Press Release: Final Submission to Appeal Court

The Family Federation issues press release on submission to Tokyo High Court of final brief challenging state-sought dissolution order

Submission of the final statement of arguments regarding the petition for a dissolution order

Press release issued by the Family Federation of Japan 21^st November 2025 concerning the submission of the Federation‘s final statement of arguments to Tokyo High Court, the appeal court, regarding the state’s request for a court order to dissolve the Family Federation. See original article in Japanese.

See also Dissolution: Members’ Voices Ignored by Courts

See also Long-Running Donation Claims Settled in Japan

See also Warning Signal from Japan: Dangerous Precedent

See also Japan: President Tanaka (69) Names Hori Successor

See also Social Media, Reporting Cited as Fueling Terror

In the appeal proceedings before the Tokyo High Court concerning the government’s petition for a dissolution order against our organization (“this petition”), we have thus far endeavored to establish, based on law and evidence, the errors contained in the Tokyo District Court’s decision (the original decision).

Today (21^st November 2025), we submitted our final written statement to the Tokyo High Court. Below is today’s report, along with a summary of the arguments and evidence our organization has presented during the appeal proceedings.

1. Our Organization’s Arguments in the Appeal Proceedings

The outline of the written arguments and evidence our organization has submitted in the appeal proceedings is as follows:

1. A detailed rebuttal to the original decision’s presumption that our organization’s unlawful acts have “continued uninterrupted to recent times” even after the issuance of the Compliance Declaration (2009) [See editor’s note 1 below].
2. A detailed rebuttal to the original decision’s characterization of the Compliance Declaration as merely a “stopgap measure”, including the submission of numerous pieces of evidence showing thorough implementation and effective results of the Compliance Declaration.
3. Arguments showing that pre-Compliance Declaration [See editor’s note 1 below] civil cases do not constitute valid evidence to justify a dissolution order (including outdated cases or cases in which unlawful acts were inferred unreasonably).
4. Arguments based on the history of religious persecution in Japan (especially the Ōmoto Incident) [See editor’s note 2 below], the development of “freedom of religion” under the Japanese Constitution, and structural aspects of Japanese society, demonstrating that this petition [the state’s petition for a court order to dissolve the Family Federation] constitutes an impermissible act of religious oppression.
5. Arguments that punishing a party for acting in reliance on legal interpretations long established through precedent and government interpretation, violate the principle of legality and the prohibition of retroactive punishment – both of which ensure legal stability and protect individuals’ freedom of action (violations of Articles 31 and 39 of the Constitution).

   

   ※ The original decision retroactively applied a new interpretation of Article 81, Paragraph 1, Item 1 [See editor’s note 3 below] of the Religious Corporations Act, which the government abruptly changed overnight after long being settled as precedent and official interpretation.

6. Arguments that a dissolution order directly restricts missionary activity and the freedom of religious association, and therefore must be examined with strict and careful scrutiny. Requirements such as:
   • dissolution being indispensable to protect the public interest,
   • the existence of a current danger to the public interest warranting dissolution, and
   • the inability to achieve the intended purpose through less restrictive alternatives (LRA),
     were all ignored by the original decision.
7. Arguments that this petition [the state’s petition for a court order to dissolve the Family Federation] constitutes an arbitrary “targeting” of our organization by the government, amounts to “pressure or interference applied to religion,” and violates the principle of separation of religion and state (violation of Article 20 of the Constitution).
8. Submission of approximately 50 expert opinions (from constitutional, legal, political, and religious studies scholars, attorneys, religious leaders, etc.) pointing out the impropriety of this petition [the state’s petition for a court order to dissolve the Family Federation] and the original decision.
9. Evidence showing that our organization and its members have faced unjust treatment as though they were “second-class citizens” at the hands of the national government, local authorities, communities, workplaces, and schools, resulting in major human-rights violations. Over 1,000 statements and letters attest to this. Should dissolution be ordered, these harms are highly likely to worsen and expand dramatically. The original decision contained no consideration whatsoever of the severe negative impact a dissolution order would have on our members’ human rights.

2. Today’s Submitted Brief

The outline of the written statement submitted today to the Tokyo High Court is as follows:

1. Based on the October testimony of two believers, the brief highlights the severity of the human-rights harms that would be suffered by our staff, families, and believers as a result of a dissolution order.
2. Noting warnings from UN human-rights experts that “the District Court ruling violates international law,” explaining the background of attacks on our organization by communist and left-wing forces, and addressing fabrications in media coverage revealed through the Yamagami case trial (such as condoning terrorism, failing to criticize attacks on democracy, and shifting the focus to criticism of the church).
3. Demonstrating that our organization has continuously made sincere efforts to resolve various issues, including participation in collective mediation and the establishment of a compensation committee, therefore rendering a dissolution order unnecessary.
4. Pointing out that no concrete facts support the existence of malicious unlawful acts by our organization. Even at the High Court, the Agency for Cultural Affairs has failed to present any specific facts despite the court’s instructions. There are neither “unmanifested harms” nor any risk of harm reoccurring; thus, grounds for dissolution do not exist.

This concludes the report.

A nation has no future if the government, driven by political motives, decides to “crush” a religious corporation, and the judiciary follows blindly, ignoring “the justice of the law” and the principle of adjudication based on evidence. In the appeal proceedings, we earnestly hope for a fair and impartial judgment – one that can withstand historical scrutiny – based on law, evidence, and facts, not on public sentiment or prejudice.

Our organization will continue to exert its utmost efforts to restore lost trust and to become a religious community broadly accepted by society through ongoing, dedicated efforts.

See also Dissolution: Members’ Voices Ignored by Courts

See also Long-Running Donation Claims Settled in Japan

See also Warning Signal from Japan: Dangerous Precedent

See also Social Media, Reporting Cited as Fueling Terror

See also Japan: President Tanaka (69) Names Hori Successor

See also Rising Religious Persecution in SKorea, Japan

See also Dissolution, System of Faith-Breaking, Lawsuits

Featured image above: The building housing Tokyo High Court and Tokyo District Court. Photo (2012): Rs1421 / Wikimedia Commons. License: CC ASA 3.0 Unp 

[Editor’s note 1: The 2009 compliance declaration of the Unification Church of Japan (now the Family Federation for World Peace and Unification) was a formal commitment by the organization to reform its practices in response to longstanding public criticism and legal challenges.

The Unification Church in Japan had faced numerous allegations related to recruitment tactics and donation solicitation, termed “spiritual sales” (霊感商法) by a hostile network of activist lawyers who had declared the religious organization an enemy. These issues led to multiple lawsuits orchestrated by the activist lawyers and significant media backlash. This prompted the organization to take measures to restore its reputation and demonstrate compliance with legal and ethical standards.

The religious organization pledged to stop possibly unethical donation practices, including what the hostile network of lawyers claimed amounted to “pressuring members into making large financial contributions under spiritual pretexts.”

This was in response to accusations from the same activist lawyers that followers “were being manipulated into giving away substantial amounts of money or property.”

The Unification Church stated it would enhance internal oversight to ensure compliance with ethical and legal standards. Measures included better training for leaders and stricter guidelines for evangelization and solicitation of donations.

After this compliance declaration, there was a significant decrease in the number of lawsuits against the Unification Church – since 2015 called the Family Federation. The religious organization has used this as evidence that it has improved its practices and should not be subject to dissolution.]

[Editor’s note 2: The Ōmoto Incident (大本事件 Ōmoto jiken) refers to two major crackdowns by the prewar Japanese government against the Ōmoto (Oomoto) religious movement – Omotokyo (大本教). It is a Japanese new religious movement that originated in the late 19th and early 20th centuries. It was founded by Nao Deguchi (1836–1918), a peasant woman who claimed to have received divine revelations, and her successor Onisaburo Deguchi (1871–1948), who played a significant role in shaping the religion’s teachings and structure.

Omotokyo emphasizes universal salvation, spiritual purification, and the ultimate unity of all religions. The religion stresses the importance of living in harmony with divine will and nature.

There were two incidents. The first Ōmoto Incident (1921) was triggered by government suspicion that Ōmoto teachings were socially disruptive. Authorities raided Ōmoto facilities, arrested leaders, and charged them with lèse-majesté (insulting the emperor) for certain religious texts. This was part of a broader pattern of suppressing new religions seen as politically or ideologically threatening.

The second Ōmoto Incident (1935) was far more severe, and is usually what people mean by “the Ōmoto Incident”. The military and police launched a large-scale crackdown. Temples and buildings were destroyed (including with explosives). Leaders and many followers were arrested. The state accused the group of subversion, criticizing the emperor system, and spreading dangerous ideas. Essentially, it was an attempt to eliminate Ōmoto as a movement.

It is considered one of the most extreme examples of state suppression of religion in prewar Japan. It’s often referenced today in discussions about religious freedom, state control, and the role of new religious movements in Japan.

Today, Omotokyo remains a small but active religious group in Japan. It has also inspired the foundation of Aikido, the martial art developed by Morihei Ueshiba, who was a follower of Omotokyo.

Omotokyo holds a significant place in the history of Japanese religion, not only as a spiritual movement but also as a symbol of resistance to religious persecution during Japan’s militaristic period.]

[Editor’s note 3: Article 81, Paragraph 1, Item 1 of the Religious Corporations Act (宗教法人法) says that a religious corporation may be dissolved by court order if it engages in “acts in violation of laws and regulations that are clearly detrimental to the public welfare” (法令に違反し、著しく公共の福祉を害すると明らかに認められる行為).

This provision is the main legal hook the Japanese government has used when asking courts to dissolve the Family Federation as a religious juridical person.

The quoted sentence explains that the court needed a way to decide whether the Family Federation’s fundraising/donation practices actually count as “violations of laws and regulations” under Article 81.

But here’s the complication: Most of the Unification Church’s donation practices were never prosecuted criminally. Instead, victims won civil lawsuits where courts recognized tort liability (不法行為, unlawful acts under the Civil Code). Civil torts are not always straightforwardly treated as “violations of law” for the purposes of Article 81, which is meant to be a serious standard (dissolution is a drastic step).

So the Tokyo District Court set its own interpretive standards (基準) to decide what counts as a “law violation” in this context.

Critics argue that the court blurred the line by relying not directly on the Act on the Prevention of Improper Solicitation of Donations (2022 law) – since that can’t apply retroactively – but instead by creating a vague “criteria” derived from it.

This allowed the court to treat past civil cases (where plaintiffs won damages) as proof of “violations of law”, even though those cases were not criminal convictions.

Supporters of dissolution say this was necessary to protect victims and reflect the accumulated judicial record of harm.

Opponents (including some legal scholars and the Family Federation itself) say this stretched the meaning of “法令に違反” (violation of laws) beyond what the statute really permits, effectively bending the law to make dissolution possible.]

Related to final submission to appeal court: Lawfare: State Uses Legal System in War on Faith

Also related to final submission to appeal court: MEXT’s Legal Spin and “Dissolution at All Costs”

Also related to final submission to appeal court: UN Report: Japan’s Lawfare Against Faith Minority

And also related to final submission to appeal court: Protesting No Transparency in Closed-Door Trial

More, related to final submission to appeal court: Dangerous Flaws in Dissolution Order Decried

Also related to final submission to appeal court: “Lawyers Lying and Shaming Japan” for 50 Years

And also related to final submission to appeal court: Japan Following the Way of China

And also related to final submission to appeal court: Japan’s Dissolution Case Echoes China’s Playbook

More, related to final submission to appeal court: Media/Legal Expert: Communism Behind Persecution

And more, related to final submission to appeal court: Militant Lawyers Dictate Government Policy

More, related to final submission to appeal court: Collusion to Rob Minority of Its Rights

And more, related to final submission to appeal court: State and Media Creating “Today’s Non-Citizens”

Still more, related to final submission to appeal court: Japan Copying China: State Seizure of Churches

And still more, related to final submission to appeal court: 12 Religious Freedom NGOs Denouncing Japan

More, related to final submission to appeal court: 4300 Abductions and Forcible Detentions

And more, related to final submission to appeal court: Japan: Families Fear for Graves of Loved Ones

Yet more, related to final submission to appeal court: Lawyers Manipulating, Coercing, Lying

Also related to final submission to appeal court: Kishida Follows Anti-Family Federation Minister

Also related to final submission to appeal court: Militant Lawyers Dictate Government Policy

Still more, related to final submission to appeal court: Malicious One-Sided Government Source Selection

Yet more, related to final submission to appeal court: Kishida’s Self-Defeating Populist Decisions

And still more, related to final submission to appeal court: Japan Urged to Make U-Turn

And yet more, related to final submission to appeal court: Dangerous Precedent to Crush Religions

Even more, related to final submission to appeal court: Japan Following the Way of China

Yet more, related to final submission to appeal court: Japanese Communists’ Final War

Still more, related to final submission to appeal court: Political and Social Activism behind Oppression