A/HRC/10/8/Add.4 page 11 unnecessary confusion to the number of members required in order to register a religious organization. In addition, it is not clear which provisions of the Religious Organizations Law apply to religious groups or religious organizations. 27. The authorities have allegedly used the registration process to unduly restrict the right of freedom of religion or belief of members of certain religious communities, in particular of religious minorities. The Special Rapporteur was informed by members of certain religious communities seeking registration that they had often faced obstructions on procedural and/or substantive grounds. For instance, certain religious communities have seen their registration application being repeatedly sent back by officials of the Ministry of Justice requesting additional materials or suggesting amendments to the wording in the charter of the religious community and therefore delaying action on the application. While, according to article 11 of the Religious Organizations Law, decision regarding the registration of a religious community shall be made within three months from the date of the submission of the application, certain applications have reportedly been pending for several years. Other cases of obstruction relate to the requirement that the registration application be signed by all members of the religious organization and should contain their full names, dates of birth and places of residence.6 The Special Rapporteur would recommend that this requirement be at least limited to the initiators of the religious organizations, since it might in practice be difficult to obtain before registration the signature of all members, especially in large religious communities. Furthermore, those who were not included in the registration application might subsequently face difficulties when taking part in religious activities of their fellow believers. In addition, some members may legitimately wish to keep their religious affiliation confidential. 28. The Special Rapporteur would like to recall that registration procedures shall be applied in a non-discriminatory manner. Therefore, they shall make no distinction between large or small religious communities or between traditional religions and other religions or beliefs. As stated by the Human Rights Committee in its general comment No. 22 (1993), “the terms ‘belief’ and ‘religion’ are to be broadly construed. Article 18 is not limited in its application to traditional religions or to religions and beliefs with institutional characteristics or practices analogous to those of traditional religions. The Committee therefore views with concern any tendency to discriminate against any religion or belief for any reason, including the fact that they are newly established, or represent religious minorities that may be the subject of hostility on the part of a predominant religious community”. 29. The case of the small community of Jehovah’s Witnesses living in Turkmenistan is of particular concern to the Special Rapporteur. Although their members have sought to register their community for many years, the Council on Religious Affairs has invoked substantive reasons in order to deny legal status to the Jehovah’s Witnesses. These reasons relate, for instance, to the manner in which Jehovah’s Witnesses disseminate their religious views, to their refusal to serve in the army or to allow any blood transfusions. The Special Rapporteur would like to recall that while limitations on freedom to manifest one’s religion or belief are permissible under certain strict conditions, no limitations may be made to the internal and private 6 See article 11 of the Religious Organization Law and the Rules for Registration of Religious Organizations.