A/80/205 37. The principle of non-refoulement is well established in multiple sources of international law, both customary law and treaty law, including under article 33 (1) of the Convention relating to the Status of Refugees and article 3 of the Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment. Under the International Covenant on Civil and Political Rights, the Human Rights Committee has explained that the article 2 obligation to respect and ensure Covenant rights “entails an obligation not to extradite, deport, expel or otherwise remove a person from [a State Party’s] territory, where there are substantial grounds for believing that there is a real risk of irreparable harm [in the State of destination], such as that contemplated by articles 6 and 7 of the Covenant”. 61 In the jurisprudence of the Committee on the Elimination of Discrimination Against Women relating to deportations or expulsions, it is recognized that “gender-related asylum claims may intersect with other proscribed grounds of discrimination, including e thnicity and religion”. 62 States Parties are obliged “to undertake an individualized assessment of the real, personal and foreseeable risk of gender-related persecution” or violence that a woman may face in a receiving State. 63 38. Sur place conversions give rise to particular concerns regarding credibility and can necessitate a rigorous investigation of the circumstances or sincerity of the conversion (or renouncement of religious identity in question). 64 When an asylum applicant converts to a new religion after his or her initial application has been denied, “it may be reasonable that an in-depth examination of the circumstances of the conversion be carried out by the authorities”. 65 The authorities nonetheless have an obligation to assess all the information before them before making a decision on the removal of an individual and must carry out a sufficiently serious ex nunc examination of the consequences of conversions, including how the religion or belief that they have adopted is expressed. 39. The Human Rights Committee has observed that, “regardless of sincerity”, the State must still consider whether the individual’s “behaviour and activities in connection with or to justify his or her conversion, such as attending a church, being baptized, participating in proselytizing activities, could have serious adverse consequences in the country of origin so as to put him or her at risk of irreparable harm”. 66 This is in line with UNHCR guidelines, 67 which also note that, even where a claim “is found to be self-serving but the claimant nonetheless has a well-founded fear of persecution on return, international protection is required”. 68 40. The risks associated with the act of conversion itself – either to another religion or away from religion altogether – must also be taken into account. The European Court of Human Rights has ruled that failure to take account of the greater danger faced by converts and the specific targeting that they are at risk of would constitute a violation of articles 2 and 3 of the Convention for the Protection of Human Rights and Fundamental Freedoms (European Convention on Human Rights). 69 41. It is unreasonable to expect an individual to simply hide his or her religion or belief upon return. As emphasized in the UNHCR guidelines, the Convention would __________________ 61 62 63 64 65 66 67 68 69 25-11829 CCPR/C/21/Rev.1/Add.13, para. 12. CEDAW/C/62/D/53/2013, para. 9.5. CEDAW/C/85/D/173/2021, para. 7.6. See https://hudoc.echr.coe.int/fre#{%22itemid%22:[%22001-161829%22]}, para. 144. CCPR/C/121/D/2419/2014, para. 11.8. Ibid.; CCPR/C/125/D/2439/2014, para. 8.5; CCPR/C/128/D/3032/2017, paras. 7.5 and 7.8; and CCPR/C/131/D/3069/2017, para. 9.4. See https://unhcr.org/uk/media/guidelines-international-protection-no-6-religion-based-refugeeclaims-under-article-1a-2, para. 35. Ibid., para. 36. See https://hudoc.echr.coe.int/fre#{%22itemid%22:[%22001-216976%22]}. 11/23