Republic, Amnesty International v Zambia, Timishev v Russia and Feryn constitute a welcome development in anti-discrimination law. In contrast, the case law on religious discrimination is limited and requires a higher level of scrutiny of state measures. This is particularly important in the cases concerning intersectional discrimination based, for example, on the grounds of religion and gender. The jurisprudence of the ECtHR is particularly disappointing in this respect, as it seems to be outdated: the Court continues to be unwilling to consider the applicants’ claims of multiple discrimination. Although it is commendable that racial discrimination is strongly condemned, the differentiation between the grounds of non-discrimination may lead to an undesirable hierarchy. Such hierarchy of grounds is particularly visible in the context of EC Equality Directives, with race and ethnicity in the first place, sex second, and other grounds, such as religion or belief, accorded the least protection. However, the Directives could be used as a fertile ground for developing the concept of ‘intersectional’ discrimination in practice, particularly where a group may share a common ethnic origin and a common religion. MINORITY GROUPS AND LITIGATION: A REVIEW OF DEVELOPMENTS IN INTERNATIONAL AND REGIONAL JURISPRUDENCE 19

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