constitute a violation. Rights of an intermediate nature, often categorized as welfare rights (such as the right to work, property, and survival), are subject to adjustments based on each country’s specific circumstances. The sincerity and attitude of a state in protecting the constitutional rights of foreigners should be evaluated against international human rights covenants to ensure that treatment does not fall below the general standard of civilized nations—a test for modern constitutions. 3 The state must also adhere to the principle of equality when implementing welfare rights. Whether the welfare policies are mandated by fundamental national policies or not specified in the Constitution, they must be bound by the principle of equality. However, due to the limited fiscal resources of the state, J.Y. Interpretation No. 485 has clarified that identity alone cannot justify differential treatment: "Given limited national resources, social legislation must consider the economic and financial situation of the state, adhere to the principle of effective resource utilization, and ensure fair distribution of welfare resources among the general population. The determination of the scope of beneficiaries should be carefully regulated based on their financial capability, income, household burden, and the necessity of care, without solely relying on the beneficiary's specific position or identity as the sole basis for differential treatment..." Additionally, some scholars have drawn from comparative observations of German law to point out that the principle of equality requires that there must be a legitimate and reasonable connection between nationality and any measures of differential treatment. In recent trends, social benefits are subject to more stringent scrutiny, and the European Court of Human Rights often views such differential treatment as a violation of the prohibition against discrimination. Judicial practices are increasingly inclined to reject the justification of differential treatment for foreigners who have resided long-term or frequently in a country. However, in the absence of long-term residence, it is possible to justify differential treatment among foreigners based on the length of their stay. In the realm of civil rights, nationality does not 3 Li Zhen-shan, ibid., pp. 57-58. 16