China’s Law Governing the Trial of War Criminals (1946) provides that “mass deportation of non-combatants” constitutes a war crime. 

In the Takashi Sakai case in 1946, the War Crimes Military Tribunal of the Ministry of National Defence of China found the accused guilty of war crimes and crimes against humanity inasmuch as he had incited or permitted his subordinates to commit, inter alia, acts of deportation of civilians.