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From Tort to Article 81: The Legal Path to Dissolving the Unification Church

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From Tort to Article 81: The Legal Path to Dissolving the Unification Church

This article records tradition as it has been passed down and reported. Its sources are not yet part of the atlas's verified catalogue.

Article 81 of Japan's Religious Corporations Act allows a court to dissolve a religious corporation that clearly and substantially harms public welfare. Before 2025, it had been used exactly twice: against Aum Shinrikyo after its 1995 sarin gas attack on the Tokyo subway, and on narrower grounds against Myokakuji temple. Both were criminal cases first. The Tokyo District Court's March 25, 2025 order against the Family Federation for World Peace and Unification, formerly the Unification Church, was the first to reach dissolution through civil tort findings alone, with no criminal conviction anywhere in the record.

The path there ran through Japan's ordinary civil courts, not a special tribunal. Individual followers and former followers had sued the organization over what Japanese courts call spiritual sales, a pattern of manipulative, sustained solicitation of donations, and had won at least 32 separate civil judgments recognizing the practice as tortious before the dissolution petition was ever filed. Those accumulated rulings became the evidentiary spine of the government's case: a decade-plus record of courts already finding the organization's conduct unlawful, one plaintiff at a time.

The petition itself came from Japan's education ministry, acting through the Agency for Cultural Affairs, filed October 13, 2023, a little over a year after the assassination of former Prime Minister Shinzo Abe exposed decades of ties between the church and ruling-party politicians and put the organization's conduct back under public and political scrutiny. The ministry's filing drew on roughly 5,000 documents and interviews with more than 170 people. When the Tokyo District Court ruled, it found the accumulated harm substantial enough to meet Article 81's public welfare standard on tort grounds alone, without waiting for, or requiring, a single criminal conviction.

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