Extract from The Law and Practice Relating to Charities, 4th Edition Hubert Picardo QC (pp. 220-221)

It now appears to be possible to isolate a further [4th] head of charity [in addition to relief of poverty, advancement of education and advancement of religion] consisting of ‘trusts for certain purposes which are not religious but tend to promote the moral or spiritual welfare of the community or a sufficiently important section of the community’. [Emphasis added]

Note: A trust to elevate the community spiritually has been upheld in Canada: see Re Orr (1917) 40 OLR 567.

See Tudor on Charities (9th edn) 115-117 [for discussion on what constitutes “a sufficiently important section of the community”]

This far from compendious [4th] head [of charity] is admittedly fashioned from heterogeneous materials. No general principle should be deduced from animal charities which are an anomaly. Trusts for the promotion of temperance are more surely justified as charities by reference to the promotion of health than by reference to the somewhat vaguer concept of moral improvement….

Re Price ….[involving] an unincorporated association called the Anthroposophical Society of Great Britain …. The learned judge [Cohen J] on hearing evidence that the teachings of Dr Rudolf Steiner were directed to the mental or moral improvement of man and were not contra bonos mores decided that they might result in such mental or moral improvement and upheld the gift under Lord Macnaghten’s forth head of charity….

Certainly religion has been described as ‘fostering the moral or mental improvement of the community‘ [ Waltz v Tax Comrs of City of New York 397 US 664 (1970)]. But the notion of moral improvement was further upheld as charitable in Re South Place Ethical Society [ [1980] 1 WLR 1565] and there are other Commonwealth cases supporting the charitability of moral improvement. [See Re Wright (1923) 56 NSR 364 (training in higher ideals); cf Cameron v Church of Christ Scientist (1918) 57 SCR 298 at 304 (uplifting of humanity).