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Is the United States truly secular?

The United States (US) purports to be a secular nation, but one which holds tolerant neutrality, i.e. pro religion. The First Amendment seeks to establish state neutrality through preventing government from any religious endorsement but whilst also still protecting religious freedom. The Establishment Clause of the First Amendment was implemented to ensure [N]either a state nor the Federal Government ... can pass laws which aid one religion, aid all religions, or prefer one religion over another. It features 5 core principles; Neutrality, Separation, Equality, Liberty and Civil Peace; all derived from court decisions and academic sources. Additionally there are 4 tests to determine whether the Establishment Clause has been breached. This demonstrates that the US government has gone to a great extent in attempting to protect the secularism of the US. However, despite calling itself secular, I would question how secular the country really is. 

In God We Trust is Americas national motto and is printed on all US currency.  God bless America is how every US President ends their speeches. The Presidential proclamation on Thanksgiving for 2019 mentions God 6 times. These few examples conveying the heavy use of the word God, I would argue, are a clear religious reference. I would even go further to purport that the word God holds strong Christian connotations. This is unsurprising considering the Christian influence and majority in American history, however this does not exhibit a secular state. Even the U.S. Supreme Court fell victim to this mentality in 1892, with Justice David Brewer declaring in Holy Trinity v. United States that America is a Christian nation. [1]  At the time the traditions first began they were arguably very appropriate, representing US history, however as time has gone on they simply are not representative of a secular society.

The US does not deny its affiliations with religion We are a religious people whose institutions presuppose a Supreme Being, a declaration made by the US Supreme Court in Zorach v. Clauson, which as Bacquet conveys captures the essence of the United States Government relationship with religion. [2] Religious authority is considered a competing sovereign within the US. [3] There is a historical commitment to religious authority, as reflected in the demographics with over half of the American population considering themselves religious and believing religion to play an important part in their lives, as opposed to 28% in Poland, being the highest in Europe. [4] Congress even passed a resolution proposing a national day of public prayer and thanksgiving, provided land for churches and specified the necessity of religious education.These factors create significant barriers to the application of a genuinely secular state.

It must be conceded that in terms of American schooling and education, secularism stands ground. Stone v. Graham prevented state schools from posting the Ten Commandments in their classrooms, furthermore, Santa Fe Indep. Sch. Dist. v. Doe disallowed prayers prior to high-school football games. But having said this the words In God We Trust are displayed on many public-school buildings, and in the state of Kentucky a bill has been drafted to make it compulsory. Over a dozen US states have either passed or considered religious liberty laws. For example, whilst in Roe v Wade the Supreme Court ruled abortion legal, some states still essentially ban it on religious grounds.   Using the Wilke’s ‘Handbook on Abortion’ aka Bible of the pro-life movement [5], forty two abortion restrictions were enacted between 01/01/19 and 15/05/19 alone. Even President Trump has an anti-abortion agenda, with the enactment of the global gag rule. With the majority of anti-abortion arguments stemming from religion, how does this imply a secular state. Furthermore, since Trumps election, over 75 bills have been brought forward which appear to be modelled on Project Blitz, a Playbook developed by a set of Christian groups setting out pro-Christian model bills.

There is a continual persistence of religion within the US as demonstrated above, I have only touched upon some of the many examples. Perhaps with a country so big and one that pertains such a high number of religious believers, it is impossible to prevent. The founders of the constitution arguably never intended to exclude religion from public life, but merely prohibit the national government from establishing a state church. Whether they have succeeded there is an endless debate, but regardless it is not representative of a secular state. I would like to emphasise that this is not to be criticised. The US certainly has its own understanding of secularism, different to understandings which prevail elsewhere in present day. This is why I would argue that the US cannot be classified as a ‘secular’ state.

Sources with private access 

[1] Mokhtar Ben Barka, « The Christian Nation Debate and the U.S. Supreme Court », European journal of American studies [Online], 6-2 | 2011, document 1

[2] Bacquet, Sylvie. Religious Symbols and the Intervention of the Law (Routledge 2020)

[3] Conkle, Daniel O. (2006) "Religious Expression and Symbolism in the American Constitutional Tradition: Government Neutrality, But Not Indifference," Indiana Journal of Global Legal Studies: Vol. 13 : Iss. 2 , Article 4. 

[4] Theodorou, Angelina. 2015. Americans Are in the Middle of the Pack Globally When It Comes to Importance of Religion. Washington: Pew Research Center, December 23. 

[5] Dr. and Mrs. J.C. Willke, Handbook on Abortion, 8th rev. Cincinnati, OH: Hiltz Publishing Co. 1972

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Nearly half of young LGBT people who are left homeless after coming out are from religious backgrounds…

This was the headline of a BBC article which really caught my eye and struck a chord.  How can society permit this to happen a fifth of the way into the 21st century?  Research suggests that 1 in 4 homeless people identify as LGBT, 45% identify with a faith background, and 77% result directly from abuse or familial rejection. 

Strict interpretations of religious texts, from the Koran to the Bible, argue that to be LGBT is a sin. Consequently, when advocating freedom of religion and belief, as protected in Article 9 of the HRA, issues of contradiction arise. Whilst freedom of religion and to manifest one’s belief is of great importance, it must not undermine the rights of anyone else, in this case the LGBT community. The International Covenant on Civil and Political Rights (ICCPR), requires that no manifestation of religion or belief may equate to advocacy of national, racial or religious hatred that constitutes incitement to discrimination, hostility or violence. Therefore, whilst a person has the absolute right to hold the worst homophobic beliefs, as with any beliefs, they are limited in expressing and manifesting such beliefs externally.

The problem however arises in that you cannot control what someone says in private, particularly in their own home and to their own child. Dr Nazim Mahmood was driven to suicide following recommendations from his family to seek a cure for being gay, as they believe homosexuality to be a disease and expressed as such to Nazim.  His fiancé said that if Nazims family knew they were together they’d be praying on the doorstep until we break apart. Events such as this are all too frequent in todays society, which poses the question of whether the state should be doing more to intervene?

On balance, both courts and society deem freedom from discrimination on the grounds of sexual orientation as higher than freedom of religious beliefs. London Borough of Islington v Ladele for example concerns a registrar who was overruled in attempting to refuse civil partnership duties for religious reasons. The Court concluded that, other than Regulation 14s limited exceptions, the prohibition of discrimination in the Equality Act (Sexual Orientation) Regulations 2007 overruled any right of an individual by virtue of his or her religious belief to practise discrimination on the grounds of sexual orientation.

One way in which society can attempt to protect the rights of the LGBT community is through education. This at least been recognised. From September 2020 it will be compulsory for schools to include relationships education and sex education.  However even this has resulted in controversy. A group of Birmingham Muslim parents protested over their children learning about LGBT rights and homophobia. Additionally, a petition towards parents being able to withdraw their children from sex education lessons has attracted 118,050 signatures (04.12.19).

Whilst the law goes some way to protecting the rights of the LGBT community and not just prioritising religious beliefs, as in London Borough of Islington v Ladele, it is clearly still insufficient. It did not prevent Dr Nazim Mahmood from killing himself, nor stop Sameer Poselay from considering entering a fake marriage to disguise the fact he was gay from his family, and it does not stop many LGBT’s from being kicked out of their homes or being made to feel like they are no longer welcome due to their sexual preference. The Duke of Cambridge even admitted that whilst he would fully support his children whatever their sexual preferences, he did fear the pressures they could face.  Unsurprising as homosexuality continues to be a criminal offence in 35 of the 53 commonwealth nations, but that's a debate for another day.

Whilst some people with strong religious conviction are able to reconcile their faith with acceptance of the LGBT community, for others the interpretation of their faith still creates insumountable barriers. Fear of the unfamiliar is something which the law is unable to counter. Perhaps a more open and accepting society, with a broader education could go some way to breaking down these barriers. The law is unable to control what a parent says to their child or how they make them feel. I question here how the level of protection afforded religious beliefs is so high when such beliefs can be interpreted to adapt a person’s view so strongly that they would give up their children for something as simple as coming out as gay. How can the law provide so much protection and respect to religion when it has the potential to cause so much harm?

Image above: Dr Nazim Mahmood

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Should Uluru have been granted more protection as a religious symbol?

Most are aware of the giant red rock occupying the centre of Australia, known as Uluru. A popular tourist destination and an essential for backpackers. The climbing of the rock has been permitted for years and very popular, however only very recently did the board of the Uluru-Kata Tjuta National Park voted unanimously to end the climb, officially ending it on 26/10/19. Unbeknown to many, Uluru holds sacred value to many aboriginals, especially Anangu’s. In Anangu culture, Uluru marks the site of significant events such as The Dreaming; when the landscape was formed. It is the home of their ancestors and ancient spirits, and along with its neighbour Kata Tjuta, is considered a living, breathing, cultural landscape. [1]

Beliefs held by aboriginals are similar to those of religions such as Christianity or Islam. All are characterised by having a god or gods who created both the surrounding environment and people at the start of time. Rather than praying to that god however, aboriginals believe in a number of deities who can be depicted in some tangible form, such as a landscape feature, a plant or an animal form, or an image in a rock art shelter. Aboriginals feelings towards Uluru are not too dissimilar to the relationship between Allah and Muslims, and God and Christians. The difference being the tangible element, Uluru is perceptible by touch, unlike God and Allah. It is this tangible element which through the misjudgement of the government, has caused aboriginals so much distress and feelings of disrespect. It is far more difficult to cause disrespect to something intangible; you can’t just walk all over it.

Tourists are like ants up and down every day, climbing up and down, Their shoes they are scraping away at the rock, little by little bit. It's now like a rope when you see it from far away. It wasn't meant to be like that. The first recorded climb of Uluru took place in 1936, and thousands have climbed the rock every year since. This has been despite protests from the Anangu, including signs in six languages surrounding the base of Uluru asking people not to climb the rock, explaining that it violates traditional law and is their home.  Photography is prohibited around certain areas of the rock, for religious reasons, yet climbing was still permitted. In 2017, the board of the Uluru-Kata Tjuta National Park voted unanimously to end the climb because of the spiritual significance of the site, however this was not officially implemented until 26.10.19. Meaning climbing has been permitted for almost a century. Increasingly, indigenous people must repeatedly demand the revitalization of their traditional cultures. [2] The protection of sacred sites in particular is viewed as being necessary for the empowerment, vitality, and sustainability of indigenous communities. [3]

If you compare the treatment of Uluru to another sacred sight, the Temple Mount in Israel for example, the difference is considerable. The Temple Mount is only open during specific times, adheres to a modest dress code, security checks, sacred Jewish objects are restricted, and non-Muslims banned from the Dome of the Rock. [4] A significant contrast exists between the respect paid to the two sites, which is the result of individual and Government interest and their homage towards what they feel is deserving and perhaps to what they understand.

Whilst religious symbols are not directly protected by law; it is the freedom of thought, conscience and religion which grant protection, they still hold serious testimonial. Symbols contribute to the construction of group identity [5], they unite members of a common faith, Membership of a family, clan, tribe or country has been asserted symbolically [6]. Down to their lack of protection from the law, religious symbols have always been vulnerable to intolerance and hatred due to their defining a particular group, in the same way as colour, race and ethnicity do. However, it is such definition that makes them the pivot of the cultural tradition of a group. Religion, ethnicity, culture, family, history and tradition are all so closely connected, that when a religious symbol is attacked it is all of those aspects that are being targeted.

The permitted climbing of something so sacred to aboriginals was a huge lapse in judgement by the government. Furthermore, the public continuing to climb despite protests and pleading from aboriginals, illustrates how indigenous beliefs are undermined in society. I myself visited Uluru whilst climbing was still permitted, and the feelings of distress from aboriginals but also non aboriginals; tour guides and locals, caused by the disrespect of some visitors was very apparent. The importance and necessity of the law in protecting religion and beliefs is fundamental, however this example suggests that it is insufficient. It insinuates how religious beliefs are tiered, clearly prioritising populous religions such as Islam, Judaism, and Christianity.

Sources with private access 

[1] Hickling, James (2017) Religious Freedom in the New World? Indigenous Sacred Sites and Religious Beliefs in the Courts in British Columbia, Oxford Journal of Law and Religion, 6:3, 544–579, https://doi.org/10.1093/ojlr/rwx050

[2] Ibid

[3] N1

[4]  Lapidoth, Ruth and Treger, Tomor (2017) The Temple Mount: Israel's Commitment to Preserve the Status Quo, Israel Journal of Foreign Affairs, 11:1, 15-24, DOI: 10.1080/23739770.2017.1301464

[5] Bacquet, Sylvie. Religious Symbols and the Intervention of the Law (Routledge 2020)

[6] Bacquet, Sylvie. Religious Symbols and the Intervention of the Law (Routledge 2020)

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Why does the law offer prevalence to religious freedoms over animal rights?

Ritual slaughter is the mandatory practice and method of the slaughter of animals for food production, practiced by Muslim and Jewish communities. They demand that slaughter is carried out with a single cut to the jugular vein, carotid artery and windpipe, whilst the animal is alive and healthy, and that all blood is then drained from the carcass.  Muslims then refer to the meat as Halal; Arabic for permissible. This method is opposed to the more widespread method of stunning with a bolt in the head prior to slaughter. The Muslin Council of Britain claims that animals are not distressed, nor do they suffer pain, however this is not a common feeling, with many objecting to the inhumane treatment of animals.

The animal welfare legislation requires all animals to be stunned prior to slaughter in order to minimise suffering, with the only exemption being for religious communities; Jewish and Muslim’s religious dietary beliefs. Specialists in the area make clear however that it is far more humane to stun an animal prior to slaughter than to not do so. The Government's own advisory body, the Farm Animal Welfare Council (FAWC), stated that the practice should be banned, yet it is still permitted within the UK. The FAWC concluded that animals slaughtered without pre-stunning are likely to experience very significant pain and distress before they become unconscious.

Furthermore, the Federation of Veterinarians of Europe (FVE) have stated: FVE is of the opinion that the practice of slaughtering animals without prior stunning is unacceptable under any circumstances. EU's Scientific Panel on Animal Health and Welfare (AHAW) expressed that: Due to the serious animal welfare concerns associated with slaughter without stunning, pre-cut stunning should always be performed.  Finally, the RSPCA, Compassion in World Farming and the British Veterinary Association all support an end to non-stun slaughter to improve animal welfare at the time of death.

The Secular Society responded to an Animal Welfare draft consultation Bill, emphasising that by recognising animals as sentient beings and their need for protection, religious exemptions to animal welfare laws on slaughtering should be banned. According to a 2018 Government survey, sheep were the species with the largest proportion of animals slaughtered by a non-stun method (25%), with almost all of this being Halal. For all other species the proportion of non-stun slaughter was around 10%. Furthermore over 94 million cattle, sheep and poultry were slaughtered without first being stunned in England and Wales.

So, one must ask, why does the law prioritise the religious beliefs of Muslim and Jewish communities over animal rights? Especially when there is so much evidence in favour of the opposition. Whilst Article 9 of the European Convention on Human Rights provides for a right to freedom of thought, conscience, and religion, including manifesting a religion or belief, it is qualified. This means if justified, there is a restriction to the right, which arguably is satisfied by animal welfare. Countries that ban slaughter without any form of stunning include Austria, Belgium, Denmark, Estonia, Finland, Iceland, Latvia, Norway, Slovakia, Slovenia, and Sweden. A solution for Muslim and Jewish communities who refuse to eat non-halal meat would be to simply abstain from eating meat. Both veganism and vegetarianism are increasing, both purporting a healthy balanced diet. By continuing to permit ritual slaughter, the UK risks normalising the mistreatment of animals, [1] a perfect phrase used by the NSS’s criticism of a £25m export agreement to supply 50,000 halal lambs to Saudi Arabia.

Furthermore, from a different perspective, the allowance by UK law of religious privilege risks opening the floodgates to increased demands of beliefs and religious practices. Whilst there is a fair argument for freedom of religion, purporting perhaps that in preventing religious slaughter you are discriminating against religious freedoms, an important constitutional right. This should not outweigh animal welfare interests when there are clear ways around this by abstaining from eating meat. If religion holds the privilege to abuse fundamental animal rights, then what’s next for human rights?

Sources with private access

[1] (2018) UK export agreement with Saudi Arabia will see no animals stunned before they are slaughtered Veterinary Record 183, 204.

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“The veil can be perceived as a passport that enables women to participate in public affairs”

Engeland purports the idea of the passport veil (all categories and types included) in her recent journal, What if? An Experiment to Include a Religious Narrative in the Approach of the European Court of Human Rights. [1] She views it as a key for Muslim woman to cross between private and public spheres, and religious and secular spheres, whilst maintaining respect for their own values. The European Court of Human Rights (ECHR) however has expressed views categorising the veil as a threat to public order, gender equality and social cohesion, and through adopting a discourse upholding such views, has excluded veiled Muslim women from the European public sphere.

Recent case law such as, inter alia, Dahlab v. Switzerland, and Aso- ciación Watani para la Libertad y la Justicia v. Lleida demonstrates the challenges faced by European Muslim women who choose to wear the veil, particularly within education and work. Furthermore in Sahin v Turkey the ECHR upheld a ban on wearing the veil within a university, saying it served the need for gender equality. Public covering of the face has been banned in 15 countries; Austria, Denmark, France, Belgium, Tajikistan, Latvia, Bulgaria, Cameroon, Chad, Congo- Brazzaville, Gabon, Netherlands, China, Morocco and Sri Lanka. Moreover in the upcoming British election; the British National Party are purporting to ban the Burqa, referring to it as a conscious refusal to integrate with Western culture. 

One of the recurring debates within parliament in regard to banning the covering of the face/body is the necessity to promote equal rights between men and woman, preventing coercion by men towards woman to wear such items. As Wiles argues, the headscarf is a mark of womans inferiority to men, [2] Howard adds to this purporting that the veil is an infringement of a womans right, imposed on women and girls by men . [3] Furthermore, the court has taken a new approach recently, in SAS v France, claiming the veil contradicts the ability of living together.

What Engeland asks the courts to do however is to change their perspective, and to look upon the issue from the points of view of Islamic Feminists. She argues the veil is a symbol of Islamic feminisms, demonstrated within social media outlets; Nadiya Takolia, The hijab has liberated me from society’s expectations of women, and Pina Sadar, “Muslim Feminists reclaim the hijab in fight against patriarchy.  The ban is counterproductive to the promotion of gender equality itself, and as paternalistic and patriarchal as putting pressure on women to wear these garments. Engeland describes the veil as a liberating tool, owned by women, and an opportunity to cross borders, thus becoming autonomous individuals and citizens. [4] She builds on the idea that the veil is a way of gaining societal mobility, as Akhtar conveys, it forms part of Muslim womens character, behaviour and identity.

With the passport veil, Muslim women turn the argument of the veil as an instrument of protection from the male gaze on its head: they accept wearing it to be protected in public, and in exchange expect to fully contribute to social activities. The veil becomes more than a passport to cross the divide; it also becomes a way of controlling one’s destiny through appropriation of the public space. [5]

It is a contradiction to ban something to force people to be free. You are taking away a part of Muslim woman’s identity in restricting the veil. Engeland encourages the courts to look upon the veil as an enrichment of women’s empowerment, not as a threat to equality, living together, or national security.

Five female football players stopped mid-game to shield an opponent player after her hijab came loose during a tackle.

Sources with private access

[1] Van Engeland, A. (2019). What If? An Experiment to Include a Religious Narrative in the Approach of the European Court of Human Rights, Journal of Law, Religion and State, 7(2), 213-241. doi: https://doi.org/10.1163/22124810-00702004

[2] Wiles, E. (2007), Headscarves, Human Rights, and Harmonious Multicultural Society: Implications of the French Ban for Interpretations of Equality. Law & Society Review, 41: 699-736. doi:10.1111/j.1540-5893.2007.00318.x

[3] Howard, E. (2012). Banning Islamic veils: Is gender equality a valid argument? International Journal of Discrimination and the Law, 12(3), 147–165. https://doi.org/10.1177/1358229112464450

[4] N1.

[5] N1.

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Can a secular state actually protect religion? A focus on the dangers of secularism in France.

Asad, a postcolonial theorist, questions whether a secular state can actually ensure a tolerance of religion, as opposed to a focus on the necessities of law. [1] Whilst there is no one definition of secularism, it is essentially the separation of state and church. Secularism is on a spectrum; Adhar and Leigh categorise secularism into two categories of hard and soft. France has adopted a hard secularism approach; Laïcité.

Secularism is a popular method in protecting both religious believers and non-believers. As Fish said, It is now a formula- if you want to secure a role for religious symbols in the public sphere, you must de-religionize them. [2] However, whilst it is believed secularism could be the solution in providing a balance in state and church, there are many examples in history and present purporting that perhaps it is not the idealistic solution believed by many, or perhaps it needs a redraft as to what a secular state actually means.

French secularism; Laïcité, is a very militant approach, and would be categorised as Hard secularism per Adhar and Leigh. It is a clear result of France’s history and the everlasting power struggle, rooted in the French revolution as the 1789 Declaration, Article 10; sets the idea that manifestation of belief can be limited. The 1905 Law separating Church and State  was then followed by Article 1 of the 1958 Constitution, formally introducing Laïcité. It is based on three core values, which I would argue are unable to co-exist; the freedom of conscience and the freedom to manifest one’s convictions within the limits of respect for public order, the separation of public institutions and religious organizations, and the equality of all before the law.  

The l'affaire du voile [3] is an old controversial case in France where a public school expelled three Muslim schoolgirls for refusing to remove their headscarves worn for religious reasons. The argument being that the principle of secularism is a central tenet of French public policy, particularly where public education is concerned. [4] Whilst, eventually, the legal opinion held the girls were entitled to wear their headscarf’s, a similar case arose very recently. A mother accompanying her child on a school trip to a state building was asked to remove her hijab, as it did not adhere to the belief of secularism.

The Hijab is a very important aspect of Islam for some Muslim woman due to their interpretation of the commands of Allah in the Quran. It is thought of as a duty according to Asad. As a fundamental part of Islam, preventing the hijab from being worn, can be a cause of disrespect and discrimination. It is performing the opposite of protecting religion and treating Muslim woman as second class citizens, taking away their liberty, and contradicting one of the supposed main principles of Laïcité; equality of all.

In further attempts to become secular France banned the total covering of the face in 2010, which was upheld despite the argument of violation of the ECHR in S.A.S v France, where it was argued to be a breach of Articles 3, 8, 9, 10, 11 and 14.  President Sarkozy cited that the ban is about giving women freedom and promoting their dignity. [5] However he fails to consider if a women chose to cover her face. The court stated that regarding the exercise of Article 8 and 9, the ban represented a limitation and interference. Further the minority held that the decision sacrifices concrete individual rights.

Another question arises of secular education. State funded schools within France have excluded Religion from the curriculum. This purports the question of whether religion is protected if not taught, and risks spreading the belief religion is dangerous through restricting it to the private sphere. It results in children unaware of how to respect another’s religion, they may not understand the significance of the hijab and offend. Boyle explores how the elimination of prejudice requires enlightenment and education. [6] One is also unable to form their own decision on a religion if not educated. It could lead to a state which is coercively atheist. Religion is slowly becoming a part of the curriculum due to increased protest and demands for religious awareness to be taught within state schools, illustrating another group, not just Muslims, objecting to a completely secular society. By introducing religion into state curriculum, the bridge between separation of church and state is being crossed, edging away from hard secularism and towards a softer secularism.

A state that adheres to a prohibitive form of secularism, such as France, cannot be neutral in the same way as a state adopting a Christian, Hindu, Islam stance cannot be either.  French secularism ‘technically’ produces an anti-religious state that pushes the doctrine of atheism, which in itself is considered a belief. A secular state can restrict freedom of choice, as demonstrated in France's rulings surrounding the Burkha and Hijab. An argument can be made towards Laïcité targeting Islam over other religions, particularly when it purports secularism yet adheres still to many Catholic values. The few examples mentioned above demonstrate the dangers of hard secularism, and how restrictive it can be, risking harming religion as opposed to protecting it.

Sources with private access

[1] Talal Asad, Formations of the Secular, Christianity, Islam and Modernity (Stanford University Press: 2003)

[2] Stanley Fish, Think Again: Contrarian Reflections on Life, Culture, Politics, Religion, Law and Education (Princeton University Press: 2015)

[3] Jones, N. (2012). Religious Freedom in a Secular Society: The Case of the Islamic Headscarf in France. In Babie P. & Rochow N. (Eds.), Freedom of Religion under Bills of Rights (pp. 216-238). South Australia: University of Adelaide Press. Retrieved from www.jstor.org/stable/10.20851/j.ctt1t3051j.16

[4] Ibid.

[5] Hunter-Henin, M. (2012). WHY THE FRENCH DON’T LIKE THE BURQA: LAÏCITÉ, NATIONAL IDENTITY AND RELIGIOUS FREEDOM. The International and Comparative Law Quarterly, 61(3), 613-639. Retrieved from www.jstor.org/stable/23279928

[6] K. Boyle, Freedom of Religion in International Law; Cited in; Javaid Rehman and Susan C. Breau, Religion, Human Rights and International Law, A Critical Examination of Islamic State Practices (Martinus Nijhoff Publishers; 2007)