Do advancement of religious (and non-religious) beliefs deserve charity status?

This paper uses the history since the 1960s of organisations representing non-religious beliefs such as Humanism to explore the errant application of charity law, tracing it to its origins in the 1601 Statute of Charitable Uses. It critiques the long-standing culturally biased definition of ‘religion’ in charity law, describes rejected proposals by Humanists UK for a neutral definition that would embrace both religious and non-religious beliefs, and shows how recent legislation and litigation have produced a superficially equal regime for religious and non-religious beliefs – one, however, that is undermined by the law on public benefit which, despite Parliament twice legislating that there should be no presumption of public benefit for any category of charity, persists as a result of questionable court rulings and timid compromises by the Charity Commission in preserving that presumption for religious charities. Finally the paper questions the justification for charitable status (for which read public subsidy) for any organisation whose principal purpose is to promote a belief, religious or non-religious, arguing that many such organisations in fact produce no public benefit but often the opposite and that most could justify charitable registration under another head without undue difficulty.

The paper was written for the journal Law and Justice and is based on a talk given to the conference ‘Beyond Belief: Religion, Law and Ethics in the 21st Century’ on 22 April 2021 sponsored by Cardiff University, the Edmund Plowden Trust and the journal.

1960s: Humanism Not Charitable

Humanists UK started in 1896 as the Union of Ethical Societies, later known as the Ethical Union (EU) and then the British Humanist Association. In 2016 it adopted the name Humanists UK. The ethical societies that came together in 1896 were congregations whose Sunday morning lecturers were frequently listed alongside the principal church preachers in the classified columns of the newspapers. One of them, the West London Ethical Society, operated for some decades after 1910 as the Ethical Church, hoping to attract the Church of England towards a non-theistic set of beliefs.

However, by the 1950s the ethical movement was increasingly describing itself as humanist and developing the coherent and attractive non-religious belief system that is today influential across the world.

The 1960s saw an unprecedented flourishing of humanism, but in 1965 the Ethical Union, whose charitable status, always seen as educational if not quasi-religious, had never been considered in doubt, was shocked when an irate ratepayer objected to the rates relief given to its Kensington offices. The question went to the Ministry of Education, which then oversaw educational charities, and they decided that the EU was a ‘propagandist’ organisation and not one for the advancement of education. The EU was struck off the register, followed in short order by all the other humanist charities.

The EU consulted lawyers and law books (I recall hours poring over Tudor on Charities!) and had protracted correspondence with the Ministry – to no avail. And there was no way we could afford to appeal: our office building might have looked grand but most of it was let and our finances were on a knife-edge.

Given the ruling that advancing information about the philosophy of humanism was not educational, it appeared that the law held that advancing a belief was not charitable in law – unless it was a religious belief!

Charity Law from 1601 to 2006

The law at the time was exclusively case law, derived originally from the preamble to Elizabeth I’s Statute of Charitable Uses of 1601.1

The Statute was a late addition to Elizabethan Poor Law, which was itself in part a response to the dissolution of the monasteries, which had been a traditional, albeit far from generous, source of poor relief. The Poor Law discouraged indiscriminate alms-giving and applied parochial funds to support for the indigent, with legal discrimination between the more and the less deserving poor. The State wished also to encourage charitable and other private spending in the public interest so as to minimise calls on parochial funds. But there was widespread suspicion that such funds were too often diverted to private use, and action in Chancery, the only legal means to check such defalcations, was almost entirely ineffective. The Statute set up local Charity Commissioners who for the decades until the civil war provided an efficient guarantee of honest administration.

In its preamble [see below] the Statute recited examples of the type of charitable giving the Government wished to encourage, and this list – oddly derived in part from William Langland’s fourteenth century poem Piers Plowman – became by accident rather than intent the touchstone for the courts for the next several centuries: a purpose was charitable if it was for the benefit of the public or a section of it and it was ‘within the spirit and intendment’ of the preamble to the Statute.

The Preamble to the Statute of Charitable Uses

An Acte to redresse the Misemployment of Landes Goodes and Stockes of Money heretofore given to Charitable Uses
Whereas Landes Tenementes Rentes Annuities Profittes Hereditamentes, Goodes Chattels Money and Stockes of Money, have bene heretofore given limitted appointed and assigned, as well by the Queenes most excellent Majestie and her moste noble Progenitors, as by sondrie other well disposed persons, some for Releife of aged impotent and poore people, some for Maintenance of sicke and maymed Souldiers and Marriners, Schooles of Learninge, Free Schooles and Schollers in Universities, some for Repaire of Bridges Portes Havens Causwaies Churches Seabankes and Highewaies, some for Educacion and prefermente of Orphans, some for or towardes Reliefe Stocke or Maintenance of Howses of Correccion, some for Mariages of poore Maides, some for Supportacion Ayde and Helpe of younge tradesmen Handicraftesmen and persons decayed, and others for releife or redemption of Prisoners or Captives, and for aide or ease of any poore Inhabitantes concerninge paymente of Fifteenes, setting out of Souldiers and other Taxes; Whiche Landes Tenementes Rents Annuities Profitts Hereditaments Goodes Chattells Money and Stockes of Money nevertheles have not byn imployed accordinge to the charitable intente of the givers and founders thereof, by reason of Fraudes breaches of Truste and Negligence in those that shoulde pay delyver and imploy the same.

It is notable that religious purposes do not figure in the Preamble except as public works – ‘the repair of … churches’. At the time the state had expropriated the wealth of the Church and it no longer had the wherewithal to finance philanthropic works. Moreover, religion was an intensely political matter and donations to religious funds were liable to dangerous misinterpretation. 2

However, by the time that Lord McNaghten in 1891 sought to clarify the accumulated case law in a quadripartite classification, the advancement of religion was one of three named heads, along with advancement of education, the relief of poverty and (inevitably) the residual category of ‘other purposes beneficial to the community’.3

1980s: Humanism again Charitable

In 1967 the Ethical Union, by now the British Humanist Association, gave up hope of regaining charity status. There was then an interval of a dozen years – save that the BHA convened an independent Charity Law Reform Committee with members drawn from many organisations to campaign for reform, gathering plentiful publicity but no Government action.

Finally in 1980 one of the other humanist ex-charities went to the High Court: the South Place (now Conway Hall) Ethical Society, somewhat perversely on the strength of their 18th and early 19th century history within Unitarian Christianity and an objective in terms of the ‘cultivation of a rational religious sentiment’, tried to get accepted as a religious charity. Mr Justice Dillon rejected them, telling them firmly, however, that ‘the objects of the Society are charitable, but not for the advancement of religion.’4

This led in due course to all the main humanist organisations being reinstated, albeit with contorted objectives to fit the law – the BHA’s were grandly ‘for the advancement of the mental and moral improvement of the human race’!5

The Definition of Religion

Over the centuries case law developed also a definition of religion as manifesting three key elements – a supreme being, who had to be worshipped and whose cult had to be evangelised – a definition plainly derived from Christianity. In the twentieth century this gave rise to problems. For example, it was plain that Judaism was a religion but it did not evangelise. Hinduism had no supreme being but multiple gods; while Buddhism had neither a supreme being nor worship. But the law brushed aside such difficulties – as witness Mr Justice Dillon’s dismissive remark in South Place: ‘I do not think it is necessary to explore this further because I do not know enough about Buddhism’.

What was important was to ensure the churches and evangelists got their charitable tax relief – subsidies from the public purse. And so the non-Christian religions took on charity status, and this was formally recognised in 2006 when a new Charities Act was prepared. Grasping the nettle, Parliament decided that religions included those with multiple gods and those with none:

‘religion’ includes—
(i) a religion which involves belief in more than one god, and
(ii) a religion which does not involve belief in a god.6

This obviously secured the position of non-Christian religions, but it did nothing to clarify the legal meaning of ‘religion’.

That had to wait for Louisa Hodkin and her fiancé Alessandro Calcioli. The Supreme Court’s judgement in their case in 2013 was not about charity law but marriage law: did the Church of Scientology’s building qualify as a place of worship and therefore as a place that could be registered for the solemnisation of marriages? Lord Toulson provided what he emphasized was not a definition but a description of ‘religion’ for the specific purpose of the Places of Worship Registration Act and marriage law:

For the purposes of PWRA, I would describe religion in summary as a spiritual or non-secular belief system, held by a group of adherents, which claims to explain mankind’s place in the universe and relationship with the infinite, and to teach its adherents how they are to live their lives in conformity with the spiritual understanding associated with the belief system. By spiritual or non-secular I mean a belief system which goes beyond that which can be perceived by the senses or ascertained by the application of science. I prefer not to use the word ‘supernatural’ to express this element, because it is a loaded word which can carry a variety of connotations. Such a belief system may or may not involve belief in a supreme being, but it does involve a belief that there is more to be understood about mankind’s nature and relationship to the universe than can be gained from the senses or from science. I emphasise that this is intended to be a description and not a definitive formula.7 (Emphasis added)

He then went on to reject the narrow definition of ‘religious worship’ that had ruled since the Scientologists’ earlier Segerdal case in 19708, extending it to include the ‘religious rites’ of any religious congregation. So Scientology was secured as a religion – but interestingly, given its very dubious claims to public benefit, it has not yet tried again to be recognised as a charity.

Non-religious beliefs

What though of non-religious beliefs? The legal doctrine had long been that enunciated by Mr Justice Cross:

As between different religions, the law stands neutral, but it assumes that any religion is at least likely to be better than none.9

But this was incompatible with the 1998 Human Rights Act, which requires State neutrality as between not only different religions – including new age religions, South Sea cargo cults, or the inventions of a science fiction novelist – but also equivalent non-religious beliefs.

This had in fact long been Strasbourg law10 but now it was domestic law as well11. Given the Strasbourg mandate of State neutrality as between religions and non-religious beliefs one might have expected the Government to abandon any separate definition of ‘religion’ when it prepared its reform of charity law and instead to look for a definition of ‘religion or belief’ as a single concept. Not so: when the Charities Bill was being drafted and going through Parliament we in Humanists UK lobbied intensely but in vain for ‘advancement of religion’ to be extended to ‘advancement of religion or belief’ with a definition of belief by reference to Human Rights Act .

We did not give up when the Bill was passed unamended but sought to persuade the Charity Commission that, as a public authority, it was bound by section 6 of the Human Rights Act to act as if the law had been amended as we wished. This led to a friendly meeting after which at their request we submitted a paper12 to them which argued that the old definition of ‘religion’ was in terminal trouble and proposed instead a definition of the portmanteau term ‘religion or belief’.

In doing so we tackled the problem of the wide meaning of ‘belief’ in human rights law (for example, Lord Walker in re Williamson had said ‘Pacifism, vegetarianism and total abstinence from alcohol are uncontroversial examples of beliefs which would fall within article 9’). Such a wide application of the word ‘belief’ is obviously welcome where it is a matter of defending someone against unjustified discrimination but it is decidedly not suitable for application when you are conferring a legal privilege such as charity status. There seemed – and seems – no reason why the term should not bear different meanings in different legal contexts, especially where one – recognition as a charity – is so clearly distinct and delimitable.

We demonstrated that the privilege could be limited in charity law to types of belief analogous to religion. This is arguably what English law should do anyway, given that the word ‘belief’ in the Convention, so wide in reference in the English language, is ‘conviction’ in French and ‘Weltanschauung’ in German – far more narrowly defined concepts. Beliefs not analogous to religion might of course qualify under some other head of charity (as perhaps might pacifism or vegetarianism); others again might not qualify for charity status at all.

We drew on sources such as these in preparing our proposals to the Commission:

  • Convention jurisprudence suggests that beliefs must have certain qualities before they qualify for protection. – Baroness Hale in re Williamson [2005] UKHL 15
  • [Belief means] more than just ‘mere opinions or deeply held feelings’; there must be a holding of spiritual or philosophical convictions which have an identifiable formal content. – Thomas McFeeley & Ors v United Kingdom – 8317/78 [1984] ECHR 23
  • The term ‘beliefs’ . . . denotes a certain level of cogency, seriousness, cohesion and importance. – Campbell and Cosans v. UK: (1982), 4 EHRR 293
  • ‘belief’ means a collective belief in, or other adherence to, a systemised set of ethical or philosophical principles or of mystical or transcendental doctrines. – Communications Act 2003 (sn.264)

Further, given that the courts are obviously debarred from passing judgement on the validity of a religion or belief, we offered a definition that referred to the function and form of the religion or belief rather than to its content.

We posited that the common characteristics of religions and those non-religious beliefs within the relevant range were that:

1 – They make claims about the nature of the world we live in and of human life; and

2 – They draw implications for the way one should live – typically establishing a basis for morality and values.

Both elements are important: a free-floating ethical code without connection to claims about the nature of the world would fall short of what is required (though it might qualify for charitable status by some other route). Equally, claims about the nature of the world are what scientists advance all the time. It is the relatedness of the claims to the ethics that is distinctive.

We therefore proposed a definition for a ‘religion or belief’on these lines:

A collective belief that attains a sufficient level of cogency, seriousness, cohesion and importance and that relates the nature of life and the world to morality, values and/or the way its believers should live.

This categorises religions as beliefs, which is valid whereas the reverse is not. The ‘and/or’ formulation is needed because some beliefs put a predominant emphasis on orthopraxy rather than orthodoxy or moral behaviour. And the limitation to believers of the teachings about how to live is needed because some beliefs confine their rules in that way – e.g., Judaism does not seek to apply its rules to gentiles.

It is incidentally worth taking note of the extensive overlap of our definition of ‘religion or belief’ with the description of ‘religion’ provided six years later by Lord Toulson in the Hodkin case – see the emboldened words in his text quoted above.

Our proposals were taken seriously by the Commission but (needless to say) not agreed. Nevertheless, in 2008 they did tinker with some Supplementary Guidance on Public Benefit and the Advancement of Moral or Ethical Belief Systems before abandoning it. However, after consideration involving prolonged internal discussions, the Commission finally agreed in 2011 revised objects for Humanists UK which ditched the ‘mental and moral improvement of the human race’ in favour explicitly of ‘the advancement of Humanism’, which was then defined.13

It could be said therefore that in practical terms we had achieved parity with religious charities. However, true parity is another matter altogether because of the way the law on public benefit operates.

Public Benefit

The plain intention of the Government and Parliament in 2006 was that there should be an end to the long-standing presumption of public benefit in the advancement of religion and education.

The Act said that there was to be no presumption, as previously, that any category of charity was for the public benefit: benefit had to be demonstrated.14 We took part in conferences and consultations in 2007 about the manner in which the Commission might assess benefit and disbenefit in religious charities and I gave oral evidence to the Public Administration Select Committee15 when they conducted a short enquiry on religion and public benefit.

In 2008 the Commission produced its guidance on public benefit, including The Advancement of Religion for the Public Benefit. However, thanks to resistance by the public schools16 and the Preston Down Trust (one manifestation of the Exclusive Brethren)17 and thanks in the former case to the conservatism of the courts who misused a general provision in the Act for continuity to negate an explicit statutory change and in the latter to the pusillanimity of the Commission, the will of Parliament was frustrated and the presumption of public benefit was in effect resurrected – while public disbenefit is again largely ignored.

The Commission’s guidance is still on its website but for years it has carried the rider ‘This guidance is currently under review. It no longer forms part of our public benefit guidance…’ and an attempt in 2017 via a Freedom of Information request to get them to explain the position was contemptuously brushed aside. Meantime in 2013 the National Audit Office had produced a damning report on ‘The regulatory effectiveness of the Charity Commission’.18

Thus despite Parliament’s wish in 2006, repeated in the 2011 Act, that religious charities should have to prove their public benefit, that test has been watered down so as to become almost meaningless and the Commission has rolled over, perpetuating its eternal ineffectiveness.

The result is that, while most charities, including certainly humanist ones, have to demonstrate explicitly the public benefits they produce in return for their substantial tax privileges and GiftAid, many religious charities remain securely on the register that either produce no obvious benefit to the public or arguably actually produce a net disbenefit.19

Ignore for the moment those that preach that the cause of rape is women wearing trousers20, or that promote gay conversion therapy21, or that split up families by ‘shunning’ members who break their stringent rules22, or that call for sinners of various stripes to be stoned to death23, or that peddle quack medicine24 or that run a lucrative business making strong and addictive alcoholic drinks and paying their directors – all religious ministers – over £2.5m in fees annually.25 Ignore also that the Charity Commission continues to recognise as charities unregistered religious schools that the Department for Education and Ofsted are persistently trying to close down, such as Talmud Torah Tashbar, a strictly Orthodox Charedi Jewish school for boys aged 3-13.26

Consider instead only those charities that simply promote their own beliefs or practise their own rituals. Research by the National Secular Society from 2019 found that out of the 165 religious charities with an annual income of over £10 million, over 25% list no objectives apart from religious activities.27

And as the Commission says in its guidance28:

… ways in which charities can advance religion include:
seeking new followers or adherents…
the conducting of religious ceremonies…
the saying of masses open to the public…
’passive advancement’, meaning leaving religious buildings open for people to enter and benefit from personal spiritual contemplation
advancing belief in a particular miracle or miracles…
producing and promoting religious books…
religious devotional acts…

These are selected examples – but each of them is seen as charitable and can stand alone as an organisation’s object and attract the privilege of public financial support as a result. Many such charities are concerned solely with trying to convert people from their current beliefs – or unbelief – at the proven risk of causing upset and division. For example, the International Mission to Jewish People can spend its time ‘sharing the Good News of Jesus the Messiah with the Jewish people’.29 On a far larger scale, the British and Foreign Bible Society spends about £20m a year30 and the Watch Tower Bible and Tract Society of Britain (Jehovah’s Witnesses)31 almost £100m a year purely on evangelism: promoting their beliefs. You could well argue that the Church Commissioners for England32 are in the same business and they spend well over £200m a year.

This proselytising and propaganda is partly paid for from public funds through tax exemptions and GiftAid, supporting highly controversial beliefs and producing very little if any demonstrable public benefit.

Yet when it came to the tiny Cult Information Centre that aims to educate the public about the dubious activities of some religious organisations, the Commission complained that they had entrenched views!

The problem is that the CIC’s education work seems to be coming from a pre-conceived standpoint whereas, when we granted charitable status, we specified that any educational work needs to be objective and factual.33

There is a serious double standard operating here: you can promote just about any zany religious belief but the Commission will pounce on you if you take an educational stand against such nonsense.

So finally I am inclined to come full circle and agree with 1965’s irate Kensington ratepayer – why should the taxpayer subsidise the propagation of beliefs of any kind – including humanism?

What is valuable in a charity is public benefit of a genuinely identifiable kind. A narrower definition, dispensing with the advancement of religion or non-religious belief as such, would leave a wide scope for advancement of education about the religion’s beliefs, but this needs to be combined with a far more intense scrutiny of claims of benefit. There would be scope for a huge range of ‘good works’ of genuine public benefit but in every case this would need to be demonstrable – indeed, demonstrated. Charities are required to be exclusively charitable, and so in the time honoured fashion some current religion and belief charities might have to split themselves into charitable and non-charitable wings. Those that lost out would probably survive, but the great majority of religious – and humanist – charities would have no difficulty in proving their genuine public benefit.

Such a development would be vastly preferable to indiscriminate largesse to ‘propagandist’ organisations such as those I have cited and many thousands more. Sadly it is of course profoundly unlikely.

Meantime, I commend the concept of the portmanteau concept of a ‘religion or belief’ and the idea of drawing no legal distinction between religious beliefs (some of them having no gods) and non-religious beliefs such as Humanism.

21 July 2021


1. Fishman, James J., ‘The Political Use of Private Benevolence: The Statute of Charitable Uses’ (2008). Pace Law Faculty Publications (Paper 487), and on which I rely for other details on the Statute.

2. Religious and other (‘exempt’) funds not covered by the Preamble continued to be subject to control by complaint to the attorney-general who could take action in Chancery. After the Restoration this route largely replaced the local Charity Commissioners.

3. Income Tax Special Commissioners v Pemsel: [1891] AC 531.

4. re South Place Ethical Society [1980] 1 WLR 1565.

5. ‘The mental and moral improvement of the human race by means of the advancement of Humanism, that is to say, the moral and social development of the community free from theistic and dogmatic beliefs and doctrines’.

6. Charities Act 2006, sn 2(3).

7. Lord Toulson in Hodkin & Anor, R (on the application of) v Registrar-General of Births, Deaths and Marriages [2013] UKSC 77 77 at 57.

8. R v Registrar General ex parte Segerdal and another, [1970] 3 All ER 886.

9. Neville Estates v. Madden [1962] Ch 832.

10. ‘[Article 9] is, in its religious dimension, one of the most vital elements that go to make up the identity of believers and their conception of life, but it is also a precious asset for atheists, sceptics and the unconcerned. The pluralism indissociable from a democratic society, which has been dearly won over the centuries, depends on it.’ – Kokkinakis v Greece: (1994) 17 EHRR 397, para 31.

11. ‘[T]he difficult question of the criteria to be applied in deciding whether a belief is to be characterised as religious . . . will seldom, if ever, arise under the European Convention. . . it does not matter whether the . . . beliefs . . . are categorised as religious. Article 9 embraces freedom of thought, conscience and religion. The atheist, the agnostic, and the sceptic are as much entitled to freedom to hold and manifest their beliefs as the theist. These beliefs are placed on an equal footing for the purpose of this guaranteed freedom.’ – Lord Nicholls in re Williamson [2005] UKHL 15.

12. ‘Religion and Non-Religious Beliefs in Charity Law’ (2007) – see

13. ‘The advancement of Humanism, namely a non-religious ethical lifestance the essential elements of which are a commitment to human wellbeing and a reliance on reason, experience and a naturalistic view of the world.’

14. ‘In determining whether that requirement is satisfied in relation to any such purpose, it is not to be presumed that a purpose of a particular description is for the public benefit.’ – Charities Act 2006, section 3(2), replaced with near-identical wording by Charities Act 2011, section 4(2).


16. The Independent Schools Council v The Charity Commission for England and Wales, The National Council for Voluntary Organisations, HM Attorney General and Others: [2011] UKUT 421 (TCC) – and see commentary in Charlotte Kynaston: ‘The Impact of the Charities Act 2006 on Private Schools’ (

17. Charity Commission: ‘Summary of the Decision of the Charity Commission for England and Wales made on 3 January 2014: Application for Registration As A Charity by The Preston Down Trust’ – See also Frank Cranmer: ‘Exclusive Brethren & Preston Down: Charity Commission to accept application for registration’ (Law & Religion UK: 10 January 2014) –

18. ‘The Commission continues to make little use of its statutory enforcement powers… The Commission can be slow to act when investigating regulatory concerns… The Commission does not take tough enough action in some of the most serious regulatory cases… The Commission relies heavily on trustees’ assurances, but should do more to check whether trustees have actually complied… The Commission is reactive rather than proactive, making insufficient use of the information it holds to identify risk…’ – National Audit Office: The regulatory effectiveness of the Charity Commission, HC 813 December 2013.

19. The distinction was neatly drawn by Lord Greene MR in the Court of Appeal in Gilmour v Coats [1949] A.C. 426: ‘The contrary of ‘beneficial to the public’ is not ‘detrimental to the public’, but ‘non-beneficial to the public’.’

20. The Holiness Revival Movement Worldwide Europe: see Andrew Penman: Why do religious groups that spout vile views while doing no public good get charitable status? Daily Mirror, 17 June 2021:

21. In April 2021 the Charity Commission for Northern Ireland gave the Core Issues Trust the all-clear for its gay conversion therapy activities – it was ‘not the role of the Commission to adopt a position on the charity’s conduct in this matter’.

22. The Preston Down Trust was registered after reportedly spending £2m on legal action and lobbying despite their restricting contact with non-members, shunning members who break their rules and so on. On their heels another 130 or more Exclusive Brethren congregations have got registered as charities. Echoing the Public Administration Select Committee, Paul Flynn MP denounced the Commission: ‘You climbed down because you didn’t want the financial and legal problems. You’ve become weakened and emasculated. You agreed to surrender your previous principled position in exchange for an easy life. You aren’t going to turn anyone down again because you’ve become cowardly as a result of the might of a lobbying organisation.’ – see ‘Charity Commission criticised for action on Plymouth Brethren case’

23. The Islamic Education and Research Academy called for homosexuals and female adulterers to be stoned to death; it was associated with organisations and individuals who ‘encourage or support terrorism and/or extremist views’ – see Camilla Turner: ‘Leading Islamic charity told by watchdog to distance itself from extremism’ (Daily Telegraph 12 November 2016) –

24. The Kingdom Church GB sold alleged COVID-19 ‘cures’ labelled ‘plague protection kits’ for £91 – ‘Charity regulator launches inquiry into church found promoting fake Covid-19 protection kits’ –

25. Buckfast Abbey Trust, with an objective ‘to promote or maintain any charitable purpose connected with the Roman Catholic religion’, runs a lucrative business making the strong caffeine-infused alcoholic drink called Buckfast Tonic Wine which is notorious for its association with anti-social behaviour. Alex Neil MSP has denounced it: ‘Buckfast has been the scourge of my constituency… for a great number of years…’ – ‘MSP reveals concerns that Antiques Roadshow will promote infamous Buckfast drink’ (2018) – In 2016, the charity’s trading arm, J Chandler (Buckfast) Ltd, employed just 28 people yet paid an average of £144,984 to each person. Directors’ fees exceeded £2.5million in 2013. Directors and past directors include those described in formal documents as ministers of religion. The Commission decided in 2017 that regulatory action was not required. (National Secular Society: ‘For the Public Benefit?’ (2019) –

26. In 2016 Humanists UK revealed that eight illegal Charedi schools, including Talmud Torah Tashbar, were registered as charities despite the education they provided being essentially entirely scripture-based with extremely limited teaching of any secular subjects, often leaving pupils unable to speak English. Five years later the Charity Commission had still not completed its enquiries into these schools, which remained registered as charities and thus subsidised by public funds despite their illegal operation. In particular, in the three consecutive years from 2012-2014, Ofsted had produced pre-registration inspection reports rejecting applications from Talmud Torah Tashbar to register as a private school. The reports detailed significant failings at the school, founded in 1976, including a curriculum which as a matter of religious principle ‘does not provide lessons in written or spoken English’ or provide any secular education and which ‘encourages cultural and ethnic insularity’. See ‘BHA repeats calls for crackdown on illegal ‘faith’ schools in response to Government consultation’ (, ‘BHA exposé: unregistered ‘faith’ schools enjoying charitable status despite operating illegally’ ( and ‘Charity Commission still investigating charities operating suspected illegal schools five years after being alerted to them’ (

27. National Secular Society, op.cit.

28. Charity Commission: ‘The Advancement of Religion for the Public Benefit’ –





33. See and ‘Cults watchdog faces danger of being shut down’ (The Observer, 4 March 2012 – and ‘UK: Cult information charity faces Charity Commission curb, reportedly after Scientology complaint’ (Religion News, 13 January 2012 –