When a student commits suicide because of bullying at school, a lawsuit for damages is often filed against the offending student or school. The issue at trial is whether the defendant is responsible for the suicide. This is a matter of interpretation of Article 416 of the Civil Code. Traditionally, Japanese courts have regarded a student's suicide as special damages under Article 416(2), denying the foreseeability of the offending student, or school teacher. In other words, the perpetrator and the school have been held not liable for the suicide. However, even if suicide is a special damage, it is not reasonable to conclude that suicide could not have been foreseen today. Suicide is obviously a generally foreseeable injury. If that is the case, then, suicide should be considered as ordinary damages under Article 416, paragraph (1), not as special damages under paragraph (2) of the same article.