The shadow of discarded concepts of “brainwashing” and “mind control” can be seen in the government’s choice of advisors in the Family Federation dissolution case and appointment of Supreme Court judge

Tokyo, 26th June 2026 – Published as an article in the Japanese newspaper Sekai Nippo. Republished with permission. Translated from Japanese. Original article.
Part 2 of opinion contribution by Dr. Massimo Introvigne, Founder and Managing Director of the Center for Studies on New Religions (CESNUR)
Japan’s Supreme Court Finalizes Dissolution of the Family Federation
Serious Questions About Neutrality and Due Process
by Massimo Introvigne, Sociologist of Religion
Ignoring the Warnings of UN Special Rapporteurs; the Shadow of “Mind Control” Theory

The extraordinary speed with which the judgment was delivered has also attracted attention. Although the case involved constitutional rights and the dissolution of a religious organization with a long history, the Supreme Court reached its decision in an exceptionally short period.
See also part 1: Ruling Leaves Serious Questions on Due Process
See also Dissolution Case: Pseudoscience Shaping Verdict
See also Brussels Press Conference Condemns Dissolution
See also The Hidden Story Japan Doesn’t Want You to Hear
See also Japanese Court Assumes the Role of Inquisitor
See also Brainwashing Theory Returns Under New Names
Given the gravity of the consequences, the Court’s reasoning is strikingly brief.
Many observers expected the Supreme Court to dismiss the appeal, since it had already signaled a degree of predisposition on the underlying legal issue. At the same time, many had hoped for a more substantive examination of the constitutional and international law questions raised by the case.
Instead, the Court issued what amounts to a formal affirmation of the existing judgments rather than a genuinely substantive review.
The outcome also cannot be separated from the Supreme Court’s own earlier role. In 2025, the Court reinterpreted the Religious Corporations Act by expanding the meaning of “acts violating laws and regulations” to include civil torts. This new interpretation became the legal foundation for dissolving the Unification Church. [See editor’s note 1 below]
Having opened the legal path toward dissolution, the Supreme Court has now completed the process by affirming the very outcome made possible by its own reinterpretation.
Concerns regarding judicial impartiality also remain unresolved.


As Bitter Winter reported, the Unification Church [See editor’s note 1 below] sought the recusal of Justice Masami Okino (沖野眞已) after it became known that she had participated in a seminar critical of the Church [See editor’s note 1 below].
At that seminar, speakers denounced the Unification Church [See editor’s note 1 below], endorsed the so-called “mind control” theory [See editor’s note 2 below], and portrayed the Church‘s activities as inherently malicious. According to the Church‘s recusal motion, Justice Okino herself made comments indicating that she had already formed opinions about the Church‘s nature and activities.
The Supreme Court rejected the recusal motion without explanation in a decision consisting of only two lines.
Justice Okino’s signature does not appear on the Supreme Court’s decision, and it remains unclear whether she participated in drafting it. Nevertheless, the mere fact that the recusal request was denied casts a shadow over the legitimacy of the Court’s final decision.
If the Court rejected the recusal request, however, why did she not sign the judgment?
The Supreme Court’s ruling brings the judicial proceedings concerning the dissolution order to a close. At the same time, however, many important issues remain unresolved.




The decision does not respond to concerns raised by four United Nations Special Rapporteurs [See editor’s note 3 below]. They warned that the Japanese government’s actions against the Unification Church [See editor’s note 1 below] relied upon an excessively vague concept of “public welfare” that is incompatible with Article 18 of the International Covenant on Civil and Political Rights (ICCPR).
Nor does the decision address its continued reliance on theories of “mental harm” based on the now-discredited concept of “brainwashing” [See editor’s note 4 below], or on standards such as “social acceptability”, which are inconsistent with international law.
It also fails to examine the dangers of using civil tort liability as grounds for dissolving religious organizations.
Nor does it consider what precedent this may establish for other minority religions.
Finally, it does not address the implications of allowing political pressure and media campaigns to influence the interpretation of legal principles designed to protect freedom of religion.
Believers will undoubtedly continue practicing their faith. They will do so, however, without their places of worship, without their assets, and without the legal protections and organizational stability upon which Japan’s religious corporations have long relied.
The Supreme Court insists that these are merely indirect consequences. Yet it is difficult to conclude that this characterization adequately reflects the profound changes brought about by the decision.
Japan has long presented itself to the international community as a democratic nation committed to pluralism and the rule of law. This case, however, raises questions about how firmly those commitments will be upheld when a religious minority becomes the target of political controversy.
The Supreme Court had an opportunity to reaffirm constitutional protections and restore balance to a process that had been criticized on numerous grounds. Instead, it chose simply to endorse the course adopted by the government and the lower courts, without confronting the fundamental concerns that had emerged throughout the proceedings.
The judgment has now been rendered. Its impact on religious freedom in Japan will become apparent only gradually over the years to come.
See also part 1: Ruling Leaves Serious Questions on Due Process
See also Dissolution Case: Pseudoscience Shaping Verdict
See also Brussels Press Conference Condemns Dissolution
See also The Hidden Story Japan Doesn’t Want You to Hear
See also Japanese Court Assumes the Role of Inquisitor
See also: Japan: The Political Origins of Smear Campaign
See also: This Is About More Than One Religion
See also Brainwashing Theory Returns Under New Names
See also: The Contradictions of the Dissolution Order
Featured image above: Dr. Massimo Introvigne speaking at an international conference in Bordeaux, France 14th June 2024. Photo: FOREF. Published with permission.
[Editor’s note 1: Although Massimo Introvigne uses the name “Unification Church” and also the word “church”, please be aware that the Unification Church in Japan in 2015 changed its name to Family Federation for World peace and Unification.]
[Editor’s note 2: 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.]
[Editor’s note 3: A Special Rapporteur (or Independent Expert) is an independent human rights expert appointed by the United Nations (UN) to provide reports or advice on human rights issues from either a thematic or country-specific perspective. These experts are selected by the UN Human Rights Council and operate independently of any government, playing a crucial role in monitoring the actions of sovereign nations and democratically elected governments.
Special Rapporteurs do not receive financial compensation from the United Nations for their work. However, they receive support from the Office of the United Nations High Commissioner for Human Rights and are often funded by charities and corporations. Annually, they convene in Geneva to discuss common issues, coordinate their efforts, and engage with various stakeholders, including states and civil society organizations.
These experts frequently conduct fact-finding missions to investigate human rights violation allegations in different countries. In addition to these missions, they regularly review complaints from alleged victims of human rights abuses. If a complaint is verified, they send an urgent letter or appeal to the concerned government. Even without a specific complaint, Special Rapporteurs can intervene on behalf of individuals or groups at their discretion.]

[Editor’s note 4: “Brainwashing” was a popular term that emerged during the early Cold War to explain why some prisoners of war and political detainees appeared to adopt beliefs favored by their captors. The idea suggested that powerful psychological techniques could erase a person’s existing beliefs and replace them with new ones against their will, almost like reprogramming a machine.
Over time, however, the concept was largely discarded by mainstream psychology and cognitive science as a scientific explanation of persuasion or belief change. Researchers found little evidence for such a process, that any special, unique process existed that could fundamentally override human autonomy and completely remake a person’s personality or convictions.
Studies in psychology, sociology, and psychiatry showed that belief change is usually gradual, variable, and dependent on many factors: social pressure, isolation, coercion, rewards, threats, conformity, identity, and existing motivations. People can certainly be influenced, manipulated, indoctrinated, or coerced, but there is no scientifically demonstrated mechanism that allows a person’s mind to be completely overwritten in the dramatic way implied by “brainwashing”.
The concept came under especially heavy criticism in the 1970s–1990s during debates about new religious movements – by anti-religious activists and others often called “cults”. Some experts testified that members had been brainwashed, while other scholars argued that the theory lacked clear definitions, reliable measurements, falsifiable predictions, and strong empirical support. Courts increasingly viewed brainwashing testimony skeptically because it often could not meet scientific standards of evidence.
A major problem was that “brainwashing” lacked a clear, measurable definition. Different writers used it to describe very different phenomena, from prisoner interrogation to religious conversion to participation in controversial groups. Because it could not be reliably operationalized or tested, it failed to meet basic scientific standards. Studies of prisoners of war and members of new religious movements showed that apparent ideological conversions were often temporary, strategic, situational, or reversible rather than evidence of a mysterious mind-control process.
By the 1970s and 1980s, many psychologists, sociologists, and legal scholars concluded that brainwashing functioned more as a cultural and political metaphor than as a validated scientific theory. Courts also became increasingly skeptical of expert testimony claiming that members of new religious movements had been “brainwashed”. Today, scholars generally prefer more specific concepts – such as persuasion, coercive control, social influence, indoctrination, obedience, and group dynamics – rather than assuming the existence of a mysterious power that can completely rewrite a person’s beliefs.]
Related to shadow of mind control myth: Lawfare: State Uses Legal System in War on Faith
More, related to shadow of mind control myth: Scholar Questions Secrecy in Dissolution Case
And more, related to shadow of mind control myth: Shocked Author: “Japan Ignores Basics of Justice”
Still more, related to shadow of mind control myth: Legal Inconsistencies A Blow to Democracy
Even more, related to shadow of mind control myth: Japan: Court Accused of Using Speculation
Also related to shadow of mind control myth: MEXT’s Legal Spin and “Dissolution at All Costs”
Also related to shadow of mind control myth: UN Report: Japan’s Lawfare Against Faith Minority
And also related to shadow of mind control myth: Protesting No Transparency in Closed-Door Trial
More, related to shadow of mind control myth: Dangerous Flaws in Dissolution Order Decried
Also related to shadow of mind control myth: “Lawyers Lying and Shaming Japan” for 50 Years
And also related to shadow of mind control myth: Japan Following the Way of China
And also related to shadow of mind control myth: Japan’s Dissolution Case Echoes China’s Playbook
More, related to shadow of mind control myth: Media/Legal Expert: Communism Behind Persecution
And more, related to shadow of mind control myth: Militant Lawyers Dictate Government Policy
More, related to shadow of mind control myth: Collusion to Rob Minority of Its Rights
And more, related to shadow of mind control myth: State and Media Creating “Today’s Non-Citizens”
Still more, related to shadow of mind control myth: Japan Copying China: State Seizure of Churches
And still more, related to shadow of mind control myth: 12 Religious Freedom NGOs Denouncing Japan
More, related to shadow of mind control myth: 4300 Abductions and Forcible Detentions
And more, related to shadow of mind control myth: Japan: Families Fear for Graves of Loved Ones
Yet more, related to shadow of mind control myth: Lawyers Manipulating, Coercing, Lying
Also related to shadow of mind control myth: Kishida Follows Anti-Family Federation Minister
Also related to shadow of mind control myth: Militant Lawyers Dictate Government Policy
Still more, related to shadow of mind control myth: Malicious One-Sided Government Source Selection
And still more, related to shadow of mind control myth: Japan Urged to Make U-Turn
And yet more, related to shadow of mind control myth: Dangerous Precedent to Crush Religions
Even more, related to shadow of mind control myth: Japan Following the Way of China
Yet more, related to shadow of mind control myth: Japanese Communists’ Final War
Still more, related to shadow of mind control myth: Political and Social Activism behind Oppression
Still more, related to shadow of mind control myth: Dissolution Case: Rule of Law on Trial 4th March







