A/HRC/10/8/Add.1 page 34 […] In interpreting the scope of permissible limitation clauses, States parties should proceed from the need to protect the rights guaranteed under the Covenant, including the right to equality and non-discrimination on all grounds specified in articles 2, 3 and 26. Limitations imposed must be established by law and must not be applied in a manner that would vitiate the rights guaranteed in article 18. The Committee observes that paragraph 3 of article 18 is to be strictly interpreted: restrictions are not allowed on grounds not specified there, even if they would be allowed as restrictions to other rights protected in the Covenant, such as national security. Limitations may be applied only for those purposes for which they were prescribed and must be directly related and proportionate to the specific need on which they are predicated. Restrictions may not be imposed for discriminatory purposes or applied in a discriminatory manner”. Communication sent on 7 November 2008 126. The Special Rapporteur brought to the attention of the Government information she had received that the Parliament had approved the first reading of the draft law “On Freedom of Conscience and Religious Organizations in the Kyrgyz Republic” on 9 October 2008. Reportedly, this draft law would impose undue restrictions on freedom of religion or belief of individuals and religious or belief communities. For instance, the draft law would allegedly prohibit the activity or operation of all religious organisations which are not registered at the State Body on Religious Affairs. The proposed registration procedures also seem to impose minimum membership requirement (at least 200 adult citizens) to acquire legal entity status and would offer the possibility for the authorities to undertake substantial reviews of the registration applications submitted to them. Furthermore, the draft law would prohibit private religious education at all levels and certain proselytising activities such as the distribution in public places of religious literature and other materials of religious content and visits to private apartments and schools. 127. Fears have been expressed that the draft law contains vague provisions which could lead to the introduction of collective sanctions for actions committed by individuals or which could result in abusive interpretation and discrimination on the part of the law enforcement authorities. Finally, various religious communities have voiced their concern at the lack of public and open debate on the proposed draft law. Observations 128. The Special Rapporteur regrets that she has not received a reply from the Government of Kyrgyzstan concerning the above mentioned allegations. The Special Rapporteur would like to refer to her framework for communications, more specifically to the international human rights norms and to the mandate practice concerning registration (see above, para.1, category I.3.h) and concerning the right to manifest one’s religion or belief and the teaching and dissemination of materials, including missionary activity (see above, para. 1, category I.3.f). The Special Rapporteur would like to emphasize that registration should not be a precondition for practicing one’s religion, but may only be appropriate for the acquisition of a legal personality and related benefits. In the latter case, registration procedures should be easy and quick and not depend on extensive formal requirements in terms of the number of members or the time a particular religious group has existed. The Special Rapporteur would also like to reiterate that registration should not depend on reviews of the substantive content of the belief or its structure and clergy.