A/HRC/10/8/Add.4 page 12 realm of the individual’s belief (forum internum). This is a core element of religious freedom, where the State has no right to interfere. No substantive review of an application should therefore be allowed, since it might lead to a discriminatory and excessively intrusive practice from the authorities. In a secular State like Turkmenistan,7 the authorities should remain neutral with respect to religious matters and restrict themselves to a formal review of registration applications. 30. Among the different reasons for denial of registration or liquidation of a religious organization spelt out in articles 12 and 14 of the Religious Organizations Law, some of them lack clarity. It is difficult to determine what exactly constitutes an offence and this might lead to abusive interpretation or excessive discretion by the authorities. Further, this could result in the imposition of collective sanctions for offences committed by individuals or a small group of individuals within the religious organization. Some examples include denial of registration if the organization fails to be recognised as a religious one (article 12) or the liquidation of an organization if there are interferences into family relationships that result in the break-up of a family (article 14). The Religious Organizations Law also refers to the commitment of “illegal actions” as a basis for liquidating a religious organization. During her mission, the Special Rapporteur was often told by Government officials that there were organizations using religious cover to carry out illegal activities and that these should be denied registration and/or liquidated. In this regard, she wishes to reiterate that the use of registration law is rarely efficient in tackling such criminal activities and that related allegations should be addressed on a case-by-case basis in accordance with the common criminal or civil legislation. 31. Although the Special Rapporteur was told by Ministry of Justice officials that, once registered in Ashgabat, religious organizations have the right to operate on the entire national territory and to establish local branches, it appears that in practice local registration is required in order to carry out religious activities. The Religious Organizations Law contains no provisions on that issue and since local authorities are left with wide discretionary power, registration requirements at the local level are often unclear. As a result, religious organizations have reportedly faced difficulties when trying to obtain local registration. The 2004 presidential decree, which has relieved the Ministry of Justice from the obligation to publish the list of registered religious organizations in the local media, has created further difficulties for religious organizations wishing to establish local branches and having to provide proof of their registration on the national level. 32. While religious organizations which have obtained registration seem to be able to operate with greater freedom, their activities, especially those of religious minorities, are still under great scrutiny on the part of the authorities. For instance, registered religious organizations still require permission from the authorities before holding a special meeting. The Special Rapporteur received reports that some religious communities preferred not to register, in order to avoid exposure to, and interference from, the authorities. 7 See article 1 of the Constitution of Turkmenistan.