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Why the New French Law on “Cults” is Wrong

The French National Assembly has re-introduced in the amended law on “cults” the strange crime of “psychological subjection” the Senate had eliminated.

by Eileen Barker*

Source: Bitter Winter

Broadly speaking, there are two kinds of political approach to legislation. There are those states that punish perpetrators for an actual harmafter” they have been proved guilty in court of law. This is the approach to be found in the USA, the UK, and most other Western democracies. Alternatively, there are those States which claim to protect their citizens from potential harm “before” any criminal act has been perpetrated  This latter approach tends to be found among some of the  more totalitarian states, such as Russia and China—but also, it might appear, in France for instigating a law that is designed to protect its citizens from potential harm from groups exhibiting “dérives sectaires,” a concept roughly equivalent to religious movements referred to by the pejorative term “cults” in English. This can mean not only that behavior by one religion, labelled as a “cult,” can be deemed criminal in law whilst the same act performed by a group considered a “religion” could be perfectly legal, but also that “cults” may be legally condemned before they have actually done anything illegal other than being labelled a “cult.” 

Eileen Barker and her 1984 seminal book debunking the idea that those joining the Unification Movement did so before they were “brainwashed.”There is, however, no agreed definition of a “cult,” the term generally being used to denote a religion or other movement of which one disapproves. I cannot tell the number of times I have been asked whether a particular movement is a “cult” or a “real religion.” If I ask what the questioners mean by a “cult,” they are rarely able to give a coherent reply, but might, on being pressed, mumble something about brainwashing, child abuse, suicide, murder, or belief in some kind of satanic heresy, whereupon I am usually able to reassure them that the movement in question does not fit their description.

Eileen Barker and her 1984 seminal book debunking the idea that those joining the Unification Movement did so before they were “brainwashed.”

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Buenos Aires Yoga School

Source: The Journal of CESNUR

by Alessandro Amicarelli - Director of FOB (European Federation for Freedom of Belief)

ABSTRACT: On December 7, 2023, an important development happened in the Argentinian court
case of the Buenos Aires Yoga School (BAYS). The Court of Appeals annulled the elevation to trial of
the defendants and sent the case back to the investigating judge, urging him to evaluate the new
evidence that had surfaced, in dialogue with the parties. The prosecutors filed an appeal in cassation
against the Court of Appeals decision. The BAYS case is paradoxical, as the prosecutors insist that
several mature women were victimized and compelled to work as prostitutes by the movement. On the
other hand, all women deny being victims and having ever worked as prostitutes in their lives. The
article insists on the crucial role of the forensic psychological expertises that found the women “normal”
and believable. It also emphasizes the dissenting opinion of one of the three appeal judges, who would
have simply acquitted all the defendants and closed the case.
KEYWORDS: BAYS, Buenos Aires Yoga School, PROTEX, Brainwashing, Anti-Cult Movement in Argentina.

On December 7, 2023, the 2nd Chamber of the National Court of Appeals for Criminal and Correctional Matters of Argentina (hereinafter “Court of Appeals”) rendered three rulings in the Buenos Aires Yoga School (BAYS) case and annulled the elevation to trial of the defendants (Sala 2 de la Cámara Nacional de
Apelaciones en lo Criminal y Correccional Federal de Argentina 2023a, 2023b,2023c). Seventeen BAYS members were prosecuted for alleged human trafficking for the purpose of sexual exploitation, money laundering, smuggling, and illicit association. The Court of Appeals’ ruling means that the case file must
be returned to the lower court. The latter is urged to examine the newly filedevidence and the constitutional exceptions raised by the defense.

The Journal of CESNUR has published detailed reports by Massimo Introvigne and Susan Palmer on the BAYS and its trial (Introvigne 2023a; Palmer 2023).
This is an extraordinary case where, based on the accusations of one single anti-cult activist, the prosecutors of the anti-human-trafficking unit PROTEX—who have fully embraced (Introvigne 2023b) the unscientific and discredited theory of brainwashing (Introvigne 2022)—insist that a number of mature women were
victimized and forced to work as prostitutes and to transfer the earnings from that activity to the yoga school.
It must be noted that, without exceptions, all the women involved in this case, who are middle-aged professionals, deny being “victims” of the BAYS and having ever worked as prostitutes in their lives. Yet, the prosecutors maintain the paradoxical theory that, having been brainwashed by the BAYS, the women could
have been victims and prostitutes without realizing it (Fautré 2023a, 2023b).

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Iglesia Tabernáculo Internacional: Argentinian Court Chastises PROTEX for Fabricating Victims

The defendants were absolved and the judge recommended to investigate the “scandalous” abuses of the anti-trafficking agencies and psychologists.

by Massimo Introvigne

Judge Roberto Manuel López Arango, who presided the court and drafted the decision. From Facebook. Judge Roberto Manuel López Arango, who presided the court and drafted the decision. From Facebook.

There are horror movies and then there are “horror cults.” In the incredible case of the Buenos Aires Yoga School (BAYS) the expression “secta del horror” was liberally used by the media. But it seems that in Argentina it is now a general category: an Evangelical church called Iglesia Tabernáculo Internacional (ITI) was also called “secta del horror” by the media.

What the cases of the BAYS, the ITI, and Cómo vivir por fe (How to Live by Faith), the Argentinian affiliate of the Australian movement Jesus Christians, have in common is the key role of a special prosecutorial office called PROTEX (Procuraduría para el Combate de la Trata y Explotación de Personas, Office of the Procurator for Combating the Trafficking and Exploitation of Persons). PROTEX raids with great fanfare and the presence of the media groups it accuses of being “cults” practicing “coercive persuasion” or “brainwashing” and “trafficking” their members, arrests their leaders, and “liberates” the “victims”—who unanimously deny being victims.

While the BAYS case is still pending, the Jesus Christians were found not guilty of trafficking or any other crimes on November 28, 2022, by the Federal Criminal and Correctional Court of Sáenz Peña, with an order severely criticizing PROTEX.

Even more severe for PROTEX, the other prosecutors, and the anti-cult “expert” psychologists who see “cults” and “trafficking” everywhere is the decision rendered on February 1, 2024, by the Court of Paraná in the case of the ITI.

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“Abuse of Weakness” - New Struggles of Spiritual Movements

Interview with Prof. Massimo Introvigne - part 3 of 3

The struggle of New Religious Movements in the current antagonistic climate of state and mass media is reaching higher levels.

Often the term “Brainwashing” seems to be used in the discussions of cults - how is this term relevant?

Most scholars of new religious movements agree that “brainwashing” does not exist, and its incrimination is basically a fraud. When the normal process of religious persuasion has as its object beliefs and practices that the powers that be regard as “normal,” it is argued that there is no “brainwashing.” When the beliefs and practices are non-conventional or unpopular, this is offered as evidence that only “brainwashed” victims can embrace them because they have been put in a status of “psychological subjugation” (or “subjection”).

The French government solemnly proclaims that through the new law it is not criminalizing beliefs, only the techniques through which certain beliefs are promoted. In fact, however, the proof that a belief has been inculcated through “illegal” techniques is that the anti-cultists, the MIVILUDES, the majority of society, or the media regard it as a “cultic deviance.” Source:

Prof. Massimo Introvigne interview offered to Soteria International brings further perspectives. Here is third part of three.

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"Abuse of Weakness" or "Brainwashing" - A New Threat to Spirituality

Interview with Prof. Massimo Introvigne - part 2 of 3

Considering the similarities and repetition of the police raids upon spiritual communities, in different countries, a certain question is rising: are NRM - New Religious Movements or spiritual communities in danger?

In France, as prof Massimo Introvigne wrote in his article "France Plans to Make a Bad Law Worse - the anti-cult About-Picard law is ineffective against real abuses and dangerous for religious liberty. The government wants to make it even more dangerous." the situation of spiritual communities becomes increasingly difficult.

On November 15, the government presented a draft law to “reinforce the fight against cultic deviances.” The reason offered for a new crackdown on “cults” is that the number of “saisines” received by the MIVILUDES is growing. As “Bitter Winter” has documented, the “saisines” are not reports of actual incidents, include simple questions sent to the MIVILUDES, and may easily be false or manipulated. ...

The anti-cult measures are also reinforced by allowing the anti-cult associations to be present in the court cases against “cults” as civil parties and by encouraging judges and prosecutors to seek the opinion of the MIVILUDES on groups they are judging or prosecuting.

The heart of the new draft law is the creation of a new crime of “psychological subjection.” Those who place their victims in a state of “psychological subjection” through “serious or repeated pressure or the use of techniques capable of modifying their judgement” will be punished with a jail penalty of three years, or of seven years when the defendants are part of an “organized band” routinely using these techniques, in other words a “cult.” The crime is perpetrated when the use of the “psychological subjection” techniques has “the effect of causing a serious deterioration in the persons’ physical or mental health or leading the persons to perform an act or abstain from an act which is seriously prejudicial to them.” “Psychological subjection” will also affect already existing crimes as an aggravating circumstance.  Source:

Prof. Massimo Introvigne offered new perspectives and explanation during the interview, as it follows here, in the second part of three.

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"Abuse of Weakness" or "Brainwashing" - Does It Really Exist?

Interview with Prof. Massimo Introvigne - part 1 of 3

In December 2023, the French parliament debated to reintroduce or not the controversial law of mental manipulation. This law has a history in France.

It is necessary to open up to see the comprehensive perspective offered through academic studies, to understand that people who join spiritual movements are normal people, merely having their particular beliefs or practices. And as long as they respect the laws of their country they should enjoy freedom, respect and social protection, just like any other citizen. Yet the repetitive police raids and their scandalous presentation in mass media tell a different story.

There are several publications and academic studies on questionable concepts such as "abuse of weakness" or "brainwashing".

When France introduced in 2001 the controversial anti-cult About-Picard law, the first draft tried to punish “mental manipulation.” International and French scholars, and leading legal experts, protested that this was just a synonym of the discredited theory of “brainwashing,” exposed as pseudo-science and a tool to discriminate against unpopular religions by academics and courts of law in several countries.

Afraid that a law against “mental manipulation” would run into constitutional problems, the anti-cult politicians backed off, and introduced instead the “abuse of weakness” (abus de faiblesse). This was another cosmetic and semantic game hiding their intention to criminalize “brainwashing.” However, finding evidence that something that does not exist caused concrete harm proved to be difficult. As Canadian scholar Susan Palmer demonstrated in her acclaimed Oxford University Press 2011 book “The New Heretics of France,” the About-Picard law is strong with the weak and weak with the strong.

If a religious movement lacks the resources to hire good lawyers and experts, its leaders may be convicted of the imaginary “abus de faiblesse” and go to jail. Groups that command significant resources would easily find ways of challenging a law born under a pseudo-scientific cloud. In fact, even groups guilty of real abuses—to be distinguished from the non-existing “brainwashing”—may take advantage of the vague wording of the law and get away with their crimes. Source:

Prof. Massimo Introvigne gives his insights on the subject of mental manipulation during an interview offered to Soteria International. Here is the first part of three.


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Brainwashing Theories: the Myth and the History of “Mind Control”

Brainwashing theories: origins, application in the military field, and to religious groups, up to their discredit. Are mind control theories making a comeback?

by Massimo Introvigne*

*This article collects, for ease of reading, a series of articles published on this site in August 2021.


Table of Contents

“Brainwashing”: A False Accusation Against Unpopular Minorities

We are at it again. New books are launched with great fanfare that revive old theories of “brainwashing,” and almost everybody, from Donald Trump to Bill Gates, is accused of using “mind control techniques” to gather followers. And of course, that they use “brainwashing” is an old accusation against groups discriminated and labeled as “cults.”

Do these techniques exist? That the answer is “no” is one of the key conclusions of the academic discipline of the study of new religious movements (NRM studies). A tiny minority of scholars of religious movements, with connections to the anti-cult activists, rejected this conclusion, seceded from the majority, and created a different discipline of “cultic studies.” However, as Mike Ashcraft emphasized in his authoritative textbook on the academic study of new religious movements, while NRM studies are generally regarded as a legitimate part of the scholarly study of religions, “cultic studies” are “not mainstream scholarship.”

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Behind the Bivolaru Case. 4. GéPS Versus MISA

How Gascan and his friends framed Gregorian Bivolaru looks like a fairy tale. But behind any fairy tale lies a truth.

by Massimo Introvigne

Article 4 of 4. Read article 1article 2, and article 3.

Gregorian Bivolaru Gregorian Bivolaru.

I study fairy tales and their influence on Western esotericism and both romantic and modern art. However, fairy tales have a symbolic truth, which should not be confused with factual truth.

After he was put on the Interpol most wanted list by the Finnish authorities in October 2017, Bivolaru became a fugitive and the police of several countries were hunting him. That a small private anti-cult group, Hugues Gascan’s GéPS discussed in previous articles of this series, found and framed him, succeeding where Interpol had failed, belongs to the category of fairy tales.

According to Gascan, the methodology he and his “group of friends” used was very simple. They contacted non-French women who were telling the cloak-and-dagger story of how they were brainwashed in their countries where they attended MISA courses, invited to go to Paris, received and blindfolded by drivers in Paris, and taken to locations in France where they were compelled to have sex with Bivolaru. While readers of French media are led to believe that this was the result of a Sherlock-Holmes-like work by GéPS, these stories had been known for years. The late Swedish scholar Liselotte Frisk encountered them—and found them hard to believe—when she investigated the Finnish case in 2018. Some of the women who told these stories spread them through the Internet, wrote books, and were involved in civil cases with Bivolaru’s organization. I discussed their narratives in my own 2022 book about MISA. There was nothing new about them, except the claim that on November 28, 2023 several women were held captive in France to be abused by Bivolaru—a story as far as I know none of the women reportedly “liberated” by the police has confirmed so far.

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Behind the Bivolaru Case. 3. Enter the MIVILUDES

The French anti-cult governmental agency played a crucial role in persuading those who were against other Tantric groups that they should focus on MISA.

by Massimo Introvigne

Article 3 of 4. Read article 1 and article 2.

Alban Bourdy and his self-published 2018 book. From Facebook. Alban Bourdy and his self-published 2018 book. From Facebook.

In the last article of the series, we discussed the court case Hugues Gascan lost again his colleague P.J., whom he had accused of being part of a “sex cult” led by Canadian independent Tantric teacher Jean Bouchart d’Orval.

We have a precious if biased document about what happened next: the autobiographic book self-published by an ex-member, turned anti-cultist, of the Soledad Domec schismatic branch of Ashram Shambala called Alban Bourdy (“Un Bisounours au pays des se(x)ctes ,” Norderstedt: Book on Demand, 2018). Having emerged as a public critic of Soledad Domec and the groups inspired by Rudnev, Bourdy received a phone call from Gascan in 2015 (p. 391). The latter followed up with a second call in December 2015, where according to Bourdy he wanted the two of them to join forces to expose the Tantric groups. However, Gascan was still so obsessed by P.J. that he accused Bourdy of being in touch with her (p. 393).

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The Rule of Law, Freedom of Religion or Belief, and the Tai Ji Men Case

The expression “rule of law” was first used in the 17th century in connection with freedom of religion or belief. This connection is still crucial today.

by Massimo Introvigne*

*A paper presented at the 2024 Judicial Day Forum “Review and Vision of Judicial Independence: The Tai Ji Men Case,” National Taiwan University, Taipei, January 9, 2024.

Samuel Rutherford (1600–1661) coined the formula “rule of law.” Credits. Samuel Rutherford (1600–1661) coined the formula “rule of law.” Credits.

Taiwan’s Judicial Day 2024 commemorates the anniversary of the fateful date of January 11, 1943, when the Republic of China (R.O.C.) entered into a new treaty with the United States and the United Kingdom, making R.O.C.’s judicial system completely independent from any foreign jurisdiction. It is a day when Taiwanese proudly reflect on the rule of law.

It is interesting to note that the idea of the “rule of law” first emerged in connection with freedom of religion. The first known use of the expression “rule of law” was by a Church of Scotland minister, Samuel Rutherford, in 1644.  Scotland had a Presbyterian church with a Calvinist theology, which was very different from the Anglican doctrine and organization of the Church of England. 

King Charles I, to better control religion in the United Kingdom, tried to merge the Church of England and the Kirk, as the Church of Scotland was called. In practice, this merger meant that the Church of Scotland would be compelled to accept Anglican ideas and practices foreign to its tradition. The King’s project generated widespread opposition in Scotland, where a National Covenant was signed in 1638 to defend the freedom of the Kirk to define its own theology and organization. In time, the confrontation escalated from ideological to military and inaugurated the time of civil wars in the United Kingdom.

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