A/80/205 give no protection from persecution for reasons of religion if it was a condition that the person affected must take steps – reasonable or otherwise – to avoid offending the wishes of the persecutors. 70 The same point has been upheld in European Court of Human Rights judgments 71 and emphasized by mandate holders. 72 42. In the UNHCR guidelines, it is also recognized that “individuals may be persecuted on the basis of their religion, even though they have little or no substantive knowledge of its tenets or practices” and that that “less formal knowledge may also be required of someone who obtained a particular religion by birth and who has not widely practised it”. 73 The credibility of converts is, nevertheless, often questioned 74 due to supposedly incorrect answers to questions relating to their new religion. 43. Bias and ridicule also encroach on the assessment and interview process. In the reports submitted to the mandate holder, there are critiques of an overemphasis on knowledge-based questions, rejection of affidavits from religious institutions as evidence of conversion, ridicule from interviewers, sectarian influences 75 and ignorance relating to the non-religious. 76 44. There is also little understanding of the fact that conscientious objection to military service relates to freedom of religion or belief and that the rejection thereof may constitute religious persecution. In the report of the Office of the United Nations High Commissioner for Human Rights on conscientious objection to military service, the importance of better understanding of relevant international obligations is highlighted, 77 and the particular challenges faced by conscientious objectors, including the imposition of “exacting standards and burdens of proof that would render it difficult for deserters and draft evaders for reasons of conscience to achieve refugee status”, is acknowledged. 78 45. Special procedure mandate holders have expressed concern about deceptive and coercive measures being used to compel refugees escaping religious persecution to __________________ 70 71 72 73 74 75 76 77 78 12/23 See www.unhcr.org/uk/media/guidelines-international-protection-no-6-religion-based-refugeeclaims-under-article-1a-2, para. 13. See https://hudoc.echr.coe.int/fre#{%22itemid%22:[%22001-139903%22]}, para. 55. The Court of Justice of the European Union has come to a similar conclusion; see Bundesrepublik Deutschland v. Y and Z, Joined Cases C-71/11 & C-99/11 (2012), paras. 78–80. See also European Court of Human Rights, F.G. v. Sweden, Application No. 43611/11 (2012), para. 145. A/HRC/6/5, para. 30; and A/67/303, para. 40. See www.unhcr.org/uk/media/guidelines-international-protection-no-6-religion-based-refugeeclaims-under-article-1a-2, paras. 30 and 31. Federal Court of Australia, Mashayekhi v. Minister for Immigration and Multicultural Affairs, Case No. FCA 321, 22 March 2000. See www.ohchr.org/sites/default/files/documents/issues/religion/cfis/cfi -ga80/subm-freedomreligion-belief-cso-10-european-centre-law-justice.docx, www.ohchr.org/sites/default/files/ documents/issues/religion/cfis/cfi-ga80/subm-freedom-religion-belief-cso-13-joint-submissionassociation-pr-cern.pdf, www.ohchr.org/sites/default/files/documents/issues/religion/cfis/cfiga80/subm-freedom-religion-belief-cso-3-adf-international.docx, www.ohchr.org/sites/default/ files/documents/issues/religion/cfis/cfi-ga80/subm-freedom-religion-belief-cso-16-jointsubmission-by-international-hum-ience.docx and www.ohchr.org/sites/default/files/documents/ issues/religion/cfis/cfi-ga80/subm-freedom-religion-belief-cso-8-conscience-peace-taxinternational-onal.doc. See www.ohchr.org/sites/default/files/documents/issues/religion/cfis/cfi -ga80/subm-freedomreligion-belief-cso-12-humanists-uk.pdf. See also www.ohchr.org/sites/default/files/documents/issues/religion/cfis/cfi-ga80/submfreedom-religion-belief-cso-26-quaker-un-office.pdf. A/HRC/56/30, para. 33. 25-11829