The Court held on the evidence that the teachings of Rudolf Steiner advanced by the Anthroposophical Society of Great Britain were directed to “the mental or moral improvement of man,” an aim which constituted a “charitable” purpose, and that its activities served a “public benefit”.
Source: Analysis of the law underpinning Public Benefit and the Advancement of Moral or Ethical Belief Systems.
Legal Analysis by UK Charities Commission (Annex, Digest of Cases) pp. 8-9. September 2008.
Re Price  1 Ch. 422-435.
A bequest was made to the Anthroposophical Society in Great Britain [“ASGB”] to be “used at the discretion of the chairman and executive council of the society for carrying on the teachings of the founder, Dr. Rudolf Steiner” (variously described by Steiner as “spiritual science” and “anthroposophy” – the wisdom of mankind).
The society was an unincorporated voluntary association founded in 1923 at a meeting at which Dr. Rudolf Steiner was appointed president for life. Its constitution was divided into three parts, statutes, rules and bye-laws. The statutes were in the following terms:
“2. The aim of the society is to form, in the words of Rudolf Steiner, a union of human beings who desire to further the life of the soul, both in the individual and in human society, on the basis of a true knowledge of the spiritual world.
“The society will endeavour to fulfil its tasks:
“(a) by providing adequate facilities for individual study and mutual aid in the study of spiritual science;
“(b) by encouraging practical activities which will bring into the civilisation of our time the beneficial results of spiritual science….
“5. The society is an entirely public organization and in no sense a secret society. It was averse to any sectarian tendency and does not consider politics to be among its tasks. A dogmatic position in any sphere whatsoever should be excluded from the society.”
In his affidavit, Mr Harwood, who is the teacher in the principal school conducted on Rudolf Steiner’s education principles, stated:
“The teachings of Steiner are directed to the extension of knowledge of the spiritual in man and the universe generally and of the interaction of the spiritual and the physical. He sought to show both how this knowledge could be acquired and how it could be applied for the benefit of man in a wide range of activities. It could be acquired, he taught, by the development of consciousness and with it of the perceptive faculties. He expounded a theory of knowledge, the philosophical basis of which is set forth by Steiner in certain of his books, in particular The Philosophy of Spiritual Activity. In such books he sought to show the the capacity of man for spiritual development leading to wider knowledge of the spiritual or supersensible in the world at large. In other books Steiner taught a method of mental and moral discipline designed to train the imaginative, creative and devotional faculties of the mind and so to develop the faculties of spiritual intuition and perception…. Steiner taught and developed the application of this knowledge to religion and education generally including medicine, art and agriculture.”
Evidence [was provided] that the sole purpose for which the society [ASGB] actually carried on was to carry on the teachings of Dr Rudolf Steiner. But this was not the only object that the society had or could have (power to amend). It [the bequest] was held not to be an absolute gift to society. But, even if there was a trust, it did not tend to a perpetuity since there was nothing to prevent members from spending it immediately for the benefit of the class intended. There was the necessary certainty as to the purpose on which the bequest was to be expended (so the court could come to a conclusion as to the propriety of any item of expenditure that might be challenged). The area and content of Steiner’s teachings were not so vague and indeterminate as to impede this.
[The Court] “Held [on the evidence presented] (1) that, under the terms of the will, … the bequest was valid” and ”
(2) that it was a valid charitable gift.” The teachings of Rudolf Steiner were taken to be directed to the mental or moral improvement of man.
Comments by SPCS:
The aim of ASGM (quoted above) is extremely broad and embodied concepts which would be considered vague and incomprehensible to mainstream science today, such as the concept that society itself, in contrast to the individual, actually possesses a “soul” whose spiritual life, can be furthered, enhanced and enriched through the study of “spiritual science”. While some philosophers such as Teilhard de Chardin have espoused the concept of a “world soul”, few philosophers would treat such an extrapolation of the individual soul to the “soul” of a society or civilisation, as nothing more than metaphor or literary devise, even if they did hold to the metaphysical reality of an individual human soul.
Mainstream scientists find terms such as “spiritual science” to be an oxymoron: science can only deal with facts that are verifiable applying the empirical method, while scientific theories are required to pass the falsifiability test. The notion of a “spiritual” world is utterly alien to the language of discourse in mainstream science.
Despite all these reservations, the court found Steiner’s teachings were directed to the mental or moral improvement of man. The Anthroposophical Society therefore, in promoting the “beneficial results of spiritual science”, clearly qualified as a genuine charity advancing charitable purposes.
The second means listed by ASGB to achieve this aim – “encouraging practical activities which will bring into the civilisation of our time the beneficial results of spiritual science” (emphasis added) is very similar to those of SPCS, which include:
2(a) “to encourage self-respect and the dignity of the human person made in the image of God”… 2(b) to promote recognition of the sanctity of human life and its preservation …. 2(c) … to promote the benefits of lasting marriage…. wholesome personal values… etc.
All SPCS objects presuppose the notion that society stands to see beneficial results if individuals and groups embrace a lifestyle and behaviour that is based on a good moral foundations and one that aspires to a “spiritual” understanding of relationships both with fellow-man and his Creator (see s. 2[a] – “The human person made in the image of God”).
Like ASGB, SPCS is an a public organisation and is in no sense a secret society. It is averse to any sectarian tendency and has never considered party politics to be among its tasks. A dogmatic position in any sphere whatsoever is excluded from the SPCS, in the sense that it recognises the merits of “responsible freedom of expression” (s. 2[f] of its objects) that derives from the celebration of free will as one of the gifts humans are endowed with by their Creator.
Steiner taught a “method of mental and moral discipline” in the belief that adherence to it by individuals would benefit them and society at large. SPCS has as one of its objects: “To foster public awareness of the benefits to social, economic and moral welfare of community standards …” For individuals to adhere to community standards a certain degree of “mental and moral discipline” is obviously required. Legislation establishes the boundaries in law, and each time enforcement is applied to ensure adherence to these limits, society, in effect expresses its desire that its citizens apply “mental and moral discipline” to advance the “public good”.
SPCS has objects that are in part directed to the “mental or moral improvement of man” – a broad concept no doubt – but one that seeks to promote “the public good”. For example, by advancing its case for “the recognition of the sanctity of human life and its preservation in all stages” (s. 2[b] of its objects), SPCS is merely holding up the same ideals as embodied in, for example, the Hippocratic Oath, that all physicians and healthcare professionals swear to uphold when carrying out their duties, and The United Nations Declaration on Human Rights, which must be adhered to by all member states.
Reference: In re Price
Midland Bank Executor and Trustee Company, Limited v. Harwood.
J. Cohen 1943.