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February 29, 2012

宗教法人代表資格は訴訟問題か

包括宗教法人(本山)は末寺に住職を派遣する。本山の最高権威者は「法主」と呼ばれる。その宗教活動を統括する者は「管長」と呼ばれる。管長は通常,法主が就任する。管長は宗教法人の代表者を兼任する。末寺の住職はその管長が任免する。そして末寺の代表役員は,末寺の住職が就任する。
 さて,日蓮正宗の法主兼管長Aが在位のまま死亡した。包括宗教法人の緊急会議が開かれ,大僧都Bが,亡きAから「次はお前だ」と言われていたと述べた。僧侶及び信徒の多くがそう思い,Bが新法主兼官長に就任することに異議を唱えなかった。
ところが,一部の僧侶が組織を結成し,指導部と対立するようになったため,B側はこれに対抗して一部の僧侶を宗規に基づいて僧籍を剥奪の懲戒処分にした。
 問題となった末寺には,亡くなった管長からD住職が派遣・任命されていた。Dは寺院の建物等を占有した。このAが本山に反対する組織に所属して活動していたため,法主兼管長はDの僧籍を剥奪し,後任の住職兼代表役員を任命した。そこから裁判が始まった。
 末寺側はDに建物明渡を,末寺住職兼代表役員はその地位確認を請求し(同様の裁判は全国の日蓮正宗の寺院で行われた),どちらの訴えも却下された。そのため,Dはその後も末寺を占有し管理し続けた。
しばらくしてDは体調を崩し,Yに住職を譲って建物から退去したあと亡くなった。
本山では,その末寺の住職にEを任命した。Eは代表役員として登記もされた。本件建物明渡請求の原告は宗教法人X,被告は占有している僧侶Yである。
 宗教法人X本山法主 A → B → C (Eを末寺住職に任命)
 同      末寺住職 D(Aが任命) → Y
XはYに末寺建物等の明渡を求めた。これに対し,YはEを住職に任命した管長B自身が,そもそも先代Aから正式の血脈承継を受けていないから,Eを任命する資格もない,つまりEには末寺を代表する権限がない,と争った。
 訴状には,Yは包括宗教法人の正当な代表者によって任命された住職ではない,したがって占有権限がない,と書かれている。これに対し,Yは亡Dから寺務を委任された,Xこそ血脈承継を受けていない者の任命した住職だから末寺を代表する資格はない,と反論した。X.,Y双方が,相手方を任命した者の任命権を争っているのである。
 一審の京都地裁は,Xを住職兼管長に任命した法主の包括宗教法人の代表権限が証明されていない以上(その理由も裁判所の裁判権が及ばないという奇怪なもの),Xの代表権限も証明されていないとして明渡請求を却下した。Xは控訴し,高裁判決(大高平22.1.28)は次のように判決した。
 それぞれの代表権限の由来に争いはあっても,30年以上に亘って,法主が包括宗教法人の管長として被包括宗教法人の代表役員の任命を繰り返し,そのように宗教活動を行っている。つまりそれが,宗教法人としての自治的決定内容である。明渡請求を行う末寺宗教法人の代表者が誰であるかによって,請求の当否に違いが生じるものではない。法主やそこから法主を引き継いだ新法主が管長である秩序が成立しているのだからそれを尊重すべきだ。
 裁判は宗教を裁けない(最判平1.9.8,平5.9.7,平11.1.29,平14.2.22ほか)。
しかし,事案は宗教の内容ではなく,代表権の有無である。
代表者が誰かは,教義の争いではない。こうして,明渡請求を判断せずに,一審に差戻した。なるほど,宗教法人の裁判が全て宗教問題になるわけではない。金の貸借は宗教問題ではないし,民事上の紛争は宗教とは関係ない。どちらが法人役員かは,「血脈承継」を持ち出すと宗教問題になるが,法人登記をみれば,一応裁判できる。登記に推定力はないとは言え,明渡しの可否を判断するのに中心に役員資格が決め手になるとは思えない。
宗教法人の紛争は,どちらが本家か,という本論外の紛争に跳び易いことが分かる。
訴訟要件が請求の当否を判断する前提問題となっている場合,裁判所がどこまで「血脈承継」に立ち入ることができるのか。Eを任命した管長が包括宗教法人の代表資格を持っていなかった場合,Eは末寺代表者として裁判を起こす事ができない。
 高裁はそこの部分に踏み込まなかった。宗教法人内に新秩序が成立していることを理由に,Eの末寺住職の地位を認めた。結果的に,血脈論争,本家論争を避けたのである。宗教法人内の紛争はすべて裁判にならない,前提問題であっても裁判にはならない,というのは常識に合わない。いま成立している秩序が法的にも正しいものと一応認められる,というのも弥縫的解釈にすぎる。先に「秩序」を確立した方が優位に立つ,というのは,法人格を認められた組織として組織原理が正しく働いているかもチェックできない,ということにならないか。

次は,臨済宗妙心寺(大本山・妙心寺)の末寺住職の懲戒免職事件。
京都市右京区の末寺住職が懲戒免職された件で,地裁,高裁は懲戒免職決議を記載した議事録が偽造だと認定したようだ。ただし,詳細は判決を閲覧できていないから分からない。
妙心寺側は上告受理申立てをしている。平成20年7月3日,末寺は妙心寺派からの離脱を決議し,7日にその旨を大本山に通知した。
 大本山は,この住職を懲戒免職にする7月1日付の文書を,15日に住職に交付し寺の明け渡しを求めた。大本山は最高幹部6人が免職処分を決めたという議事録や審判判定書を裁判所に提出したようだ。22年10月,京都地裁は「7月1日に本人に聞かずに処分したという妙心寺本山の説明は拙速に過ぎ,処分はないと考えるのが合理的だ」と明け渡し請求を退けた。23年6月の大阪高裁判決も「日付を7月1日に遡らせているのは,処分の真の目的は離脱の阻止の隠蔽にあると推認できる」として,本山側の控訴を退けた。
本山側は懲戒処分と離脱決議は関係ない,職務を放棄していたからだ,と主張している。
これは宗教問題ではない。懲戒処分が手続的に有効か無効か(つまり今も住職か)の手続の瑕疵又は処分の有無を争う問題だから,裁判になじむ。懲戒を決める責任役員の会合が開かれたのかが論点になっているようだが,離脱決議の2日前に懲戒処分したというのは,タイミングが悪すぎはしないか。

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