 In Japan, medical negligence and other species of negligence are governed by the criminal code, which may impose much harsher penalties than civil law.For instance, many causes of action which would subject a defendant to a potential punitive damage award in the U.S. would subject the same individual to prison time in Japan.In New Zealand it was held in "Donselaar v. Donselaar"  and confirmed in "Auckland City Council v. Blundell"  that the existence of the Accident Compensation Corporation did not bar the availability of exemplary damages.