29.Memorandum submitted by the National
Secular Society
SECTION A—INTRODUCTION
WHO WE
ARE
Founded in 1866 by radical MP Charles Bradlaugh,
the National Secular Society is the most prominent organisation
in Britain supporting the rights of the non-religious and campaigning
for an end to religious privilege and the separation of church
and state.
OUR INTEREST
IN THIS
CONSULTATION
The NSS has, since its foundation, been in the
forefront of the battle to protect the right of free speech and
expression. This concern was originally prompted by the existence
of blasphemy laws but has since been directed at wider protection
of free speech from threats by growing religious pressure.
We would be keen to give oral evidence to the
Home Affairs Select Committee on legislative proposals on "religious
incitement" and religious discrimination, as well as the
blasphemy laws and the operation of the recently introduced higher
maximum sentences for religiously aggravated offences (more details
of which are shown below).
The Society worked closely with the House of
Lords Religious Offences Select Committee (ROC) in 2002 and 2003
as well as submitting oral and written evidence.[46]
The Committee was set up following the defeat of the Government's
measure included in the Anti-Terrorism Crime and Security Act
2001 (A-TCSA) to add "religious hatred" to the incitement
to racial hatred provisions.
The Society and several unions also opposed
extensive religious exemptions in the Employment Equality (Religion
or Belief) Regulations 2003 and Employment Equality (Sexual Orientation)
Regulations 2003, discussing the matter with two ministers. Our
intervention resulted in a successful amendment in the EU Parliament
to the original Directive. The UK Regulations have been the subject
of a judicial review and a complaint to the EU Commission by the
Society backed by an all-party group of MEPs.
We were called to give our views in person on
the proposed religious incitement law to the Community Cohesion
Unit (CCU) of the Home Office on 7 October and it was thought
appropriate there that we should also submit our views to the
Home Affairs Select Committee.
THE HOME
OFFICE
The Government has established a Faith Communities
unit which assures us that it also represents those without faith,
yet there is no formal representation for those without faith.
The non-religious have received just tokenistic mention in: "Working
Together: Co-operation between Government and Faith Communities"
published on 29 March and not even that in the Home Office's citizenship
survey (Home Office Research Study 274); it almost entirely ignores
the non-religious, even as a control group. Both these Home Office
publications were published in March 2004. We recommend a formal
acknowledgement by the Home Office that the non-religious community
be equally catered for, including in publications.
FREEDOM OF
EXPRESSION
In the Australian Newspaper The Age on
4 June 2004, Amir Butler, executive director of the Australian
Muslim Public Affairs Committee criticised the reasoning behind
the religious vilification laws and we hope the Committee will
bear these in mind in its deliberations on related issues in the
UK:
"The problem is that as long as religions
articulate a sense of what is right, they cannot avoid also defining—whether
explicitly or implicitly—what is wrong. If we love God,
then it requires us to hate idolatry. If we believe there is such
a thing as goodness, then we must also recognise the presence
of evil. If we believe our religion is the only way to Heaven,
then we must also affirm that all other paths lead to Hell. If
we believe our religion is true, then it requires us to believe
others are false. Yet, this is exactly what this law serves to
outlaw and curtail . . .
All these anti-vilification laws have achieved
is to provide a legalistic weapon by which religious groups can
silence their ideological opponents, rather than engaging in debate
and discussion. In doing so, people who otherwise might have been
ignored as on the fringes of reality will be made martyrs, and
their ideas given an airing far beyond anything they might have
hoped for. And at the same time as extremist ideas are strengthened
and given legitimacy by attempts to silence them, the position
in our society of the religions themselves is weakened and undermined.
Who, after all, would give credence to a religion that appears
so fragile it can only exist if protected by a bodyguard of lawyers?"
1. We also have grave misgivings about the
deterioration in freedom of expression in recent years and cited
the failure to prosecute those threatening Salman Rushdie with
violence or death. Several of our honorary associates have been
intimidated for expressing views that impinge on Islam. Polly
Toynbee has been the subject of pressure from the Islamic Human
Rights Commission, in the form of an "award", for (they
claimed) being the most Islamophobic journalist. She had written
about the right of the French government to run their secular
state as they wished. As a result of which she received hate mail
that she found threatening. For articulating the same view, another
honorary associate, Dr Evan Harris MP, has been named by the Islamic
Human Rights Commission as a "Islamophobic" politician
and has been the subject of attacks by Muslims both in the press
and through leaflets which have been distributed, and which were
sufficiently threatening for him to report the matter to the police.
We fear that public pressure brought by the Muslim Council of
Britain (MCB) on those with which they disagree (including open
letters to editors, shown on their website) had resulted in widespread
self-censorship in the media. We are convinced that this is already
operating more generally to restrict healthy open debate and is
being reinforced because of fear of the draconian maximum penalties
of Section 39 ATCSA and would be increased with any religious
incitement law
http://www.publications.parliament.uk/pa/ld200203/ldselect/ldrelof/95/2071804.htm
(around question 223.)
Written http://www.publications.parliament.uk/pa/ld200203/ldselect/ldrelof/95/2071810.htm
2nd Written http://www.publications.parliament.uk/pa/ld200203/ldselect/ldrelof/95/2071811.htm
2. We believe some religious people will
consider any criticism of their religion as part of free debate
to be an insult to them personally, and will therefore press for
the criminal law to be used by pressing for religiously aggravated
insult charges. We believe there is a growing expectation among
minority religious groups that the law should to be applied to
stifle such free debate, and that Section 29 ATCSA has fuelled
such expectations and any introduction of a religious incitement
law would do so even more. The MCB have specifically indicated
their expectation that the proposed religious incitement law will
be used to protect Islam from insult (referred to in Section B
9 below). This significant potential threat to freedom of expression
and to a whole new area of "religious" litigation might
not be confined to criticism by the non-religious.
3. Both the proposed incitement law and
the existing Section 39 ATCSA can also be expected to result in
cases being taken out against religious defendants, and not just
non-religious defendants, as religions are generally antithetical
to each other and also therefore potentially insulting to all
others. A further objection to laws that protect religions themselves
from insult is that they discriminate in favour of the religious
while the non-religious are unlikely to receive equivalent protection.
We note that, following what we understand to be a concerted campaign
by the Roman Catholic church, the BBC has decided against broadcasting
a satirical cartoon about the RC's pontiff that cost the taxpayer
millions of pounds.
4. We emphasise that freedom of expression
is not just an ideal (which we strive to defend)—we are
convinced that free expression helps to control such excesses
by exposing them to rational argument through the rigours of public
debate.
SECTION B. PROPOSED
INCITEMENT TO
RELIGIOUS HATRED
LAW
1. We believe that the existing law is adequate
to deal with the problem of incitement such as resorted to by,
for example, racist groups. Much of the justification for adding
"religious" to "race" related to such groups
using religion as a proxy. In particular, however, we note that
the CPS Guidance on prosecuting racial and religious crime referring
to the current absence of a religious incitement law noted that:
"the courts have yet to decide if behaviour that is aimed
ostensibly at a religious group is capable of amounting to an
incitement to racial hatred where the members of a group are also
members of a racial group". It can be concluded that the
courts have not ruled out wider use of the racial incitement law
as a possible solution, and one which we feel should be examined
further.
We accept that our proposals would not protect
for example white Muslims, but we doubt whether the scale of this
problem of them alone being singled out for hatred justifies the
major risks such legislation runs in terms of freedom of expression
or self-censorship.
2. Other measures open to prosecutors include
anti-social behaviour orders, Criminal Sentencing Act 2000 s 153
(extending the sentencing duty) and Crime and Disorder Act 1998
s 28 and the provisions against conspiracy are also likely to
be of use. It is often the case that other offences will have
been committed at the same time as alleged incitement to hatred.
3. The Lords' Religious Offences Committee
(ROC), with whom we worked closely, had started out by trying
to replicate the Home Secretary's previous attempt to introduce
religious incitement law. Some of the opposition was partly about
the procedure: that the proposals (a) had been formulated without
sufficient time for due consideration; and (b) an anti-terrorism
bill was not an appropriate legislative vehicle. Although the
ROC set out by intending to reintroduce the Government's 2001
Incitement to Religious Hatred proposals in a more timely manner
and with a draft ad hoc Bill, after taking a great deal of evidence
over many months it later abandoned this approach as being unsustainable,
which was also the position the Society had advocated, and felt
unable to recommend a satisfactory alternative.
4. The ROC specifically concluded that the
racial incitement law did not work satisfactorily. It is rarely
used, difficult to obtain convictions and there is a great concern
that failure to secure a conviction could result in "victorious"
publicity for the acquitted. There seems even less prospect for
it working for religious hatred than it has for race hatred.
5. There was extensive opposition drawn
from a wide political, cultural and even religious spectrum to
Government's previous attempt to introduce this law, and opposition
is mounting on a similar scale against the current attempt. We
cannot see what grounds the Home Secretary has to be confident
that all the opponents of his previous attempt and the ROC were
misguided and that he is justified in attempting to take the same
broad approach once more.
6. We were concerned about the Attorney
General's draft guidelines published in 2001 by David Blunkett
in a last ditch attempt to secure more support for his previous
attempt to introduce a religious incitement law. In our view,
they would have provided for more lenient treatment of the religious
than the non-religious in terms of the prosecution of offences
under the proposed religious incitement provisions. (Extract of
5.13: Legitimate expressions of religious belief which, taken
within their context, time and the wider national and international
arena, could not be construed as anything other than the expression
of a religious tenet are, similarly, not likely to amount to an
offence of incitement to religious hatred.). No provision was
made for "legitimate expressions of lack of religious belief",
as we believe should have been the case.
We warn against equivalent religious privileges
being introduced as part of the current attempt to reintroduce
the law.
7. We note from CPS statistics that of religiously
aggravated cases (by virtue of Section 39 of the A-TCSA) finalised
between 14 December 2001 and 31 March 2003 around 60% of the perceived
victims were Muslims, and of these Muslim victim cases, 60% of
the defendants were also Muslim. We think that these proportions
are very high and recommend further close scrutiny.[47]
8. A further unwelcome aspect of a religious
incitement law would be that it would draw the Crown and the courts
into judging on subjective and imprecise religious matters. Difficulties
can be expected in establishing what constitutes a religious group.
While it is convenient from the legislator's perspective to leave
this to the courts, this would not offer the certainty the public
is entitled to expect. A religious incitement law would draw the
Crown and the courts into highly charged religious matters. Regardless
of the evidence, verdicts will be interpreted by religious groups
as supporting or failing to support them. Even the failure to
bring charges—a highly likely scenario—would be seen
by those who perceived themselves to be victims as the State's
failure to support their particular group: the law would therefore
introduce a new and avoidable political risk. Such tensions between
religion and justice are a familiar problem in theocratic countries.
9. We are disturbed about the expectations
raised among religious minorities (many of which have rather different
traditions about freedom of expression) about the proposed law
being able to be a major restriction on freedom of expression.
This concern has turned into alarm after influential figures have
reportedly publicly advocated such restrictions. According to
Will Cummins in The Daily Telegraph on 12 July 2004:[48]
"In a recent television panel, Iqbal Sacranie
explained why the Secretary-General of the Muslim Council of Britain
(MCB), had pushed for this legislation. The British should . .
. not be permitted to `criticise' [Islam]".
(Similarly, according to the Christian charity
the Barnabas Fund,[49]
Iqbal Sacranie, speaking on BBC Radio 4's The Moral Maze on 14
July 2004 stated that any "defamation in the character of
the Prophet Muhammad" would be "a direct insult and
abuse on the Muslim community". He indicated that this should
be made illegal under the new law.)
Mr Cummins continued: "Ken Livingstone
has gone even further . . . The Mayor of London welcomed . . .
Dr Yusuf al-Qaradawi. "Basing his teaching on Islam's holiest
texts, Dr al-Qaradawi has urged his fellow Muslims to beat their
wives; to use child suicide bombers to kill female and infant
civilians; to murder Jews, homosexuals and British servicemen;
and to colonise, desecrate and usurp Christian Rome".
"Mr Livingstone said that the newspapers
that had condemned Dr al-Qaradawi for such views `showed why this
legislation [Blunkett's] is necessary'. It was the critics of
Dr al-Qaradawi's beliefs, Mr Livingstone insisted, who were, as
the Muslim Association of Britain put it, `the image of evil'.
Dr al-Qaradawi, a mainstream figure in a major religion, had endorsed
Jew lynching and wife beating: Mr Livingstone seemed to imply
that, like Islam, such activities should therefore be above criticism."
10. We largely share the following concerns
of the Barnabas Trust. They opine "that if such a law had
been in place 15 years ago, instead of protecting Salman Rushdie
from extremist Muslims who sought his life for writing The
Satanic Verses the government could have prosecuted him themselves.
If the law is drafted as Mr Sacranie wants, it would ban all criticism
of the founder of Islam irrespective of whether the speaker intended
to incite hatred to Muslims. Thus it would prevent legitimate
criticism and free speech". (http://www.barnabasfund.org/News/ITRHC/ITRHC.pdf)
"But the religion Mohammed taught is based on specific rejection
of Christianity," Barnabas Fund said in a document. "It
is impossible to protect both these belief systems from `insult'
simultaneously". The charity said the law could be used against
modernist Muslims who called for reforms to Islam. [See also potentially
related statistical point in B.7.] It could also hinder efforts
to work for greater rights and equality for Muslim women. The
law could furthermore be used to silence those who campaign against
injustices endured by non-Muslims living under Islam.
(The breadth of opposition to the proposed incitement
law is further demonstrated by our sharing the concerns of a Christian
charity.)
http://www.cps.gov.uk/publications/docs/rims02-03.pdf
opinion/2004/07/11/do1102.xml
11. Our biggest worry about the proposals
on religious incitement, and it has been expressed in several
quarters, is that they could result in religious extremists silencing
critics, even if the law did not directly enable this, simply
because of self censorship borne out of fear of prosecution. (This
effectively happened over Section 28 of the Local Government Act
over what was described as the promotion of homosexuality in schools.)
12. We welcome the reported desire of the
Home Secretary for the law to move away from protection of religion,
in favour of protecting people, especially from a public order
perspective. We acknowledge that Section 39 ATCSA takes a similar
approach, but it has serious flaws on grounds of freedom of expression,
referred to below.
13. We draw attention to experiences of
the religious vilification law enacted in the state of Victoria
in Australia. It was brought in at the request of Muslims, but
the problems it has brought have been on such a scale that we
now understand many of those who called for the law would now
like it to be repealed.
We recognise that incitement proposals are much
narrower than the Victoria law. They would be constrained be by
the ECHR freedom of expression on the one hand, and other law
on incitement to commit a criminal offence, on the other, and
will presumably be subject to the Attorney General's guidelines.
The Victoria law also appears to lack clarity. (It includes, for
example, the phrase "On the ground of the religious belief",
which appears to confuse the beliefs with the people who hold
them.)
Nevertheless, having observed the large extent
of unforeseen problems caused by the Victoria law, we have given
a detailed account of it in the Appendix, written by a barrister.
SECTION C. RELIGIOUSLY AGGRAVATED SENTENCES
AND BLASPHEMY
1. One of our greatest concerns, however,
relates to religiously aggravated sentences under Public Order
offences as a result of s 39 of the Anti-Terrorism Crime and Security
Act 2001 (A-TCSA). (Where racially aggravated sentences had been
established under the Crime And Disorder Act 1998 to a list of
offences, Section 39 provides for religiously aggravated sentences
to also be applicable to these offences.) We are particularly
concerned about adverse freedom of expression implications, in
particular from the insulting behaviour provisions of s 39 of
the A-TCSA.
2. We signal our alarm formally about both
the excessive breadth and the application of Section 39 of the
A-TCSA. Some of the offences, such as insulting behaviour, covered
by Section 39 are (in relative terms) not serious in nature, yet
it introduced increased (typically seven years maximum) aggravated
sentences on grounds of religion in line with the aggravated sentences
introduced in 1986 for race, to the Public Order Act and other
offences.
As to application, we cite the case teacher
Hazel Dick in Peterborough (acquitted in March 2004). The view
was expressed in several newspapers that she should not have been
charged and there was a suspicion that justice had appeared to
be operated unevenly in favour of Muslims. We are aware of another
Section 39 case with disturbing similarities. We are happy to
provide details.
3. Blasphemy. We further recommend, as we
have repeatedly called for over a century, for the blasphemy law
to be abolished as recommended by the Law Commission Law in 1985.
We welcome the Home Secretary's announcement that he plans to
review this rarely used law (The Guardian, 18 October 2004,
page 1). The Society would, however find any extension to an "all
religions" blasphemy law deeply objectionable and it would
stifle freedom of expression to an outrageous extent and is beset
with practical problems. These would include deciding which religions'
tenets should be protected, and whether this should this include
cults/new religious movements with a reputation for coercion or
mass suicide. Such movements tend to be litigious and generously
resourced. Such a law would also involve protecting mutually incompatible
beliefs and enmesh the courts in having to conclude on which of
competing doctrines is the authoritative one, but we are adamant
that such judgments should be entirely outside the competence
of a secular court. The restrictions on freedom of expression
that such a law would entail would be unprecedented in modern
times in severely restricting criticism of ideas and constitute
gross discrimination against the non-religious.
SECTION D. RELIGIOUS DISCRIMINATION LAW
We are not sure whether the Committee is actively
considering this, but offer it in case it might be of use.
1. We understand that that this legislation
is at an earlier stage of formulation than incitement and that
the Home Office CCU has informed us it is seeking views on it
widely.
2. We are most concerned that despite the
widespread calls for a Single Equality Act and for an avoidance
of a hierarchy/pecking order of minorities—a call echoed
by Minister Patricia Hewitt—one specific strand has been
chosen to be the subject of an individually tailored act to be
introduced years before a single equality act.
3. We call for a single equality act to
be introduced first rather than, as is now proposed, Parliament
adopting a piecemeal approach.
4. That religion is the chosen first strand
is no surprise to the National Secular Society as it is yet a
further example of religion having favoured treatment. This was
the case on the employment regulations where not only had organisations
with a religious ethos been granted protection, but they had secured
massive exemptions—in some instances evading the consultation
process—from following the regulations that applied to others,
despite the fact they were the very organisations most likely
to want to discriminate.
5. A further example of the excessive importance
afforded to religion is revealed by the Home Secretary's opening
words in the press release announcing this legislative proposal:
"Faith plays a vital role in people's lives—even those
that are not overtly religious". This is completely at odds
with the Home Office's own recently published 2001 Citizenship
survey which showed religion ninth of "things [that] would
say something important about you, if you were describing yourself".
The NSS had been disappointed but sadly not surprised that there
had been no reference in press release to the implications for
the non-religious, albeit we now understand, as is essential,
that the non-religious would be protected.
6. We welcome the proposal in the Home Office
Press release that the law would not "normally" require
providers to provide "a wider range of goods or services
in order to meet a customer's religious needs". We consider
it essential that the Government stands firm on this. We accept
however it is reasonable for a requirement to apply in locations
where consumers have restricted choice of providers, such as in
prisons or hospitals. Conversely, we draw the Committee's attention
to objections, from Sikhs and those concerned with animal welfare,
for example, to ritually slaughtered meat. We abhor the growing
practice in some canteens of serving exclusively such meat, even
where not all students are Muslim or Jewish.
7. We understand that it is proposed to
make an exception and permit discrimination in the unusual event
of a charity giving away goods or services etc or selling them
at heavily subsidised prices.
We formally urge great caution in the wording
for any legislative exemption covering this aspect, urging for
it to be as restricted as possible. We suggest that any exemption
to permit discrimination should be restricted to a charity's distribution
of goods or services without cost or their sale at substantially
less than full value and even then only the exemption should be
limited to extent necessary to comply with the charity's deeds.
We formally express our total opposition to
the religious exemptions proposed for "faith based charities
to discriminate in favour of that faith in the provision of services
on the grounds of religion or belief"—especially where
public funds are provided for "faith based welfare".
We do not see why taxpayers should be funding discrimination against
themselves. We also oppose the exemption to allow "faith
based schools to allow them to continue to discriminate in favour
of that faith in selection policy", although we realise that
this latter simply formalises the current discrimination.
8. A major concern has been raised by barrister
Neil Addison who is concerned about the potential for the discrimination
law to be misused to restrict freedom of expression. He is "convinced
that such a case could also be brought under anti religious discrimination
legislation if it covered the provision of `services'. The provision
of a lecture or seminar would classify as a `service' and so could
provide the basis for a claim in damages on the grounds of harassment.
Similarly if we had another Salman Rushdie case then the publishers
and the author could also be sued." It is essential that
the drafting of the law precludes such possibilities. He is not
alone in holding this view; the Barnabas Trust does too.
9. Another area of potential difficulty
which we raise formally relates to those who provide goods or
services who decline because of religious objections. The CCU
indicated that this was the first time this had been raised with
them. We cite an actual case of a pharmacist (in Preston) who
had refused to dispense a prescription for emergency contraception.
The pharmacist had claimed to suggest an alternative supplier,
but the customer denied this. Clearly time is of the essence in
such circumstances and the implications of delay potentially enormous.
The CCU asked how this differed from a doctor
or nurse being excused from taking part in an abortion. We suggested
that it was a very much more remote involvement, and that—taken
to an extreme—the pharmacists' acknowledged duty to give
an alternative source of supply was only slightly less of an involvement
than dispensing.
We observed that the rural areas were the very
ones most likely to be religiously "conservative", yet
these remote areas where alternatives were most difficult to provide
and indeed may not exist.
We urge that the law should be revised to impose
a duty on pharmacists not to refuse to dispense anything which
was legal, although currently the RPS guidelines contain a conscience
clause, and they had declined to review this in the light of our
representations.
Until the law is so changed, pharmacies which
reserved the "right" not to supply any product should
be required to place a notice prominently listing products potentially
affected and giving full details of alternative sources of supply.
10. According to the latest census, the
non-religious constitute three to five times the numbers of all
the minority religions added together. Although the non-religious
were not referred to in the press release over the discrimination
legislation proposals, we have been assured that the non-religious
will be equally protected under "religion and belief".
We urge that the protection of the non-religious be specifically
made clear in the anti-discrimination legislation.
25 October 2004
APPENDIX
"Religious Vilification" law in Victoria,
Australia
The dangers in the Government's approach are
demonstrated by a case taking place in Australia. The Australian
case involves an allegation of "Religious Vilification"
brought by the Islamic Council of Victoria (ICV) against Catch
the Fire Ministries (CTFM) and two of its Pastors, Daniel Scot
and Daniel Nalliah. It relates to a seminar which they presented
in March 2002. The seminar lasted an entire day and dealt with
the Muslim concept of jihad, the history of Islam, the future
of Islam in Australia and whether the practice of Islam was compatible
with western concepts of Democracy. The seminar involved quotations
from the Koran and references to the life of Mohamed and the Hadith
(traditions) of the prophet which together form the basis of Islamic
Sharia law.
Present during various parts of the seminar
were three Australian converts to Islam who reported back to the
ICV who subsequently brought the case against CTFM under s8 of
the Victoria "Racial and Religious Toleration Act 2001"
which had come into effect in 2002. That section says:
"(1) A person must not, on the ground
of the religious belief or activity of another person or class
of persons, engage in conduct that incites hatred against, serious
contempt for, or revulsion or severe ridicule of, that other person
or class of persons."
The claim asked for damages and also that the
defendants be ordered to "acknowledge" that remarks
at the seminar were inaccurate, "retract" the statements,
"sincerely apologise" for the offence caused and be
prohibited from "further publication or distribution, directly
or indirectly of any material containing statements, suggestions
and implications to the same or similar effect". If such
an order was made any breach would be a contempt of court punishable
with imprisonment.
In their defence CTFM not surprisingly argued
that the seminar accurately reflected Islamic teaching and history,
it was an exercise in free speech and reflected their personal
religious beliefs. During the case it became apparent that the
Muslim converts had been deliberately sent to the seminar by ICV
with a view to bringing a case. Both pastors were known to have
strong views regarding Islam and Sharia but their views were based
on knowledge and experience. Scot is a Christian from Pakistan
who had gone to Australia to escape persecution whilst Nalliah
had worked in Saudi Arabia where the practice of Christianity
is a criminal offence. Much of the case revolved around interpretations
of the Koran and incidents in the life of Mohammed. At one point
Scot was asked whether he believed that Muslims and Christians
prayed to the same God and the question was allowed by the judge.
The trial took place in the Victorian Civil
and Administrative Tribunal and was originally scheduled to last
for three days. It actually extended over seven months and the
judgement is still awaited. Whilst the verdicts are awaited in
that case another case has been launched by a witch who claims
that her religious beliefs have been vilified by the christian
mayor of her town and relationships between Muslim and Christian
groups in Australia have been damaged. If the two are cleared,
Muslim groups will claim that the law is not protecting them and
if they are convicted they will be regarded as martyrs on the
altar of political correctness.
46 Oral 18 July 2002 Back
47
CPS Racist Incident Monitoring Annual Report 2002-2003 Para 15.5 Back
48
http://www.telegraph.co.uk/opinion/main.jhtml;sessionid=W20Y0EG3GJWL1QFIQMGCM5OAVCBQUJVC?xml=/ Back
49
http://www.barnabasfund.org/News/ITRHC/ITRHC.pdf Back
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