Article 9 of the Japanese Constitution not only forbids the use of force as a means to settling international disputes but also forbids Japan from maintaining an army, navy or air force. Therefore, in strictly legal terms, the Japan Self Defense Forces are not land, sea or air forces, but are extensions of the national police force. This has had broad implications for foreign, security and defense policy. According to the Japanese government, war potential' in paragraph two means force exceeding a minimum level necessary for self-defense. Anything at or below that level does not constitute war potential." Apparently when the JSDF was created, "since the capability of the JSDF was inadequate to sustain a modern war, it was not war potential". Seemingly, the Japanese government has looked for loopholes in the wording of the peace clause and the "constitutionality of the Japanese military has been challenged numerous times". Some Japanese people believe that Japan should be truly pacifist and claim that the JSDF is unconstitutional. The Supreme Court, however, has ruled that it is within the nation's right to have the capacity to defend itself. Scholars have also discussed "constitutional transformation ... occurs when a constitutional provision has lost its effectiveness but has been replaced by a new meaning".