A/69/261 criteria in this regard, and the Human Rights Committee has dedicated several paragraphs of its general comment no. 22 in order to further clarify this issue. 34. According to the Committee, for limitations to be legitimate, they must satisfy a number of conditions. Moreover, one should bear in mind that the internal dimension of freedom of thought, conscience, religion or belief (traditionally termed forum internum) benefits from an unconditional protection, 11 according to article 18, paragraph 2, of the Covenant, which states that “[n]o one shall be subject to coercion which would impair his freedom to have or to adopt a religion or belief of his choice”. The Committee stresses that policies or practices, such as “those restricting access to education, medical care, employment or the rights guaranteed by article 25 and other provisions of the Covenant, are similarly inconsistent with article 18(2).” 12 35. With regard to manifestations in the forum externum, limitations are only permissible if they meet all the criteria set out in article 18, paragraph 3, of the Covenant. Accordingly, any limitations must be legally prescribed and must be “needed” to pursue a legitimate aim — the protection of “public safety, order, health, or morals or the fundamental rights and freedoms of others”. In addition, such restrictions must remain within the realm of proportionality, which, inter alia, means that they must always be limited to the minimum degree of interference that is necessary to pursue a legitimate purpose. These criteria are prescribed with a view to safeguarding the essence of freedom of religion or belief, even in situations of conflict with the rights or freedoms of others or with important public interests. 36. The onus of proof therefore falls on those who argue in favour of the limitations, not on those who defend the full exercise of a right to freedom. Confirming this critical function, the Human Rights Committee i nsists “that paragraph 3 of article 18 is to be strictly interpreted: restrictions are not allowed on grounds not specified there […]. Limitations may be applied only for those purposes for which they were prescribed and must be directly related and propor tionate to the specific need on which they are predicated. Restrictions may not be imposed for discriminatory purposes or applied in a discriminatory manner”. 13 3. Limitations on religious manifestations through employment contracts? 37. By signing a labour contract or a similar employment agreement, employees usually accept certain work-related obligations. In some cases such contract-based obligations can implicitly or explicitly limit the right to manifest one’s religion or belief in the workplace. Assuming that labour contracts have a basis in public labour law, one might argue that limitations of freedom of religion originating from contract-based obligations may, in many cases, satisfy the requirement of a legal basis, as prescribed by article 18, paragraph 3, of the Covenant. However, even then, it remains to be seen whether such limitations serve a legitimate purpose and whether they are applied in a proportionate manner. Each specific situation and each individual case deserves a careful empirical and normative assessment. 38. Workplace-related considerations that conflict with an individual’s right to freedom of religion or belief, and which arguably fall within the list of legitimate __________________ 11 12 13 10/23 Ibid., para. 3. Ibid., para. 5. Ibid., para. 8. 14-58756