(Russian)
C O M P L A I N T (in the procedure stipulated by Article 14 of the Federal Law "On the Freedom of Conscience and Religious Associations") for the liquidation of the religious The prosecutor's office of the Northern Administrative Circuit of the city of Moscow has reviewed the declaration of T. I. Kushnirskaya, chairman of the Youth Salvation Committee, on the negative effects of the influence of the religious organization "Jehovah's Witnesses" on those who have been drawn into it, as well as a number of violations of current legislation by the given religious organization. It has been established that the religious community "Jehovah's Witnesses", located at ul. Mikhalkovskaya 36, was registered as a legal entity by the Justice Administration of the city of Moscow on December 30, 1993 under registration no. 432. The review conducted by the circuit prosecutor's office has uncovered significant disparities between the registered Statute of the Religious Community of Jehovah's Witnesses in Moscow and the actual practical everyday activity of the organization, as well as systematic violations of Article 14, Item 2 of the Russian Federation Law "On the Freedom of Conscience and Religious Association" by the religious community of Jehovah's Witnesses. Thus, Item 1.2 of the Statute states: "The Community acts on the basis of the Law 'On the Freedom on Religion' ..., and in observance of the Constitution and legislation of the Russian Federation". According to the Constitution of the Russian Federation and the Federal Law "On the Freedom of Conscience and Religious Associations", religious organizations are prohibited from: 1. Fomenting religious discord. Its religious literature, which is mandatory study material for believers, contains tenets claiming that Jehovah's Witnesses are the only true religion; all others are declared to be false and their imminent end is predicted. All those who do not practice the religion of Jehovah's Witnesses are called "goatlike" or "supporters of Satan's world", which cannot help but insult the sensibilities of other believers that do not espouse the doctrines of Jehovah's Witnesses. 2. Coercion to destroy the family. Jehovah's Witnesses demand that individuals relinquish all personal ties outside the organization. All aspects of the traditional way of life, such as collective and personal holidays (birthdays, anniversaries, funerals, and so forth), are called "tests to one's faith". In the event that a member of one's family does not wish to become a member of the community, and especially if this is accompanied by critical statements about Jehovah's Witnesses, discord sets in within the family. Since those who do not espouse the religion of Jehovah's Witnesses are represented as Satan's world, they cease to be loved ones. In essence the community attempts to take the place of the member's true family. Thus, for example, the following is written on the identity card of Natalya Zhuravlyova, a minor: "As parents we are deeply interested in the welfare of our child. Due to our convictions, we, as a family of Jehovah's Witnesses, refuse blood transfusions..." This is in spite of the fact that Yuriy Alekseyevich Zhuravlyov, the girl's father, has not been stripped of his parental rights and is categorically against the mother involving the child in the religious community's activity. The leaders of the religious organization, in encouraging members of the community to dedicate the greater part of their time to the community, its rituals, and beliefs, in doing so on the one hand force them to undermine all contact with people who might be able to seed doubt or awaken critical feelings, and on the other hand, all this leads to violations of family duties [sic]. 3. Inclining one to suicide or refusal to render medical assistance to individuals in a life or health threatening condition for religious motives. The religious organization of Jehovah's Witnesses categorically forbids its followers to accept medical assistance in the form of blood transfusions and treatment with medicinal preparations containing blood. Each believer is directed to carry with him a "Medical Document", whereas minors are to carry an "Identity Card", on which the words "NO BLOOD" are written in bold lettering accompanied by text in accordance with which orders are given to not administer a blood transfusion regardless of the patient's condition and even when there exists a lethal risk. A. N. Solovyov, director of the Moscow Health Department, in response to the inquiry of T. I. Kushirskaya, reported that the department has in its possession information from the head doctors of institutions of prophylactic medicine of the city concerning the refusal of blood transfusions and blood components by patients and their relatives who are members of the community of Jehovah's Witnesses. Thus, in 1996 the patient P. V. Semitko was hospitalized in City Hospital No. 40. The grave condition of P. V. Semitko required immediate treatment with blood components. However, the patient categorically refused, and gave religious convictions as the grounds for her refusal. The letter of M. I. Fyodorova, N. M. Omelyanenko, and A. B. Batalova, doctors at City Hospital No. 40, shows that the patient was repeatedly visited by "brothers" in the faith - Jehovah's Witnesses, who exerted crude pressure on him, and also tried to force the treating doctor from performing [sic] vitally necessary therapy. 4. Infringements on the individual and the rights and freedoms of citizens. Each candidate for service in Bethel is handed an application with a letter from the Governing Committee, which states: "... Do not think that you will be able to act according to your own will or as independently as you do now. You will have to subordinate your personal desires and tendencies and you will have to adapt to the demands of close cooperation with a large number of other people in order to be able to fulfill the service tasks assigned to you... Even if you have certain abilities or experience in a professional field, in Bethel you will receive your assignment according to what is needed." In this way such instructions by the organization of Jehovah's Witnesses belittle the human dignity of the individual, which is protected by the state (Article 21 of the Russian Federation Constitution). 5. In accordance with the Statute of the Religious Community of Jehovah's Witnesses registered in the procedure established by law, members of this religious organization are: "Item 3.1. ... adult believers that have become Jehovah's Witnesses through their voluntary dedication to God and subsequent water baptism." However, in defiance of current legislation and its own Charter (see point above), teenagers and even young children are drawn into the activity of the organization as its active members, which is confirmed by the numerous declarations of citizens who are close relatives of [these] minors, as well as by the organization's own literature, the study of which is mandatory for all. For example, in the book Organized to Accomplish Our Ministry on page 101 it is stated that "baptized publishers who are attending school, ... can go out in service during school vacations or when there are no classes due to worldly holidays"; the book [sic] Our Kingdom Ministry states on page 3: "Students need to preach in school, ... during recess, ... during holidays, regularly attend the meetings, striving to serve full-time." On page 150 of the book Organized to Accomplish Our Ministry it is written that "serious wrongdoing by minor baptized members of the congregation should be reported to the elders." The drawing of children into the organization, as a rule, takes place without the consent of the second parent, and any attempts to return the child to an ordinary life are interpreted by the other side as nothing other than the interference of Satan. On the basis of that which has been set forth above, and taking into consideration the expert conclusions on the content of the teachings and practice of the activity of the religious organization "Jehovah's Witnesses" that have been prepared by specialists I. A. Galitskaya and I. V. Metlik with the religious studies research group at the Institute for Development of the Individual of the Russian Academy of Education, and F. V. Kondratyev, doctor of medical sciences, professor at the State Scientific Center of Social and Forensic Psychiatry, and Russian doctor emeritus, and F. R. Ovsiyenko, doctor of philosophical sciences, professor of the religious studies department of the Russian Civil Service Academy with the President of the Russian Federation, and governed by Article 14 of the Federal Law "On the Freedom of Conscience and Religious Associations", and Articles 22 and 27 of the Russian Federation Law "On the Prosecutor's Office of the Russian Federation", I REQUEST: that the Religious Community of Jehovah's Witnesses be liquidated as a legal entity and the activity of the religious organization of Jehovah's Witnesses be banned in the city of Moscow. Attachment: 80 pages. I ask that the following be called to the court hearing: 1. T. A. Aydinova, Leningradskiy pr. 35, apt. 8 Prosecutor of the Northern
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