Battle of Nanking
The first academic accounts of the Nanking Massacre included as massacre victims all Chinese who were killed by the Japanese Army in and around Nanking, including Chinese soldiers who were killed in action. This definition was supported by Hora and other early scholars. In 1986 Ikuhiko Hata became the first historian to call this definition into question. Hata argued that Chinese troops killed on the battlefield were part of the Battle of Nanking rather than Nanking Massacre, and that only civilians and disarmed POWs should be counted as massacre victims.