A/HRC/9/12 page 15 42. The ethical challenge inherent in the tension between the uniqueness of each phobia and the universality of their causes corresponds to the fundamental and difficult choice that the victims must make, whether individuals or groups, between retreat into separate identity or solidarity with all victims. Retreat is the expression of the priority given by the victim of discrimination, including defamation, to the unique character of his or her own experience. It leads not only to a lack of empathy with the sufferings of other communities and respect for their memory, but also to the temptation to create a hierarchy of phobias. 43. The ideologues and theoreticians of the clash of civilizations and religions exploit and derive their legitimacy from the lack of solidarity between the victims of Islamophobia, anti-Semitism, Christianophobia and other forms of defamation of religions and discrimination. This tendency, exploited by political parties, is the main obstacle to the universal and effective struggle against discrimination in general and the defamation of religions in particular. Another approach, more difficult from both the individual and collective standpoint, consists in recognizing the universality of all forms of discrimination, that is to say, transforming the uniqueness of one’s experience into solidarity with the cultural, ethnic and religious experience of other communities. This approach is individualistic from an ethical standpoint and collective from a political standpoint. It rests on the following elements: (a) in the legal sphere, equal treatment for all religions; (b) in the political sphere, the achievement of a difficult balance between freedom of expression and freedom of religion; (c) in the cultural sphere, a multicultural approach to education in general and the teaching of history in particular; and (d) in the social sphere, realization of the goal of “living in harmony” in all spheres of multicultural coexistence (housing, urban planning ,workplace, etc.). IV. INCITEMENT TO NATIONAL, RACIAL OR RELIGIOUS HATRED IN INTERNATIONAL, REGIONAL AND NATIONAL HUMAN RIGHTS INSTRUMENTS 44. In the preceding chapters, the Special Rapporteur has sought to draw the Council’s attention to the basic characteristic common to all manifestations of religious defamation and all forms of religious phobia and discrimination, namely incitement to racial and religious hatred. In order to address the question of the defamation of religions from a universal standpoint, it is essential to relate the discussion to international human rights instruments. In particular, the Special Rapporteur notes that provisions relating to incitement to national, racial or religious hatred already form part of the main international instruments to which a large majority of countries are signatory. Linking the political discussion on the treatment of religious discrimination to specific legal provisions will show that combating incitement to hatred is not a North-South ideological question but a reality present in a large majority of national legislations in all regions. 45. With a view to promoting this change of paradigm, translating religious defamation from a sociological notion into a legal human rights concept, namely incitement to racial and religious hatred, the Special Rapporteur will consider the provisions of international, regional and national instruments concerning three fundamental questions, namely freedom of expression, religious freedom and incitement to national, racial or religious hatred.