PART FIVE: DISCRIMINATION AND EXPRESSION fact that article 5 (1) of the Covenant provides that: “Nothing in the present Covenant may be interpreted as implying for any State, group or person any right to engage in any activity or perform any act aimed at the destruction of any of the rights and freedoms recognized herein or at their limitation to a greater extent than is provided for in the present Covenant.”1146 However, any restrictions of the right to freedom of expression must be provided by law (articulated in a clear manner);1147 necessary and proportionate;1148 and adopted to respect the rights or reputation of others, or national security, public order, or public health or morals.1149 In interpreting the latter requirement, the Human Rights Committee has held that: “‘the concept of morals derives from many social, philosophical and religious traditions; consequently, limitations … for the purpose of protecting morals must be based on principles not deriving exclusively from a single tradition’. Any such limitations must be understood in the light of universality of human rights and the principle of non-discrimination.”1150 Examining the interaction between articles 19 (3) and 20 in particular, the Committee has concluded that the two provisions are “compatible with and complement each other”, stating further that: The acts that are addressed in article 20 are all subject to restriction pursuant to article 19, paragraph 3. As such, a limitation that is justified on the basis of article 20 must also comply with article 19, paragraph 3. … What distinguishes the acts addressed in article 20 from other acts that may be subject to restriction under article 19, paragraph 3, is that for the acts addressed in article 20, the Covenant indicates the specific response required from the State: their prohibition by law. It is only to this extent that article 20 may be considered as lex specialis with regard to article 19. … It is only with regard to the specific forms of expression indicated in article 20 that States parties are obliged to have legal prohibitions. In every case in which the State restricts freedom of expression it is necessary to justify the prohibitions and their provisions in strict conformity with article 19.1151 The Human Rights Committee has upheld States’ action on hate speech, going so far as to condone loss of employment for those inciting hatred, in particular in cases in which there were strong procedural guarantees accorded to the speaker.1152 1146 Ibid. 1147 E/CN.4/1995/32, paras. 38–55. 1148 “Appropriate to achieve their protection function; they must be the least intrusive instrument amongst those which might achieve the desired result; and they must be proportionate to the interest to be protected.” See Human Rights Committee, general comment No. 27 (1999), para. 14; and general comment No. 34 (2011), para. 34. 1149 A/74/486, para. 6. 1150 Human Rights Committee, general comment No. 34 (2011), para. 32. 1151 Ibid., paras. 50–52 (footnote omitted). 1152 Human Rights Committee, Ross v. Canada (CCPR/C/70/D/736/1997). 1153 Inter-American Court of Human Rights, Granier et al. v. Venezuela, Case 12.828, Report No. 112/12, Merits, 9 November 2012, para. 124. PART FIVE Regional human rights systems have developed approaches for reconciling their approaches to hate speech with freedom of expression requirements. Thus, the Inter-American Commission on Human Rights and the Inter-American Court of Human Rights have consistently held that “freedom of expression is not absolute” and that “restrictions may be deemed permissible even if the speech in question is political in nature”.1153 In Europe, where the European Court of Human Rights has repeatedly heard cases in which persons inciting racial or other hatred have appealed to the Court after national authorities took action against them, it has 177