Rabat Action Plan

We publish the conclusions and recommendations of four regional expert meetings organized by OHCHR in 2011, adopted by experts in Rabat (Morocco) on October 5, 2012.

Conclusions and recommendations of four regional expert meetings organized by OHCHR in 2011, adopted by experts in Rabat (Morocco) on October 5, 2012

I. Preface

1. In 2011, the Office of the United Nations High Commissioner for Human Rights (OHCHR) organized a series of expert workshops in various regions of the world on the issues of propaganda of national, racial or religious hatred and its interpretation under international human rights law. During the meetings, participants reviewed the situation in various regions and discussed strategic responses, both extra-legal and legal, related to incitement to hatred.

2. Events took place in Europe (Vienna, 9 and 10 February 2011), Africa (Nairobi, 6 and 7 April 2011), Asia and the Pacific (Bangkok, 6 and 7 July 2011) and the Americas (Santiago de Chile, 12 and 13 October 2011). [1] Thus, the goal of OHCHR was to conduct a comprehensive assessment of the implementation at the national and regional levels of legislation, legal and political practice in the field of propaganda of national, racial or religious hatred, consisting of calls for discrimination, hostility or violence [2] , at the same time promoting the development of a fully respectful attitude towards freedom of speech (self-expression), protected by international human rights legislation. The main focus of the discussion was the relationship between freedom of expression and hate speech, especially in the area of ​​religion - an issue that is increasingly in the spotlight and has repeatedly caused tensions and episodes of violence both between and within different communities.

3. The 2011 expert meetings provided a wealth of information and a range of practical proposals for more effective ways of implementing relevant standards in international human rights law. [3] To take stock of the series of meetings held in 2011, OHCHR initiated a final expert meeting (in Rabat, 4 and 5 October 2012) to benchmark the results of the four previous meetings, formulate possible actions at all levels, and think about the best ways and means of sharing experience.

4. The expert meeting in Rabat was attended by four moderators and experts from all four previous meetings, including the Special Rapporteur on freedom of speech and expression, the Special Rapporteur on freedom of religion or belief, the Special Rapporteur on racism, discrimination, xenophobia and related intolerance, representative of the Committee on the Elimination of Racial Discrimination and representative of the non-governmental organization “Article XIX”

5. In accordance with the practice of previous meetings, participating States were invited to participate as observers. They were recommended to include leading experts in their delegations. Relevant UN departments, funds and programs, as well as relevant international and regional organizations, national human rights institutions and civil society organizations (including the press, academic and religious organizations) were also invited to participate as observers.

6. The outcome document below reflects the conclusions and recommendations developed during the Rabat meeting by experts who participated in all four workshops or moderated one of them.

II. Context

1. As the world becomes increasingly interconnected and the fabric of society more multicultural, incidents in recent years in various parts of the world have brought renewed attention to the issue of incitement to hatred. It should be emphasized that, despite this, many of the conflicts that have unfolded in the world in recent decades also, to varying degrees, also contained a component of inciting national, racial or religious hatred.

2. All human rights are universal, indivisible, interdependent and interrelated. This interdependence becomes abundantly clear in the discussion of how the right to free speech relates to other human rights. The implementation of the right to freedom of expression makes possible lively, multifaceted debates on issues of interest to society, voicing different approaches and points of view. Respect for freedom of expression is critical to democracy and sustainable human development and contributes to peace and security in the world.

3. However, individuals and groups unfortunately become victims of various forms of discrimination, hostility or violence due to factors such as ethnicity or religion. One of the specific challenges in this area is curbing the negative consequences of manipulation of issues of race, ethnicity and religion, protecting against the unwanted use of concepts of national unity or national identity, which are often used, including for political and electoral purposes.

4. It is often argued that freedom of expression and freedom of religion or belief are difficult to reconcile and may even contradict each other. On the contrary, they are interdependent and reinforce each other. Freedom to profess or not to profess a religion or belief is impossible in the absence of freedom of expression, since free public discourse depends on the degree of respect for the diversity of people's deep convictions. Likewise, freedom of expression is necessary to create an environment in which it is possible to have constructive conversations about religious issues. Indeed, free and critical thinking through open discussion is the best way to test whether religious interpretations are consistent with or distort the original values ​​underlying the religion.

5. It is of concern that incidents that can actually be qualified as a violation of Art. 20 of the International Covenant on Civil and Political Rights (ICCPR) do not lead to prosecution or punishment. At the same time, members of minorities are subject to de facto persecution through abuses of unclear domestic laws, enforcement and procedures, which negatively impact other members of the community. This dichotomy, namely (1) lack of prosecution in cases of “real” incitement to hatred and (2) persecution of minorities under the guise of national incitement to hatred laws, appears to be significantly widespread. The laws against incitement to hatred used in different countries of the world can be characterized as heterogeneous, sometimes overly narrow or vague; Legal practice in the area of ​​incitement to hatred is sparse and inconsistent, and although States have adopted procedures, most of these procedures are too general, not systematically applied, poorly focused and their effectiveness is not adequately analysed.

6. In light of the above, holding four meetings in all regions of the world and a final meeting in Rabat with the full participation of experts from relevant organizations and special mandate holders is a very timely and useful initiative.

III. Implementation of the ban on hate speech

1. Against this backdrop, the following conclusions and recommendations represent a synthesis of the experts' lengthy, open-ended, and in-depth reflections. These conclusions - in the areas of legislation, judicial infrastructure and political strategy - are aimed at supporting all parties interested in implementing the international ban on the promotion of national, racial or religious hatred that constitutes incitement to discrimination, hostility or violence.

A. Legislation

conclusions

1. In accordance with international human rights standards, which must be complied with by legislation at the national level, speech that falls under the definition of “hate speech” may be limited in accordance with Art. 18 and 19 ICCPR on various grounds, such as respect for the rights of others, public order, and sometimes even national security considerations. States are also required to “prohibit” speech amounting to “incitement” to discrimination, hostility or violence (under Article 20.2 of the ICCPR and, under certain other conditions, also under Article 4 of the International Convention on the Elimination of All Forms of Racial Discrimination ( ICERD).

2. Discussions during various meetings demonstrated that there is no legal prohibition against incitement to hatred in the statute books of many countries around the world. In addition, legislation prohibiting incitement to hatred is inconsistent in terminology, which is often inconsistent with Art. 20 ICCPR. The broader the definition of incitement to hatred in a country's legislation, the greater the potential for arbitrary application of these laws. The terminology associated with crimes of incitement to national, racial or religious hatred varies from country to country and is becoming increasingly vague as new categories of restrictions on freedom of expression are added to legislation. This increases the risk of misinterpretation of Art. 20 ICCPR and the emergence of additional restrictions on freedom of expression not specified in Art. 19 ICCPR.

3. Some countries' laws include offenses relating to incitement to both racial and religious hatred, while others deal exclusively with racial and ethnic issues. Some countries also prohibit incitement to hatred for other reasons. The approaches of states to the distribution of issues between civil and criminal law are also different. In many countries, incitement to hatred is a criminal offense, while in others it may be dealt with under both criminal and civil, or exclusively civil, laws.

4. At the international level, the prohibition of incitement to hatred is clearly defined in Art. 20 ICCPR and Art. 4 ICERD. In General Comment No. 34, the Human Rights Committee emphasizes that prohibitions on disrespect for a religion or other belief system (including blasphemy laws) are incompatible with the Covenant, except in the specific circumstances provided for in paragraph 2 of Art. 20 of the Pact. Such prohibitions must also comply with the strict requirements of paragraph 3 of Art. 19, as well as articles 2, 5, 17, 18 and 26 of the ICCPR. Thus, for example, it is unacceptable for such a law to provide discrimination in favor of one or a number of religions (belief systems) or against them, as well as discrimination against adherents of any religion (religions) in relation to others, or discrimination of believers in relation to non-believers. Nor should such prohibitions be used to prevent criticism of religious leaders or commentary on matters of religious doctrine and principles of faith, or as a punishment for such criticism or commentary.

5. Art. 20 of the ICCPR provides for a high threshold of liability in accordance with the fundamental principle that restrictions on freedom of speech must be an exceptional measure. This threshold must be considered in conjunction with Art. 19 ICCPR. Indeed, the test for the admissibility of restrictions (consisting of three parts - legality, proportionality and necessity) also applies to cases of incitement to hatred, i.e. restrictions must be established by law, defined narrowly enough to promote legitimate public interests, and must be necessary to protect those interests in a democratic society. This means, among other things, that restrictions must meet the following requirements: they must be clearly and narrowly defined, they must respond to a compelling social need, they must intrude to the least extent possible on public and private life, and they must not be too broad (i.e. . do not impose broad or vague restrictions on freedom of expression), be proportionate in the sense that the benefit to the interests protected outweighs the harm to freedom of expression, including in relation to the sanctions they impose.

6. At the national level, blasphemy laws are counterproductive because they can effectively censor dialogue and debate between and within different religious and ideological systems, as well as suppress criticism that, for the most part, may be constructive, healthy and necessary. In addition, many blasphemy laws provide varying levels of protection for different religions and, in practice, have often been and are being applied in a discriminatory manner. There are numerous examples of persecution of religious minorities or non-conformists, atheists and non-believers through the use of religious offenses legislation or the overzealous application of various neutrally worded laws. Moreover, the right to freedom of religion or belief, as enshrined in relevant international legal norms, does not imply the right to a religion or belief that is not subject to criticism or ridicule.

Recommendations

• In terms of general principles, a clear distinction must be made between three types of speech: speech that constitutes a criminal offence; speech that is not criminally punishable but may be subject to civil action or administrative sanctions; speech that is not subject to criminal, civil or administrative sanctions, but nevertheless raises concerns from the point of view of tolerance, civility and respect for the rights of others.
• Taking into account the relationship between Art. 19 and 20 ICCPR, states must ensure that national legislation on incitement to hatred is based on an express reference to Art. 20 ICCPR (“advocacy of national, racial or religious hatred constituting an incitement to discrimination, hostility or violence”), and also consider reliable definitions for key terms such as hatred, discrimination, violence, hostility, etc. In particular, legislation may draw on the guidance and definitions set out in the Camden Principles on Freedom of Expression and Equality. [4]
• States must ensure that the three criteria for restricting freedom of expression – legality, proportionality and necessity – also apply to cases of hate speech.
• States should take into account the guidance of leading international human rights expert mechanisms, including the Human Rights Committee and the Committee on the Elimination of Racial Discrimination (CERD) and their General Comment No. 34 and General Recommendation No. 15, respectively, as well as the guidance of relevant special mandate holders procedures of the Human Rights Council.
• States are encouraged to ratify and effectively implement relevant international and regional human rights instruments, remove existing objections, and comply with relevant reporting obligations.
• States with blasphemy laws should repeal them, as such laws have a negative impact on freedom of religion or belief and the ability to engage in healthy dialogue or debate about religion.
• States must adopt comprehensive anti-discrimination legislation, including preventive and punitive measures to effectively combat incitement to hatred.

B. Enforcement

conclusions

1. An independent judicial infrastructure that is regularly brought into line with current international standards and legal practice, and whose representatives act impartially, objectively and with respect for due process of law, is critical to ensuring that the facts and legal qualifications are assessed in each case that meets international human rights standards. In addition, other checks and balances, such as independent national human rights institutions established in accordance with the Paris Principles, are necessary to protect human rights.

2. The level of recourse to judicial and quasi-judicial mechanisms in cases of alleged incitement to hatred is often extremely low. In many cases, victims come from disadvantaged or vulnerable groups. Throughout the world, information about precedent law in the field of prohibition of stimulation of hatred is reluctant. In some cases, this can be explained by the lack of legislation, the lack of adequate legislation, or the lack of judicial assistance accessible to minorities and other vulnerable groups that make up most victims of hatred. The lack of information about judicial practice may be associated with the lack of available archives, but also simply with the lack of appeals to the court due to insufficient awareness of the company and distrust of the judicial system.

3. It was proposed to establish a high threshold to introduce restrictions on freedom of expression in determining the excitement of hatred and for the application of Art. 20 MPGPP. The severity criterion necessary to overcome the threshold implies that only the most grave and emotionally charged insults are classified as arousing of hatred. Possible parameters for assessing the degree of hatred may include the cruelty of what has been said, the degree of harm, to which the speaker, the frequency and number of statements and the degree of their publicity called. In this regard, a test of six parts was proposed to determine the statements subject to persecution in criminal order.

4. Context : The context is very important for assessing whether specific statements really encourage discrimination, hostility or violence, it can be directly related to intentions and/or reason. Contextual analysis should place a statement in the social and political context that prevailed at the moment when this statement was made or spread.

5. Orator : It is necessary to take into account the position or status of the speaker in society, in particular, the position of a given person or organization in relation to the desired audience of the statement.
6. Intent : Art. 20 MPGPP assumes the presence of intent. Negligence and recklessness are not sufficient grounds for the use of Art. 20, which requires "propaganda" and "excitement of hatred", and not just distribution. In this regard, the article suggests the presence of a triangle of relations between the object of the statement, the subject of the statement and the audience.
7. Content or form : The content of the statement is one of the main objects of judicial consideration and the main component of the excitation of hatred. The analysis of the content involves the clarification of how direct and provocative was the statement, as well as the consideration of the form and style, the nature of the arguments put forward by the speaker, the balance of argumentation, etc.
8. The degree of publicity : this item includes such elements as the availability of the statement, the character of the addressee, the significance and size of the audience. Further considerations - whether the statement is public, what are the means of its distribution. It is necessary to take into account, the statement was distributed through the only leaflet, by broadcasting in the media or via the Internet, what were the frequency, quantity and width of coverage, whether the audience had the opportunity to act in accordance with provocative calls, the statement (or work of art) was distributed in a narrow circle or was publicly available.
9. The probability of the implementation of the call, including inevitability: the excitement of hatred, by definition, is a crime in the bud. The action that the statement encourages is not obliged to take place so that the statement can be recognized as criminal. However, to some extent, a potential risk of harm should be determined. This means that the courts will have to establish that there was a real probability that the statement could provoke an actual action against the target group, realizing that in this case a fairly direct causal relationship should be indicated.

Recommendations

• National and regional courts should regularly receive updated information about international standards and international, regional and comparative legal practice in relation to hatred, since, faced with similar cases, the courts should conduct a thorough analysis based on well -thought -out threshold criteria.
• States should ensure the right to a fair and public proceedings of the case by a competent, independent and impartial court formed in accordance with the law.
• Prheardly attention should be paid to minorities and vulnerable groups, their representatives should be provided with legal and other assistance.
• States should provide persons who have suffered real damage as a result of the excitement of hatred, the right to effective means of legal protection, including a civil or non -court mechanism for compensation for damage.
• Criminal sanctions associated with illegal forms of utterance should be considered as extreme measures that should be used only strictly justified in special situations. It is also necessary to consider the possibility of civil sanctions and means of legal protection, including compensation for material and moral damage, along with the right to refute and the right to answer. It is also necessary to consider the possibility of using administrative sanctions and means of legal protection, including those that are defined and applied by various professional institutions and regulatory authorities.

S. Politics

conclusions

1. For all the importance of legal response, legislation is only part of a set of tools that can be used in the fight against the enemy language. Any relevant legislation should be supplemented by initiatives coming from various layers of society and focused on the multiplicity of political and practical measures to educate public consciousness, tolerance, awareness of change and open discussion. The purpose of these steps is the creation and strengthening of the culture of the world, tolerance and mutual respect between people, state officials and the judicial community, as well as the influence of the media, religious leaders and leaders of local communities in order to increase their ethical and social responsibility. The states, the media and society are collective liability in order to express a protest and take measures in accordance with international law in the field of human rights.

2. Political and religious leaders should refrain from the expression of intolerance or statements that encourage violence, hostility or discrimination. Their firm and timely statements are against intolerance, discriminatory stereotypes and the language of hostility also play a decisive role. It should be explained that the use of violence in response to the excitement of hatred is categorically unacceptable.

3. To eliminate the indigenous causes of intolerance, a much wider set of strategic measures is necessary, for example, in the field of intercultural dialogue (mutual understanding and interaction): the education of pluralism and the ability to appreciate the diversity, the attitude towards minorities and indigenous peoples the opportunity to fulfill their right to express opinions .

4. The states are responsible for providing minorities with the opportunity to use basic rights and freedoms, for example, by promoting the registration and functioning of their media organizations. States should encourage communities in their desire to access a wide range of opinions and information and share them, as well as welcome a healthy dialogue and discussion that arose as a result.

5. Some regions clearly preferred an outside-which approach to the fight against the excitation of hatred, in particular, applying socio-political measures and creating various types of institutions and processes, such as a commission to establish truth and reconciliation. The work of regional human rights mechanisms, specialized organizations, active civil society and independent monitoring institutions is fundamentally important in all regions of the world. In addition, positive traditional values, compatible with international-recognized norms and standards in the field of human rights, can also contribute to the fight against hatred.

6. The media and other means of communication play a fundamental role in ensuring freedom of expression and establishing equality. On a global scale, traditional media are still important, but they experience a significant transformation. New technologies - including digital broadcasting, mobile telephony, Internet and social networks - make possible significantly wider distribution of information and give rise to new forms of communication, such as blogosphere.

7. The steps taken by the UN Council for Human Rights, in particular, the adoption of a resolution of 16/18 “On the fight against intolerance, negative stereotypes, stigmatization, discrimination, calls for violence and the use of violence in relation to their religion or beliefs”, create A promising platform for effective, complex and comprehensive actions by the international community. This resolution requires the implementation and permanent state control over execution at the national level, including through the “Rabat plan of action”, which is a contribution to its implementation.

Recommendations to states

• States need a large degree of involvement in a wide campaign to combat negative stereotypes and discrimination of individuals and communities based on their nationality, ethnic origin, religion or beliefs.
• States should contribute to intercultural understanding, in particular, in gender issues. In this regard, all states are responsible for building a culture of peace and the obligation to put an end to impunity.
• States should provide teachers with additional training on the issues of values ​​and principles in the field of human rights, initiating or strengthening the emphasis on intercultural understanding in school programs for students of all ages.
• States should allocate a larger number of resources for the training of employees of security agencies, law enforcement agencies and persons participating in the administration of justice, and attracting their attention to issues regarding the prohibition of hatred.
• States should consider the creation of institutions to ensure equality, or strengthen such a function within the framework of existing national human rights organizations (established in accordance with Parisian principles), with an increased level of professionalism in the field of promoting social dialogue, as well as with powers to accept complaints in cases of exciting hatred . For the effective execution of such functions, new adapted manuals, tests and recommended practices are also necessary to avoid arbitrariness and contribute to the coordination of practice at the international level.
• States should guarantee a systematic collection of data on crimes related to the initiation of hatred, and ensure the existence of the necessary mechanisms and institutions.
• States should develop a public strategy and regulatory framework that would contribute to the development of pluralism and the variety of media, including using new media technologies, and would provide a lack of discrimination in access to means of communication and in their use.
• States should strengthen the support of international human rights mechanisms, in particular, contractual bodies (such as the Human Rights Committee and CLD) and mandatarians of special procedures, since they provide consultations and assistance to states in the work on the implementation of human rights legislation.

Recommendations of the United Nations

• The Office of the Supreme Commissioner for Human Rights should be provided with resources necessary for adequate support for international expert mechanisms designed to protect freedom of expression and freedom of religion, prevent the excitement of hatred and calls for discrimination, etc. States should support such efforts of the Supreme Commissioner for Human Rights aimed at strengthening the contractual bodies, and ensuring adequate resources for the system of special procedures.
• The Office of the Supreme Commissar for Human Rights is proposed to cooperate with states who want to use its help to strengthen the normative and political basis relating to the prohibition of emitting hatred. In this regard, UVKPH can consider - using the experience of four regional meetings as part of this process - the creation of tools that meet the international human rights legislation, such as a collection of recommended practices and elements of typical legislation in the field of prohibitions on hatred. In order to contribute to progress in the development of national legislation and precedent law in this developing area, the UVKPH may also consider the organization of regular legal colloquiums to provide national judicial authorities with updated information and to stimulate the exchange of experience in terms of hatred prohibitions.
• It is necessary to increase the level of interaction and cooperation between the relevant contractual bodies, and the mandatar of special procedures, including, if necessary, with the help of joint steps to condemn the propaganda of national, racial or religious hatred, which is a motivation for discrimination, hostility or violence.
• Various institutions of the United Nations, including the Office of the Supreme Commissioner for Human Rights, the initiative of the “Alliance of Civilizations” and the office of the special adviser to prevent genocide, should activate cooperation in order to achieve maximum effect and stimulate joint activities.
• Cooperation and exchange of information must be strengthened (a) between various regional and interregional mechanisms, such as the Council of Europe, the Organization for Security and Cooperation in Europe, the European Union, the Organization of American States, the African Union, Asian, as well as the Organization of Islamic Cooperation, and (b. ) between these organizations and the United Nations Organization
• Consider the possibility of implementing at the national level and in cooperation with the member states of measures to implement the recommendations of this document addressed to states.

Recommendations to other interested parties

• Non -governmental organizations, national human rights institutions, as well as other civil associations, should create and support dialogue and mechanisms that contribute to intercultural and inter -religious understanding and knowledge.
• The political aspects should approve the ethical principles that determine the behavior of their representatives, especially during public speaking, and monitor their compliance.
• Self -regulation, where it is effective, remains the most suitable way to solve professional issues related to the media. In accordance with the Code of Code of Cranial Principle No. 9, all media should, in the manner of moral and social responsibility and by self -regulation, participate in the fight against discrimination and promote intercultural understanding, including as follows:
• Take measures to ensure that their messages are placed in context, be balanced and based on facts, while doing everything so that the acts of discrimination are brought to the attention of the public.
• Understand the danger that the discrimination of individuals and groups and negative stereotypes in their regard when they are distributed by the media.
• Avoid unnecessary mention of race, religion, gender and other group characteristics that can contribute to intolerance.
• Increase the level of awareness of the harm caused by discrimination and negative stereotypes.

• To pay attention to various groups or communities, giving their representatives the opportunity to speak out and be heard in a way that contributes to their better understanding, and, at the same time, reflects the attitudes of these groups or communities.

• In addition, voluntary professional codes of behavior for the media and journalists should reflect the principles of equality, and effective steps should be taken to proclaim them and implement.

IV. Final remarks

1. Несмотря на систематическое внимание, уделяемое концепции свободы выражения мнения в международном законодательстве в области прав человека и во многих национальных законодательствах, практическое применение и официальное признание этой концепции осуществляются не в полной мере во всем мире. В то же время, во многих частях мира международным правозащитным стандартам о запрещении возбуждения национальной, расовой или религиозной ненависти еще только предстоит войти в национальное законодательство и политическую стратегию. Вышесказанное объясняет как объективную сложность, так и политическую деликатность определения возбуждения ненависти в духе уважения к свободе выражения мнения.

2. Вышеизложенные выводы и рекомендации являются шагами в направлении решения этих проблем, которые, как хочется надеяться, будут способствовать как дальнейшей работе внутри стран, так и международному сотрудничеству в этой области.

[1] Около 45 экспертов в различных областях приняли участие в четырех региональных совещаниях и встрече в Рабате. Более 200 наблюдателей приняли участие в дебатах.

[2] Ст. 20 Международного пакта о гражданских и политических правах гласит: «Всякое выступление в пользу национальной, расовой или религиозной ненависти, представляющее собой побуждение к дискриминации, вражде или насилию, должно быть запрещено законом».

В дальнейшем в тексте это будет упоминаться как « возбуждение ненависти ».

[3] С обращением Верховного комиссара к четырем экспертным совещаниям, справочными исследованиями, докладами экспертов, выступлениями заинтересованных сторон и отчетами о совещаниях можно ознакомиться по ссылке: www.ohchr.org/EN/Issues/FreedomOpinion/Articles19-20/Pages/Index.aspx

[4] Эти принципы были подготовлены организацией «Article XIX» на основании обсуждений, проведенных рядом заинтересованных сторон с участием экспертов-правозащитников в области международного права, специализирующихся по проблемам свободы выражения мнения и равенства. Принципы являются прогрессивной интерпретацией международного права и международных стандартов, принятой государственной практики (в частности, отраженной в национальных законах и решениях национальных судов), а также общих правовых принципов, признанных международным сообществом.

В соответствии с принципом № 12, в правовых системах стран должно быть указано (прямо или с помощью авторитетного толкования), что термины «ненависть» и «вражда» относятся к «интенсивным и иррациональным эмоциям осуждения, вражды и неприязни по отношению к целевой группе», что термин «пропаганда» следует понимать как подразумевающий «наличие намерения публично возбудить ненависть к целевой группе» и что термин «возбуждение ненависти» относится к «заявлениям о национальных, расовых или религиозных группах, создающим непосредственную угрозу дискриминации, вражды или насилия в отношении лиц, принадлежащих к этим группам».

Sources:

• Рабатский план действий о запрете пропаганды национальной, расовой и религиозной ненависти, представляющей собой подстрекательство к дискриминации, вражде и насилию (на английском языке) // Сайт Управления Верховного комиссара ООН по правам человека. 2013. February 21.