Jehovah's Witnesses in Australia foster distrust of secular authorities and the church's way of responding to child sex abuse falls short of best practice, it is open to the royal commission to find.

In a damning submission published on Tuesday, Angus Stewart SC, counsel to the child abuse commission, recommends 77 adverse findings against the fundamentalist church, which since 1950 has received 1066 allegations against its members and never reported any of them to police.

Mr Stewart's recommendations arise out of a public hearing into the Jehovah's Witnesses and its oversight body, the Watchtower Bible and Tract Society of Australia, in July this year.

He said the Witnesses receive approximately three and four reports of allegations of child abuse a month.

"The Jehovah's Witness organisation presents its members with conflicting and ambiguous teachings regarding their relationship with secular authorities, thereby fostering a distrust of such authorities," Mr Stewart said.

He was also critical of the church for requiring abuse victim BCB, who gave evidence at the July hearing, to confront her abuser and for not allowing the involvement of women when her complaint was being investigated.

He said it was "inconsistent of the elders' professed sympathy for BCB".

The evidence in July was that although elders in the Western Australia congregation at Narrogin - where BCB was abused by elder Bill Neill - believed her, Neill was allowed to keep his job because under "witness" regulations, based on a second century interpretation of the bible, two witnesses are needed to prove a crime.

BCB - who was in her mid-teens and had been groomed by Neill for a number of years - was made to continue to attend Bible classes with him and discouraged from discussing the abuse with anyone, Mr Steward found.

Among the other findings open to the commission are that there is no justification for the Jehovah Witnesses not to report to police when the victim is a minor and others are still at risk.

One of the most senior members of the Jehovah Witness Church, Geoffrey Jackson, who is on the New York-based governing body that oversees decisions made internationally, gave evidence on the final day of the public hearing.

On Tuesday, Mr Stewart said it could be found that Mr Jackson, by only familiarising himself with the testimony of church witnesses and not reading the testimony of survivors, "belies his stated empathy for the survivors and his stated recognition of the importance of their perspective".

In a submission responding to Mr Stewart's proposed finding, the Watchtower Bible and Tract Society of Australia said the finding that the Jehovah's Witnesses organisation fosters distrust was "just not true".

The submission says Mr Stewart was selective in what doctrinal teachings he used to support the proposed finding.

Mr Stewart's logic around the church's relationship with secular authorities is also flawed because Witnesses believe it is their "Christian responsibility to be good citizens," and encourage obedience to the law.

The submission said many of Mr Stewart's proposed findings were based on "incorrect assertions" and the proposed finding against Mr Jackson did not reflect what he actually said.

He was in Australia to care for his ailing father and did not expect to be called to the commission, the society said.