Historically the law has been interpreted in different ways—recently it has been interpreted to mean that all pornography must be at least partly censored; however, there have been very few arrests based on this law.
As publishing became more popular in the Edo Period, the Tokugawa shogunate began to turn to censorship.
This means, as Donald Keene observes, that for some producers of texts "the Occupation censorship was even more exasperating than Japanese military censorship had been because it insisted that all traces of censorship be concealed.
This meant that articles had to be rewritten in full, rather than merely submitting XXs for the offending phrases." Due to the current interpretation of Article 175 of the Criminal Code of Japan, which forbids distributing "indecent" materials, it is believed that most pornography in Japan must be at least partially censored.
When he appealed the case to the Supreme Court of Japan on arguments that the manga was not as indecent and explicit as much material on the Internet and that Article 175 violated the Japanese Constitution's protection of freedom of expression, the Court upheld the ruling and the fine was tripled to 1.5 million yen.