54 International Journal of Cultic Studies ■ Vol. 10, 2019
decision of the High Court in 1983, allowing the
Church religious institutional exemption from
payroll tax in the state of Victoria.8 Scientology
was able to leverage its early victories into later
successes. These successes included the repeal
(between 1973 and 1982) of legislation passed
earlier in three Australian states (between 1965
and 1968) aimed at suppressing the group,9 and
access to other privileges generally available to
the religious sector, including charitable status
for the advancement of religion.10
However, Scientology’s inability to sustain
significant numbers of adherents, reflected in
official government figures, seems a realistic
indication of its failure to translate these hard-
won successes into genuine organizational
flourishing. Nearly twenty years after finally
prevailing, in 1982, over attempted state
government suppression,11 and Scientology’s
1983 victory in the High Court, membership
figures had stalled in Australia. In response to
the optional census question on religious
affiliation in the 2001 census, a mere 2,032
Scientologists indicated their religious
allegiance. This figure increased marginally to
2,513 in the 2006 census. But in the Australian
8 Church of the New Faith v. Commissioner of Pay-Roll Tax
(Victoria), CLR 120, Caberrra, 27 October 1983. J. T. Richardson
sees the decision as “quite thorough and impressive,” noting “it is
cited in case law in other countries” (idem, Scientology in court: a
look at some major cases from various nations, in J.R. Lewis [ed.],
Scientology, Oxford, 2009, p. 285). However, the decision should
be treated with caution. For a critical appraisal, see S. Mutch,
From “Cult” to “Religion”: Claims for Religious Freedom
Enabled the “Cult” of Scientology to Overcome Government
suppression, Win :egal recognition and Gain Tax Exempt Status As
a Religious Institution in Australia, Graduate Diploma in Arts,
Sydney, 2000 idem, Cults, Religion and Public Policy: A
Comparison of Official Responses to Scientology in Australia and
the United Kingdom, PhD thesis, Sydney, 2004.
9 These legislative repeals were also facilitated by changes in
government, and some acknowledgement that the laws were not
particularly effective.
10 The Australian Business Register reveals that Scientology
(through various entities) is registered as a religious charity,
enjoying GST concessions and income tax exempt concessions,
with Deductible Gift Recipient (DGR) status for its church
building fund (Australian Government, Australian Business
Register, https://abr.business.gov.au/
SearchByName.aspx?SearchText=Scientology+ [19 June 2015])
see also Australian Charities and Not-for-profits Commission,
ACNC register, http://www.acnc.gov.au/ACNC/FindCharity/
QuickSearch/ACNC/OnlineProcessors/Online_register/Search_the
_Register.aspx?noleft=1 (19 June 2015).
11 With the repeal of the anti-Scientology sections of the Victorian
state government’s Psychological Practices Act 1965.
census held in 2011, the figure had dropped back
to 2,163—statistically a still birth and well
below what might once have been anticipated.12
The latest figures for the 2016 Australian Census
reveals a further decline to 1,685.13
In an organization where growth is important,
some possible explanations for poor census
figures have been offered. Scientology has
suggested that the official census figures are not
reflective of its true membership base, and some
disparity between the membership claims of the
organization and official government numbers
can be noted. In 2007, in an article on building
extensions to Scientology headquarters in
Sydney, it was reported that: “Mr [James]
Packer, Australia’s richest man, was introduced
to the church by [celebrity Tom] Cruise and will
soon be married in a Scientology service in
France. Scientology publicists say he is just one
of many people joining the church founded by
science-fiction writer L. Ron Hubbard. The
church claims to have 250,000 followers in
Australia, even though in the 2001 census only
2,000 gave their religion as Scientology. ‘Many
people come in and do Scientology courses and
still think of themselves as Christians’, Mrs
Dunstan [president of Scientology Australia]
said. ‘We are expanding rapidly and want to
bring the building up to the standard it needs to
be to present Scientology in its proper light.’”14
12 In 1988, I. Gillman noted that “the active membership across
Australia probably stands at about 2,000, with some thousands of
others involved to varying degrees” (I. Gillman, Many Faiths, One
Nation: A Guide to the Major Faiths and Denominations in
Australia, Sydney, 1988, p. 368) the Australian Bureau of
Statistics Census for 2001 revealed that 2,032 Australians claimed
the Church of Scientology as their religion in the optional question
(S. Mutch, Cults, Religion and Public Policy, p. 27) by the 2006
Census, it had marginally improved to 2,513 (idem, “Scientologists
in Australia,” in J. Jupp [ed.], The Encyclopedia of Religion in
Australia, Cambridge. 2009, p. 561) and B. Doherty reports its
“small demographic profile and a membership decline of 13.5
percent from 2006–2011” to 2,163 members (idem, “Sensational
Scientology! The Church of Scientology and Australian tabloid
television,” Nova Religio: The Journal of Alternative and
Emergent Religions, February 2014, vol. 17, no. 3, p. 44).
Australian censuses are taken every five years.
13 Australian Bureau of Statistics, 2016 Census of Population and
Housing, https://guest.censusdata.abs.gov.au/webapi/jsf/
login.xhtml (12 August 2017).
14 F. Walker, “Scientologists want to raise the roof,” The Sydney
Morning Herald, 6 May 2007, http://www.smh.com.au/
news/national/scientology-on-the-up/2007/05/05/
1177788468873.html A more conservative assessment, over 30

International Journal of Cultic Studies ■ Vol. 10, 2019 55
This deflection, to celebrity gossip and dual faith
adherence, and counterpoint that the
organization was in fact rapidly expanding,15 is
the type of coverage that Scientology could only
welcome.16 The article is certainly reflective of
skilful public relations interaction with the
media.17 However, Scientology’s membership
claims in Australia, as elsewhere, can be taken
with a grain of salt.18
Other explanations seeking to explain the poor
census figures, which might inculcate some
sympathy for Scientology, include: the possibly
damaging effects of government suppression,
discrimination against members of the group,
resistance common to transplanted religion, and
some allegedly unfair, damaging media reports.
Other plausible explanations, but detrimental to
the standing and ambitions of Scientology,
include complaints of persistent anti-social and
internally harmful behaviour, and the possibility
of genuine consumer resistance to the
Scientology brand. The latter might be due to
aspects pertaining to its core beliefs, the
marketing of its spiritual products, and the
controversial reputation of its founder.
Government Suppression
For an historical perspective, we can note the
record of governmental opposition to
Scientology in its formative years, which
arguably may have stunted its growth. In 1965
and 1968, three Australian state governments
years previously, noted that the Church was operating in
Melbourne, Perth, Adelaide and Sydney and that “although 20,000
members have passed through the books, officials agree that 3,000
would be close to the actual number of practicing brethren” (J.
May, “Scientology’s new reverence,” Nation Review, 28 April–3
May 1973, p. 845).
15 Perhaps also relying on a nice distinction between the human
and structural components of “organization.”
16 The article contained a picture of a smiling, photogenic
Scientology president outside HQ. The only note of mild discord
was at the end of the article, with the pastor of the Church next
door expressing some possible concern about the proposed
expansion.
17 Note the mention of Scientology publicists.
18 Citing membership claims worldwide and in Britain, D.V.
Barrett notes that “these numbers include people who have only
had one or two introductory auditing sessions [and are] cumulative
rather than current. … The Church does not appear to have clear
membership figures itself” (idem, The New Believers: a Survey of
Sects, Cults and Alternative Religions, London, 2001, p. 447).
enacted draconian legislation aimed at
suppressing the nascent organization.
In Victoria, the Psychological Practices Act
1965 contained provisions aimed indirectly at
Scientology through the regulation of
psychology. The act also attacked the
organization directly, banning the E-meter or
galvanometer, banning the practice or
application of Scientology for a fee or reward
and banning all advertising relating to the
teaching of Scientology (whether for reward or
not). It provided for confiscation of Scientology
records by the Attorney General and for the
imposition of substantial fines (and even
imprisonment for two years) for teaching
Scientology for reward. As soon as the
legislation was proclaimed, Scientology
headquarters was raided, and 4,000 personal
files on clients were seized, and signs
advertising free introductory lectures were
reportedly removed.19
The governments of South Australia and
Western Australia followed suit, enacting the
Scientology (Prohibition) Act 1968 (SA) and the
Scientology Act 1968 (WA). The purpose of the
South Australian legislation was to “prohibit the
teaching, practice or application of the system of
study known as Scientology”. Its provisions
closely reflected the anti-Scientology provisions
of the Victorian act, except that it de-coupled the
provisions relating to psychology, opting to deal
with that aspect separately. The Western
Australian legislation was similar, except that it
also provided penalties for the “practice” of
Scientology, including fines and imprisonment
for one year.20 At the beginning of 1969, raids
were conducted by police in both states and
material seized.21 In addition, arrests were made
in Western Australia under the “practice”
provisions.22 However, in 1969, after a failed
prosecution of the Hubbard Association of
19 “Scientology files seized in raid,” The Sydney Morning Herald,
22 December 1965, p. 1 “Hunt for hidden Scientology files,” The
Australian, 23 December 1965, p. 3. For a full account, see S.
Mutch, Cults, Religion and Public Policy, p. 78–93.
20 See S. Mutch, Cults, Religion and Public Policy, p. 94–136.
21 “Police seize Scientology material,” The West Australian, 29
January 1969, p. 15.
22 “15 charged in Wa’s first Scientology hearing,” The Sun, 28
March 1969.