保元之亂
Nakanari's execution is held to be the last carried out by the central Japanese court until the Hōgen Rebellion of 1156. However, according to the scholar Masataka Uwayokote, because the method of execution used did not comply with the beheading or strangling options defined in the Yōrō Code, and because it happened after Nakanari was officially demoted, this execution may have been a personal command by the emperor rather than a formal execution under the Ritsuryō law.