Unification Church Dissolution in Japan: An In-Depth Analysis of a Wrong Decision. 1. “Spiritual Sales” and Criminal Cases

Although the decision does mention criminal verdicts against Church members (not the Church itself), they were not part of the argument for the dissolution.

By Massimo Introvigne

April 3, 2025

Article 1 of 5.

The Tokyo District Court. Credits.

On March 25, 2025, the Tokyo District Court granted the request by the Ministry of Education, Culture, Sports, Science and Technology (MEXT) to dissolve the Japanese branch of the Family Federation for World Peace and Unification, formerly known as the Unification Church and still often referred to by that name (“the Unification Church” or “the Church”). The request followed a campaign instigated by long-time opponents of the Church, particularly the anti-cult National Network of Lawyers Against Spiritual Sales, after former Prime Minister Shinzo Abe was assassinated in 2022. The assassin claimed that he wanted to punish Abe for his friendly attitude to the Church, of which his mother is a member. He reported she went bankrupt in 2002 because of her excessive donations to the Church. 

The assassin did not explain why he acted only twenty years after the bankruptcy. The fact that half of the donations were reimbursed after complaints by relatives was also not mentioned. There is conclusive and undisputed evidence that the National Network of Lawyers Against Spiritual Sales (“the Network”) was established in 1987 by a group of attorneys, most of whom were members of the Socialist or Communist parties, with the declared purpose of stopping the successful anti-Communist and pro-American campaigns of organizations connected with the Church.

The decision of the Tokyo District Court is biased, grounded on pseudo-scientific theories of mind control, and contradictory. It is, in one word, wrong, as I hope to demonstrate by analyzing the reasons it offers for dissolving the Church.

The decision notes that the Church was established as a religious corporation in 1964 and that (as is normal for all large religious organizations, which cannot subsist on faith only) includes among its statutory purposes to “conduct financial, operational, and business activities” needed to support its spiritual and social goals.

The case only concerns certain “financial activities,” i.e., soliciting donations, both monetary and through the sale of artifacts for a price exceeding their commercial value, which the court equates to donations. Although the public controversy after the Abe assassination has also focused on the education of second-generation believers, accused of being too strict and conservative, on the Church being a “cult” rather than a religion, and on allegedly disparaging Japan to advance the interests of South Korea, where it was founded and has its headquarters, none of these matters is discussed in the verdict. The dissolution is based on the illicit soliciting of donations only.

The court focuses on the so-called “spiritual sales.” This is an expression coined by the Network and its lawyers to further its politically motivated propaganda against the Church. The decision defines them as sales of artifacts such as miniature pagodas, seals, and others for exorbitant prices “taking advantage of people’s fears that misfortune will befall them due to the karma of their ancestors” if they do not buy the items. In other cases, the court says, monetary donations were solicited through the same strategy. The two cases—selling artifacts and collecting money—are not regarded by the court as substantially different and they are discussed together.

To justify a decision of dissolution the court had to answer nine questions positively. This series examines them one by one.

The first question is “Did the Church commit criminal acts?”

The court asks whether the criminal acts committed by individual Church believers or companies operated by believers could be regarded as “acts by the religious corporation” under Article 81 (1) (i) of the Religious Corporations Act. The “criminal acts” the court refers to were committed by the executives of four companies involved in the so-called “spiritual sales.” Note that the verdict discusses these criminal cases, but they are not part of the argument for the dissolution. It is thus unclear why the verdict mentions them and spends some paragraphs to assert that they were “acts of the religious corporation.” Perhaps these pages’ aim is just to convey the idea that the Church is a “suspicious” organization.

Spiritual sales”: items Japanese members of the Unification Church (rather than the Church itself) were accused of selling at excessive prices claiming they would bring good luck.

The court mentions criminal decisions by the Okinawa Summary Court against three defendants, the manager and two employees of a seal shop called Tenjudo (2007); by the Niigata Summary Court against three representatives of Hokugen Co. Ltd., whose business was selling devotional Buddhist items (2008); by the Fukuoka Summary Court against a salesperson working for Sanjust Fukuoka Y.K., who had been active in door-to-door sales of craft items and semi-precious stones (2009); and of the Tokyo District Court against two executives of Shinsei Ltd., whose business was to sell seals and other items. The latter decision was the only one imposing, in addition to fines, prison sentences, of two years for the company’s director, and of one year and six months for the sales manager, both with a four-year probation.

In addition, the court discusses at length the activities of a company incorporated in 1971 by Unification Church devotees as Kosei Shoji Co., Ltd., which later changed its name into Sekai no Shiawase Co., Ltd. and then to Happy World Co., Ltd. (“Happy World”). Its business was to sell ginseng products, marble vases, pagodas, and seals. Although there were no criminal decisions against Happy World executives, the company is identified by the court as the main culprit for the “spiritual sales.”

It is true that Happy World engaged in aggressive and objectionable practices to sell its products. This is also acknowledged by scholars who are members of the Unification Church such as Michael L. Mickler in his book “The Unification Church Movement” (Cambridge: Cambridge University Press, 2022, p. 26). The question the Tokyo District Court examines, however, is whether the activities of Happy World and of the four companies whose representatives were sanctioned by criminal courts were “acts by the religious corporation,” i.e., acts by the Church.

To suggest that the question may be answered in the positive, as it did, the court had to distinguish the case law of Japan’s Supreme Court. In its 1996 ruling on the case of Aum Shinrikyo, the new religious movement responsible for the deadly terrorist sarin gas attack against the Tokyo subway in 1995, the Supreme Court stated that only criminal decisions against “executives and senior officers” of a religious corporation may be regarded as concerning “acts by the religious corporation” in a dissolution case. The Tokyo District Court argues that this and similar lower court statements were only “based on the specific facts of that case” (Aum Shinrikyo) and are not applicable to the Unification Church. 

The argument is, however, not persuasive. The court tries to support it by reporting that Happy World executives were praised by Japanese Unification Church leaders in speeches and articles in Church magazines, one of which also published “greetings” by the then Happy World President, but this does not prove that they were active as representatives of the Unification Church. At any rate, those found guilty in criminal cases did not represent Happy World but different companies. 

Obviously, not all crimes committed by members of a religious organization can be attributed to the organization and used as a ground to dissolve it. Otherwise, cases involving pedophile priests should be ground to liquidate the Roman Catholic Church. 

Additionally, the cases involving Happy World and other companies date back to more than twenty years ago. The decision acknowledges that the Unification Church did try to rein in Happy World as early as 1987. “After that,” the decision reports, “Happy World reported in writing to the then Ministry of Health and Welfare, etc., that ‘our affiliated companies were thoroughly notified at the end of March 1987 that any sales of goods that could be misunderstood as so-called «spiritual sales» were prohibited’, and also sent documents to interested parties reporting on the details of these events, etc., and from around 1987 the number of damage reports began to decrease.” Eventually, Happy World ceased its operations altogether. 

Lawyer Hiroshi Yamaguchi, one of the founders of the National Network of Lawyer Against Spiritual Sales. Screenshot.

Another argument supporting the conclusion that the activities of those who were found guilty in criminal judgements were not Church activities is that they included the sales of Buddhist altars and prayer beads. The Unification Church is a Christian new religious movement, although mainline Christians may question its orthodoxy. Its believers do not use Buddhist altars or prayer beads, which is not inconsistent with the fact that individual members were active in selling them as their private commercial activity.

We can thus conclude that there were no criminal decisions for “acts by the religious corporation.” Individual believers were sentenced for acts they did not commit on behalf of the Church. It would be difficult to find a religious organization with hundreds of thousands of members where no devotees have ever been found guilty in a criminal trial. There is no evidence that the number of these criminal verdicts was higher for Unification Church members with respect to devotees of other large religions. 

It is important, however, to reiterate that, as mentioned earlier, in the section discussing the legal violations constituting grounds for dissolution, the court exclusively examines past cases of civil torts under the Civil Code. It does not discuss at all cases involving individuals who were convicted in the past for commercial activities. These criminal cases are only mentioned in the background description.

The criminal convictions were not treated as part of the reasoning to determine the existence of grounds for dissolution. It may be inferred that the judgment introduced such cases to suggest that the organization is “anti-social,” although this is not stated explicitly.

Source: bitterwinter.org