PROTECTING MINORITY RIGHTS – A Practical Guide to Developing Comprehensive Anti-Discrimination Legislation on the extent of existing limitations on other symbols and how these impact other individuals/ communities. The experiences of Muslim women wearing the headscarf, beyond the case law, seem to show widespread instances of discrimination, as well as exposure to violence. Given the situation, States should be mindful of how restrictions on the wearing of the veil can further stigmatize Muslim women and prevent them from seeking redress. Moreover, some narratives surrounding debates on the wearing of the headscarf can perpetuate stereotypical, biased perceptions about the Muslim faith and the role of women.1011 Questions arise about whether acceptance of complete body coverings is consistent with States’ positive obligation under the Convention on the Elimination of All forms of Discrimination against Women to end traditional practices leading to the subordination of women.1012 Thus, for example, the Special Rapporteur on freedom of religion or belief has noted that: “Special attention should be paid to the protection of women’s rights, in particular in the context of wearing the full head-to-toe veil.”1013 Similar questions have arisen over the full-face veil.1014 Successive Special Rapporteurs on freedom of religion or belief have stressed the importance of safeguarding both the positive freedom to voluntarily display religious symbols and also the negative freedom from being forced to display religious symbols. Thus, for example, the Special Rapporteur noted that a “negative” side of freedom of religion or belief – the right not to be pressured, especially by the State or in State institutions, to participate in religious practices – “does not mean a right to be free from any confrontation with religious symbols or other manifestations of religious faith or practice in the public domain”. Such an approach “would clearly run counter to the human right to publicly manifest one’s religion or belief, either individually or in community with others”.1015 Rather, “the purpose of the ‘negative’ side of freedom of religion or belief is to make sure that no one is exposed to any pressure, especially by the State, to confess or practice a religion or belief against one’s own convictions”.1016 2. Religious or belief communities as duty bearers A further area explored in jurisprudence has been the question of whether religious or belief communities may themselves differentiate on the basis of religion or belief when acting in the role of employer or housing or health-care provider. In the area of employment, it is established that religious or belief communities or institutions affiliated with them may only preferentially hire co-religionists to positions with explicit doctrinal or dogmatic content. There can be no discrimination for positions lacking religious or doctrinal content. CLARIFYING THE LIMITS OF RELIGIOUS AUTONOMY: EGENBERGER V. EVANGELISCHES WERK FÜR DIAKONIE UND ENTWICKLUNG EV The question of whether religious organizations may hire only co-religionists has been repeatedly the subject of legal challenge in Germany. Germany has a number of large charitable organizations constituting a significant segment of the workforce, many of which enjoy significant State funding. Jobs in these organizations frequently have minimal if any religious content. In 2018, one legal challenge against these organizations’ practice of refusing to employ persons who are not co-believers reached the Court of Justice of the European Union. In 2012, Vera Egenberger applied for a job at Evangelisches Werk für Diakonie und Entwicklung, a charitable organization with a religious affiliation. The job had no religious doctrinal content, but 146 1011 Ibid., p. 30. See also E/CN.4/2006/5, para. 55. 1012 Article 5 (a) of the Convention on the Elimination of All Forms of Discrimination against Women states: “States Parties shall take all appropriate measures … to modify the social and cultural patterns of conduct of men and women, with a view to achieving the elimination of prejudices and customary and all other practices which are based on the idea of the inferiority or the superiority of either of the sexes or on stereotyped roles for men and women.” 1013 A/65/207, para. 34. 1014 OHCHR, “Human rights of women wearing the veil in Western Europe”, p. 8. 1015 A/HRC/19/60/Add.1, para. 31. 1016 Ibid.