki Prefecture. This “ Matsushima ” must be
Ulleungdo because Kitajima ʼs letter stated that “the island is covered by dense forest, andbig trees can be found around the island.” Present-day Takeshima is a group of small rocky
islands with poor vegetation. In his reply letter, Ōkubo stated that, with respect to “the island inquestion,” the Ministry had decided “there is no relation to Japan” as a result of an examinationof the exchanges between Japan and Korea pertaining to the Genroku Takeshima Incident in the
17th century, and the Ministryʼs judgment had received approval from the Council of State. In
other words, Ōkubo specified that, with respect to the 1877 Instruction of the Council of State,“Matsushima” had been the subject of discussion in both the inquiry from the Ministry of Home
Affairs and the reply from the Council of State. On the other hand, as mentioned above, theMinistry of Home Affairs only identified Takeshima as the subject of discussion in its inquiry
pertaining to the 1877 Instruction of the Council of State. Therefore, it has become crystal clearthat both the Ministry of Home Affairs and the Council of State considered both “Takeshima” and“Matsushima” to refer to the island that was discussed in the Genroku Takeshima Incident, i.e.,
Ulleungdo.
Another such document was the “ Petition on the Development of Matsushima” 6 dated
December 9, 1876 that Kitajima submitted to Ōkubo Toshimichi, Minister for Home Affairs,
and Terashima Munenori, Minister for Foreign Affairs. In this petition, Kitajima stated that it
would be profitable if Japan were to export lumber from “Matsushima” to Vladivostok. This
“Matsushima” must be Ulleungdo because it is the only island on which forestry could develop in
the Sea of Japan. It is important that this petition was sent to both the Ministry of Home Affairs
and the Ministry of Foreign Affairs. In December 1876, the Ministry of Home Affairs was still
conducting the investigation it had begun in response to the inquiry on “Takeshima and the otherisland” from Shimane Prefecture. It is not plausible that the Ministry of Home Affairs, which
had the latest geographical information, depended upon only the old Edo-era information in theSummary of Background Information and the Simplified Map of Isotakeshima, the appendices of
the inquiry from Shimane Prefecture. It is quite natural that the Ministry of Home Affairs drafted
its inquiry to the Council of State while taking into account the latest geographical perception that
“Matsushima” referred to Ulleungdo.
The two above-mentioned documents, one of which was prepared right after the issuanceof the 1877 Instruction of the Council of State and the other when the Ministry of Home Affairs
was examining the inquiry from Shimane Prefecture, make clear the perception of the Ministryof Home Affairs on “Matsushima.” They support the conclusion of the report by the Takeshima
Documents Study Group. Moreover, they prove that the Ministr y of Home Affairs and theCouncil of State perceived “Takeshima” and “Matsushima” to be Ulleungdo. The chart below
shows the relevant documents in chronological order. “The other island,” namely “Matsushima,”
referred to present-day Takeshima in the appendices of the inquiry from Shimane Prefecture.
5

The document is filed in “Hanabusa Yoshimoto related documents” owned by Tokyo Metropolitan
University Library ( 東京都立大学附属図書館蔵『花房義質関係文書』「書類の部」「A 朝鮮国関係 4 公務類・公信類」「2) 対朝鮮交渉のための書類一綴り明治９年６月 10 日〜明治 10 年 11 月 23 日」).

6

The document was confirmed in a file in Nagasaki Museum of History and Culture. The title of the fileis『明治九年 外務課事務簿 拾遺書類 雑之部 第二 .』For more detail, please see Fujii Kenji, “Researchon the Dajōkan Instruction has come to a new phase,” Mid-term Report of the 5th term of the Takeshima
Issue Research Group (Shimane Prefecture, 2023)[ 藤井賢二「新局面を迎えた「太政官指令」問題研究」
第５期竹島問題研究会編『第５期「竹島問題に関する調査研究」中間報告書』(2023 年 )].

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A Reexamination of the 1877 Instruction of the Council of State

The Ministry of Home Affairs considered “Takeshima” and “Matsushima” to be Ulleungdo anddrafted its inquiry based on such understanding, and the Council of State endorsed the Ministryʼs
judgment. The 1877 Instruction in which the Council of State “understand(s) that, with respect tothe inquiry on Takeshima and the other island, there is no relation to Japan” concerns Ulleungdo,
which was called “Matsushima” and “Takeshima” at the time, and it had nothing to do withpresent-day Takeshima.

1877 年７月 13 日 長崎県令から内務省に対する「松島開島之儀ニ付伺」

1876 年 12 月９日 長崎県令から内務省と外務省に対する「松島御開拓之儀ニ付上申書」

1877 年８月 18 日 大久保利通
内務卿から長崎県令への回答書

Examination Process of Inquir y on “Takeshima and the Other Island”

October 5, 1876

October 16, 1876

December 9, 1876

March 17, 1877

March 20, 1877
March 29, 1877
April 9, 1877

Two land register incorporation super visors of the Ministr y of Home
Affairs sent a letter (Otsu No.28) to Shimane Prefecture proposing that theprefecture conduct an investigation on Takeshima (Ulleungdo) and send
the Ministry an inquiry over whether the prefecture should incorporate theisland into its land register.
Sakai Jirō, Vice-Governor of Shimane Prefecture, sent an inquir y on
“Takeshima and the other island” to Ōkubo Toshimichi, Minister for Home
Affairs (“Inquiry on the Incorporation of Takeshima and the Other Island in
the Sea of Japan into the Land Register”).
Kitajima Hidetomo, Governor of Nagasaki Prefecture, submitted a petitionon the development of Matsushima to Ōkubo Toshimichi, Minister for Home
Affairs, and Terashima Munenori, Minister for Foreign Affairs.
Maejima Hisoka, Vice-Minister for Home Affairs, sent an inquiry (Shimachi
No. 664) to the Council of State to get its approval for the Ministr y ʼ s
judgment that “there is no relation to Japan.”A Council of State of ficial drafted an approval document for the 1877
Instruction of the Council of State (Draft No. 20).
The 1877 Instruction of the Council of State was sent from Iwakura Tomomi,
Minister of the Right, to Maejima Hisoka, Vice-Minister for Home Affairs.
Maejima Hisoka, Vice-Minister for Home Affairs, instructed Sakai Jirō, Vice62
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The Takeshima Documents Study Group

July 13, 1877
August 18, 1877

Governor of Shimane Prefecture, to “understand that, with respect to theinquiry on Takeshima and the other island, there is no relation to Japan.”
Kitajima Hidetomo, Governor of Nagasaki Prefecture, submitted “the inquiry
on the development of Matsushima” to the Ministry of Home Affairs.
Ōkubo Toshimichi, Minister for Home Affairs, replied to the inquir y by
Kitajima.

9. The political situation at the time (Chapter 6)

Chapter 6 (“The Political Situation at the Time of the 1877 Instruction of Council of State: Neither
the Emperor nor the Chancellor of the Realm Were Involved with the Issuance of the Instruction”
by Kanji Matsuzawa, former Program Director of NHK World Radio Japan) highlights the factthat Ōkubo Toshimichi and other key persons in the Meiji government were in western Japan
dealing with the Satsuma Rebellion when considering who was involved in the decision-making
for the 1877 Instruction of the Council of State.
He points out that the approval document of the 1877 Instruction of the Council of State
only has the approval seals of four officials (State Councilor or higher): Minister of the Right
Iwakura Tomomi, Councilor Ōkuma Shigenobu, Councilor Ōki Takatō, and Councilor Terashima
Munenori. Just as the draft of the 1877 Instruction of the Council of State was being preparedon March 20, 1877, government forces were successfully concluding a major attack that took
Tabaruzaka during the Satsuma Rebellion. He then introduces the fact that Emperor Meiji
appointed Iwakura Tomomi as regent to handle matters in Tokyo while the emperor visited
Kyoto in January 1877. Iwakura was specifically instructed that “[i]mportant matters should bereported to the traveling court for approval, while matters that cannot wait may be decided andsubsequently reported,” meaning that Iwakura Tomomi as regent was entrusted with politicalmatters, but that important matters needed to be reported to and approved by the emperor(although urgent matters could be decided and then reported to the emperor). He then draws
attention to the fact that there are no traces of discussions with or reports to the emperor about
the 1877 Instruction of the Council of State. As an example of east-west communications, hepresents the fact that Iwakura Tomomi in Tokyo presented his views about the Satsuma Rebellion
to Sanjō Sanetomi and Kido Takayoshi in Kyoto. Considering the above, it is unlikely that the 1877
Instruction of the Council of State decided such an important matter as changing the borders ofJapan. He concluded that “Takeshima” (Ulleungdo) had been determined to be Korean territory
in the Edo-period Genroku Takeshima Incident, and the 1877 Instruction of the Council of State
merely confirmed that decision from the Edo period. Regarding the Instruction, Iwakura thoughtthat there was no need to report it to or discuss it with the emperor.
Moreover, he points out that the Ministry of Foreign Affairs was not involved in the decisionmaking behind the 1877 Instruction of the Council of State, considering the following facts: 1)
in the Koˉbunroku the March-April 1877 “Inquiry about Incorporating Takeshima and the Other
Island into the Land Register” has a “regional” seal rather than a “diplomatic” seal (as categorized
in the Precedents and Rules of the Council of State), 2) there were no inquiries about “Takeshima”
from the Ministr y of Foreign Af fairs to the Council of State around that time, and 3) theTakeshima Koˉshoˉ, an 1881 compilation of documents about the discussions on “Takeshima” and“Matsushima” in the Ministry of Foreign Affairs, makes no reference to the 1877 Instruction of
the Council of State. The author concludes that, if the 1877 Instruction of the Council of State had
determined a new national border, then the Ministry of Foreign Affairs would naturally have been
consulted, so this again shows that the decision in the Genroku Takeshima Incident was simply
confirmed.
As an addendum, he points out that his conclusion that the 1877 Instruction of the Council ofState followed the decision in the Genroku Takeshima Incident strangely matches what the South63
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A Reexamination of the 1877 Instruction of the Council of State

Korean side is saying. In this regard, he tries to reconsider what was decided in the Genroku
Takeshima Incident. He reaffirms that what was discussed between Japan and Korea at the time
was “Takeshima” (Ulleungdo) only, as confirmed by the primary sources from South Korea andTsushima Domain in the Genroku period. Moreover, when it comes to an exchange between
the Edo Shogunate and Tottori Domain (Tottori Domain replied to a Shogunate inquest that
“Takeshima” and “Matsushima” did not belong to the provinces of Inaba and Hōki, over which
Tottori Domain was reigning) that the South Koreans consider evidence for their argument, hepoints out that there is no mention of “Matsushima” in any diplomatic exchanges between Japanand Korea at the time, so the reply from Tottori Domain is not meaningful as a historical source toverify what was discussed between the two countries. He also criticizes the Korean interpretationof all instances of the name “Ulleungdo” to mean “Ulleungdo and Dokdo,” since this automaticinterpretation prohibits any meaningful dialogue when it is doubtful there is any truth to the
Korean claim that Dokdo is a dependency of Ulleungdo.

10. The 1883 Order of the Council of State (Chapter 7)

Chapter 7 (“Examining the 1883 Order of the Council of State” by Yamasaki Yoshiko) points outthat the 1877 Instruction of the Council of State should not be isolated as a single moment to be
discussed but should be considered as a part of the Meiji Governmentʼs efforts to get an accurate
grasp of the islands in the Sea of Japan from a comprehensive perspective on the Japanese
governmentʼs geographical perception of “Takeshima” and “Matsushima” from the Genroku to
the Meiji period. She points out that, in the diplomatic exchanges between Japan and Korea fromthe 17th through the late 19th century, the Korean side never raised the issue of the ownershipof present-day Takeshima. She looks in particular at legislation enacted in 1883 in which theJapanese government conveyed the perception that both “Takeshima” and “Matsushima” refer to
Ulleungdo to the Japanese public and prohibited Japanese from traveling to the island (the 1883
Order of the Council of State). The Order was originally prompted by the Korean governmentʼscomplaint to the Ministry of Foreign Affairs that Japanese nationals were engaged in lumberingon Ulleungdo. She points out that the Order provides a stark contrast with the 1877 Instructionof the Council of State, which was nothing more than a confidential instruction to Shimane
Prefecture. In the case of the 1883 Order, for instance, ships were dispatched to Ulleungdo
to repatriate Japanese after the Order was issued. In addition, documents dispatched acrossJapan to promulgate the Order are still extant in various prefectures (the author sur veyed
many prefectural archives and presents some in her paper). In her analysis, she especially
focuses on the first volume of the Retrieval and Punishment of Japanese Illegally Crossing over to
Ulleungdo, Korea, a document file about a proposal made by the Ministry of Foreign Affairs to
the Council of State that resulted in the issuance of the 1883 Order. The Ministry proposed that
all Japanese leave the island and that the Japanese government inform the Korean governmentof the fact it had prohibited Japanese from going to the island based on the Korean complaint.
The file includes the 1877 Instruction of the Council of State, the original inquiry from Shimane
Prefecture, and Kitazawa Masanariʼs text on “Takeshima” (the Takeshima Hanto Shozoku Koˉ,an abridged version of the Takeshima Koˉshoˉ). The author points out that the Ministry reached
the final judgment, after considering all the relevant facts including the 1877 Instruction of theCouncil of State, that it was only Ulleungdo that fell outside Japanese territory. What is especially
important are the exchanges between the Ministry of Home Affairs and the Ministry of Foreign
Affairs when a request to develop “Matsushima” was submitted by Ōya Kensuke and anotherperson (see Chapter 3). “Shimachi No. 1114,” which is an inquiry from the Ministry of Home
Affairs concerning the request, articulated that “the other island” in the 1877 Instruction of
the Council of State was “Matsushima.” Based on such understanding, the government clearly
expressed once again its view that “Matsushima” and “Takeshima” referred to Ulleungdo in the
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The Takeshima Documents Study Group1883 Order of the Council of State. As the Order, which only concerns Ulleungdo, states that“[t]he two governments have previously agreed on this,” the author emphasizes that the Meiji
governmentʼs view was that Ulleungdo was the only subject of Japan–Korea negotiations during
the Genroku Takeshima Incident. She also points out that this fact has been ignored by past
Korean studies.
Next, she argues that, even if present-day Takeshima were somehow included in the scopeof the 1877 Instruction, the 1883 Order of the Council of State would prevail because of theprinciple “lex posterior derogat priori ”; the 1877 Instruction was no more than an instruction to
Shimane Prefecture, whereas the 1883 Order was legislation binding people in general. We ought
to prioritize the 1883 Order, which clearly did not include present-day Takeshima in its scope,
as the governmentʼs decision. She also writes that, unlike the 1877 Instruction of the Councilof State, which was drafted in the context of compiling a domestic land register, the 1883 Orderof the Council of State was issued following communications between the Japanese and Korean
governments (meaning it was a diplomatic measure) prompted by a Korean complaint about
Japanese activities on Ulleungdo.
Moreover, the author states that, due to the focus on identifying “the other island” in the 1877
Instruction of the Council of State, which was no more than an internal administrative documentof a temporal nature, the discussion on Takeshima has deviated from the essence of the issue.
The 1883 Order of the Council of State, which was conveyed to the Korean government as theresult of diplomatic negotiations, should instead be prioritized when considering the intentsof the parties concerned. Finally, she concludes that the Takeshima issue as a territorial issue
should not be discussed only using a historical approach as it requires a comprehensive and interdisciplinary approach that involves international law, domestic law, international relations theory
and so on, meaning that it is inappropriate to persistently seek to identify “the other island” in the1877 Instruction of the Council of State from a historical point of view bereft of other perspectives.

11. T he Instruction of the Council of State in South Korean research andeducation (Chapters 8–9)

Chapter 8 (“South Koreaʼs Territorial Claim to Takeshima and the Instruction of the Council ofState” by Fujii Kenji, Advisor on the Takeshima Island Issue, Shimane Prefecture) examines theimpacts that the 1877 Instruction of the Council of State has had on South Korean research on
Takeshima. The author points out that, although the first scholar to introduce the 1877 Instructionof the Council of State in an academic paper was Japanese (Hori Kazuo, later a professor at Kyoto
University), South Korean papers have built on Professor Horiʼs research, including his clear
misreadings and mistakes, in particular those parts advantageous to the Korean cause such as
the use of the Summary of Background Information and the theory that present-day Takeshima is
a dependency of Ulleungdo, citing research by Shin Yong-Ha and Song Byeong-Gi. He then points
out that these papers have even engaged in the “development” of South Korean narratives using
the 1877 Instruction in ways that could be considered a distortion of facts and a manipulation ofimpressions: this includes but is not limited to the following allegations: 1) the 1877 Instructionof the Council of State is proof that the Japanese side admitted that “Takeshima and the otherisland” were Korean territory (in reality, it only says that “there is no relation to Japan”) and 2) the
Summary of Background Information and the Simplified Map of Isotakeshima have the same value
as Reference Materials No. 1 to No. 4 that formed the basis of the judgment by the Ministry ofHome Affairs (looking at the inquiry of the Ministry of Home Affairs, the Summary of Background
Information and the Simplified Map of Isotakeshima were treated as part of the “appendices” of
the inquiry submitted by Shimane Prefecture and were not included in the attached documentsthat formed the grounds for the decision that “there is no relation to Japan”). By so doing, theSouth Korean side has tried to make the 1877 Instruction of the Council of State into something
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A Reexamination of the 1877 Instruction of the Council of State

more advantageous to South Korea than Professor Hori himself thought. The author is concerned
about the current situation where the false image of the 1877 Instruction of the Council of State,including the misrepresentation that the Simplified Map of Isotakeshima came attached to theInstruction, is being reproduced in South Korea, with even some Japanese starting to doubt thetrustworthiness of the Japanese governmentʼs view.
Based on notes verbales exchanged between Japan and South Korea in the 1950s and 1960s,
the author points out that the South Koreans were utterly defeated in the exchanges about
Takeshima as they were unable to produce any grounds for their possession of Takeshima. He
introduces one example: although the South Korean government “asked prominent historians
and international law experts in South Korea” to produce any objection to the Fourth Japanese
View on several occasions in connection with the normalization of relations between Japan andSouth Korea in 1965, they were unable to do so. He points out that Shin Yong-Ha and other
Korean scholars tried to prove Korean possession of Takeshima based on Korean evidence
but were unable to produce good results. 7 He concludes that the failure to establish Korean
possession based on Korean evidence led to their efforts to deny Japanese possession andestablish Korean possession based on Japanese sources, most notably the 1877 Instruction of
the Council of State. Then, a few years ago, an examination by the Ministry of Education of a
“Japanese History B” textbook for Japanese high schools revealed a footnote in the textbook draft
stating that “The Japanese government decided in 1877 that the island corresponding to presentday Takeshima had no relation to Japan.” While the footnote was not adopted, this episodesuggests that Japanese, too, are now being influenced by the South Korean arguments about the1877 Instruction of the Council of State. Lastly, he emphasizes that South Korea ought to show
grounds for their possession rather than try to find fault with the Japanese positions by using
Japanese documents such as the 1877 Instruction of the Council of State.
Chapter 9 ( “ The Takeshima Issue in South Korean Social Studies Education and theInstruction of the Council of State” by Fujii Kenji, Advisor on the Takeshima Island Issue,
Shimane Prefecture) introduces in detail how the Takeshima issue, including the 1877 Instructionof the Council of State, is treated in South Korean elementary, middle, and high school textbooks
as part of social studies education. He concludes that the typical, per verted approach to the1877 Instruction of the Council of State that seeks “grounds” for South Korean possession of
Takeshima in Japanese documents can also be seen in South Korean social studies education. He
also writes that in South Korean “Dokdo” education there is a growing tendency to perceive theTakeshima issue as an issue of historical perception by presenting the 1905 Shimane Prefecture
incorporation as “aggression.” In this regard, he emphasizes that Japan must reject this assertionand convey that the Japanese side only seeks a peaceful resolution to the Takeshima issue.
Moreover, he suggests the importance of communicating accessible information in languages
other than Japanese and telling the truth to the young South Koreans who will build the future by,for example, explaining that denial of Japanese possession of Takeshima as such will not establish
South Korean possession or that Korean textbooks are wrong to say that the Simplified Map of
Isotakeshima came attached to the 1877 Instruction of the Council of State.

12. Lee Kyu-Won and the Ulleungdo Sur vey Diar y (Supplementar y Chapter)

The Supplementar y Chapter (“Lee Kyu-Won and the Ulleungdo Survey Diary” by Professor
Nagashima Hiroki, Kyushu University) is not directly concerned with the 1877 Instruction of
the Council of State but reinforces the theme of the report by presenting historical sourcesthat show the Korean perception of “Takeshima” in the same period. The chapter examines
7

E.g. 신용하『독도의민족영토사연구』( 지식산업사 , 1996) [ 愼鏞廈『独島の民族領土史研究』（知識産業社 ,1996 年）Shin Yong-Ha, Dokdo from the perspective of Korean National Territorial History (JISIKSANUP PUBLICATIONS CO., LTD, 1996)].

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The Takeshima Documents Study Groupthe Ulleungdo Survey Diary authored by Lee Kyu-Won. Lee Kyu-Won was a military official in
the late 19th-century Joseon Kingdom and was ordered by King Kojong to survey Ulleungdo
in 1881. The Ulleungdo Survey Diary is thought to have been a draft of the report he wrote onthat occasion. The document is cited by Japanese and South Koreans alike as a source about theperception of Ulleungdo (and non-perception of present-day Takeshima) in late 19th-centur y
Korea. The original text donated by Lee Hye-Eun (then professor of geography education at theCollege of Education, Dongguk University), a great-grandchild of Lee Kyu-Won, can be found at
Jeju National Museum. Having seen it with his own eyes, the author has photographed it and iscomparing it with existing transcriptions by South Korean researchers (including Lee Seon-Geunand Shin Yong-Ha).
He points out that the Ulleungdo Survey Diary consists of “a rough draft hidden on the back”(first draft), a secondary text with corrections to the first (second draft), and a draft of the reportsubmitted to the king (royal report draft). Next, he comments on two South Korean claims ( ①“Usando” on premodern maps is present-day Takeshima and ② “Seokdo” in Imperial Edict No.
41 from 1900 is present-day Takeshima) by writing that the Ulleungdo Survey Diary “may not be
decisive for the latter but has the potential to shoot down the former [...] South Korean claim.”
The end of the royal report draft states “when I climbed the height of (Ulleungdo) on a clear day
and looked out over the sea, I could not see a single rock or lump of earth” and “Usan is Ulleung
likely in the same way that Tamna is Jeju.” Meanwhile, the Sŭngjŏngwŏn ilgi (Journal of the Royal
Secretariat), which is an official record of the Joseon court, states that Lee Kyu-Won, prior to his
departure for the survey, answered a question from King Kojong by saying that Usan is the oldname for a province, just like Tamna is the old name for Jejudo, showing that he was correctly
informed that Usando and Ulleungdo are the same island. In other words, just as the Journal of
the Royal Secretariat says, Lee Kyu-Won possessed very accurate geographic information about
the surroundings of Ulleungdo even before his departure, and the accuracy of his argument waslater proven after his on-site survey, as indicated in the royal report draft of the Ulleungdo Survey
Diary. The author then concludes that this matches the depiction of “Chikdo” and “Tohang” on
the Ulleungdo oedo (Map of Ulleungdoʼs Surroundings), which is thought to have been attachedto the royal report.
Moreover, there is a part in the second draft that shows Lee Kyu-Wonʼs title to be t’ongjŏngtaebu ( 通政大夫 ) so at least this part was very likely written in July and August 1882 since thatwas when he held the title of t’ongjŏng taebu. This is also supported by other parts, so Professor
Nagashima points out that, if the Ulleungdo Survey Diary was drafted in the summer of 1882, thenit is a precious and highly contemporaneous Korean historical record.

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