A/HRC/9/25 page 4 violence and terrorism in the aftermath of the 2001 terrorist attacks in the United States of America, the dissemination of ideas based on superiority, discriminatory laws, policies and practices that have targeted minority religious groups, and physical attacks on individuals and communities and their properties and places and symbols of worship. 7. While these resolutions make reference to “defamation of religions”, it appears that they often use the term in the generic sense to describe some of the above phenomena - notably hostile statements, unfair association with violence, stigmatization, ridicule, insults against religion, attacks, “Islamophobia” - rather than in the strict legal sense. In this context the resolutions perceive defamation in conjunction with the need to combat hatred, discrimination, intimidation, coercion, etc. Thus, paragraphs 8 and 9 of resolution 7/19 urges States “to prohibit the dissemination ... of racist and xenophobic ideas and material aimed at any religion or its followers”, and calls on them to provide “adequate protection against acts of hatred, discrimination, intimidation and coercion resulting from the defamation of any religion”. 8. The notion of defamation as is known in many national legal systems is designed to protect individual reputation and image. In its general legal meaning, it refers to an inaccurate statement (oral, written) that is published through various means of communication (printed, audio-visual, electronic) and is intended to or actually causes harm to a person’s reputation. Some national laws require the additional element of negligence or malice in the making of the statement. In general, the sanction for defamation is a civil penalty, although some countries also recognize defamation as a criminal offence. 9. Some countries have blasphemy laws which envisage sanctions for profane acts (physical, oral, printed, audio-visual, electronic, etc.). Others have adopted specific defamation of religions, laws that extend the concept of defamation to protect religions and, in that sense, regard defamation of religions as essential to the protection of freedom of religion or belief. 10. In the framework of international human rights law, the combination of “defamation” with “religion” remains unclear for a variety of reasons. It is within this context that this study is framed around the following questions: (a) To what extent the concept of defamation of religions can be derived from existing international human rights law framework; (b) The scope of existing international human rights law related to religion - namely, the freedom of religion or belief, discrimination on the basis of religion and incitement to religious hatred and violence - and if it sufficiently addresses the phenomena with which the resolutions are concerned; (c) The implications of “defamation of religions” to the international human rights framework, particularly the relationship to freedom of expression and other fundamental human rights. II. INTERNATIONAL NORMS AND JURISPRUDENCE 11. Issues related to religion are addressed in several international instruments, including the United Nations Charter, the Universal Declaration of Human Rights, the International Covenant