Developed in the early 1950s by science fiction writer L. Ron Hubbard, Scientology was part of the larger postwar therapeutic culture that blended religion and psychology in a search for mental well-being. Unlike contemporaneous self-help gurus such as Norman Vincent Peale and Harry Overstreet, however, Hubbard painted a much bleaker portrait of modern life, one rife with forces of psychological and social control. Railing against communists, homosexuals, and feminists as well as against the decay of the family and the rise of the welfare state, Hubbard argued that Americans suffered from a waning sense of ontological security, living in a world that provided no support for self-identity. Hubbard refused, however, to shrink from such changes and lapse into nostalgia for a pre-modern, pre-technological world like Peale and others did; instead, he offered a way for individuals to appropriate the dynamism of modernity for themselves. As advanced industrialization erased distances between societies, revolutionized transportation, and computerized information systems, Hubbard reimagined the self as spiritual being possessing precisely those powers to manipulate time and space and to remake the world at large. Borrowing freely from Eastern religious ideas, cybernetic theory, and German idealism, Hubbard produced a philosophy that was staunchly libertarian, spiritual, and future-oriented, one that tapped into Cold War fears about psychological manipulation and waning personal autonomy and into dreams about the immanent power of human beings.

At first glance, it appeared to be a technical and dry decision about the operation of the Places of Worship Registration Act 1855, yet the Supreme Court judgment in R (on the Application of Hodkin) v Registrar General of Births, Deaths and Marriages was actually one of the most significant decisions related to law and religion in 2013. The Justices of the Supreme Court held that a church within the Church of Scientology could be a ‘place of meeting for religious worship’ within section 2 of the 1855 Act. In so doing, the Supreme Court overruled one of the most well-known decisions in English religion law, R v Registrar General, ex parte Segerdal. In Segerdal, although the Court of Appeal had held that a chapel within the Church of Scientology could not be registered under the Act, the reasoning of their Lordships differed: Buckley LJ and Winn LJ focused on what they perceived to be the lack of ‘worship’, refusing to define the ‘chameleon word’ religion, while Lord Denning emphasised the phrase ‘religious worship’, holding that this required ‘reverence or veneration of God or a Supreme Being’ and that this was not met in the case of the Church of Scientology, which was ‘more a philosophy on the existence of man or of life than a religion’. All of these statements have been questioned by the bold Supreme Court judgment in Hodkin, which provides guidance on how the terms ‘religion’ and ‘religious worship’ are to be understood by English law in the twenty-first century.