A/HRC/37/49 clergy. 26 The Special Rapporteur observes that States which officially identify with a religion, or that have significant entanglements with particular religion(s), or those that maintain a negative posture towards religion, are most prone to these types of unlawful interference. 47. Nevertheless, States that adopt more secular or neutral governance models may also run afoul of article 18 (3) of the Covenant if they intervene extensively, overzealously and aggressively in the manifestation of religion or belief alleging the attempt to protect other rights, for example the right to gender equality or sexual orientation. Such protection efforts need to be reconciled with the obligations to uphold freedom of religion or belief, although its manifestation can be limited if this leads to the violation of the rights and freedoms of others. When these rights ultimately clash, every effort must be made, through a careful case-by-case analysis, to ensure that all rights are brought in practical concordance or protected through reasonable accommodation. D. Implications and consequences of relationships between State and religion on implementing protections for freedom of religion or belief 48. Whether States support religion formally or do so in practice, or do not identify with any religion, or pursue policies intended to limit religion or belief in public life, many States adopt policies and engage in practices which result in a range of impediments and/or violations of freedom of religion or belief and/or interrelated rights. While States that impose official religions on their populations and those that seek to restrict all forms of religion are most prone to violating the right to freedom of religion or belief, no governance model for the relationships between State and religion is truly immune from unlawfully restricting or unduly interfering with manifestations of religion or belief. 49. For example, States with a negative view of religion that attempt to “sanitize” the public sphere from any religion or belief, or by rejecting policies for accommodation may, in some cases, run afoul of their duty to respect the right to manifest one’s religion or belief. Such efforts may also fail the “test” of non-discrimination, by which States are obliged to realize formal and substantive equality for all individuals, including members of groups in vulnerable situations, such as religious minorities. 50. Thus, regardless of the relationships States may allege or may have with religion(s) or belief(s), the manner and extent to which they support, restrict, regulate and limit religion in the public or private spheres pose significant implications for the implementation of human rights obligations. The extent to which State actions result in intervening with religion or belief or in undermining other underlying human rights, and the level to which government and religious institutions are entangled, have serious implications for the ability of States to respect, protect and promote freedom of religion or belief. 1. States with official or favoured religion(s) 51. The majority of States with official religions, or that favour one religion over others, devise systems for managing varying degrees of support to the preferred religion and in many cases to other religions being practised in their jurisdictions. This means that in most of these countries, the institutions of one or more religions receive benefits that are not shared by those of all faiths. States that officially identify with or confer preference on a particular religion are, typically, more likely than other States to interfere with religious practices. 27 According to one recent study, some 78 per cent of States with official or favoured religion interfered to some degree with the religious manifestation of individuals or belief groups in 2015.28 26 27 28 12 See, for example, article 6 of the Declaration on the Elimination of All Forms of Intolerance and of Discrimination Based on Religion or Belief. Fox, Political Secularism (see footnote 2). Pew Research Center, “Many Countries Favour Specific Religions” (see footnote 5).