A/HRC/40/58 ambiguous terms such as “insult” or “defamation”, which are incompatible with article 19 of the International Covenant. The law set a foreboding precedent for the proliferation of restrictions that, in effect, serve to give rise to ever increasing attempts to filter and criminally sanction opinions deemed offensive to States or populist authoritarian sentiment. Moreover, online tools designed to combat expression that constitutes incitement are not guaranteed to be free from human bias, and their use might reinforce societal prejudices against minorities, exposing them to further stigmatization, discrimination and marginalization. Their use in a climate of intolerance, for example, at times, can result in the over-policing of certain faith communities and further inhibit communicative action. Individuals and whole communities may also be targeted through the manipulation of online filters, and the use of some tools, such as facial recognition technology, risks undermining the activities of civil society actors that peacefully pursue the exercise of fundamental human rights. 54. VII. Conclusions and recommendations Freedom of religion or belief and freedom of expression are closely interrelated and mutually reinforcing rights when they are exercised in the legal framework established by international human rights law. Both rights are fundamental to a democratic society and individual self-fulfilment and are foundational to the enjoyment of human rights. The Special Rapporteur asserts that the cases presented in the present report are illustrative of the fact that measures for addressing the challenges posed by expression involving religion or belief are open to abuse and can be counterproductive, oftentimes victimizing adherents of myriad religions and beliefs in their application. International law compels States to pursue a restrained approach in addressing tensions between freedom of expression and freedom of religion or belief. Such an approach must rely on criteria for limitations which recognize the rights of all persons to the freedoms of expression and manifestation of religion or belief, regardless of the critical nature of the opinion, idea, doctrine or belief or whether that expression shocks, offends or disturbs others, so long as it does not cross the threshold of advocacy of religious hatred that constitutes incitement to discrimination, hostility or violence. 55. Freedom of religion or belief relies on verbal and non-verbal forms of expression for public manifestation of thought, conscience, religion or belief in worship, observance, practice and teaching. It is also important for the realization of the right of parents or legal guardians to raise their children in accordance with their religious or moral convictions. Nevertheless, it is not uncommon for arguments to be advanced to impose restrictions on freedom of expression in the name of religion. Nearly 70 States have anti-blasphemy laws, and 30 States also have anti-apostasy laws. In some jurisdictions, either or both of these laws may provide for the use of the death penalty. These laws cannot be justified under the international human rights framework as that framework is intended to protect human beings and does not protect religions or beliefs as such. Some anti-blasphemy laws no longer claim to protect religions per se but claim to protect individuals from offence to their religious feelings. These laws against the defamation of religion, however, also have no basis in international law, as such restrictions do not comply with the limitations regime established by international law. 56. Increasingly, limitations on freedom of expression related to religion or belief take the form of anti-“hate speech” laws. Article 20 (2) of the International Covenant on Civil and Political Rights provides that States must prohibit by law any advocacy of religious hatred that constitutes incitement to discrimination, hostility or violence. At the same time, general comment No. 34 (2011) stresses that prohibitions under article 20 (2) must comply with the regime for limitations under article 19 (3). Moreover, advocacy of hatred requires a nuanced response that includes criminal sanctions as well civil, administrative and policy measures. States must ensure that criminal sanctions are imposed only in the most serious cases and be, based on a number of contextual factors, including intent. 57. 15