In finding that the Minister was correct that the establishing of a sanctuary and sculpture park did not constitute a charity for religious purposes, Noël CJ stated (at para. 5):
[T]he concept of "Oneness of Reality" advanced by the appellant is so broad and vague as to be practically unascertainable. The appellant has failed to show the existence of a "particular and comprehensive system of faith and worship" or a body of teachings and doctrine that would bring the concept which it promotes within the legal acceptation of the word religion... .
Likewise, merely "expressing aspirations" to initiate and support "multi-religious, educational programs and services and will organize lectures, workshops and seminars" were not a basis for overturning the Minister's findings, as (para. 8):
...the Minister may require the applicant to provide detailed and credible plans for the latter's proposed activities.