Nor did the ECtHR consider the applicant’s claims of discrimination based on the ground of sex under Article 14 read in conjunction with Article 9 ECHR. In Dahlab, the ECtHR merely noted that the measure by which the applicant was prohibited: ‘purely in the context of her professional duties, from wearing an Islamic headscarf was not directed at her as a member of the female sex but pursued the legitimate aim of ensuring the neutrality of the State primary-education system. Such a measure could also be applied to a man who, in similar circumstances, wore clothing that clearly identified him as a member of a different faith.’ 75 Thus, the ECtHR’s leading case law, where the applicants claimed the right to non-discrimination on the grounds of religion and sex, does not take into account multiple grounds of discrimination. Moreover, the Court applied the same line of reasoning as in Şahin in its recent case law. In 2006, the ECtHR declared inadmissible three ‘headscarf ’ cases against Turkey. The case of Emine Araç v Turkey 76 concerned the rejection of an application for university because the applicant was in her headscarf in the accompanying photo. In Şefika Köse and 93 others v Turkey,77 the ECtHR found that the headscarf ban ‘in a second level school providing theological training’78 did not violate Article 9 ECHR. Nor did the ECtHR accept the arguments of a university lecturer in Kurtulmuş v Turkey,79 who lost her job after refusing to remove her headscarf. Moreover, the ECtHR has recently affirmed the principles established in Şahin in the context of secular France in its identical judgments in Dogru v France 80 and Kervanci v France.81 In Dogru, the applicant, a Muslim girl aged 11 in 1998, enrolled in a state secondary school in Flers. From January 1999 she wore the headscarf to school. Despite repeated requests by her teacher to remove the headscarf, she failed to comply with the instructions. On 11 February 1999, the school’s pupil disciplinary committee expelled the applicant from the school for not complying with the duty of assiduity.82 The applicant’s parents appealed against the school’s decision; however, French national courts repeatedly rejected their application and explained that, by not complying with instructions, Ms Dogru ‘overstepped the limits of the right to express and manifest her religious beliefs on the school premises’.83 The applicant claimed violation of her rights under Article 9 ECHR before the ECtHR. In its assessment, the ECtHR established that the ban on wearing the headscarf during sports classes and the expulsion of Ms Dogru from the school for her refusal to remove it constituted interference with her freedom of religion under Article 9(1). It then proceeded to determine 10 whether such interference was prescribed by law, pursued a legitimate aim and was necessary in a democratic society to achieve the aims concerned. The ECtHR found that the criterion of ‘prescribed by law’ was satisfied. Because the facts of the case took place in 1999, the Court considered that case law of the Conseil d’État comprised the relevant legal framework. The Court further noted that the interference pursued the legitimate aim of protecting the rights and freedoms of others and public order. Where the criterion of necessity in a democratic society is concerned, the ECtHR recapitulated its case law 84 to reiterate that to protect the rights of others states may impose limitations on the exercise of freedom of religion. Furthermore, the ECtHR repeatedly emphasized the role of the national decision-making bodies and states’ wide margin of appreciation in regulating the wearing of religious symbols in educational establishments.85 The ECtHR also observed that, as in Turkey and Switzerland, secularism is a constitutional principle in France and an ‘attitude which fails to respect that principle will not necessarily be accepted as being covered by the freedom to manifest one’s religion and will not enjoy the protection of Article 9 of the Convention’.86 Accordingly, taking into consideration states’ wide margin of discretion on the matter, the ECtHR ruled that the interference with the applicant’s right was justified under Article 9(2). Nor did the ECtHR consider it necessary to rule on violation of the applicant’s right to education under Article 2 of Protocol 1 ECHR. The ECtHR has recently examined the 2004 French law banning wearing of conspicuous religious symbols in public schools. On 17 July 2009, the ECtHR declared inadmissible several cases against France, which concerned the expulsion of pupils from school for wearing a religious dress. Thus, in Aktas v France,87 Bayrak v France,88 Gamaleddyn v France 89 and Ghazal v France,90 on the first day of school, the girls, who were Muslims and wore headscarves, were banned from public schools for wearing conspicuous religious dress.91 The ECtHR found that there was no violation of Article 9 ECHR, because the restriction was provided by the law of 15 March 2004 and restated in Article L.141-51 of the Education Code, which pursued the legitimate aim of protecting the rights and freedoms of others and public order. The ECtHR emphasized the importance of the state’s role as the neutral and impartial organizer of the exercising of various religions; furthermore, the ban on all conspicuous religious symbols was based on the constitutional principle of secularism, which was, in the ECtHR’s view, consistent with the values protected under the ECHR and its case law. Since the interference by the authorities with the pupils’ freedom to manifest their religion was justified and proportionate, the applications were rejected as manifestly ill-founded.92 The ECtHR also MINORITY GROUPS AND LITIGATION: A REVIEW OF DEVELOPMENTS IN INTERNATIONAL AND REGIONAL JURISPRUDENCE