A/HRC/9/12 page 18 56. The African Charter on Human and Peoples’ Rights contains no direct reference to incitement to national, racial or religious hatred, but declares in article 27 that “The rights and freedoms of each individual shall be exercised with due regard to the rights of others, collective security, morality and common interest.” The Declaration of Principles on Freedom of Expression in Africa, adopted by the African Commission on Human and Peoples’ Rights, makes no reference to limitations on the exercise of the right to freedom of expression for the protection of the reputation of others. 57. As regards the inter-American human rights protection system, the American Convention on Human Rights recognizes in article 13 limitations relating to respect for the rights or reputations of others. In the same article, it addresses directly the question of inducement to hatred, declaring that: “Any propaganda for war and any advocacy of national, racial, or religious hatred that constitute incitements to lawless violence or to any other similar action against any person or group of persons on any grounds including those of race, colour, religion, language, or national origin shall be considered as offenses punishable by law.” C. National legislation 58. In addition to the aforementioned international and regional instruments, the Special Rapporteur also notes that most national legislations of countries in all regions contain provisions that protect against incitement to national, racial or religious hatred. A systematic analysis of the national instruments, in particular constitutions and penal codes, cannot be attempted within the scope of this study. However, the Special Rapporteur would note that domestic provisions limiting the exercise of freedom of expression involve various kinds of special restrictions. In the European context for example, the Venice Commission has identified four types of restriction: blasphemy, offending religious feeling or insulting doctrine; obstructing the exercise of worship and/or of religious freedom; disparaging an object of worship; and inducement to discrimination or to religious hatred.1 Of the 47 European countries considered in this study, 43 have provisions relating to incitement to discrimination or religious hatred. Many countries in other regions of the world also have domestic provisions relating to incitement to national, racial or religious hatred. 59. A more exhaustive analysis of national legislations would show that, contrary to the international polarization concerning the phenomenon of the defamation of religions, there is a broad consensus among Member States in recognizing limitations on freedom of expression so as to prohibit incitement to national, racial or religious hatred. By linking the discussion on the defamation of religions to human rights instruments, in particular the provisions relating to incitement to national, racial or religious hatred, a close correspondence will be found to exist with specific clauses in the domestic legal systems of a number of Member States. 1 See the Recueil des législations nationales d’Europe relatives au blasphème, aux insultes de caractère religieux et à l’incitation à la haine religieuse, compiled by the European Commission for Democracy through Law (Venice Commission) in 2007.