A/HRC/10/8/Add.4 page 10 of particular relevance when examining the registration issue in Turkmenistan. While it would be appropriate to require registration for the acquisition of a legal personality and similar benefits, registration should not be a mandatory precondition for practicing one’s religion. Registration procedures should be easy and quick and should not depend on extensive formal requirements in terms of the number of members or the length of existence of a particular religious group. Registration should not depend on the review of the substantive content of the belief, the structure of the faith group and methods of appointment of the clergy. Additionally, provisions which are vague and which grant excessive governmental discretion in giving registration approvals should not be allowed. It is imperative that no religious group be empowered to decide about the registration of another religious group. 24. The fact that the Religious Organizations Law prohibits the activities of unregistered religious organizations stands in contradiction with international human rights standards as well as the principles enshrined in the Constitution of Turkmenistan. Unregistered religious activity is no longer a criminal offence but has become an administrative offence in 2004. The prohibition of unregistered religious activity remains a matter of great concern to the Special Rapporteur. It adversely affects numerous aspects of the freedom to manifest one’s religion or belief. Indeed, members of unregistered groups, especially those living outside of Ashgabat and those who are not Sunni Muslim or Russian Orthodox, seem to be under constant threat. They are not permitted to congregate, are unable to find facilities for meetings, and any collective observance is liable to punishment. 25. The Special Rapporteur wishes to reiterate that international human rights law recognizes freedom of religion or belief regardless of registration status. Those who cannot or do not want to register should therefore still be able to manifest their religion or belief both individually and collectively, in private or in public. Any limitations to the freedom to manifest one’s religion or belief must not only be prescribed by law but must also be necessary to protect public safety, order, health or morals or the fundamental rights and freedoms of others, according to article 18 paragraph 3 of the International Covenant on Civil and Political Rights. The Human Rights Committee in its general comment No. 22 (1993) emphasizes that paragraph 3 of article 18 is to be strictly interpreted and that restrictions are not permitted on grounds not specified there, even if they would be allowed as restrictions to other rights protected in the Covenant, such as “national security”. However, article 3 of the Religious Organizations Law states that the practice of freedom of religion shall not be contrary to the established public legal order and that it can be temporarily restricted to ensure national security and to protect public order, life, health, morality, rights and freedoms of other citizens. Consequently, article 3 of the Religious Organizations Law is not in consonance with international law since it includes “national security” as a possible limitation ground. 26. Concerning formal requirements in terms of the number of members or the length of existence of a particular religious group, the Religious Organizations Law does not require a particular religious group to have a lengthy existence in order to be registered and the 2004 Presidential Decree has reduced the number of required members for registration from 500 to 5. It is, however, not clear why the Religious Organizations Law distinguishes between “religious groups” (up to 50 members) and “religious organizations”, which shall consist of no less than 50 citizens. Though presumably the latter can be granted legal status, such a distinction adds