A/HRC/2/3 page 12 48. A link is often made between article 20 and the relevant provisions of the International Convention on the Elimination of All Forms of Racial Discrimination, and in particular its article 4 which provides, inter alia, that States parties: “(a) [s]hall declare an offence punishable by law all dissemination of ideas based on racial superiority or hatred, incitement to racial discrimination, […] against any race or group of persons of another colour or ethnic origin,”. 49. However, the 1981 Declaration on the Elimination of All Forms of Intolerance and of Discrimination Based on Religion or Belief does not contain a prohibition of incitement to religious discrimination similar to article 4 above. The Special Rapporteur cautions against confusion between a racist statement and an act of defamation of religion. The elements that constitute a racist statement are not the same as those that constitute a statement defaming a religion. To this extent, the legal measures, and in particular the criminal measures, adopted by national legal systems to fight racism may not necessarily be applicable to defamation of religion. 50. Domestic and regional judicial bodies - where they exist - have often laboured to strike the delicate balance between competing rights, which is particularly demanding when beliefs and freedom of religion are involved. In situations where there are two competing rights, regional bodies have often extended a margin of appreciation to national authorities and in cases of religious sensitivities, they have generally left a slightly wider margin of appreciation, although any decision to limit a particular human right must comply with the criteria of proportionality. At the global level, there is not sufficient common ground to provide for a margin of appreciation. At the global level, any attempt to lower the threshold of article 20 of the Covenant would not only shrink the frontiers of free expression, but also limit freedom of religion or belief itself. Such an attempt could be counterproductive and may promote an atmosphere of religious intolerance. III. CONCLUSIONS AND RECOMMENDATIONS 51. In the light of the above analysis, bearing in mind that the basic premise of the protection of human rights is respect for human dignity and the integrity of all individuals, regardless of their racial, ethnic, religious, gender or group affiliations, the Special Rapporteurs have articulated the conclusions and recommendations set out in the paragraphs below. 52. The Special Rapporteurs recommend that the Human Rights Council call upon Governments of Member States to continue to work for the implementation of the Durban Declaration and Programme of Action, which needs to remain the cornerstone in the combat against racism, racial discrimination, xenophobia and related intolerance. In this regard, the Council is invited to welcome the positive initiative of the Government of Brazil in organizing a regional conference aiming at identifying progress and remaining challenges in the implementation of the Durban Declaration and Programme of Action against racism, racial discrimination, xenophobia and related intolerance, and to encourage other regions to carry out the same analysis with the participation of Governments, civil society and individual experts.