Civil Lawsuits as Weapons Against Religion

Massimo Introvigne on civil lawsuits

To dissolve the Family Federation, Japan relied on hostile legal activism, civil lawsuits, the rebranding of donations as “spiritual sales”, and an abrupt reinterpretation of the law

See part 2 of the opinion piece: Settlements Used as Evidence of Wrongdoing

See also Flawed Reasoning of a Politician Backing Torts

See also Beyond Dissolution: A Religious Purge in Japan?

See also How to Remain Free in an Age of Inquisition

In recent years, few legal controversies in Japan have attracted as much international attention as the government’s effort to dissolve the Family Federation for World Peace and Unification, previously known as the Unification Church. The issue has generated intense debate not only within Japan but also among scholars of religion, legal experts, and advocates of human rights and religious liberty around the world. At the center of this debate lies the question: can a religious organization be dissolved on the basis of civil judgments and allegations of manipulative fundraising, even in the absence of criminal convictions against the organization itself?

Bitter Winter
Logo of Bitter Winter, the world’s leading online magazine on religious liberty and human rights.

In an article published 28th March 2026, in Bitter Winter, the leading global online magazine on religious liberty and human rights, sociologist of religion Dr. Massimo Introvigne examines the Tokyo High Court’s reasoning in affirming the dissolution of the Family Federation. His discussion focuses especially on accusations involving so-called “spiritual sales” and excessive donations, which Japanese courts and critics have presented as evidence that the organization psychologically manipulated followers into giving large sums of money.

Offering donations
Faithful believer offering donation, termed “spiritual sales” by hostile activist lawyers. Illustration by Microsoft Designer Image Creator 14th July 2024.

See also The Return of Labeling Faith as Manipulation

See also: Law Expert: Too Weak Legal Basis for Dissolution

The article explores how the High Court in line with a negative narrative repeated for decades by hostile lawyers, portrayed the Family Federation as an organization driven less by spiritual concerns than by financial interests. According to the court’s interpretation, believers were allegedly pressured into making donations or purchasing religiously associated objects at inflated prices because they feared spiritual misfortune or hoped for blessings and protection.

Activist critics even coined a special expression – “spiritual sales” – to describe these practices. Originally, the term referred to the sale of items such as seals, miniature pagodas, marble vases, and similar objects said to possess spiritual significance. Over time, however, a network of hostile activist lawyers expanded the concept to include donations themselves, even when no physical goods were involved.

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Dr. Introvigne notes that the court relied in part on several criminal cases from the late 2000s involving individuals connected to businesses operated by members of the faith then called the Unification Church. One of the most important of these cases involved Shinsei Ltd., where executives received suspended prison sentences in addition to financial penalties. Yet the High Court did not formally treat these convictions as direct grounds for dissolving the religious organization itself. Instead, the judgments were presented more as background material intended to create an image of the movement as socially harmful.

This distinction is significant. The article stresses that crimes committed by individual members of a religious organization do not justify dissolving the organization as a whole. Dr. Introvigne argues that if such logic were applied consistently, many major religious institutions would face dissolution whenever some members committed criminal acts. He uses the example of abuse scandals involving Catholic clergy to illustrate the point that wrongdoing by individuals cannot automatically be equated with institutional criminality.

Marble vase
Marble vase, one of the products sold by Happy World Co. Photo: Knut Holdhus

A substantial portion of the High Court’s argument focused on the activities of a company known eventually as Happy World Co., Ltd. Founded by followers of the Unification Church in the early 1970s, the company sold products including ginseng, seals, marble items, and decorative religious objects. Although criminal charges against company executives had earlier resulted in acquittals in the Kobe District Court, the High Court nevertheless treated Happy World as a central actor in the phenomenon of “spiritual sales”.

Dr. Introvigne acknowledges that some of Happy World’s marketing methods were aggressive and objectionable. Even scholars associated with the Family Federation have admitted this point. However, he also emphasizes that the religious organization attempted to restrict such practices decades ago. As early as 1987, according to the court’s own findings, Happy World informed Japanese authorities and consumer protection agencies that it had prohibited sales methods likely to create misunderstandings connected to “spiritual sales”. Eventually, the company ceased operating altogether.

The article argues that these historical incidents, many of which occurred more than twenty years ago, were revived primarily to cast the Family Federation in a negative light rather than to establish present misconduct. The actual legal basis for dissolution, Dr. Introvigne explains, rested mainly on twenty-six civil court judgments and numerous settlements reached either in court or outside of court.

This raises what the author sees as the central legal problem in the case: whether civil decisions alone are sufficient grounds for dissolving a religious organization. Historically, Japanese legal interpretation answered this question negatively. Previous governments repeatedly maintained that criminal convictions against the religious corporation itself were necessary before dissolution could be pursued.

Fumio Kishida
Former prime minister Fumio Kishida deliverin a speech at the UN Climate Change Conference in Glasgow (COP26) 2nd Nov. 2021. Photo: 首相官邸ホームページ / Wikimedia Commons. License: CC Attr 4.0 Int. Cropped

The article recounts that in both 1994 and 1998, Japanese authorities resisted demands from “anti-cult” lawyers seeking dissolution of the Unification Church. In 2012, those lawyers even sued the government for refusing to initiate dissolution proceedings, but the government prevailed. Following the assassination of former Prime Minister Shinzo Abe (安倍晋三) in 2022, however, the political atmosphere changed dramatically. Prime Minister Fumio Kishida (岸田文雄) initially stated that dissolution would not be legally possible without criminal convictions against the religious organization. Yet within a day, he reversed his position and declared that civil judgments could provide adequate grounds.

According to Dr. Introvigne, the High Court attempted to justify this shift by referring to a 2025 Supreme Court ruling concerning a fine imposed on Family Federation president Tomihiro Tanaka (田中富広) for failing to fully answer questions from the Ministry of Education, Culture, Sports, Science and Technology. In that decision, the Supreme Court indicated that civil torts could indeed support dissolution proceedings against a religious organization.

Continued in part 2: Settlements Used as Evidence of Wrongdoing

See also Flawed Reasoning of a Politician Backing Torts

See also Beyond Dissolution: A Religious Purge in Japan?

See also How to Remain Free in an Age of Inquisition

See also The Return of Labeling Faith as Manipulation

See also: Law Expert: Too Weak Legal Basis for Dissolution

See also: Religious Freedom in Jeopardy After Dissolution

See also Japan’s Treatment of Faith Headed to The Hague?

Text: Knut Holdhus, editor

Featured image above: Dr. Massimo Introvigne, an Italian scholar specializing in the sociology of religion. He founded and serves as managing director of the Center for Studies on New Religions, an international network of academics focused on the study of new religious movements. He has authored around 70 books and over 100 scholarly articles in this field. Here, speaking in Geneva, Switzerland 16th June 2025. Screenshot from video by UPF.

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