E/CN.A/1992/52 page 177 181. Notwithstanding the inherent difficulty of providing a legal definition of religions, religious sects and religious associations, the Special Rapporteur noted that the majority of countries tended to adopt a neutral stance with regard to this issue and did not indicate the distinction made between them but limited themselves to enumerating the conditions required for their registration. The few relatively specific answers indicated a negative connotation attached to the notion of religious sects. This absence of precise definitions contrasted sharply with the Special Rapporteur's experience concerning so-called sects where these religious entities have not only been depicted in derogatory terms, but were openly persecuted and denied legal status on account of financial fraud, proselytism, heresy or simple lack of acceptance. Irrespective of the controversy which "sects" or "new religious movements" have caused in recent years, the Special Rapporteur maintains the position he adopted previously in carrying out his mandate, namely that the 1981 Declaration is the best instrument at the disposal of the international community allowing for a distinction to be made between legal and illegal practices of religious entities. 182. Replies to the questionnaire came from countries which offer a very broad representation of religions, civilizations and cultures. The Special Rapporteur noted that not all of them view the notion of believers and non-believers (freethinkers, agnostics and atheists) in the same way. Although the majority of replies attested to freedom of religious worship, only Western countries specifically referred to the "negative freedom" of holding no religious beliefs. In carrying out his mandate, the Special Rapporteur has come across instances where even persons belonging to a different school of the same religion were considered as inferior or infidels. He is of the opinion that the same principles of tolerance should apply to believers and to non-believers, who should not be discriminated against. Their rights should also be guaranteed in any new international instrument on the elimination of intolerance and discrimination based on religion or belief. 183. Despite the generally liberal attitude with regard to religious minorities that became apparent from most of the answers, the Special Rapporteur has once again noted the contrast with the hardships encountered by members of religious minorities, especially in countries with an official or clearly predominant majority religion. The attitude depended to a large extent on how the minority in question was viewed in doctrinal terms, which had a direct bearing on its juridical status. The Special Rapporteur has noted from experience, however, that even in the case of "recognized" religions, a ranking of sorts could nevertheless be observed in a number of countries. On the basis of the allegations submitted to the Special Rapporteur, in most countries where Islam is the predominant or official religion and where the Sharia (Islamic Law) prevails, proselytism and apostasy were particularly sensitive issues. On the other hand, he was pleased to note that some countries had formulated very specific legal dispositions to protect religious minorities. He believes that the 1981 Declaration provides clear guidelines in this respect. 184. The Special Rapporteur was pleased to note that most Governments do not apply the principle of reciprocity to foreigners in matters of religion or belief, even if they are aware that their own citizens may not enjoy the same