Cultic Studies Journal, Vol. 12, No. 1, 1995, page 59
Following PB‟s attendance of a lecture course taught through the use of videos concerning
the teachings of the UC, PB was called to a private room of the Sunflower Society where in
addition to PB, UCZ and Gondo were also present. Here, PB was asked by Gondo to speak
about her (PB‟s) personal history and about her (PB‟s) personal problems.
PB was then told by Gondo, who spoke in a very sharp and strong voice, that her (PB‟s)
personal problems and the death of her (PB‟s) husband by common-law marriage were due
to the karma of her grandmother on her mother‟s side of the family. Also, at this same
time, PB was told by Gondo about her (PB‟s) deceased husband‟s wishes (for PB to donate
money) and about (PB‟s) ancestral karma --the latter term suggesting a vague concept of
indeterminate existence. Gondo then demanded that PB donate money in order to atone for
the above karma. Shortly thereafter, PB was told by Gondo that (among other things) if she
(PB) did not comply with the above demand, she would not be saved.
Hence, as a result of (1) being solicited relentlessly over a long period of time, and thus, (2)
being trapped in a situation where she was being forced to comply immediately with the
above demand, (3) being driven into a state of despair, (4) being made to suffer reductions
in her normal emotional and intellectual stability necessary for her to make competent
decisions, PB finally consented to donate the exorbitant sum of 2,100,000 yen.
Similar to the case of PA, the amount of PB‟s donation was determined from the very
beginning. In addition, other UC members demanded that PB yield further cash
disbursements subsequent to PB‟s above monetary donation. However, and again, as was
similar in PA‟s case, PB was strictly forbidden by Gondo et al. to say anything to anyone
concerning her donated monies.
All the above statements have been recognized as true and valid.
Therefore, based on the objectives, methods, and results of the acts of solicitation for the
procurement of monetary donations of 2,100,000 yen against PB by UC members Gondo et
al, and based on the similarities of the above same acts as have been shown in the cases of
both PA and PB, it is impossible to conclude that these same such acts were entirely socially
appropriate acts.
Accordingly, the above acts of solicitation for the procurement of monetary donations which
were established through a conspiracy of Gondo et al. must be stated as unlawful acts in
accordance with Article 709 of Japanese Civil Law.
Part III: Court decision on the liability for unlawful acts committed by the UC
Section A
In accordance with Article 715 of Japanese Civil Law:
First, a religious corporate body which is necessarily construed to be a nonprofit
organization. When members of this religious organization cause damages to a third party,
the same members are judged to be of employee status. Accordingly, persons of employee
status are understood to function as bodies between the religious organization and the
members of the religious organization. Hence, when such members of employee status
commit damage-causing acts for the purpose of work or business (e.g., religious activities)
of the religious organization, it is appropriate to construe that the religious organization
carries the burden of employee liability for such damages incurred.
Grounds for this conclusion exist as follows: (1) No logical reasons exist which should
exclude Article 715 (Japanese Civil Law) from being applied to religious organizations, and
(2) No logical reasons exist to exclude provisions stated in Article 11 of the Religious
Corporate Body Law, which stipulates that a religious organization is liable for third party
Following PB‟s attendance of a lecture course taught through the use of videos concerning
the teachings of the UC, PB was called to a private room of the Sunflower Society where in
addition to PB, UCZ and Gondo were also present. Here, PB was asked by Gondo to speak
about her (PB‟s) personal history and about her (PB‟s) personal problems.
PB was then told by Gondo, who spoke in a very sharp and strong voice, that her (PB‟s)
personal problems and the death of her (PB‟s) husband by common-law marriage were due
to the karma of her grandmother on her mother‟s side of the family. Also, at this same
time, PB was told by Gondo about her (PB‟s) deceased husband‟s wishes (for PB to donate
money) and about (PB‟s) ancestral karma --the latter term suggesting a vague concept of
indeterminate existence. Gondo then demanded that PB donate money in order to atone for
the above karma. Shortly thereafter, PB was told by Gondo that (among other things) if she
(PB) did not comply with the above demand, she would not be saved.
Hence, as a result of (1) being solicited relentlessly over a long period of time, and thus, (2)
being trapped in a situation where she was being forced to comply immediately with the
above demand, (3) being driven into a state of despair, (4) being made to suffer reductions
in her normal emotional and intellectual stability necessary for her to make competent
decisions, PB finally consented to donate the exorbitant sum of 2,100,000 yen.
Similar to the case of PA, the amount of PB‟s donation was determined from the very
beginning. In addition, other UC members demanded that PB yield further cash
disbursements subsequent to PB‟s above monetary donation. However, and again, as was
similar in PA‟s case, PB was strictly forbidden by Gondo et al. to say anything to anyone
concerning her donated monies.
All the above statements have been recognized as true and valid.
Therefore, based on the objectives, methods, and results of the acts of solicitation for the
procurement of monetary donations of 2,100,000 yen against PB by UC members Gondo et
al, and based on the similarities of the above same acts as have been shown in the cases of
both PA and PB, it is impossible to conclude that these same such acts were entirely socially
appropriate acts.
Accordingly, the above acts of solicitation for the procurement of monetary donations which
were established through a conspiracy of Gondo et al. must be stated as unlawful acts in
accordance with Article 709 of Japanese Civil Law.
Part III: Court decision on the liability for unlawful acts committed by the UC
Section A
In accordance with Article 715 of Japanese Civil Law:
First, a religious corporate body which is necessarily construed to be a nonprofit
organization. When members of this religious organization cause damages to a third party,
the same members are judged to be of employee status. Accordingly, persons of employee
status are understood to function as bodies between the religious organization and the
members of the religious organization. Hence, when such members of employee status
commit damage-causing acts for the purpose of work or business (e.g., religious activities)
of the religious organization, it is appropriate to construe that the religious organization
carries the burden of employee liability for such damages incurred.
Grounds for this conclusion exist as follows: (1) No logical reasons exist which should
exclude Article 715 (Japanese Civil Law) from being applied to religious organizations, and
(2) No logical reasons exist to exclude provisions stated in Article 11 of the Religious
Corporate Body Law, which stipulates that a religious organization is liable for third party
