‘Faction’ members lose court challenge against expulsion from Buddhist organisation

Twenty members of Buddhist organisation Soka Gakkai Singapore (SGS) who were expelled for taking part in an informal study group have lost their High Court challenge against their expulsions.

The leadership of SGS was largely of the view that the existence and activities of the “faction” group were contrary to the interest and harmony of the association.

The 20 individuals alleged that they were not given a fair opportunity to be heard and that the leaders who expelled them showed bias and prejudgment.

In a written judgment on July 8, Justice Philip Jeyaretnam rejected their arguments and upheld the expulsions.

The judge concluded that the claimants were given a full and fair opportunity to be heard, but made a deliberate choice not to defend themselves.

“The claimants chose not to avail themselves of this opportunity and cannot complain that they were denied the right to be heard,” he said.

The judge added: “Upholding the decisions to expel the claimants does not mean that the claimants are not free to pursue their faith, only that they must do so outside membership of SGS.”

SGS, an organisation practising Nichiren Buddhism in Singapore, is part of an international network of affiliated organisations.

It was first registered as a society in 1972 and then as a charity in 1985.

Under its Constitution, members can be expelled if they are determined by the management committee to have, among other things, acted against the interests or harmony of the association.

In the current case, the 20 individuals were in a group named Solidarity of Genuine Sensei’s Disciples (SGSD).

One of the leadership figures of the group is an expelled former member of SGS.

The group held monthly study sessions over Zoom. It also pooled funds to buy study materials and develop a mobile application.

Their lawyer, Mr Choo Zheng Xi, likened SGSD to a Bible study group formed by members of the congregation of a Christian church.

In August 2022, a former member of the group, whose former wife is one of the 20 claimants, revealed its existence to a leader of SGS.

In December that year, the management committee took the view that the formation of the group, if true, would be “unorthodox and unacceptable, being contrary to the interests and harmony of SGS”, and required further investigation.

In February 2023, senior leaders of SGS held training sessions for all levels of leaders, where they stated that SGSD “spread resentment and dissatisfaction towards SGS and its central figures”.

The senior leaders said there was a need to “confront the influence of evil... (and) crush the malicious actions” of the group.

All the claimants were also invited to dialogue sessions, in an attempt to stop them from being part of the group, said SGS, which is represented by Mr Goh Kok Yeow.

The seven who attended the sessions were told by leaders that the “faction” group disrupted the unity of SGS.

Between April 2023 and January 2024, SGS notified the individuals to attend disciplinary hearings.

The alleged misconduct included congregating as a group with a self-given name, organising activities not aligned with SGS’ objectives, and soliciting funds without SGS’ knowledge and approval.

SGS provided bundles containing text messages and other documentary evidence after the individuals asked for substantiation.

None of the claimants attended the hearings, which began in November 2023.

After the hearings concluded, the individuals were asked to resign, in letters issued between December 2023 and February 2024. When they refused, the association issued them notices of expulsion in March 2024.

Expulsion meant the loss of the right to participate in regular SGS activities and to certain benefits such as conferment of a sacred object and issue of an introduction letter to visit Soka Gakkai International in Japan, both of which are discretionary.

The 20 individuals then took SGS to court, seeking a declaration that the expulsions were null and void because they were in breach of the rules of natural justice or were irrational or unreasonable.

In his judgment, Justice Jeyaretnam emphasised that the court does not intervene on whether the individuals deserved to be expelled, or on any question of religious doctrine.

The judge said the question before him was whether the decisions were procedurally fair and whether the decisions were irrational or unreasonable.

Justice Jeyaretnam said the claimants were given ample notice of the allegations that they had to answer to but made a deliberate choice not to attend the hearings or rebut the allegations.

SGS provided evidence of SGSD being an organised group led by an expelled former member.

Evidence was also provided that the group had its own mobile app and raised funds for an unauthorised project.

The judge also disagreed that the leadership had prejudged the disciplinary cases against the claimants. He noted that it was only after the training and dialogue sessions failed to bring the group members back into the fold that the leadership moved on to disciplinary proceedings.

Tang Huixian and others v Soka Gakkai Singapore [2025] SGHC 131

Source: The Straits Times © SPH Media Limited. Permission required for reproduction.

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