A/HRC/37/49 discourse, competing with non-religious beliefs and other rationales to influence public policy, in the “marketplace of ideas”. 65. However, these States may also, in practice, face several challenges. For example, benefits provided on an equal basis may be more accessible to established religious communities than some newer or emerging groups who may struggle for recognition and continue to be perceived and/or stereotyped as “sects”. Furthermore, in some cases, where attempts to accommodate religious distinctions are rejected as signs of inappropriate State favouritism or differential treatment, the erosion of the freedom of religion or belief, frequently in the name of “others’ rights”, can occur. A string of judicial proceedings, debates in the media and political initiatives have contributed to this transformative process, putting into jeopardy certain religious rites and practices such as male circumcision, kosher slaughtering and the wearing of religious symbols. Such regulation of religious practice sometimes tends to “erect a barrier between one’s conscience and actions manifesting that conscience” 32 and can be indifferent to the integral nature of some forms of practice to individual conscience and agency. 66. Although these States appear best positioned to protect religion and the State from each other, and to recognize the universality of freedom of conscience, the extent to which the model is able to achieve its objective is in no small measure related to the ability and willingness of these States to implement their official policies. Thus, some States that profess non-identification struggle with upholding this pledge where there is disregard for the rule of law, and where politicization and rising xenophobia challenge the neutral or secular foundations of the State. Therefore, like all other models for the relationships between State and religion, the extent to which national religion laws satisfy international standards, the degree of respect for the rule of law and the level of tolerance and respect for diversity in law and practice are requisite determinates for being able to realize the goal to be an impartial and trustworthy guarantor of freedom of religion or belief for everyone.33 3. States with a negative view of religion 67. Worldwide, 10 countries pursue a policy of containing religion. Frequently associated with State-promoted atheism, the authorities in these States pursue a highly restrictive policy towards religion. The underlying feature of this model is that the State intends to control religion, both in the public and, at times, private spheres. Regulations are enforced to keep religion out of public affairs. Authorities cultivate a negative identification towards any religion. In other words, the obligation to accommodate everyone’s right to enjoy freedom of religion or belief is not respected. 68. Ironically, such State behaviour is not unlike the polar opposite of this model: “religious States”, where religion is enforced upon individuals. The top eight recipients of communications by the mandate are from these two groups. In both cases, the State embodies a sacredness where no other religion or belief should rival the State ideology. As a result, the overall context of these States is repressive and contains elements of coercion. Restrictions on religious practices are often articulated in the name of ensuring “equality” for all citizens. However, equal opportunities for individuals to enjoy these rights may be non-existent. In fact, all forms of (individual) freedom are sacrificed in the name of (collective) equality. 69. These States tend to impose high levels of restrictions, resulting in a wide-range of documented violations of freedom of religion or belief. Moreover, other interdependent and mutually reinforcing rights are invariably violated too, including the freedoms of opinion, expression, peaceful assembly and association, which are all interdependent and interrelated. Among the most notorious examples of this intersection of rights is the ability to express views, and to express, write, publish, disseminate or import religious publications — as well as to practise these rites in community with others. Censorship over press, media and publications restrain a whole range of these rights. 32 33 See Sheldon Leader, “Freedom and Futures”, in Modern Law Review, vol. 70, iss. 5, pp. 713–30. See A/HRC/25/58, para. 37. See also Bielefeldt, Ghanea and Wiener, Freedom of Religion or Belief (footnote 15), p. 357. 15