Corporation Dissolved – Organization Remains

Understanding the Japanese dissolution decision: The Supreme Court’s recognition of the continued existence of the religious organization even though it lost its corporation status

Tokyo, 13^th July 2026 – Published as an article in the Japanese newspaper Sekai Nippo. Republished with permission. Translated from Japanese. Original article.

[Opinion]

Dissolution Order and the Supreme Court’s Decision Confirm the Continued Existence of the Family Federation as a Religious Organization

by Rev. Hiroshi Kurose 黒瀬博, Tokyo West Baptist Church

Part 1

See part 2: The Contradictions of the Dissolution Order

Worship Facilities Should Be Returned Immediately

On 22^nd June, the Supreme Court of Japan dismissed the special appeal filed by the Family Federation for World Peace and Unification (formerly the Unification Church). As a result, the dissolution order has become final.

See also Using Abe’s Assassination Against Unificationism

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Without addressing the constitutional issues involved, the Supreme Court fully affirmed the decisions of the Tokyo District Court and the Tokyo High Court. Naturally, this outcome is deeply disappointing for members of the Family Federation. However, now that the decision is final, there is little point in continuing to debate its contents.

Court decisions are like an umpire’s call in baseball. Even if a ruling is mistaken, time moves forward on the basis of that decision. The reasoning behind this decision is flawed, but just as an erroneous call in baseball cannot be reversed after the game proceeds, neither can this result. Going forward, the focus should shift toward preserving a record of the decision’s injustice.

Distinguishing the Religious Corporation from the Religious Organization

One point made clear by the Supreme Court’s decision is that the dissolution order applies to the religious corporation (宗教法人 – shūkyō hōjin), while the religious organization (宗教団体 – shūkyō dantai) itself is permitted to continue to exist.

This distinction had already been hinted at by the district and high courts, but the Supreme Court’s explicit recognition of it is noteworthy. At the same time, there remains considerable room for interpretation regarding what this continued existence (存続) actually entails. Likewise, opinions differ over what the dissolution order itself legally means. It is therefore still worthwhile to examine these questions carefully.

The distinction between a religious corporation and a religious organization may seem obvious in common understanding, but legally it is much less clear.

For foundations, there are general incorporated foundations and public-interest foundations, both of which possess legal personality. Religious organizations, however, do not possess legal personality. Consequently, they not only lose tax-exempt privileges but also face numerous practical disadvantages, such as being unable to maintain bank accounts.

Nevertheless, Articles 1 and 2 of the Religious Corporations Act describe the conditions under which a religious organization qualifies to become a religious corporation – for example, engaging in religious activities and possessing places of worship. The language used even suggests that a religious organization could be the holder of legal rights such as ownership.

In practice, however, religious organizations cannot be registered as legal entities, making it unlikely that they can actually serve as holders of legal rights. The theoretical question then arises: do religious organizations have any right to own property?

This resembles questions such as whether a parent-teacher association or a school reunion association can own property. While they may exercise de facto control over property, they generally do not hold legal title. By the same reasoning, a religious organization is not a legal entity but merely a private association.

Today in Japan, obtaining legal status as a religious corporation has become extremely difficult. As a result, religious leaders seeking to conduct religious activities may instead establish incorporated associations or foundations and carry out their religious work within those legal frameworks. I have in fact heard of such cases.

From now on, not only will obtaining religious corporate status be difficult, but the recent dissolution order has made clear that even after obtaining such status, there is a risk that the organization’s assets may be seized if it is dissolved. Consequently, more religious groups are likely to choose not to incorporate at all. Even organizations that already possess legal personality may voluntarily dissolve their religious corporation and instead reorganize as foundations.

No one can predict the future with certainty, but this dissolution order will almost certainly prompt new developments within Japan’s religious community.

The Supreme Court has clearly distinguished between religious corporations and religious organizations, stating that only the corporation – not the organization – is dissolved.

Nevertheless, there are also explanations suggesting that the religious organization itself should effectively disappear. For example, seizing places of worship used by the religious corporation prevents the religious organization from carrying out its activities. Some have even argued that the organization should change its name. More generally, many people have come to believe that the court’s decision dissolved the religious organization itself.

The decision states that “because the religious organization continues to exist, there is no violation of religious freedom.” Yet in practice, does the decision not aim at dissolving the religious organization as well? Such ambiguity is problematic.

Continued in part 2: The Contradictions of the Dissolution Order

See also Using Abe’s Assassination Against Unificationism

See also Media Turning Public Opinion Against a Minority

See also Dissolution Case: Attorney Reveals Inside Story

See also Volunteer Group Barred After Question Over Ties

Featured image above: Hiroshi Kurose (黒瀬博): Born in 1951 in Hiroshima Prefecture. Completed a master’s in legal philosophy at Waseda University in 1975. Graduated from Tokyo Theological Seminary in 1978 and the Advanced Theology Program at Seinan Gakuin University in 1979. Completed studies at Zurich Baptist Seminary in 1984. Currently pastor of Tokyo West Baptist Church. Major works include The Development of a New Christianity (Good Time Publishing). Photo: Sekai Nippo

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