E/CN.4/2006/5/Add.2 page 12 50. Among other provisions, these sharia penal codes provide for a mandatory death penalty as Hadd punishments7 for criminal offences such as zina,8 rape, sodomy and incest. 51. Many of the Special Rapporteur’s interlocutors including Muslims, supported the view that sharia penal codes had been introduced by state authorities seeking to please their populations. Others maintained that the extension of sharia was a result of the Government’s failure to address the real problems of Nigerian society. Muslims had progressively turned their backs on the non-religious way of organizing their lives and had found in Islam an appropriate response to their concerns as citizens. An introductory note to the sharia Penal Code of Zamfara State by the state Attorney-General says that the “inefficacy and failure of the Common law … provide yet another cogent reason and justification for a radical departure in favour of a remodelled Sharia-oriented Penal Code”. He admitted that “the sharia issue endures as the most debated and controversial issue in Nigeria”. He explained that the law adopted in Zamfara was based on the Maliki school and inputs to the bill had included visits to the Sudan and Saudi Arabia. 52. A large number of Nigerian Muslims support the imposition of sharia. A number of Muslim leaders emphasized that sharia was a way of life for all Muslims and its non-application would deny Muslims their freedom of religion. In Nigeria sharia was only applicable to Muslims; therefore, it was argued, it did not in any way limit the freedom of religion of non-Muslims. In addition, a number of Muslim leaders believed that English common law had its roots in canon law, making Muslims subject to a legal framework based on non-Muslim norms. Muslim personal law9 has always been applied in Nigeria. On the other hand, after several years of application, Islamic criminal law has created various problems and is far from enjoying unanimous support, even among Muslims. The Special Rapporteur will limit her report to those laws (regardless of their origin) that fall within the terms of her mandate. Implementation of sharia and religious minorities 53. The speed with which the sharia penal codes were adopted has led to many difficulties and concerns regarding their practical implementation. Judges, it was contended, had not been sufficiently trained, a concern because, at the first level of sharia courts, judges do not have to be lawyers. In some cases, following the adoption of these new codes, rules of evidence and procedure had either been disregarded or not correctly followed; defendants had been deprived of legal representation and convictions were arrived at in haste; some defendants did not understand what they were being tried for or the implications of their trials. In this respect, a lack of understanding of the operation of the Nigerian sharia penal codes as well as a lack of awareness about the rights and obligations under Islamic law in general, in particular concerning women or vulnerable groups, is a real source of concern. 54. A particularly alarming development in the implementation of sharia has been the institutionalization of enforcement bodies known as Hisbah, composed of young, untrained Muslim civilians, whose role is to enforce the principles of Islam. Their activities have resulted in a number of violent, arbitrary and other illegal acts, especially against non-Muslim women, which in many cases amounted to human rights violations.