1. The bill has not comprehensive provisions against discriminations.

2. The bill does not refer to human rights "education", of which the Ministry of Education and Science has the administrative mandates.

3. It is not refereed the duty of the local governments, even if they have various functions on the human rights remedies.

4. Human Rights Commission (HRC) must be placed not in the Ministry of Justice but in the Cabinet Office so that the independence will be secured.

5. The HRC consisting of three part-time among five members might not be independent from the Government.

6. Not only central HRC, but also regional HRCs must be set up so that human rights violations occurring in local areas would be properly dealt with.

7. Human Rights Commissioners System should be drastically amended in order to be more popular among citizens.

8. The HRC must have comprehensive mandate concerning human rights violations by the public authorities.

9. The HRC must not have strong mandates concerning human rights violation by the Media in order not to intimidate journalists of their free reporting.

10. The Minister of Welfare and Labor Affaires, a cabinet member, must not have the mandates of general and special remedy procedures which is usually carried out by an independent Commission.

11. The importance of the collaboration with HRC and NGOs/NPOs must be specified.

12. The importance of the human rights policy proposals by the HRC must be referred.