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The Kawasaki Ki-38 was an early version of the aircraft that would enter production as the Kawasaki Ki-45 Toryu (Nick) twin engined fighter. In 1937 the Japanese Army decided that it wanted a twin-engined long range heavy fighter, in the same class as the Messerschmitt Bf 110 or the French Potez 630, but it could not decide if it wanted their new aircraft to be fast, manoeuvrable or heavily armed. In March 1937 the Army issued a remarkably vague specification in this class to Nakajima, Kawasaki and Mitsubishi. Work on the Nakajima Ki-37 and Mitsubishi Ki-39 designs stopped at an early stage because those companies had more urgent projects for their design teams, but the Kawasaki aircraft reached the mock-up stage.
The Ki-39 would have been a twin engined monoplane, with elliptical wings and powered by two 12 cylinder liquid cooled engines. The model was completed in October 1937, just in time for the Army to suspend the project. Over the next two months the Army finally came up with a more detailed specification, and in mid December Kawasaki was ordered to resume work on the project.
The new aircraft was to have a top speed of 335.5mph at 11,480ft, be able to operate effectively between 6,560ft and 16,405ft, have an endurance of four hours and forty minutes at 217mph plus thirty minutes of combat and be armed with two forward firing and one rear firing machine gun, and was given the new designation Ki-45.