A/HRC/9/25 page 12 sanction advocacy that constitutes incitement to hatred, it is not legitimate to prohibit merely offensive speech”. It also recalled that “most countries already have excessive or at least sufficient ‘hate speech’ legislation”.14 IV. REGIONAL NORMS AND JURISPRUDENCE 46. The main regional human rights systems contain fairly extensive norms and jurisprudence on freedom of religion, permissible restrictions and defamation of religions, revealing many similarities but also significant differences. The African regional human rights system 47. Article 8 of the African Charter on Human and Peoples’ Rights guarantees the freedom of conscience, the profession and free practice of religion and that “no one may, subject to law and order, be submitted to measures restricting the exercise of these freedoms”. With regard to freedom of expression, article 9 of the Charter stipulates that “every individual shall have the right to express and disseminate his opinions within the law”. 48. With regard to the permissible scope of restrictions on freedom of expression, the Declaration of Principles on Freedom of Expression in Africa15 in Principle II (Interference with Freedom of Expression) provides that “any restrictions on freedom of expression shall be provided by law, serve a legitimate interest and be necessary and in a democratic society”. Principle XIII (Criminal Measures) stipulates that “freedom of expression should not be restricted on public order or national security grounds unless there is a real risk of harm to a legitimate interest and there is a close causal link between the risk of harm and the expression”. 49. In 2006, at its 40th ordinary session, the African Commission on Human and Peoples’ Rights adopted a resolution on the situation of freedom of expression in Africa which emphasized the freedom of expression as guaranteed in article 9 of the African Charter and articles 19 of the Universal Declaration of Human Rights and ICCPR, respectively, and other treaties, resolutions, international instruments and national constitutions. The European system 50. Article 9 of the European Convention on Human Rights (ECHR) guarantees the right to freedom of thought, conscience and religion and provides that “freedom to manifest one’s religion or beliefs shall be subject only to such limitations as are prescribed by law and are necessary in a democratic society in the interests of public safety, for the protection of public order, health or morals, or for the protection of the rights and freedoms of others”. 14 Annual Report of the Inter-American Commission on Human Rights 2006, Volume II, Report of the Office of the Special Rapporteur for Freedom of Expression, OEA/Ser.L/V/II.127 Doc.4, 3 March 2007, p. 109. 15 Res. 62(XXXII)02: Resolution on the Adoption of the Declaration of Principles on Freedom of Expression in Africa (2002).