See - http://www.lexology.com/library/detail.aspx?g=e79986c6-4b9b-4f19-9a51-7fca9a6183c7&utm_source=Lexology+Daily+Newsfeed&utm_medium=HTML+email+-+Body+-+General+section&utm_campaign=Lexology+subscriber+daily+feed&utm_content=Lexology+Daily+Newsfeed+2013-04-04&utm_term=
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If a debtor defaults on a loan agreement, the financial institution may collect that loan from the debtor's ordinary deposit through acceleration and offset. However, an issue arises as to whether the financial institution may freeze the ordinary deposit in order to secure its claim without taking formal acceleration when the debtor's credit is uncertain, resulting in the debtor being unable to withdraw the deposit – and, if so, under what conditions.
Under the Civil Code, an ordinary deposit should be returned when the depositor requests it, and the freezing of a bank account generally has a serious and negative impact on the debtor's credibility. Therefore, the freezing of a bank account may develop into a legal dispute where the debtor claims compensation for damages against the financial institution on the grounds that the freezing of a bank account is a tortious act or a default of the financial institution's obligation. Most of the relevant lower courts' decisions deny the liability of financial institutions. However, a recent decision of the Tokyo High Court (acting as the court of appeal), while maintaining the decision of the district court, denied the liability of a financial institution and indicated the grounds on which it is justified to freeze a bank account.
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