E/CN.4/2006/5/Add.2 page 10 Complaints about violations of the right to freedom of religion 39. Both Christians and Muslims complained of limitations on the right to freedom of religion or belief suffered by members of their respective community. Generally, the limitations affecting Muslims usually occurred in areas inhabited predominantly by Christians while the limitations affecting Christians occurred in predominantly Muslim areas. Most of the time, the limitations were imposed by either non-State actors, in particular religious groups, or state governments, or a combination of both, but rarely were there complaints of limitations imposed by the Federal Government, apart from those restricting rights in situations that could potentially foment religious violence. Nigerians who are neither Muslim nor Christian complain of neglect by the Government and of being “overpowered” by the tensions between the Muslim and Christian communities. 40. In the majority of cases, Christians linked the limitations and violations that they were suffering to the adoption and implementation of sharia penal codes in a number of northern states (see sect. IV below). Sometimes, Muslims also claimed that limitations or violations of their rights were also due to the adoption of sharia penal codes (see next section), either because of retaliatory measures taken by Christians or because they could be subjected to a judicial interpretation of sharia which may not be acceptable to them. 41. A number of Muslims complained of being portrayed as “barbaric”, “militants” and “anti-women”. They were deeply hurt by this stereotyping in some national and international media. They alleged that they were not adequately represented in the police service or the armed forces. In addition, they pointed out that they were poorly represented at the peace conferences held in the Plateau region. In their defence, they gave examples of the tolerance shown by their community: Sunday rather than Friday had since time immemorial been accepted as the weekly national day of rest, and there were more Christian foreign missionaries in Nigeria than Muslims. Others who were uncomfortable with the recent introduction of sharia in the northern states feared further backlash because the “open-ended monopoly of interpreting sharia” had been left in the hands of poorly-trained judges. 42. It seems that the grave outbreaks of intercommunal violence that have unfolded along religious lines have provoked real tensions between religious communities and generated the imposition of numerous de facto and de jure limitations on the manifestation of religious belief by one or the other group. The Special Rapporteur has noted, particularly in Kaduna and Jos, that the mere existence of these tensions has created a climate of unease and, for a number of people, a real fear of openly manifesting their religion, for example by wearing certain dress or participating in public religious events. Some Muslim scholars and lawyers complained that they dared not openly criticize the substance or implementation of the sharia penal provisions. These tensions therefore undoubtedly limit the freedom of religion or belief of a number of Nigerian citizens. 43. In many cases, the examples of limitations brought to the attention of the Special Rapporteur were related to the building of places of worship, or their confiscation or transformation for a different purpose. Although it appeared that restrictions on building were justified by invoking zoning laws, it was often claimed that the zoning laws were usually not closely followed and that only in the case of places of worship were the regulations applied,