E/CN.4/1987/35 page 23 Similarly, in the recent past several wars which resulted in heavy loss of life were fought partly on religious grounds. This is equally true of civil wars in which the members of several sects and religious denominations confront each other. Even in certain countries where there is no prevailing climate of civil war, confrontations between religious communities may lead to violence and cause the death of many persons. 78. Situations also occur where members of a religious minority are the victims of persecution that is more or less tolerated by the authorities. In several countries, cases have been reported of murders committed either collectively or by individuals against members of religious minorities, with no proper legal proceedings being instituted against the principals. 79. Sometimes the authorities are more directly implicated in the infringement of the right to life. In several countries, religious authorities have been assassinated by members of the armed forces or the police. There have also been cases of clergymen dying in labour camps or prison, as a result of ill-treatment during their detention, unexplained deaths of religious leaders have also occurred in several countries. Finally, death sentences may be pronounced and executed for religious reasons. In some countries, there have been dozens, sometimes even hundreds of executions, including those of minors for religious reasons. The main charge is sometimes related to a religious matter, such as apostasy. In other cases, religious grounds are not expressly invoked, and political reasons or charges of espionage or sabotage are adduced. However, there is every reason to believe that religious considerations are the cause of these executions. 80. The right to physical integrity is also infringed for reasons of religion. As in the case of violations of the right to life, these infringements may be brought about by individuals animated by religious hatred, may enjoy the complicity of the Government, or may even be carried out by the authorities themselves. They may take the form of physical brutality such as torture, beatings, rape or psychological pressure such as threats against close relatives or various forms of harassment such as police surveillance, interrogations, and solitary confinement. In some cases believers identified at the place of worship are persecuted; in other cases, clergymen are the main victims of ill-treatment. Often, the police are responsible for persecution and ill-treatment at the time of arrest, or during detention. 81. Breaches of freedom of thought, conscience and religion often lead to the infringment of the right to liberty and security of person. Thousands of cases of arbitrary arrest and detention for reasons of religion have occurred throughout the world and may be observed in a number of countries. In several countries, there may at times be several hundred prisoners of conscience. Infringements of the right to liberty may take various forms, such as house arrest, internal exile, detention in a psychiatric hospital, imprisonment, sometimes for very long periods, and assignment to a re-education or labour camp. The legal justifications adduced by the authorities may also vary. In some cases, the law is invoked in cases of arrest of members of religious sects and various provisions concerning religious activities are applied, such as the illegality of certain sects or of certain religious demonstrations and practices; at other times, religious grounds are not explicitly cited among the charges brought, but religious demonstrations are interpreted in such a