E/CN.4/2006/5/Add.3 Page 14 the Kokkinakis case, the Court’s jurisdiction had not been invoked by a victim. The Rapporteur concluded that in all three determinations made by the Supreme Court around the issue of conversion, its decisions were “in the realm of conjecture or speculation that the disadvantaged or vulnerable would be subject to improper conversion. What material was submitted to the Court to back this impression is not clear”. 72. While not willing to discuss the findings of the European Court of Human Rights in a particular case, the Special Rapporteur is of the opinion that the supporters of the draft laws have disregarded the context of the Kokkinakis case. She recalls that the European Court eventually found a violation of the right to freedom of religion or belief of those who wanted to propagate their religion. The Court also held that “freedom to manifest one's religion is not only exercisable in community with others, ‘in public’ and within the circle of those whose faith one shares, but can also be asserted ‘alone’ and ‘in private’; furthermore, it includes in principle the right to try to convince one's neighbour, for example through ‘teaching’, failing which, moreover, ‘freedom to change [one's] religion or belief’, enshrined in Article 9 (art. 9), would be likely to remain a dead letter”. 73. In the opinion of the Special Rapporteur, the draft laws do indeed raise concern in terms of human rights law, including in terms of the right to freedom of religion or belief. While some maintain that freedom of religion, and in particular the right to choose a religion, may be violated in cases where, for example, a person in need has converted after having received presents and inducements that may significantly improve his or her life, the enjoyment of that right by the same person may equally be impaired if he or she does not have the possibility to freely decide to convert to another religion, even after having received a gift. Of even greater concern is that the decision to complain is not restricted to the aggrieved party. The Special Rapporteur’s role is indeed to ensure that individuals are both protected against acts aimed at forced conversions and that their freedom to adopt a religion of their choice or to change religion is safeguarded. In its general comment No. 22, the Human Rights Committee clearly held that “the freedom to ‘have or to adopt’ a religion or belief necessarily entails the freedom to choose a religion or belief, including the right to replace one's current religion or belief with another or to adopt atheistic views, as well as the right to retain one's religion or belief”. 74. Moreover, the draft laws challenge an aspect of the right to manifest one’s religion because they would criminalize certain acts that, according to how restrictively the laws are interpreted, may be part of the right to manifest one’s religion. According to the Human Rights Committee, “The freedom to manifest religion or belief in worship, observance, practice and teaching encompasses a broad range of acts. The concept of worship extends to ritual and ceremonial acts giving direct expression to belief, as well as various practices integral to such acts, including the building of places of worship, the use of ritual formulae and objects, the display of symbols, and the observance of holidays and days of rest… In addition, the practice and teaching of religion or belief includes acts integral to the conduct by religious groups of their basic affairs, such as the freedom to choose their religious