ORIGINAL RESEARCH |
https://doi.org/10.5005/jp-journals-11005-0079 |
Main Concepts of the Freedom of Thought, Conscience, and Religion in the Jurisprudence of the Strasbourg Court
Independent Human Rights Consultant, Former Head of Public and Private Law Development Unit, Council of Europe, Strasbourg, France
Corresponding Author: Edo Korljan, Independent Human Rights Consultant, Former Head of Public and Private Law Development Unit, Council of Europe, Strasbourg, France, Phone: +33633979800, e-mail: edo.korljan@gmail.com
Received: 13 March 2024; Accepted: 15 April 2024; Published on: 17 July 2024
ABSTRACT
The right to freedom of religion is a fundamental human right enshrined in many international documents. The European Court has amassed extensive jurisprudence, providing convention signatory states considerable latitude in assessing the justification and proportionality of encroachments on religious rights. The European Court asserts that states have considerable discretion in meeting their obligations in respect of the right to freedom of religion. However, this must be done while ensuring the comprehensive realization of religious freedoms while concurrently respecting the rights and liberties of others.
Keywords: Freedom, Neutrality, Religion, Religious symbols, Secularism
How to cite this article: Korljan E. Main Concepts of the Freedom of Thought, Conscience, and Religion in the Jurisprudence of the Strasbourg Court. Sci Arts Relig 2024;3(3–4):84–89.
Source of support: Nil
Conflict of interest: None
THE SOURCES AND CONTENT OF THE RIGHT TO FREEDOM OF THOUGHT, CONSCIENCE, AND RELIGION
The right to freedom of thought, conscience, and religion is a multifaceted and developing right in terms of its content and meaning, as well as its changing interpretation. At the European level, this interpretation is carried out by the European Court of Human Rights, based on the 1950 European Convention on Human Rights (ECHR). Its Article 9 protects the sphere of personal beliefs and religious creeds, that is, the area sometimes called ”forum Internum.”1,2 It stipulates as follows:
”Everyone has the right to freedom of thought, conscience, and religion; this right includes freedom to change his religion or belief and freedom, either alone or in community with others and in public or private, to manifest his religion or belief, in worship, teaching, practice, and observance.
Freedom to manifest one’s religion or beliefs shall be subject only to such limitations as are prescribed by law and are necessary in a democratic society in the interests of public safety, for the protection of public order, health, or morals, or for the protection of the rights and freedoms of others.”
This right is also included in a number of other international documents, such as the 1948 Universal Declaration of Human Rights, which in Article 18 proclaims the right to freedom of thought, conscience, and religion. It is noteworthy that the wording of this provision closely mirrors Article 9 of the European Convention, a resemblance that is unsurprising given the significant influence of the distinguished French jurist René Cassin on both texts. Other major international instruments include the International Covenant on Civil and Political Rights (Article 18), the Convention on the Rights of the Child (Article 14), the American Convention on Human Rights (Article 12), and the EU Charter of Fundamental Rights (Article 10).
The European Court has developed a number of guiding principles while implementing this right. This text will reflect on the right to freedom of religion, considering religion to be ”one of the most vital elements that go to make up identity... and... conception of life of many people (Kokkinakis vs Greece, Series A, no 260 (1994), para 31).” The following analysis will consider the right to freedom of religion to be ”one of the most vital elements that go to make up identity... and... conception of the life of many people” (ibid).
SCOPE OF THE RIGHT TO FREEDOM OF THOUGHT, CONSCIENCE, AND RELIGION
Article 9 of the European Convention covers a wide range of beliefs and philosophical concepts, not necessarily limited to religious ones: ”The belief needs to reach a certain degree of cogency, seriousness, cohesion, and importance so that opinions and beliefs of lesser intensity do not fall under the protection of Article 9 of the Convention” (Campbell and Cosans vs United Kingdom, app. no. 7511/767743/76, 1982, Series A, no. 48). In other words, the Court indicated ”that not all opinions, or beliefs are protected by Article 9” (Pretty vs United Kingdom, app. no. 2346/02). The Court wisely decided not to try to define religion or to enter the issues of religious dogma while keeping itself out of these gray areas where reason and faith intertwine. However, this did not prevent the Court from addressing applications from various branches of Christianity, such as Jehovah’s Witnesses, members of the Salvation Army and Mormons, and followers of Judaism, Islam, Buddhism, Sikhism, and Hinduism. The Court also dealt with the Church of Scientology, the Druids, Falun Gong, the Osho movement, and not the least important—atheists.
In several cases of such lesser-known and observed religions, the application of Article 9 would be permitted if the applicant could prove to be a follower of a known religion, raising questions about the fine line between religions and sects. The Strasbourg Court used the term ”sect” in its famous cases of Manoussakis vs Greece (app. no. 18748/91,1996, ECHR 1996-IV, para 39) as well as Kalac vs Turkey (app. no. 20704/92, 1997 ECHR 1995-V, para 26), describing the sects in a rather pejorative way, calling them a ”pseudo-religion” and a ”psycho-sect.”
Pacifism is one of the beliefs protected by Article 9 of the Convention. However, the pacifist who distributed leaflets expressing strong disagreement with British policy in Northern Ireland and advising soldiers to go absent without leave or openly refuse to be posted there did not reach the level of belief required by Article 9 (Arrowsmith vs United Kingdom, app. no. 7050/75).
Which rights are not protected under Article 9 of the Convention? In a well-known Turkish case (Kurtulmus vs Turkey, app. no. 655000/01), the Court pointed out that Article 9 does not protect every act motivated or influenced by religion or belief. It concluded that a teacher must respect normal working hours, even when he is teaching at school during prayer times, and that a teacher’s obligation to teach at that time is in line with his freedom of religion. One analyst believes that the European Commission of Human Rights considered that the applicant had given up his rights to claim any exception from the rules concerning working hours when he had accepted employment, which could have resulted in conflict with his religious obligations (Stavros, ”Freedom of religion and claims for exemption from generally applicable neutral laws: Lessons from across the pond?” EHRLR, Issue 6, Sweet and Maxwell, Ltd, 1997, 607–627). The Court, therefore, gave priority to the secularism of public schools in Turkey over the right to freedom of religion for this particular teacher.
Furthermore, the Court deemed that protection of Article 9 does not apply to a movement called Pastafarianism, whose God is the ”Flying Spaghetti Monster,” as the requirements of cogency, seriousness, cohesion, and importance have not been met (De Wilde vs The Netherlands, app. no. 9476/19). These requirements were also not fulfilled in the case of parents who had a critical stand on vaccination of their minor children, as such stand was not a conviction or belief (Vavricka and others vs the Czech Republic, app. no. 47621/13, 3867/14, 73094/94).
In an older Austrian case (Otto-Preminger-Institute vs Austria, app. no. 13470/87), the European Court stated that those who invoke the freedom of expression of their religion cannot possibly be spared from any criticism. They must tolerate and accept that others challenge and contradict their religious beliefs. However, the manner in which religious beliefs and doctrines are challenged or opposed is something that may involve the responsibility of the State to ensure the peaceful enjoyment of the right guaranteed by Article 9 of the Convention to those who hold those beliefs.
Therefore, not every act that is in some way inspired, motivated, or influenced by religion represents a manifestation of belief: a certain act must be closely related to religion or belief, and this is determined on an ad hoc basis in each case.
A debate among religious scholars concerning the historical foundations of a given religion and the merits of the demands of its followers does not suffice to deny the religious nature of those beliefs (Ancient Baltic Religious Association Romuva vs Lithuania, app. no. 48329/19, paras 118–119).3,4
THE PRINCIPLE OF SECULARISM AND THE PLACE OF CHURCHES AND RELIGIOUS COMMUNITIES IN THE SOCIETY
The place of churches and religious communities within societies is of paramount importance as most constitutions in Europe foresee the secular character of the State by the separation of churches and religious communities from the State. Some of them go even further by stating that no religion can become the State’s religion. These precepts are part and parcel of the principle of secularity, where states regulate the legal position of churches and other religious communities by law, as they are institutions of private law. Although the State is bound by the obligation of noninterference in the church’s affairs, it reserves the right to supervise the ”church’s external side.”
At this stage, the complex process of the development of secularism in Europe deserves to be highlighted. In particular, the Roman Catholic Church held significant power over certain European states and societies, as the religious authorities often controlled more than only spiritual life.
However, this strong position was first eroded by the Renaissance: with its profound interest in humanism, art, and science, it started questioning religious dogma and church authorities. This continued throughout the Protestant Reformation, led by Martin Luther and Jean Calvin, who successfully challenged the authority of the Roman Catholic Church and effectively created various Protestant denominations, contributing to the diversification of religious thinking. The next period of enlightenment had an intense intellectual and philosophical bearing, as Voltaire, Rousseau, Locke, and Montesquieu promoted notions of reason, individual rights and freedoms, and the separation of the State and the Church. They provided a strong philosophical and societal basis for secular governance, followed by the establishment of nation-states with centralized political power, which further contributed to the weakening influence of religious institutions over societal issues. Furthermore, revolutions, like the French and the American ones, also facilitated the secularization of the Church lands, the replacement of the Christian calendar with the secular one, and, more generally, the introduction of checks and balances between different branches of power. This was happening in parallel with advanced industrialization, with scientific progress and mass education further diminishing the relevance of religions.
The development of secularism in Europe varied from one country to another, being influenced primarily by political, theological, historical, social, and economic reasons. The process of secularization reached its current State in the 19th and 20th centuries with the adoption of secularized legislation and constitutions.
The concept of secularism does not tend to eliminate any religion but rather to promote a neutral and inclusive public domain where people of diverse beliefs coexist without any faith dominating public life. One of the most relevant cases in this context relates to the decision of Turkish authorities to forbid the work of the Welfare Party in accordance with the principle of secularism, the rule of law, and the protection of human rights (Refah Partisi vs Turkey, app. no. 3, 41340/98, et al.).
However, there are European countries where one religion is declared as the State’s one, as is the case in Greece with the Greek Orthodox Church. The situation is similar in England, where the Anglican Church is the State’s church, and the Evangelical Lutheran Church is in Denmark and Norway. In general, the State helps such churches by providing financial support for the maintenance and restoration of religious buildings that represent cultural heritage. This process tends to serve the interests of the religious majority better than those of religious minorities (Employment Division, Department of Human Resources of Oregon vs Smith, 108 L Ed., Ltd. 876). Since only these churches are eligible for such aid, this may hinder the ability of believers from other churches to freely practice their religion, thus constituting discrimination by definition. Similarly, several European countries envisage that only particular churches are expressly legally recognized. Such is the case with the Catholic Church in Italy and Poland and with the Orthodox Church in Bulgaria.
The above examples do contradict the principles of secularism and equality of churches and religious communities. However, they did not have their epilogue before the Strasbourg Court. All of these countries are democratic, with a functioning judicial system, and this might suggest that freedom of conscience, belief, and religion might blossom even in such conditions.
The delicate relationship between the State and religious communities received its first epilogue in Strasbourg in the case of Cha’are Shalom Ve Tzedek vs France (ECHR 2000-VII) when this Jewish Orthodox community requested a permit to open slaughterhouses for the ritual slaughter of animals (this ritual is protected by Article 9, paragraph 2 of the Convention), which would merit the use of the ”glatt kosher” label. Mostly due to the weak representativeness of this community and the fact that such meat was available, the French authorities refused to issue this permit, forcing this community to turn to the Strasbourg Court.
The Court resorted to a three-step analysis, as foreseen by Article 9, paragraph 2, by first considering whether the authorities’ decision was based on law and concluding affirmatively. The Court continued its analysis by considering whether that decision had a permissible goal and concluded affirmatively the goal was the protection of public order and health. Finally, the Court considered the question of the possible proportionality of the response of the state authorities in accordance with the goals and standards of a democratic society: it found the response to be proportional and, therefore, found no violation of Article 9.
The main reasons for this conclusion were that ”glatt kosher” meat was already imported to France, and the Central Jewish Consistory, the mainstream organization representing the majority of French Jews, had its own slaughterhouses with ”kosher” meat.
However, the analysis of this case suggests the Court entered into an uneasy relationship between the majority and minority religious communities precisely because the State should not interfere in the ”internal life” of religious communities, although many European states have done it thus, violating the right to freedom of religion.
One of the more important cases in this area is Hasan and Chaush vs Bulgaria (ECHR 2000-XI), the two being the former Chief Mufti of the Islamic community and the secretary of his office. After the establishment of a democratic system in Bulgaria, the Chief Mufti was replaced, and a kind of dual government with two parallel factions of the Islamic community was established, both factions having certain legitimacy. Mufti Hasan, the elected Chief Mufti at the National Conference of Muslims in 1992, complained to the European Court, alleging the violation of Article 9 caused by his dismissal and the changes within the Islamic community endorsed by the State.
The task of the Court was simple, as it did not have to engage in its already described three-level analysis: the very look at the Bulgarian legislation indicated the absence of clear criteria and procedural safeguards based on which changes in the leadership of religious communities might take place, as well as of the possibility of an independent body deciding against the arbitrariness of state authorities. Therefore, the Bulgarian authorities have violated Article 9.
THE PRINCIPLE OF NEUTRALITY AND RECOGNITION AND REGISTRATION OF RELIGIOUS ORGANIZATIONS
This issue has already been partly dealt with in the above-mentioned case, Hasan and Chaush vs Bulgaria, where the Court emphasized the obligation of the State’s neutrality in the case of challenges to the legitimacy of the leadership of religious communities, which is often closely related to issues of their recognition.
Due to its importance in this area, the case of the Metropolitan Church of Bessarabia and others vs Moldova stands out (app. no. 45701/99). Although canonically connected to the Bucharest Patriarchate, the state authorities connected this church to the Moscow Patriarchate, forcing them to address the refusal to recognize their religious community to the Strasbourg Court.
The Court recognized the right of the Metropolitan Church to be a party to the proceedings and established that the refusal to register it encroached on the right to freedom of religion. In its three-pronged analysis, the Court was not categorical about whether the refusal was based on the law and moved on to the second question of the permissibility of the goal of this encroachment, where the answer was affirmative because it considered that it occurred due to the need to protect public order and security.
Turning to the third level of its analysis and the question of the necessity of state intervention in the right to religion in a democratic society, the Court recalled that members of any religious community must have the opportunity to freely assemble and organize independently, without any interference from the State. Here, the Court emphasized the connection between Articles 9 and 11 (which guarantees the right to free assembly and association) and concluded that the refusal to recognize the church, in this case, cannot be considered a permissible encroachment on freedom of religion, nor it is necessary in a democratic society.
The connection between these two important articles of the Convention, Articles 9 and 11, was confirmed in another well-known case, the Moscow branch of the Salvation Army vs Russia. The case was about the request of the Russian authorities for the registration of religious communities. Complying with this request of the legislator, this religious organization applied for reregistration and was rejected. The Strasbourg Court decided that there had been an infringement of the applicant’s right: the refusal of the reregistration was not based on domestic law, so the Russian authorities neglected their duty to remain neutral and impartial, thereby violating Article 9 of the Convention.
The jurisprudence of the European Court of Human Rights establishes many obligations for states. Some of them are negative and consist of the obligation of the State not to act and to refrain from doing something, while positive obligations require the active action of the State. Such obligations exist for a large number of articles of the Convention, and their form depends on the right to be protected (on positive obligations of states in respect of the right to life.5
As already indicated, the most important obligation of the State in the field of religious issues is that it must remain neutral and impartial; the State must not discriminate against various religious communities and/or privilege one or more of them.
There are many examples of positive state obligations under Article 9 of the European Convention. One of them is the State’s respect for religious organizations because their reputation largely depends on it. In the case of Leela Förderkreis e.V. vs Germany (app. no. 58911/00), when the members of the Center for Meditation of the OSHO movement were called a ”pseudo-religion” and a ”psycho-sect,” terms that clearly do not have a positive connotation and are not neutral, the Court established a violation of Article 9.
The role of the State is even more important in cases of tension and conflict within religious communities, especially when there are multiple contenders for leadership. In Greece, the Court faced a situation where two Muftis argued about the primacy and legitimacy of performing that function. In this country, the choice of the Mufti is confirmed by the head of State, which represents a flagrant interference in the internal affairs of a religious community. The applicant was a Mufti elected by a section of the religious community, while the Greek court decided that he had usurped that position.
The Court established a violation of Article 9, considering that the decision of the Greek judiciary was not necessary for a democratic society, noting that ”the role of the Government in such circumstances is not to remove the tensions by abolishing pluralism, but to ensure mutual tolerance of opposing groups.” Popović concludes that ”the state’s positive obligation, derived from the Convention, consists, according to the Court’s understanding, in fulfilling the role of mediator and precisely the conciliatory mission.”5
The Court reached a similar conclusion in a Latvian case, Mirolubovs and Others vs Latvia (app. no. 798/05), in the case of two opposing factions of Old Orthodox communities in that Baltic State. The Court indicated that state intervention in the work of religious organizations, if it is inevitable, must be explained, must take into account all the relevant circumstances, and cannot disregard the State’s general duty of neutrality.
As in the case of the Moscow branch of the Salvation Army vs Russia, in a similar situation in Austria, the Court concluded that a serious and unjustified delay in recognition of a religious community constitutes a violation of Article 9 (Religions gemeinschaft der Zeugen Jehovas and other vs Austria, app. no. 40825/98).
In conclusion, many authors, including this one, strongly believe that a neutral relationship between the state and the church or other religious communities is the most compatible with the freedom of religion of its citizens. However, neutrality is not absolute because the State can intervene in accordance with its positive obligations under Article 1 of the Convention, which requires the State to guarantee the rights and freedoms of all persons under its jurisdiction. These obligations do not only refer to interference that may be a consequence of actions or inactions of state bodies or public institutions but may also refer to acts that can be attributed to private persons and nonstate bodies.
WEARING RELIGIOUS SYMBOLS IN PUBLIC
Establishing the rules that govern the way religious symbols are worn by employees in health care, military service, public educational institutions, the private sector, and the criminal justice system is important, despite the fact the Court afforded a wide margin of appreciation when it comes to elements of the religious life of believers such as garment, aids, signs or written material.
As the Court stated, in democratic societies where several religions coexist, restrictions on the freedom of expression might be necessary in order to harmonize the interests of various groups and respect the beliefs of each person. The European Court recalled that freedom of thought, conscience, and religion are the foundations of a ”democratic society” and are among the most important elements that form the identity of believers and their concepts of life. Religious freedom is primarily a matter of individual thought and conscience, and that right is absolute and unconditional.
The Court dealt with the number of applications related to the restriction of wearing religious clothing in public places, whether it represented a limitation of the right of an individual (or group) to manifest their religion and to review the justification of the reasons that led to that ban. The general rule is that the users of public services are free to express their religious beliefs in a public building, while States may impose restrictions on public officials in accordance with principles of secularism and neutrality. Regarding the wearing of religious symbols in public institutions, the Court considered numerous applications and concluded that the ban on wearing religious symbols in public institutions could be considered justified as such wearing cannot be easily reconciled with the message of tolerance, respect for others, equality, and nondiscrimination in a democratic society.
In Switzerland, a primary school teacher was prohibited from wearing a headscarf during class. The Swiss courts supported this decision, citing the necessary neutrality of the State and its public education system vis-à-vis all religions. Wearing a headscarf would give the impression of ”identification” of that teacher, who is a civil servant with a certain religion, which is not in accordance with the principle of neutrality of the State. The European Court justified the ban, considering that the headscarf is a ”strong religious symbol” which, especially for children in primary school, is a tool that could have a decisive influence and have a converting influence on them (Dahlab vs Switzerland, app. no. 42393/98).
In the well-known case of Leyla Sahin vs Turkey (app. no. 44774/98), whereby Ms Sahin was forbidden to wear an Islamic headscarf at the Faculty of Medicine, the European Court concluded that this encroachment on the right to exercise religion aimed at the legitimate goal of protecting the rights and freedoms of others and protecting public order and was justified and proportionate to the goals which were aimed at Turkey’s Constitutional Court supported this reasoning.
In the case of Ebrahimian vs France (app. no. 64846/11), the decision not to renew the employment contract of a hospital social worker who refused to remove the Islamic veil was not a violation of Article 9. The Court repeated that wearing a veil is incompatible with the requirement for the neutrality of public officials in the performance of their duties, so it assessed that the domestic authorities did not exceed their powers by refusing to renew the employment contract of such a person.
In the case of El Morsli vs France (app. no. 15585/06), a Moroccan citizen married to a French citizen was denied a visa to enter France because she refused to remove her headscarf at the French Consulate General in Marrakesh. The European Court found that identity verification serves a legitimate purpose (public safety) and concluded that the French authorities did not violate Article 9.
Previous cases were all about followers of Islam, but other religions were also considered. In the United Kingdom, the applicants complained that they were allowed by their employers to wear the cross at work, provided that it is worn under their clothes when they are in contact with clients or patients (Eweida and Chaplin vs United Kingdom, app. no. 48420/10, 59842/10, 51671/10 and 36516/10). When the applicant worked at the check-in desk at British Airways, the Court concluded that, in circumstances where there was no evidence of actual interference with the interests of others as the cross was discreet and could not detract from her professional appearance, the domestic authorities had failed to protect her right to exercise religion, and even fired her because she refused to cover her chest. The European Court came to the conclusion that a fair balance was not achieved in this case and found a violation of Article 9 of the ECHR.
Another applicant, Mrs Chaplin, a nurse in a geriatric ward, has worn a Christian cross on a chain around her neck since her baptism. Given that wearing collars was not allowed in order to reduce the risk of injury when working with patients, Mrs Chaplin was asked to remove the cross and chain, which she refused, and was reassigned to a nonnursing position. The Court acknowledged that hospital managers are in a better position to make decisions about hospital safety than an international court and concluded that the principle of proportionality should be applied between her right and the interests of the employer, that is, the protection of health and safety in the hospital suit. The Court gave priority to the hospital, concluding that the measures taken were not disproportionate and that, accordingly, interference with the right to freedom of religion was necessary in a democratic society.
Restrictions on the wearing of religious clothing and symbols, in accordance with the practice of the European Court, should reflect a general approach that is neutral and impartial towards all forms of religion and belief. This area remains highly contentious.
Even when a particular religious conviction attains a certain level of credibility and significance, it does not inherently denote that every action, even remotely driven by religion, constitutes an expression of belief, possessing a close and direct connection to religion. The existence of this connection must be assessed in each individual case.
A universally accepted definition of a religious symbol does not exist, and some hold that it encompasses anything involving an element of believers’ religious lives, including clothing, accessories, signs, or written material. The European Court tends towards a flexible approach, allowing each individual, State, or Court to ascertain what constitutes a religious symbol in a particular context.7
CONCLUDING REMARKS
The European Court has emphasized that individuals expressing their religious beliefs, regardless of belonging to a majority or minority religion, cannot expect immunity from critique in democratic societies. Challenges to religious beliefs are acceptable, and the State may have a responsibility to ensure the peaceful enjoyment of this right. Article 9 does not confer the right to refuse, on the basis of one’s convictions, to abide by legislation that applies neutrally and generally.
The Court has addressed various cases related to limitations on wearing religious attire in public, often considering whether such bans infringe on the right to manifest religion and the rationale behind these restrictions. For instance, bans on headscarves in schools were upheld as necessary for maintaining neutrality and secularism, protecting the rights of others.
Similarly, bans on religious symbols in public institutions were deemed justifiable to uphold principles of tolerance, respect, equality, and nondiscrimination in a democratic society. Overall, the European Court’s approach underscores the importance of neutrality and impartiality in regulating religious expression while acknowledging the complexities and tensions inherent in balancing competing rights and interests in diverse societies. The general principles of neutrality, impartiality, and secularism apply throughout Europe. Restrictions on wearing religious clothing and symbols, as delineated by the European Court’s jurisprudence, are expected to adhere to these principles. The Court considers that not every action influenced by religion necessarily constitutes an expression of belief; a close and direct connection to religion or belief must be evident and assessed on a case-by-case basis.
Recognizing that the Court also safeguards atheists, agnostics, skeptics, pacifists, and others is reassuring.
These matters continue to be sources of significant contention, and one might anticipate substantial evolution in jurisprudence in the future, as evident by current developments within national legal frameworks.
REFERENCES
1. European Court of Human Rights, Guide on Article 9 of the European Convention on Human Rights-Freedom of thought, conscience, and religion, available at https://ks.echr.coe.int
2. Harris D, O’Boyle M, Warbrick C. Law of the European Convention of Human Rights. Oxford University Press; 2023.
3. Stavros S. Freedom of religion and claims from generally applicable, neutral laws: lessons from across the pond. EHRLR 1997;(6):607–627.
4. Evans MD. Religious Liberty and International Law in Europe. Cambridge: Cambridge University Press; 1997.
5. Korljan E. The freedom of religion in the jurisprudence of the European Court of Human Rights, in State-Church law through centuries, Institute for Comparative Law, Belgrade-Budva, 2019 (in Serbian)
6. Popovic D. European Human Rights Law, Official Gazette, Belgrade, 2012 (in Serbian)
7. Wolff T. Cogency, seriousness, cohesion and importance: assessing the Strasbourg case-law on religion and belief. Oxford J Law Relig 2022;11(2–3):177–196. DOI: 10.1093/ojlr/rwad006
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