Mind control at the hands of Aum Shinrikyo founder Shoko Asahara was a key defense argument for many of the 11 cultists sentenced to death and the six others handed life prison terms for carrying out Aum's heinous crimes -- an argument that had little if any effect.

As the convicted cultists pursue their appeals, including before the Supreme Court, their lawyers continue to seek leniency, claiming their clients were brainwashed by the guru and his teachings -- a factor the courts have partially recognized.

In the case of Kiyohide Hayakawa, who was convicted of playing a role in the 1989 murders of Yokohama lawyer Tsutsumi Sakamoto and errant cultist Shuji Taguchi, the Tokyo District Court determined the accused was in a "state of absolute obedience to the guru, in which it was unthinkable to refuse his orders."