A/HRC/34/50 for the work of the Special Rapporteur. In addition, the Special Rapporteur recognizes the importance of engaging with the historic consensus achieved with the adoption of Council resolution 16/18, which brought together divergent views on eliminating religious discrimination and intolerance on the basis of proposals made on behalf of the Organization of the Islamic Conference and other stakeholders. The consensus-based approach guarantees religious pluralism and equality on the one hand, while promoting intercommunal harmony and calling for the prohibition of incitement to hatred on the other. In the resolution, the Council also underscored the importance of fostering the conditions for debate and dialogue, and reinforces protections for freedom of expression by narrowly construing exceptions to limits on speech deemed tantamount to “incitement to imminent violence based on religion or belief”. 16. The implementation mechanism for the eight-point action plan of resolution 16/18, the Istanbul Process for Combating Intolerance, Discrimination and Incitement to Hatred and/or Violence on the Basis of Religion or Belief, has facilitated six rounds of meetings organized to foster dialogue and practical experience-sharing. The objectives of the Istanbul Process remain relevant in the light of increasing reports of State actions that are incompatible with the right to freedom of religion or belief, including the use of blasphemy and apostasy laws, which render religious minorities and dissenters vulnerable to violence; increasing scrutiny of religious groups on the grounds of national security; and growing societal intolerance of religious minorities in a range of countries and regions. 17. Although progress in the implementation of resolution 16/18 has been slow, if not disappointing, the ongoing consensus achieved by its adoption, which appears fragile from time to time, should be seen in a positive light and nurtured. States should avoid a return to the divisive debates that undercut efforts to combat religious discrimination and intolerance prior to achieving this consensus agreement. In the past few years, some States have resurrected arguments over sources of discrimination and intolerance, the responsibilities that the international community should assume, and “whether the solution to intolerance lies in strengthening the enjoyment of fundamental human rights or in setting clearer limits thereon”. 2 Yet real progress by way of the Istanbul Process requires a comprehensive, introspective, transparent and inclusive approach to the implementation of the action plan outlined in resolution 16/18. Most importantly, the legal interpretations of the commitments undertaken in the action plan must comply with international human rights law. 18. The Rabat Plan of Action on the prohibition of advocacy of national, racial or religious hatred that constitutes incitement to discrimination, hostility or violence – a normative framework spearheaded by the Office of the United Nations High Commissioner for Human Rights and adopted by experts in 2012 – can serve as a road map for the Istanbul Process in this regard (A/HRC/22/17/Add.4, annex, appendix). The Rabat Plan of Action aims to clarify the obligations of State and the responsibilities of other stakeholders under articles 19 and 20 of the International Covenant on Civil and Political Rights; in doing so, it sets out a framework of measures that include the implementation of legislation, jurisprudence and policies to combat activities that constitute incitement to violence and discrimination on multiple grounds, including religion. It recommends the adoption of comprehensive anti-discrimination legislation with a view to the undertaking of preventative action to combat incitement to hatred. It identifies three distinct types of expression: expression that constitutes a criminal offence; expression that is not criminally punishable but may justify a civil suit or administrative sanctions; and expression that does not give rise to criminal, civil or administrative sanction but still raises concern in terms of tolerance, civility and respect for the rights of others. The plan of action also recommends 2 Marc Limon, Nazila Ghanea and Hilary Power, “Fighting Religious Intolerance and Discrimination: The UN Account”, Religion & Human Rights, vol. 11, No. 1 (2016), pp. 21-66. 7