Japanese tools, for example the woodcut tools, knives, gouges and chisels I use for printmaking on Cherry, Maple and Plywoods, are made with an lamination of wrought iron or mild steel body and a high carbon steel which does the edge work.

I don’t think I’ve ever seen a Japanese cutting tool made by case hardening.

Likewise, to the best of my knowledge, old American smiths used laminates, not hardening for edge tool making.

I most often see case-harden steels used in older firearms, for trigger groups or bolt-release mechanisms on old Mausers for example, parts that need a durable wear surface that are not subjected to the impacts and stresses a tool would need endure.