How Consumer Law in Japan Shapes Religion: “Spiritual Sales” as a Legal Category

Abstract: A core issue for media outlets and politicians since the assassination of Abe Shinzō has been monetary transactions between religious organizations and their current or former members. Anxieties surrounding religion’s role in the public sphere have informed legal arguments about consumer issues. A category of fraud called “spiritual sales” has become a particular concern. In this article, I describe how interpretations of consumer law have been instrumental in dealing with spiritual sales and I discuss reasons why problematic consumption practices associated with religions that have attracted intense criticism have led the Japanese government to comprehensively revise regulatory protections as they reassess consumer vulnerabilities.

Keywords: Law, Consumer affairs, Spiritual sales, Unification Church, Religion

Money has been at the center of accusations, debates, and legal responses that followed the assassination of former Prime Minister Abe Shinzō on 8 July 2022. The main motive for the murder immediately reported in the news was financial destitution experienced by the assassin Yamagami Tetsuya (b.1980) and his siblings after their mother joined the Unification Church (hereafter UC), a religious organization to which Abe maintained connections. Soon after the shooting, journalists reported that Yamagami’s mother, who had been a member of the UC since the 1990s, had donated over 100 million yen to the group, forcing her to declare bankruptcy in 2002 (Asahi 2022a). The church retorted that by the mid-2010s the organization had returned 50 million yen to the family (Asahi 2022b). However, Yamagami’s uncle testified that Tetsuya and his siblings endured a very difficult childhood due to continuous neglect and a lack of money to cover their most basic needs (Asahi 2022c).

Ideological connections between Abe’s Liberal Democratic Party and the Unification Church have attracted attention since July 2022 (Asahi 2022d; see also Saitō 2024), as have testimonies by those raised in religious groups other than the UC that have been accused of imposing hardships on children raised in their communities (Asahi Shinbun 2022e). Though media and public attention have focused primarily on these matters, legal responses by the Japanese government to the Unification Church have mainly targeted regulation of monetary transactions. In this article, I argue that attention to financial malfeasance and lawsuits demanding compensation for transactions that are perceived as forced donations to the UC have been instrumental in shaping ways “religion” is interpreted through legislation and political discourse. Although there has been much discussion of court cases concerned with the separation of religion and state in Japan (see Larsson 2020 for a recent analysis), financial transactions have also played a significant role in understandings of religion in Japanese society. Legal initiatives framed as consumer protection issues that played out in Japanese courts from the 1980s were brought to light by the murder of Abe Shinzō. Understanding the backstory of legal wrangling over consumer affairs occasioned by the UC’s exploitative monetary demands is vital to understanding why it took a relatively quick one year and three months following the assassination for the Japanese government to call for the legal dissolution of the Unification Church, even though it was not directly involved in the violent event of July 2022.

In this article, I argue that a legal emphasis on proper uses of money and consumer contracts in lieu of directly addressing religion’s role in the public sphere reveals anxieties about religion that prevail in Japan today. I make my argument in four parts. In the first section, I examine updates since July 2022 to laws and regulations concerning consumer protection, shedding light thereby on how transactions designated as “spiritual sales” carried out with the UC have been framed as bad consumption practices. In the second section, I describe what the adjective “spiritual” implies by considering court judgements that implicate the UC. Judges, lawyers, and legislators have treated spiritual sales as not related directly to religious belief, focusing instead on perceived problems that actions associated with widely criticized individuals and groups provoke in public spaces. I proceed in the third section to describe how illegality is proven in a specific case concerning the UC. I conclude in the fourth section with an analysis of a “spiritual sales” clause in the Consumer Contract Act that shows how, in their attempts to avoid discriminating against religion while they tweak regulatory interventions to target contentious consumer issues, lawyers and legislators have ended up defining “religion” based on consumer ethics. I conclude by taking up the most recent debates regarding consumer protection to show the lasting impact of spiritual sales on Japanese consumer legislation.

Religion in Japan’s Public Sphere After July 2022

On 12 July 2022, in response to motives professed by Yamagami, the National Network of Lawyers Against Spiritual Sales (hereafter the National Network) released a statement (StopReikan 2022) and held a press conference to draw attention to spiritual sales tactics the UC had perpetrated for over thirty-five years. The lawyers produced documents for 34,537 consultations since 1987 regarding money lost to the UC, amounting to a total of approximately 123.7 billion yen (Asahi 2022f). By 21 July, the Constitutional Democratic Party of Japan and the Japanese Communist Party set up control units to deal with damage caused by the UC and called on lawyers from the National Network for further information on issues regarding donations to the church (Asahi 2022g). On 26 July, Kitō Masaki, one of the lawyers in the National Network and author of The Definitive Guide to Mind Control (Kitō 2017) and Cult Religions (Kitō 2022), called for a non-partisan investigative committee, drawing attention to significant financial damage perpetrated by the UC (Asahi 2022h). On 12 August, Kōno Tarō, newly appointed as Minister for Digital Transformation, announced that he would establish a committee within the Consumer Affairs Agency to discuss “how to respond to spiritual sales that stir up anxiety and induce the purchase of expensive products”¹ (Asahi 2022i).

The term reikan shōhō, or “spiritual sales,” the National Network’s translation now generally adopted in Japan, refers to a method that belongs to a larger category of “malicious sales” (akushitsu or akutoku shōhō), in which a consumer is duped into paying more than a reasonable cost for an object or service. The Tokyo Metropolitan Police Department defines the term as “a commercial method of selling mere jars, seals, and ornaments at unreasonably high prices by making them seem as if they have supernatural spiritual powers” (TMPD 2016). One might be surprised to see “jars” and “seals” given as examples here, but this definition reflects how the term originated in the mid-1980s to describe the sales of these objects by individuals and companies suspected of working for the Unification Church. Lawyers in the National Network, which was formed in the late 1980s specifically to deal with this issue, have argued that these sales were employed by the Church to recruit new members and put pressure on existing adherents to donate their savings to the organization. Legal debates surrounding spiritual sales that surged after the Abe murder are contiguous with this decades-long history of legal activism against the Unification Church. For the National Network, spiritual sales primarily concern consumer responsibility.² At the same time, these debates also reinterpret religion.

Following Kōno’s announcement regarding regulations of spiritual sales, an eight-person committee composed of scholars, lawyers, and consumer affairs consultants met at the Consumer Affairs Agency seven times between 29 August and 13 October and produced a final report on 17 October 2022.³ Based on that report, a new law on the Prevention of Unfair Solicitation of Donations by Juristic Persons (or Corporations) was drafted, voted for in early December 2022, and fully enacted by the Japanese Diet on 1 June 2023 — a speed rarely seen in the Japanese parliament.⁴ The new law incorporated most of the report’s suggestions. It prohibits corporations (including religious corporations, such as the UC) from soliciting funds through coercion or threats, or by connecting donations to spiritual salvation. It allows members, non-member donors, and their families to seek the return of money solicited under unfair circumstances. And it stipulates that such donations can be canceled up to ten years after the donation and that parties found guilty under the law can face a maximum one-year prison sentence, a fine of up to one million yen, or both.

Reporting on the new law at the end of November 2022 pointed to contention between rival political parties that clashed over whether to ban donations based only on the actions of the organization or to factor in the mental state of victims. Opposition lawmakers wanted the concept of “mind control” to be included in the new law, but the Liberal Democratic Party and Komeito, the two parties that make up Japan’s governing coalition at the national level, were concerned that “it would be hard for a third party to judge an individual’s state of mind and whether or not they were manipulated” (Takahara 2022). Money and the state of the mind of the consumer remained primary concerns regarding this law enacted to deal with sales and donations associated with religious groups.

Concern with consumer protection is also evident in amendments to existing laws that protect against solicitations for large donations, such as those made by Yamagami’s mother. Prior to July 2022, the Consumer Contract Law, which protects consumers from various illicit types of sales, had already included a clause allowing consumers to rescind a contract if they felt that they had conducted a transaction out of fear induced by a person claiming “spiritual abilities” (reikan). An amendment made in late 2022 lengthened the time that a consumer is allowed to file a formal complaint, from one to three years after they become aware of the problem, and from five to ten years after they entered into the contract. A law regulating the National Consumer Affairs Center of Japan was updated at the same time to quicken the pace at which consumer complaints are processed and to publicize names of businesses deemed particularly harmful.⁵ While they did not specifically target religious groups, legal responses enacted during public outcry about the Unification Church focused on strengthening ways consumers can seek the refund of money lost to transactions that are against their interests or detrimental to their well-being.

Other government agencies were involved in these legal initiatives. The Ministry of Justice (MoJ) held four liaison meetings (18 August 2022, 30 September 2022, 10 November 2022, and 31 October 2023) to exchange information and coordinate activities between the MoJ and other ministries and agencies, such as the Cabinet Office, the National Police Agency, the Consumer Affairs Agency, and others.⁶ A key aspect of those meetings was coordinating helplines (taisaku daiyaru) to gather information on the number and variety of issues associated with the UC.⁷ Since 14 November 2022, a toll-free number dedicated to spiritual sales has gathered complaints and guided people to relevant consultation services established by government and local agencies.⁸ According to data published by the Japan Legal Support Center, which runs the call center, by 31 July 2024 the line had received 9,248 calls.⁹ Twenty percent (1,821) of these calls concerned the UC, with fifty-five percent (1,036) of those complaints being specifically about money troubles experienced by current (11%) or former members (27%) of the UC. The Center’s statistics do not mention caller concerns with religions other than the UC. Most consultations pertaining to the UC (1095 calls) were directed either to the National Network of Lawyers Against Spiritual Sales or to the Association of Lawyers from Across Japan for the Victims of the Unification Church,¹⁰ which was formed on 24 November 2022. In their notice to the UC (dated 14 December 2023), this association demanded more than 4 billion yen in compensation for approximately 120 victims (Asahi 2023b).¹¹

Financial complaints were, in other words, assumed to be a spiritual sales problem. Consultations with government agencies thus forged a conceptual link between spiritual sales and donations to a religious group that had attracted public criticism for its outsized demands.  

Defining the “Spiritual” Through Consumer Affairs

Although the term “spiritual sales” first appeared in the mid-1980s, members of the National Network of Lawyers Against Spiritual Sales, active since 1987, typically trace the start of the phenomenon to the mid-1970s. In 1983, a report by the National Consumers Affairs Center of Japan was the first to attract attention to this issue when it summarized 2,633 complaints received nationwide between 1976 and 1982 regarding sales of over-priced seals, marble vases, and miniature pagodas amounting to a total of approximately 1.7 billion yen (NCAC 1983: 48-49). By the early 1980s, local consumer affairs offices and lawyers who pursued victim compensation inspired the Asahi Journal to publish reports on spiritual sales. These appeared between 5 December 1986 and 4 September 1987.¹² The first installment included a survey of complaints gathered from 218 consumer affairs centers nationwide regarding seals, marble vases, miniature pagodas, Asian ginseng, and other objects. The Asahi Journal counted 10,611 cases between 1984 and the first half of 1986 that amounted to claims for 4 billion yen in damages (Itō and Fujimori 1986a: 12-13). They linked these products to the UC: labels and guarantees attached to them bore the imprint of an import company named Happy World. In the July 1984 edition of the monthly magazine Bungei Shunjū, Soejima Yoshikazu, former editor of Sekai Nippō, the UC’s newspaper in Japan, had described Happy World as the UC’s “operations division.”¹³ In subsequent reports, the Asahi Journal interviewed former salespeople who confirmed the UC connection. Makers of similar objects in Japan and South Korea also confirmed Soejima’s estimates that seals were sold at nine to eleven times, ginseng six to eight times, vases 400 times, and miniature pagodas 500 times their average retail prices (see Itō and Fujimori 1986b: 20-21 and Fujimori 1987).¹⁴ Court precedents had already established that it was “contrary to public order and morals” (Civil Code Article 90) for a payment-in-lieu contract to exceed five times the value of the substitute goods in relation to the amount of the bond (RCLN 1996: 165).

Detail from Itō, Masataka 伊藤正孝 and Fujimori Ken 藤森研. 1987. 霊感商法第三弾：水子が畳を這いまわる「悪霊」恐喝の背後捜査書 [Spiritual Sales vol. 3: Behind-the-Scenes Investigative Report on “Evil Spirit” Extortion, Where Dead Fetuses Crawl on Tatami Mats]. 朝日ジャーナル [Asahi Jānaru] 29(4), 30 January, p. 6.

But what made these transactions “spiritual?” The answer can be found in the second reason for locating the start of the spiritual sales problem from the mid-1970s. According to Yamaguchi Hiroshi, who served as the secretary of the National Network of Lawyers Against Spiritual Sales from its foundation until 2021, internal documents from the UC in Hokkaido revealed that, from 1974, there had been a unified injunction within the church to use spiritual advisors (reinōsha; lit. persons with spiritual powers) to boost sales (Yamaguchi 2017: 149). Pressure from spiritual advisors to buy seals, vases, and other objects made these sales “spiritual.” In their first press conference held on 13 February 1987, the Liaison Committee of Lawyers in Charge of Relief from Spiritual Sales (predecessor to the National Network) described the typical spiritual sales pitch as follows: 1) Victims are first approached on the street or by door-to-door salespeople who offer a palm reading before selling them a set of three ivory (or other) seals for several hundred thousand yen. 2) Victims are then brought to a “sacred site” (reijō) where someone introduces a “great teacher of fortune-telling” who tells them that their ancestors “will continue to suffer in hell” unless they buy a vase, miniature pagoda, or ginseng tea for several million yen in cash. 3) Younger victims are then brought to video centers where they are taught how to become salespeople and entice wealthy people to donate their savings (Fujimori 1987b: 106).

The “spiritual” here does not only pertain to the object being sold but also to the sales method: the adjective “spiritual” is meant to describe the technique used to defraud the consumer. In these legal descriptions, the “spiritual” in spiritual sales accusations does not pertain to a specific religion. It implies rather than identifies creed, beliefs, and acts. Concerns about spiritual sales therefore encourage negative appraisals within legal and popular understandings that can be applied broadly to “religion” as a category.

Before I discuss ways court decisions illustrate these understandings, I should note that the intersections and mutual influence of religion and law, as two political realms sharing the common aim of achieving a certain “order” (see Kirsch and Turner 2009), have recently attracted considerable academic interest (see Oraby and Sullivan 2020 for a review of recent scholarship). Considering the last two decades’ extensive analyses of the category of “religion” in Japan (see Isomae 2003, Josephson 2012, Thomas 2019, and Fujiwara 2023), the judicial construction of “religion” described in this article should not come as a surprise, especially when compared with similar processes in other contexts (see Sullivan et al. 2015).

To understand how these associations are forged in the Japanese context, let us consider the 27 May 1994 Fukuoka District Court decision from the first trial to have found the act of soliciting donations by a member of the UC illegal. This was also the first court decision that found the Unification Church liable for “spiritual sales”:

In general, the act of a believer of a particular religion soliciting donations by telling stories about ancestral causes and the spirit world, etc., of which the existence is not known, is within the scope of legitimate religious activities of a religious corporation, if the request is based on a socially legitimate purpose and the methods and results are reasonable in light of socially accepted ideas. It goes without saying that this is reasonable and not illegal in any way. However, if, on the contrary, the act of soliciting donations deviates from the scope of the above and is based on an unjustifiable purpose, such as the sole purpose of obtaining profits from donations, or if it is conducted in an unjust manner, such as by telling stories about ancestral causation or the spiritual world, or by notifying people of evil and causing them to feel uneasy and confused, the act of soliciting donations cannot be said to be socially appropriate and must be regarded as illegal in relation to the torts stipulated by the Civil Code.

“Socially legitimate purpose” and “socially accepted ideas” imply that there is a consensual understanding of what a legitimate religious donation might be. In condemning the ways sales by the UC (and potentially by other groups) are being conducted, we are required to make implicit comparisons with sales we deem acceptable. One assumes from this judgement that acceptable sales are those that would not aim only for profit and would not employ people’s belief in the agency of ancestors and the existence of spiritual worlds for nefarious ends. While courts do not directly condemn sales or donations inspired by religious creed, they assume parameters for socially acceptable consumption and imply an understanding of “religion” that does not require notable financial sacrifice.  

These implied standards have remained a constant in spiritual sales trials. Consider, for example, this 26 March 2021 Tokyo District Court decision ordering the UC to pay three former members approximately 115.84 million yen, plus late payment charges:¹⁵

It is generally accepted that a person who believes in a particular religion may, to spread the doctrines of that religion and maintain its religious activities, solicit believers to participate in its meetings, ask them to make voluntary donations or contributions, sell certain goods, or carry out other activities. The methods, manner, and amount of such sales, so long as they are within the bounds of socially accepted norms, are not contrary to the freedom of religion. They should not be illegal. In judging this point, it is necessary to consider whether the above-mentioned acts of solicitation, etc., are carried out by taking advantage of the state of mind (shinri jōtai) of the subject of the solicitation, etc., after making them uneasy or frightened; or whether the act of expenditure by the subject was carried out in such a manner that it cannot be said to be based on the subject’s free will; or whether the method and manner of the solicitation are such that the amount of the donation is unreasonably high in light of the social status and assets of the subject of the solicitation, etc.

Again, we find reference to “socially accepted norms,” accompanied by the judge’s assertion that the protection of religious freedom (shinkyō no jiyū) was duly considered. Illegality here is associated with the size of the expenditure and the state of mind of the victim, who is judged to have been unable to choose freely.

The argument that spiritual sales transactions constitute acts that do not qualify as legitimately religious has been central to the legal arguments against them. Religious acts are considered matters of choice and are meant to contribute to the public good. This can be gleaned from the two reports that a team of lawyers inside the Japan Federation of Bar Associations (JFBA) produced in July 1987 and July 1988 to explain the spiritual sales phenomenon and suggest possible legal avenues to their colleagues. The same argument can also be seen in a third JFBA report published in November 1995 that was sent to approximately 300 religious corporations to suggest caution and self-monitoring because spiritual sales were being observed nationwide across a range of religious organizations.¹⁶

By alluding to civil (from the Law on Door-to-Door Sales to the Pharmaceutical Affairs Law) and criminal (from fraud to extortion) laws, these reports excluded the possibility that religious freedom applies to this type of sales. The 1987 report references a criminal case of 20 November 1956 when the Third Petty Bench of the Supreme Court ruled that “if a faith healer (kitōshi) believes that the prayers he or she performs have no effect on curing illness or disease, and have no effect on knowing whether or not the client will find a life partner, misfortune, or lost property, and yet deceives the client by pretending that they do, and receives money from the client in the name of prayer fees, the practitioner is guilty of fraud” (RCLN 1996: 174). Based on this, lawyers considered that the existence of the sales manual and the testimonies of former salespeople assumed to be associated with the UC proved that they themselves did not believe in the alleged powers of the seals, vases, and other objects they were selling and could therefore be found guilty of fraud.

The 1995 JFBA report, which warns religious organizations about malfeasance, was more explicit about asserting the non-religiousness of illegal activities. While noting that religious freedom is protected by Article 20 of the 1947 Constitution, it also notes that Article 86 of the 1951 Religious Corporation Act stipulates that “nothing in this law shall be interpreted as preventing the application of the provisions of other laws and regulations in cases where a religious organization acts contrary to the public welfare.”¹⁷ It clarifies:

Problems arise in the act of soliciting monetary contributions by religious organizations to an unspecified number of non-believers when monetary contributions are not necessarily made voluntarily or following the true intention of the contributors. This is not a problem peculiar to religious organizations in particular [added italics], but a problem common to all acts of money collection by all organizations and individuals, so it should be confirmed that it is not necessary to consider exceptional principles in cases relating to religion” (RCLN 1996: 92).

It is worth noting here that this is the same argument that led legislators in late 2022 to not specify which types of organizations the new law on the Prevention of Unfair Solicitation of Donations by Juristic Persons (or Corporations) targets, even if the widespread understanding at the time was that UC sales practices inspired the drafting of the law. To explain why trials involving religious donations would not infringe on religious freedom, Yamaguchi Hiroshi, in an article summarizing the 1995 JFBA report for an academic audience, argued that the essence of religious freedom is the freedom of one’s “innermost beliefs” (Yamaguchi 1996: 230). However, “missionary activities that include fund-raising activities which involve reaching out to third parties differ from innermost beliefs in that they happen in public and have to abide by social restrictions” (Yamaguchi 1996: 231). In other words, spiritual sales have been treated as a consumer issue that is subject to consumer protection laws because the legal understanding of religious belief has been confined to people’s inner thoughts. This understanding does not extend to their social interactions. When donors complain about coercion, regardless of whether objects were originally purchased for their religious value or not, the transaction becomes a subject of litigation because it was carried out through social engagement.

Arguments for the Illegality of Spiritual Sales

How is illegality proven in court? Let us consider the 26 March 2021 case, one in which the Tokyo district court decided to separately judge the illegality of each purchase by three plaintiffs, taking into account each plaintiff’s individual contexts. Based on previous expenditures by plaintiffs A, B, and C, the court examined the conditions in which the payments were made. Below is an illustration of how these criteria were applied to two payments made to the UC by plaintiff A.

Plaintiff A is a woman born in 1973. She lost her mother to cancer when she was a high school student, and she grew distant from her family after her father remarried. Although she was not a member of a religious organization, plaintiff A had been influenced by her grandmother, who had contact with a spiritual advisor. Plaintiff A thus believed in the existence of the soul and a reikai, a spirit world in which the dead persisted. On 4 December 2000, on her way home from work, she was stopped by a fortune-teller at Shibuya station in Tokyo and received an offer to have her hand read for free. She accepted and was later invited to commute to a place owned by the UC to watch videos on their teachings. Although plaintiff A began suspecting that the content of the videos, as well as lectures she attended during a two-day seminar, were related to the UC, the group’s identity was only clearly announced to her on 10 March 2001, more than three months after her initial contact. The first of plaintiff A’s donations shown in the court documents concerned 400,000 yen paid in September 2001 for a genealogical tree made by an institution called Tembun Academy to which she was introduced through a lecturer at a UC training center. Plaintiff A spoke to the person at the academy about her family issues, and she was urged to have a family tree of her ancestors made so that harmful connections could be identified. Considering that she was the one who asked for the tree to be made, the court did not find this purchase illegal. The court reached the same decision on similar grounds for later purchases recommended to plaintiff A by UC members of a kimono (1,771,875 yen) on 2 February 2002 and a precious stone (3,660,084 yen) on 23 July 2002. In both cases, the court relied on the fact that plaintiff A bought these items because she believed that they would improve her life and her relationship with her father; she later testified that she believed they indeed had this effect.

In April 2005, plaintiff A was encouraged to purchase several more items, including a lucky stone and a copy of Selections from the Speeches of the True Parents, a UC collection of sermons by church leaders, for the price of seven million yen. The court judged this purchase illegal. A senior member of plaintiff A’s local UC church knew the amount of plaintiff A’s savings, that plaintiff A had been severely traumatized by her mother’s suffering and her own grief, and that she feared getting cancer due to the death of her mother from the disease. This member suggested that if plaintiff A purchased the lucky stone, her ancestors would be saved, and she would no longer risk getting cancer. The court considered that the church member had premeditated on these matters by arranging a meeting between plaintiff A and a spiritual advisor, who, referring to plaintiff A’s family tree, told her that her mother knew before she died that her father had already been close to his second wife-to-be but did not dare talk to plaintiff A about this because plaintiff A had been busy with university entrance examinations. Plaintiff A testified that the revelation came as a shock.

It was apparent that plaintiff A’s state of mind changed between buying the family tree and buying the lucky stone. Although both purchases were made because she believed her life would improve as a result, the latter purchase seemed more unavoidable than the earlier purchases because it came after a shocking revelation that filled her with regret for not communicating more with her mother before her death. Lawyers who specialize in spiritual sales typically focus on how a sense of inevitability is constructed in the minds of targeted consumers.

Plaintiff A’s experiences occurred during a time when consumer protection agencies, lawyers, and other advocates had already launched nationwide campaigns to inform the public about the “tragedy of spiritual sales” (see, for example, Yamaguchi 1993; Zenkoku Reikan Shōhō Bengoshi Renrakukai et al. 1997; Yamaguchi et al. 1999; 2000). Plaintiff A’s lawyer could not claim that plaintiff A would not have bought the lucky stone if she believed ancestral spirits do not exist or that they cannot do us any harm. It would also be counterintuitive to bring in another spiritual advisor to try to show that the original one had “misread” plaintiff A’s family tree. The only legal argument available was to assert that, regardless of what plaintiff A or other UC members believe, beliefs were brought forward as a method to convince plaintiff A that purchasing a ruinously expensive item or service was her only option for salvation.

Though they are not made public, witness statements are summarized to some extent in court decisions and, to a larger extent, in publications by lawyers dealing with spiritual sales. A pattern emerges in these summarized statements in which the illegality of these practices does not stem from a lack of information shared with the plaintiff but from a focus on ways a defendant exploits a plaintiff’s weaknesses that are interpreted through a creed shared by both parties. Legal arguments typically refer to the concept of informed consent. They often invoke the third article of the Law on Specified Commercial Transactions (Yamaguchi 2017: 83), which stipulates that a seller or a service provider should precede the solicitation with their name, their purpose to solicit a contract, and the type of the goods, rights, or services pertaining to said solicitation. While the argument for the illegality of spiritual sales has largely rested on the problem of concealment—it is assumed that if plaintiff A had been told that day in Shibuya that she was being approached by the UC, she would not have accepted any later invitations—it has also relied on the problem of affective manipulation (see Gaitanidis forthcoming). Plaintiff A was led to believe that purchases made in April 2005 would prevent her from dying from the disease that claimed her mother’s life. Her lack of choice stemmed from fear of what she perceived as an inevitable outcome, namely that she would meet the same fate as her mother. That perception relied on her beliefs regarding ancestral causations. It is not those beliefs that were judged illegal but the use of such beliefs for what the court deemed nefarious ends. Religion is thus not explicitly defined by legal judgements on consumer issues, but presumptions about its parameters implicitly underlie judgements’ criteria, which center on the emotional investment of defendants and plaintiffs in religious beliefs.  

The Co-constitution of Consumer Law and Religion

Attention to spiritual sales reveals that one cannot underestimate how incidents involving religious groups have influenced the legal perception of monetary transactions and religion in Japan, and the extent to which legal perspectives on money and religion are co-constitutive. The Asahi Journal’s series of reports on spiritual sales appeared alongside coverage of other, lurid, religion-related cases, such as the group suicide of seven women of the Church of the Friends of Truth (Michi no Tomo Kyōkai) (Ishizuka 1986) and Aum Shinrikyō’s move into national politics (Anonymous 1989). The severe impact of Aum Shinrikyō’s criminal activities would radically shape legal debates on religion. The 1995 JFBA report, which was published less than eight months after Aum’s sarin gas attack on the Tokyo subway in March 1995, begins by alluding to Aum. Many of the National Network lawyers were of the same generation as Sakamoto Tsutsumi, the lawyer assassinated by Aum members in 1989. Prior to the Aum attacks, money scandals involving practitioners in a variety of organizations had already forged an image of innocent civilians needing protection from manipulative religions. These included the Myōkakuji Buddhist group, which was dissolved by court order in 2002 after malfeasance that began in the early 1990s. The Aum trials that began in the late 1990s and continued for two decades are referred to in judgements about the UC that concern embezzlement, manipulation of believers’ finances, and the dubious management of religious assets. And the law passed by the Diet in December 2023 to track the assets of the Unification Church (see Asahi 2023c) was inspired by the fact that Aum was accused of having transferred ownership titles and hiding its assets in the six months that lapsed between the dissolution order for Aum Shinrikyō and the election of liquidators; as a result, only 40 per cent of damages awarded to Aum’s victims was compensated. 

Historical context is important for understanding how a new law aimed at protecting consumers can target religious donations but not seek to directly define “religion” in legal terms. The Consumer Contract Act’s “spiritual sales” clause was originally added in 2018 as part of significant revisions to the Act that saw the addition of six new clauses under Article 4(3), which concerns confusion of consumers during a transaction. The Consumer Contract Act came into effect in 2001 in an attempt to deal with consumer issues comprehensively instead of requiring individual laws for separate types of businesses, as had been the situation until then (Miyashita et al. 2022: 11) and was meant to forestall problems instead of chasing after them individually (Tanimoto et al. 2020: 77). The 2018 updates veered away from the law’s originally comprehensive aim, with new clauses added for every contemporaneous consumer issue. One of those issues was spiritual sales. As a result, the number of clauses of Article 4(3) rose from two to eight in 2018, and to ten in 2022.

The spiritual sales clause (Chapter 2, Section 1, Article 4(3)(viii)) reads today as follows: “To cause the consumer to fear, as a result of ‘the spiritual’ (reikan) or other knowledge based on special abilities that are reasonably difficult to demonstrate, that the consumer or his/her relatives cannot avoid a serious disadvantage that has arisen or may arise in the future with regard to life, body, property or other important matters, or to take advantage of such fear and tell the consumer that it is essential to conclude the consumer contract in order to avoid such a serious disadvantage.” Scholars of consumer law often explain this clause in relation to the rest of the clauses of Article 4(3) of the Consumer Contract Act (see Miyashita et al. 2022: 102-105). This explanation is important because it allows us to understand that the object of illegality is not “spiritual knowledge” but manipulation of the consumer based on it.

Clauses 1 to 4 pertain to duress and clauses 9 and 10 to psychological pressure. Between these are clauses 5 to 8, which are known as the “advantage-taking” clauses. They include sales that stir up anxiety due to the consumer’s lack of experience (clause 5), such as pushing job seekers to pay for seminars that guarantee job placement; sales that take advantage of a consumer’s goodwill towards the seller (clause 6, popularly known as “date sales”); sales that take advantage of poor judgment or the inability of the consumer to make a decision (clause 7); and spiritual sales (clause 8). Including spiritual sales in a larger category of problematic practices in which a seller tries to take advantage of a consumer’s psychological state does not set clause 8 apart as specifically “religious.” This is the reason why National Network lawyers argue that spiritual sales are not connected to religion. They assert that the quality of the act of soliciting donations is to blame.

There is, however, a detail that places clause 8 in a separate category. While the other clauses pertain to situations in which the seller exercises physical or psychological pressure, or takes advantage of the consumer’s state of mind, only clause 8 connects illicit techniques to the seller’s claims of chiken, or “knowledge based on special abilities that are reasonably difficult to demonstrate.” This knowledge rests on beliefs shared between seller and consumer which enable the seller to manipulate the consumer. By placing “spiritual sales” within legal categories of consumer fraud, consumer regulations have ended up defining “religion” as a matter internal to a potential consumer whose mental state should not be subject to external manipulation. The ethics of “good consumption” have thus been used as criteria to implicitly judge “bad religion.”

Conclusion: The Future of Religion as a Consumer Affair

Legal attempts to make sense of spiritual sales challenge legislative conceptions of the individual as an essentially rational being. This is most likely the reason they have preoccupied consumer protection measures from the moment such measures became a national matter in Japan. It is indeed no coincidence that when the National Consumer Affairs Center began heeding complaints about the sale of over-priced seals and vases in 1976, only three years had lapsed since Consumer Affairs Centers had opened in every prefecture of Japan. This was also only a decade after the Japanese government began putting in place legislation to deal with “the emergence of consumer issues as social issues following the rise of a mass-production and mass-consumption society” (Consumer Affairs Agency 2019: 48).

Since then, the legal conceptualization of spiritual sales has relied on two interpretations of “religion.” One identifies religion with organizations that are subject to legal responsibilities presumed of other types of organizations: in the same way that a religion registers as a “juridical person” (hōjin), so too will schools, non-profit organizations, and numerous other bodies. Another interpretation conceives of religion in terms of innermost beliefs, which are presumed to be separate from social interactions that laws seek to regulate. Both definitions tend to disregard the social dimensions of religion, and neither does justice to the experiences of religious believers. Testimonies of victims who have reclaimed millions of yen from UC and others accused of spiritual sales typically begin with how they originally felt that, to some extent, the money they paid was worth it. Their anxieties were assuaged, they had found a community, and they had temporarily solved some of their issues.

In seeking answers to why individuals made such decisions, we are compelled to ask questions about a human aspect that legal accusations against spiritual sales seek to avoid: the state of the mind of the person who pays for religious services who is a priori a rational individual who is free to believe what they want and operate according to those beliefs. The resurgence of legal debates surrounding spiritual sales that surged in the aftermath of Abe Shinzō’s murder compels us to re-consider the image of the “typical consumer” at the heart of spiritual sales lawsuits: a person who, with enough information and a positive frame of mind, would be able to make rational choices that preclude large-scale financial sacrifice.

In November 2023, a new expert committee was set up inside the Consumer Affairs Commission of the Consumer Affairs Agency with the purpose of implementing radical changes to the concept of consumer protection operative within Japan’s legal system.¹⁸ A report produced by a previous panel, which met fifteen times between 30 August 2022 and 30 June 2023 with the task to review the current state of consumer law, argues that Japan finds itself in social circumstances that require re-thinking the concept of the consumer. These circumstances involve 1) an increasing proportion of consumers with inadequate cognitive functions due to the aging of the population, 2) advances in digitization, which has led to a situation where limited rationality and cognitive bias are used to the detriment of consumers and unfair transactions are likely to occur, and 3) the internationalization of consumer transactions. Based on these criteria, the expert panel recommended a new envisioning of the consumer as a person with a plethora of vulnerabilities (2023: 4):

The “general, average, and reasonable” consumer concept, on which current consumer laws are based, assumes the classical image of the “strong consumer,” who is capable of making appropriate and reasonable decisions if given sufficient information…In reality, however, the situations in which such a consumer concept is valid are limited. Since real consumers are liable to act irrationally even after being given information, it is necessary for consumer law to be built in line with…this actual consumer image head-on. In doing so, consumer vulnerabilities in question can be broadly classified into vulnerabilities that everyone always has, such as limited rationality, situational vulnerabilities arising from certain circumstances, and typological and attributive vulnerabilities derived from certain attributes, such as youth, old age, and poverty.

Although the report cautions against excessive intervention by governmental authorities, one wonders how these new developments will influence the conceptualization of transactions with religious specialists and organizations. If there is one lesson to learn from the rise of spiritual sales as a consumer issue and a legal category, it is that the histories of consumer law and the perception of the public role of religion are potentially inextricable.

In this article, I have shown that one cannot start to comprehend the post-July 2022 legal debates surrounding financial transactions with the UC without understanding that for nearly forty years “spiritual sales” have persisted as a vexing issue in the field of consumer law. Built on the assumption that well-informed individuals would not willingly make expenditures beyond their means, lawyers and legislators have struggled to use consumer law to combat spiritual sales, where the intent to purchase or donate often stems from a religious creed shared between the seller and the buyer. Not wishing to infringe on the religious freedom of consumers and progressively realizing that spiritual sales are not the only type of transactions that can be legally defined as “advantage-taking,” legislators have sought to find common ground by focusing on what they see as emotional manipulation of victims. As a result, “religion” became a matter of inner belief. The focus of legal actions are the social responsibilities of the seller, who is not supposed to take advantage of the vulnerabilities of the buyer. This framing tactic has required lawmakers to reconceptualize the consumer, who is no longer a “rational” being who can avoid problems if equipped with sufficient knowledge about the conditions and nature of the transaction but is instead a vulnerable potential victim of a malicious fraudster who seeks to manipulate commitments to a set of beliefs. Only time will tell how such a shift in the concept of the consumer will shape legal interpretations that will take into account future financial exchanges which involve religious organizations.

Acknowledgements: I would like to thank the editors of this special issue, Levi McLaughlin and Tomomi Yamaguchi, for their encouragement and constant support through several conference panels at which I presented some of the material that inspired this article. Special thanks also go to Levi for his editorial comments on earlier drafts. Thanks to him, this has become a much more approachable and readable text. This research was supported by the Japan Society for the Promotion of Science (grant 22K00070).

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1. Unless otherwise indicated, Japanese sources used in this article have been translated by the author.
2. My summary of the arguments expressed in documents published by lawyers associated with the National Network does not reflect the diversity of opinions within the National Network, which represents a multitude of voices. There are, for example, lawyers who claim that “spiritual sales” are also a matter of human rights. My argument in this paper focuses on the most common legal interpretations of the issue.
3. The committee’s official name was the “study group on countermeasures against spiritual and other malicious sales” (reikan shōhō tō no akushitsu shōhō e no taisaku kentōkai, 霊感商法等の悪質商法への対策検討会). Its reports can be found here (accessed 1 February 2024): https://www.caa.go.jp/policies/policy/consumer_policy/meeting_materials/review_meeting_007
4. The law’s name in Japanese is hōjin tō ni yoru kifu no futōna kanyū no bōshi tō ni kansuru hōritsu (法人等による寄附の不当な勧誘の防止等に関する法律). Details of the law can be found on the Consumer Affairs Agency site (accessed 1 February 2024): https://www.caa.go.jp/policies/policy/consumer_policy/donation_solicitation/
5. See explanations regarding the Law to amend the Consumer Contract Law and the Law on the Independent Administrative Institution National Consumer Affairs Centre (shōhisha keiyakuhō oyobi dokuritsu gyosei hōjin kokumin seikatsu sentā hō no ichi bu o kaisei suru hōritsu), on the Agency of Consumer Affairs site (accessed 1 February 2024). https://www.caa.go.jp/policies/policy/consumer_system/consumer_contract_act/2022_contents_002/
6. See the liaison meeting of ministries and agencies concerned with the “former Unification Church” issue (kyū-tōitsukyōkai mondai kankei shōchō renraku kaigi) https://www.moj.go.jp/JINKEN/jinken03_00150.html (accessed 1 February 2024)
7. Note here that, as the word taisaku (“countermeasure”) denotes, the taisaku daiyaru are not lines that people call to find help but to get information on where to find help.
8. See reikan shōhō tō taiō daiyaru (accessed 12 June 2024) https://www.houterasu.or.jp/site/reikan-higai/mail-form.html
9. See the following website for a monthly analysis (accessed 6 September 2024): https://www.houterasu.or.jp/site/reikan-higai/#cmsdenwa
10. See their website (accessed 1 February 2024): https://www.uchigai.net/
11. The Consumer Affairs Agency (CAA) also started receiving complaints regarding unfair donation practices after the new law was enacted. It reported on 2 November 2023 that from 1 April to 30 Sep 2023 it processed 809 complaints that satisfied the law’s parameters. Of these, it investigated seventy. At the time of the report, twenty-seven were still under investigation; from the remaining forty-three, two were considered not unjust, nine cases preceded the date the law came into effect, and thirty-two could not be investigated because of lack of information (see https://www.caa.go.jp/policies/policy/consumer_policy/donation_solicitation/assets/consumer_policy_cms213_231102_01.pdf). Five CAA executive advisors were tasked with supporting the new law: three scholars, one lawyer, and a board member of the Japan NPO Centre, which serves as the official link between the non-profit sector and the government (see https://www.caa.go.jp/policies/policy/consumer_policy/donation_solicitation/assets/consumer_policy_cms104_230401_009.pdf).
12. Most of these articles were republished in a sixty-five-page long Asahi booklet (Asahi Journal ed. 1987).
13. Subsequently, Soejima’s story appeared in the 16 September 1984 edition of The Washington Post (accessed 1 February 2024). See https://www.washingtonpost.com/wp-srv/national/longterm/cult/unification/profit.htm
14. In an oft-cited report of similar complaints (which I have not been able to find) made public by Kanagawa Prefecture’s Consumer Affairs Division in 1986, average prices were as follows: miniature pagodas 9,110,000 yen, ginseng 6,150,000 yen, vases 1,470,000 and seals 540,000 yen. The Japan Federation of Bar Associations reports confirmed these prices (see RCLN 1996: 163-164).
15. This case is included in the most recent publication by the National Network (see Yamaguchi et al. 2022: 211–212).
16. The three reports were later published together. See RCLN 1996.
17. The Religious Corporation Law has been revised several times, most notably in 1996, following the Aum attacks. However, Article 86, which the JFBA report refers to here, has remained the same since the law was formulated in 1951.
18. The name of the committee is Expert Committee on A Paradigm Shift in the Consumer Law System. For more information, see https://www.cao.go.jp/consumer/kabusoshiki/paradigm_shift/index.html (accessed 6 September 2024).