The Return of Labeling Faith as Manipulation

From heresy to “mind control”: How Tokyo Court in dissolution case brought back historical labeling of minority faiths as using sophisticated manipulative techniques

Dr. Massimo Introvigne, renowned Italian scholar of sociology of religion, describes in an opinion piece in Bitter Winter on 27^th March 2026 what he perceives as the reasoning of the judges in Tokyo High Court in their decision of 4^th March to uphold the dissolution order against the Family Federation for World Peace and Unification. To a large extent, Introvigne claims, the honorable justices have assumed that the religious organization in an incredible way have developed “mental manipulation as the main tool” through which to spread its message.

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

See also Civil Lawsuits as Weapons Against Religion

See also Settlements Used as Evidence of Wrongdoing

In his analysis, Introvigne identifies a central conceptual pillar underpinning the court ruling: the notion that members of so-called “cults” are subject to forms of psychological manipulation that undermine or even eliminate their free will. While the court avoids explicitly invoking the term “brainwashing”, its reasoning closely mirrors that controversial and widely discredited idea. The judgment repeatedly asserts that adherents of the Family Federation are subjected to techniques that impair their autonomy, rendering them unable to make sound judgments or to disengage from the movement’s teachings. According to the court, these methods are so powerful that they effectively suppress individual agency.

This framing raises immediate concerns, not only because of its implications for the case at hand but also because of its reliance on a theoretical model that has long been rejected in both academic and legal contexts. The suggestion that religious believers can be systematically stripped of their capacity for independent decision-making through specialized psychological techniques has a deep historical lineage. Across centuries, similar accusations have been directed at minority or unfamiliar religious groups. When observers encounter beliefs or practices that appear strange, demanding, or socially disruptive, there has often been a tendency to assume that followers must have been deceived, coerced, or otherwise manipulated into their commitments.

Dr. Introvigne points out that this pattern is not new. In antiquity, critics of early Christianity claimed that converts were victims of sorcery or magical influence. Comparable accusations surfaced in imperial China, where unauthorized religious movements were frequently described as employing black magic to ensnare adherents. During the medieval period in Europe, groups labeled as heretical were similarly portrayed as manipulating followers through hidden or sinister means. In each instance, the underlying logic was consistent: rather than acknowledging that individuals might freely choose unconventional or unpopular beliefs, critics attributed conversion to external forces that overrode rational judgment.

In the modern era, this narrative evolved rather than disappeared. By the nineteenth century, opponents of movements such as the Latter-day Saints argued that no reasonable person would voluntarily embrace such doctrines without being subjected to some form of “mesmeric” or hypnotic influence. The language shifted from magic to proto-scientific concepts, but the core assumption remained intact – that deviation from mainstream belief required explanation through diminished agency.

In his article, the Italian scholar describes how the twentieth century saw the emergence of the term “brainwashing”, particularly in the context of the Korean War. Western observers speculated that Communist regimes had developed sophisticated methods for coercively transforming the beliefs of prisoners of war. However, subsequent investigations revealed that many of these claims were exaggerated or unsupported by empirical evidence. The term itself originated not within the scientific community but through journalistic and political channels, and it gained traction more through public anxiety than through rigorous research.

Despite its shaky foundations, the concept of brainwashing was later adopted by segments of the anti-cult movement in the 1960s and 1970s. Faced with the rapid growth of new religious movements, some activists and concerned families sought explanations for why individuals – particularly young people – would join such groups. The theory of coercive persuasion offered a seemingly intuitive answer: members were not exercising genuine choice but were instead victims of psychological control. [See editor’s note below]

Yet when subjected to scrutiny in legal settings, these claims failed to hold up. A pivotal moment came with the 1990 “Fishman” case in the United States, where a federal court evaluated the scientific validity of coercive persuasion theories. After examining expert testimony, the court concluded that such frameworks lacked sufficient empirical grounding to be admissible as evidence. This marked a significant turning point, signaling judicial skepticism toward the use of “brainwashing” as a legal argument.

According to Introvigne, similar conclusions emerged in Europe. The European Court of Human Rights has explicitly noted the absence of a universally accepted scientific definition of “mind control”. Moreover, it has observed that many behaviors often cited as indicators of coercion – such as strong commitment, communal living, or active proselytizing – are common across a wide spectrum of religious traditions. Earlier still, the Italian Constitutional Court invalidated the crime of “plagio” (enslaving another person’s mind) in 1981, a statute from the Fascist era (1922-1943) reminiscent of brainwashing concepts, on the grounds that it was incompatible with both scientific understanding and the principles of religious freedom.

These legal developments reflect a broader consensus: claims of psychological manipulation in religious contexts are inherently problematic. They tend to be vague, difficult to define, and highly susceptible to subjective interpretation. More importantly, they risk enabling authorities to substitute their own judgments for the lived experiences and self-understandings of believers. When courts accept such theories, they create an uneven playing field in which majority religions are presumed to operate through legitimate persuasion, while minority groups are viewed with suspicion.

It is within this context that the Tokyo High Court’s reasoning becomes particularly contentious. By asserting that the Family Federation employs undefined forms of “psychological influence”, the court effectively revives a framework that has been widely discredited. It does so without clearly distinguishing between coercion and ordinary religious practices such as teaching, preaching, or encouraging commitment. The absence of a precise definition allows the concept to function as a catch-all explanation, rather than a rigorously demonstrated claim.

This ambiguity has significant implications. Religious traditions across the world encourage acts of devotion that may appear demanding to outsiders, including financial contributions, personal sacrifice, and adherence to doctrinal teachings. If such practices are reinterpreted as evidence of manipulation, it becomes exceedingly difficult to draw a coherent boundary between acceptable religious activity and unlawful influence. The issue then shifts from objective criteria to subjective approval: beliefs and practices deemed acceptable by the majority are legitimized, while those associated with minority groups are pathologized.

At stake is a fundamental principle of religious liberty: the recognition that individuals have the right to adopt beliefs and make commitments that others may find unusual, excessive, or even irrational. A legal system that questions the authenticity of such choices risks undermining personal autonomy rather than protecting it. By suggesting that certain forms of religious adherence are incompatible with free will, the court implicitly positions itself as an arbiter of which beliefs can be sincerely held.

Introvigne’s critique ultimately frames the Tokyo High Court’s decision as a regression. By relying on the language and assumptions of psychological manipulation, the ruling departs from established academic and legal standards. It opens the door to interpreting voluntary religious behavior as coerced and to justifying state intervention on the basis of contested and unverified theories. The concern extends beyond the immediate case: if such reasoning is normalized, it could affect a wide range of religious communities, not only the Family Federation.

In this light, the debate is not merely about one movement or one court decision. It touches on broader questions about how societies understand belief, autonomy, and the limits of state authority. The reappearance of “brainwashing”-type arguments in judicial reasoning suggests an unresolved tension between skepticism toward minority religions and commitment to the principles of freedom of belief. Whether this tension can be resolved without compromising fundamental rights remains an open and pressing question.

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

See also Civil Lawsuits as Weapons Against Religion

See also Settlements Used as Evidence of Wrongdoing

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 on 10th July 2025 in a session during the 8th annual conference of the European Academy of Religion (EuARe) at the University of Vienna. Photo: Bitter Winter

[Editor’s note: In Japan, the “mind-control” myth has been a powerful tool used to stigmatize and suppress new religious movements (NRMs), particularly since the 1980s. The concept suggests that NRMs manipulate or “brainwash” their followers, depriving them of free will and rational thought. This narrative gained traction after the 1995 Aum Shinrikyō sarin gas attack, when public fear of dangerous cults intensified. Although Aum was an extreme and violent exception, the incident cast suspicion on all NRMs, allowing critics, media, and the government to label diverse groups as manipulative or psychologically coercive.

The “mind-control” myth serves multiple social and political functions. It simplifies complex questions of belief, making it easier to portray converts as victims rather than as individuals exercising spiritual agency. This framing justifies legal and social intervention, including the coercive “deprogramming” of believers – sometimes involving confinement or psychological pressure to force renunciation of faith. Lawyers, ex-member groups, and certain media outlets have used the idea of mind control to construct NRMs as threats to family stability and national order, reinforcing social conformity and Japan’s preference for established, non-controversial religions such as Buddhism and Shinto.

In recent years, the myth resurfaced following the 2022 assassination of former Prime Minister Shinzo Abe, whose attacker cited resentment toward the Family Federation. A public outrage largely created by media reignited scrutiny of NRMs, and politicians and journalists revived “mind-control” rhetoric to explain fundraising and recruitment practices. Critics argue that this framing discourages genuine religious tolerance and critical examination of Japan’s restrictive religious climate. Overall, the “mind-control” myth functions less as a scientific or psychological concept and more as a moral panic – a cultural weapon used to delegitimize minority faiths and to reaffirm mainstream social norms about religion, obedience, and the boundaries of acceptable belief.]

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