When Giving Becomes Grounds for Dissolution

Could other faiths be next? A human rights lawyer argues that voluntarily giving donations for religious and humanitarian work became grounds for dissolution

When Japan’s Supreme Court finalized the dissolution of the Family Federation for World Peace and Unification (formerly the Unification Church) on 22^nd June 2026, the decision immediately sparked debate far beyond Japan. While government officials and critics of the movement described the ruling as a necessary response to controversial fundraising practices, others viewed it as a watershed moment for religious liberty. Among the strongest critics was international human rights lawyer Patricia Duval, who argued that the judgment represents a dangerous expansion of state power over religious organizations.

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In an article in Bitter Winter, an online magazine specializing in religious liberty and human rights, Paris-based international human rights lawyer Patricia Duval contends that the Supreme Court’s decision creates an unprecedented legal precedent. In her view, the Court did not dissolve the religious corporation because its leaders committed criminal acts or because it engaged in violence or fraud. Instead, she argues, the Court accepted the government’s position that the organization should lose its legal status because its members collected donations that funded religious and humanitarian work around the world.

Duval believes this reasoning has implications extending well beyond one religious movement. If governments can dissolve a religious body because they disapprove of how believers voluntarily donate money in support of their faith and charitable missions, she argues, other religious organizations could one day face similar treatment. She also criticizes the Court for minimizing the practical consequences of dissolution. Although the judges acknowledged that believers would lose their churches and meeting places, they characterized these hardships simply as indirect consequences rather than violations of religious freedom. Duval rejects that distinction, maintaining that confiscating a religious organization‘s assets while insisting believers remain free to worship is both unrealistic and legally inconsistent.

Dissolved for Supporting Humanitarian Work?

Patricia Duval argues that Japan has taken an extraordinary step by dissolving the legal entity of the Family Federation for World Peace and Unification. According to her, this may be the first time in a democratic country that a religious organization has lost its legal status largely because it raised money to support humanitarian and missionary activities around the world.

The Supreme Court’s decision upheld the earlier ruling of the Tokyo High Court, meaning that the religious corporation would lose its legal identity and its assets could be liquidated. According to Duval, the religious organization has around 250 churches and hundreds of thousands of members in Japan.

Duval criticizes the Supreme Court for giving only a brief response to the arguments presented by the lawyers representing the Family Federation. She says the Court largely ignored detailed claims that the dissolution violates fundamental freedoms, including freedom of religion and freedom of association.

The Court stated that the dissolution merely removes the legal status of the religious organization. According to the judges, it does not legally prohibit members from practicing their religion.

However, the Court also acknowledged that losing all of the Federation‘s buildings and property would create obstacles for believers. It described these difficulties as indirect practical consequences rather than direct legal restrictions.

Duval strongly disagrees with this reasoning. She argues that taking away churches, meeting halls, and other property makes it much harder for believers to practice their faith together. Calling these losses “indirect” does not lessen their direct impact on religious life.

The Court further concluded that members of the Family Federation had, over many years, collected donations in ways that amounted to civil wrongdoing under Japanese law. These activities, it said, harmed the public welfare.

According to the judgment, the fundraising was carried out under the organized guidance by the religious organization. The Court referred to the founder‘s teaching that Japanese believers should make financial sacrifices to support religious and humanitarian work in other countries. On that basis, it found that the Family Federation itself had encouraged the fundraising.

Duval emphasizes that the government never proved that the religious organization committed criminal offenses. No leaders were prosecuted for crimes such as fraud or extortion. Instead, the government relied on civil court judgments involving former members in order to justify dissolving the religious corporation.

She also notes that the donations were not intended for personal enrichment or commercial profit. According to information presented during the case, the Family Federation and related organizations operate in nearly 200 countries. Donations collected in Japan helped finance outreach work as well as schools, women’s programs, and other charitable projects in Asia, Africa, Europe, Latin America, and elsewhere.

Duval argues that the Court effectively treated these international activities as evidence against the Federation. Because Japanese believers were making unusually large donations, courts concluded that they must have been psychologically manipulated into doing so.

She rejects this conclusion. In her view, many former members who later challenged their donations had previously been subjected to forced confinement and so-called deprogramming or faith-breaking by opponents of the religious organization. For decades, she writes, thousands of members were abducted, confined, and pressured to abandon their faith. She argues that the dissolution order is the final result of this long campaign against the movement.

Duval says the ruling sends a troubling message. It suggests that voluntarily giving substantial financial support to religious and humanitarian causes can itself become grounds for dissolving a religious organization if authorities believe such giving is socially unacceptable.

She finds this especially unfortunate because, in her opinion, the Family Federation has supported humanitarian projects that have benefited disadvantaged communities around the world. She writes that volunteers in African countries and elsewhere are now facing the difficult task of explaining that schools, women’s centers, and other projects have lost financial support because of the Japanese court decision.

Finally, Duval criticizes what she sees as a contradiction in the Supreme Court’s reasoning. The Court said that members remain free to continue practicing their religion as individuals or as an informal group. Yet it also justified dissolution by saying there was a risk that the religious organization would continue encouraging donations in the future.

According to Duval, these two conclusions cannot easily be reconciled. If believers continue following the same religious teachings, she argues, any new organization they establish could again be accused of engaging in the same fundraising activities and could once more face dissolution.

For Duval, this reveals what she considers the central flaw in the decision. She believes the ruling ultimately targets not simply the legal corporation but the religious beliefs and practices themselves. In her view, that amounts to an infringement of the rights to freedom of religion, peaceful assembly, and association, rights that democratic societies are expected to protect for all faith communities.

See also How Media Narrative Was Changed to Attack Faith

See also: The Anatomy of Japan’s Hostile Media Campaign

See also When Religious Intolerance Turns Violent

See also Police Trust Shattered After Forced Confinement

See also Liquidation Takes Psychological Toll on Members

Text: Knut Holdhus, editor

Featured image above: Attorney Patricia Duval, member of the Paris Bar Association, specializing in international human rights law. Earned a degree in public law from Sorbonne University. Has defended the rights of religious and faith minorities both in France and internationally, including at the European Court of Human Rights (ECtHR), the Council of Europe (CE), the Organization for Security and Co-operation in Europe (OSCE), the European Union (EU), and the United Nations. Author of numerous academic papers on religion and freedom of belief. Here, speaking at the UN Office in Geneva 16th June 2025. Edited screenshot from UPF video.

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