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return. 79 Urgent concerns have been raised regarding mass deportation or
“repatriation” with no individual risk assessments for religious or belief minorities. 80
E.
Targeting of asylum-seekers, refugees and migrants
46. State and non-State actors regularly target asylum-seekers, refugees and
migrants through hate speech and violence. Sharp political polarization and the
promotion of fear and hatred against people on the move to gain political “mileage”
is, regrettably, commonplace. Inputs received for the present report have added to the
record of such violations received under the mandate since it was established. The
inputs have included cases of alleged extrajudicial killings and torture of migrants on
the basis of witchcraft allegations arising from the peaceful practice of their religious
beliefs. 81
47. A sense of belonging and freedom from discrimination on the basis of religion
or belief cannot be assumed when both migrants and host communities share a
common religion or belief, since expressions may differ significantly. In addition,
minorities within religion or belief communities, whether with sectarian differences
or relating to other intersectional characteristics, find themselves vulnerable to
discrimination and may thus avoid mainstream support services. 82 Those who are
readily identifiable as belonging to a particular religion or belief, for example women
because of their headdresses or men because of their beards, may be particularly
vulnerable.
48. The African Commission on Human and Peoples’ Rights has tackled cases of
large-scale killings and forcible displacement by government-backed militias of
Indigenous tribes that were mostly Muslims. 83 Numerous violations of the African
Charter on Human and Peoples’ Rights were found, although the Commission did not
discuss the religious element of this ethnic cleansing.
49. The Karaahmed v. Bulgaria case concerned an incident where some 100–150
leaders, members and supporters of a Bulgarian political party clashed with Muslim
worshippers, including both Bulgarian nationals and immigrants, while they were
gathered for Friday prayer. Violation of freedom of religion or belief was found, due
to the failure of the domestic authorities “to strike a proper balance in the steps they
took to ensure the effective and peaceful exercise rights of the demonstrators and the
rights of the applicant and the other worshippers to pray together, as well as their
subsequent failure properly to respond to those events”. 84
50. Vaguely formulated laws are often used to frame asylum -seekers, refugees and
migrants as spies, foreign agents or criminals, with no regard for the only legitimate
limitations to the manifestation of freedom of religion or belief as referred to in article
18 (3) of the International Covenant on Civil and Political Rights , or due process.
51. Asylum-seekers may also be targeted in their host countries by members of their
community or their nationality of origin; such attacks may be facilitated by the spread
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79
80
81
82
83
84
25-11829
See communication BGD 5/2023.
See communication PAK 11/2023. See also www.ohchr.org/en/press-releases/2025/07/unexperts-alarmed-resumption-us-deportations-third-countries-warn and communication USA
14/2025.
See www.ohchr.org/sites/default/files/documents/issues/religion/cfis/cfi -ga80/subm-freedomreligion-belief-cso-14-joint-submission-libya-anti-tortur-rture.pdf.
According to consultation participants.
See www.africanlii.org/akn/aa-au/judgment/achpr/2009/100/eng@2009-05-27.
See https://hudoc.echr.coe.int/eng#{%22itemid%22:[%22001-152382%22]}, para. 111.
13/23