Fox Government Policies

10 Government religion
policy 1: official policies

and supporting religion
All governments have a policy on religion. On a basic level, governments need to choose between
supporting it, regulating or restricting it, or being neutral. In practice, most governments have
complex policies which include elements of all three of these options regarding various aspects
of religion. In this discussion I divide government religion policy into four policy areas:
1. Official policy: This looks at the big picture of the overall structure of religion policy and
focuses on issues such as whether the government declares an official religion or separation
of religion and state. The remaining categories look at an array of more specific government
policies which are promulgated in the context of these meta-policies.
2. Supporting religion: All governments support religion to some extent through various means
and for different reasons.
3. Regulating, restricting, or controlling all religion: Governments for many different reasons
seek to limit religion in general, including the majority religion.
4. Restricting minority religions: Governments often restrict minority religions in a manner they
do not restrict the majority religion.
In this chapter I discuss the first two categories, and in Chapter 11 I discuss the latter two.
! WHAT IS GOVERNMENT POLICY?
Before discussing government religion policy it is important to define what we mean by policy.
On a general level a policy is a course of action adopted by an entity such as a government,
political party, business, institution, or individual. There are several ways in which governments
can create or declare a policy:
Constitutions: Constitutions are formal documents which set out the fundamental principles of
government in a country. When they address religion they most commonly address basic principles
like whether there will be protections for religious freedom and whether the government declares
an official religion or that religion and state will be separate.
Laws: Laws are perhaps the best known means for creating a policy. Governments pass laws
on all manner of religion policy including financing religion, where places of worship may be
built, and whether it is lawful to engage in religious practices in public.
128 GOVERNMENT RELIGION POLICY 1
Regulations: While laws are usually passed through a formal process involving a government’s
legislative body, regulations are made by government administrators, usually in order to implement
laws. For example, local administrators often decide on which specific tracts of land certain
types of buildings, such as places of worship, can be built, and to what building codes they must
adhere. They also typically grant building permits, which allows them wide discretion in practice
to facilitate or restrict building these places of worship. Chief executives such as a country’s president
often also have the power to declare policy through executive orders, which are also a form of
regulation.
Agreements: Governments sometimes enter into formal agreements with religious entities that
can have the force of law. Such agreements with the Catholic Church, known as concordants,
are common in Catholic majority countries, and often contain a wide variety of clauses, including
whether the Church will be the official religion of the country, whether and to what extent the
Church will be funded by the state, and whether Catholicism classes will be taught in public
schools. For example, Venezuela’s 1964 Concordant with the Catholic Church includes the
following provisions: freedom of religion for the Catholic Church, that no part of the country
will be under the jurisdiction of a bishop whose headquarters are outside the borders of the Republic,
government approval of all Venezuelan bishops and archbishops, government funding for the
Church, and the Church’s right to establish Catholic schools.
Court decisions: In a country with an independent judicial system, courts have the power to
interpret or even make law. Laws are often unclear and it is often up to courts to decide on how
they should be interpreted. Also, laws and legal principles often contradict one another and courts
settle these contradictions. For example, in 2002 a mother in Italy filed a court case protesting
the presence of a crucifix in her children’s public school. After a series of hearings and appeals,
in March, 2011, the Grand Chamber of the European Court of Human Rights ruled that
while a crucifix is a primarily religious symbol, states may decide whether or not to display
religious symbols in public buildings such as schools. This overturned a previous ruling that declared
the display of crucifixes in public schools a violation of the freedom of religion and right to
education.1
Actions by officials: Not all government policy is set in writing. Day-to-day decisions and actions
by government officials and representatives can create a policy. Take, for example, the issue of
proselytizing. Many countries have laws restricting proselytizing and missionaries. However, many
of the restrictions on this type of activity are not written in laws, regulations, agreements, or court
decisions. For example, in Singapore, Jehovah’s Witnesses and Unification Church members may
not proselytize because these groups were refused registration. While officially all other groups
may legally proselytize, in practice Singapore’s authorities discourage activities that may upset the
intergroup relations. Based on this policy, in 2009 the government prosecuted two people under
the Sedition Act for distributing illustrated Christian religious tracts to Muslims. The defendants
served eight weeks in jail.2 Tunisia similarly has no law regarding proselytizing, but deports anyone
suspected of proselytizing to Muslims and refuses entry to suspected missionaries.
Local governments: Government religion policy is not set only at the national level. Local
governments often implement national policy and in other cases set their own policy. They use
all the tools listed above to achieve these ends. For example, local governments in countries like
Indonesia, Malaysia, and Nigeria have passed laws implementing Sharia (Islamic) laws in a manner
at odds with national policy. Local governments in multiple Western European countries,
including Austria, Belgium, Denmark, Germany, Greece, Italy, and Spain, use building codes and
permits to restrict the building of places of worship by minority religions, usually by Muslims and
groups considered cults.
GOVERNMENT RELIGION POLICY 1 129
Given all of this, it is clear that, like most types of policy, government religion policy is complex
and influenced by many actors at all levels of government.
It is also important to reiterate that, as I state in Chapter 1 about this book in general, the
purpose of the discussion in this chapter and Chapter 11 is to analyze the nature of government
religion policy and not to make value judgments. Government policy can objectively support or
restrict religion, and most governments do both to at least some extent. I avoid debates over the
issue of whether a specific policy is moral or advisable as well as debates over whether a religious
law, practice, or institution is praiseworthy or objectionable. Put differently, I focus on what is,
rather than what ought to be.
Take, for example, the issue of Islamic dress codes for women. This Islamic practice can require
modest dress and a head covering, or it can require ultra-modest full body coverings such as
the niqab or burka, depending on how one interprets the religion. Some countries restrict this
type of attire, while others require it. Some individuals consider them a religious obligation or
an expression of religious devotion that is a personal choice which cannot be restricted without
restricting the individual’s religious freedom. Others consider it a form of oppression against women
and a violation of modern morals.
These types of normative debates are important, but they are not the subject of this discussion
of religion policy. This discussion simply addresses whether a religious practice, such as a
requirement for some form of modest clothing for women, is required or banned. That is, I focus
on the objective question of whether a policy is or is not present, and do not seek to address
whether the policy is moral or advisable.
That being said, the presence or absence of policies provides a good guide to the normative
decisions made collectively by governments around the world about the desirability and morality
of various aspects of religion.
! OFFICIAL POLICY
Official religion policy is essentially the meta-religion policy of a state. That is, it is the country’s
religion policy at its most general level. However, within the framework of this type of meta-
policy, many more specific policy options are possible. The second half of this chapter as well as
all of Chapter 11 focus on these more specific policy options.
Many governments clearly declare an official religion policy. In many cases this declaration,
often in the country’s constitution, is either one that declares an official religion in the country
or one that declares that the state is secular or some other form of declaration of separation of
religion and state. Also, a number of governments have a more complex official policy, usually
outlined in a law. These laws are sometimes in addition to a constitutional declaration and sometimes
passed on the absence of one.
We can divide official government religion policy into two types which include 13 categories
which are listed in Table 10.1 along with which countries fit into each category. The two types
are states with official religions and states without official religions. Many academic studies of
religion policy limit their discussion to the presence or absence of an official religion. However,
as I demonstrate in detail below, there is significant variation in policy within each of these categories
to the extent that simply determining whether a country has an official religion or not hides
substantial diversity in how countries deal with religion.
TABLE 10.1 OFFICIAL RELIGION POLICY IN 2014
CATEGORY AND DEFINITION STATES IN THE CATEGORY

States with official religions
Religious state: The state strongly supports and enforces the majority religion. Observing Afghanistan, Brunei, Gaza, Iran, Kuwait, Malaysia, Maldives, Oman, Pakistan,
the religion is mandatory. Qatar, Saudi Arabia.
State controlled religion, positive attitude: The state both supports a religion and Bahrain, Comoros, Denmark, Egypt, Greece, Jordan, Mauritania, Morocco,
substantially controls its institutions but has a positive attitude toward this religion. Palestinian Authority, Tunisia, UAE, Western Sahara, Yemen.
Active state religion: The state actively supports a religion but the religion is not Algeria, Bangladesh, Bhutan, Cambodia, Costa Rica, Djibouti, Dominican
mandatory and the state does not dominate the official religion’s institutions. Republic, Finland, Iceland, Iraq, Israel, Kurdistan (in Iraq), Libya, Liechtenstein,
Malta, Norway, Somalia, UK, Zambia.
States with no official religion
Preferred religion: No official religion but one religion receives unique recognition or Andorra, Angola, Argentina, Armenia, Bahamas, Belize, Bulgaria, Cape Verde,
benefits. Minority religions all receive similar treatment to each other. Chile, Cyprus (Turkish), Ecuador, El Salvador, Equatorial Guinea, Gambia,
Georgia, Guatemala, Guinea, Haiti, Ireland, Ivory Coast, Moldova, Myanmar,
Panama, Paraguay, Peru, Sudan, Venezuela, Zanzibar.
Multi-tiered preferences-one religion: One religion receives the most benefits. There is Belarus, Bolivia, Colombia, Croatia, Cyprus (Greek), Honduras, India, Indonesia,
one or more tiers of religions receiving less benefits than the preferred religion but more Italy, Macedonia, Mongolia, Nicaragua, Poland, Portugal, Romania, Russia,
than others. Serbia, Slovakia, Spain, Sri Lanka, Thailand, Turkey.
Multi-tiered preferences-multiple religions: Same as above except the top tier is occupied Austria, Bosnia, Czech Republic, Hungary, Latvia, Lithuania, Montenegro,
by multiple religions. Switzerland.
Cooperation: Multiple religions receive benefits that others do not. Albania, Belgium, Chad, Estonia, Germany, Kazakhstan, Kenya, Lebanon,
Luxembourg, Malawi, Mauritius, Nepal, Papua New Guinea, Philippines,
Slovenia, Solomon Islands, Swaziland, Sweden, Tanzania, Timor, Togo, Vanuatu.
Supportive: The state supports all religions equally. Benin, Brazil, Liberia, New Zealand, Senegal, Suriname.
Accommodation: Minimal support for religion and no religion is preferred. The state has a Australia, Barbados, Botswana, Burkina Faso, Burundi, Cameroon, Canada,
positive attitude toward religion. Central African Republic, Congo-Brazzaville, Ethiopia, Fiji, Gabon, Ghana,
Guinea Bissau, Guyana, Jamaica, Japan, Lesotho, Madagascar, Mali, Mozambique,
Namibia, Netherlands, Niger, Sierra Leone, Singapore, South Africa, Taiwan,
Trinidad & Tobago, Uganda, Ukraine, United States, Zaire, Zimbabwe.
Separationist: Minimal support for religion. The state has a negative attitude toward Azerbaijan, Eretria, France, Mexico, Rwanda, Uruguay.
religion and relegates it to the private sphere.
Nonspecific hostility: Religious organizations restricted in a manner similar to other non- Cuba.
state organizations.
State controlled religion, negative attitude: The state sets up an official religious China, Kyrgyzstan, Laos, Tajikistan, Turkmenistan, Uzbekistan, Vietnam
organization which it controls. All religious outside of this institution is restricted.
The purpose is to control rather than support religion.
Specific hostility: The government restricts or bans all religion for ideological reasons. North Korea.
States with official religions

! States with official religions usually declare this in their constitutions but can do so through some
other means such as a concordant or a law. For example the 1954 Concordant between the
Dominican Republic and the Catholic Church declares the Church the country’s official religion.
Also the UK has no constitution, but by tradition the Church of England and the Church of
Scotland are the country’s official religions. Of the 183 countries in the RAS dataset 43 (23.5%)
have official religions.
Despite them having in common the declaration of an official religion, these 43 states have
diverse policies on religion. These differences revolve around the extent to which the government
supports the official religion, enforces it, and regulates it, as well as how the government treats
minority religions. For example, both the UK and Iran have official religions, but no serious observer
would claim their religion policies are similar. Because of this, placing a state into the official
religion category alone is an insufficiently precise description of that state’s religion policy.
Accordingly, I divide official religions into three categories:
Religious states have governments which strongly support the official religion to the extent that
following this religion or at least many aspects of this religion is mandatory for at least members
of that religion and in some cases members of other religions. Only Saudi Arabia and the Maldives
enforce their official religion, in both cases Islam, on all residents of the country, regardless of
whether those residents belong to the majority religion.
Kuwait is among those states which enforces its majority religion, Islam, primarily on Muslims.
Article 2 of the country’s constitution declares Islam the state religion and Islamic law a main
source of legislation. Family law is determined by one’s religion. Religious minorities have separate
courts from Muslims to handle these issues. It is illegal to possess or import alcohol, pork products,
or gambling equipment. The country bans eating, drinking, and smoking in public during
Ramadan between sunrise and sunset, even for non-Muslims. The government funds the Hajj,
Muslim clergy, and mosques as well as other Muslim institutions upon request. Religious
instruction and Koran studies are mandatory in all public schools and private schools with at least
one Muslim student. Organized religious instruction in any faith other than Islam is prohibited.
Proselytizing to Muslims is illegal.3
Restrictions on religious minorities in Kuwait are also substantial. For example, only registered
religious groups may purchase land for houses of worship but requests to purchase land are routinely
rejected. Other groups, including Bahai, Buddhists, Hindus, Seventh-Day Adventists, and Sikhs,
worship in private houses. They cannot display religious symbols or hold public religious
ceremonies. Public religious events require permits which are often denied, even for the country’s
Shi’a Muslim minority.
State-controlled religion, positive attitude: These states support an official religion and have a positive
attitude toward that religion but also substantially control its institutions. This positive attitude
distinguishes it from the second state-controlled religion category I discuss later. All of these states
have considerable, though not necessarily absolute, control over the institutions of their official
religion. While Denmark’s Evangelical Lutheran Church (ELC) is comparatively unencumbered
compared to other states in this category, the government still substantially controls its apparatus.
The ELC has no independent legal structure. Its legislative body is Denmark’s parliament, and
the monarch is considered the de-facto head of the Church. Until 1994 the minister of ecclesiastical
affairs could veto the election of bishops, but in practice this did not happen. However, ministers
are state employees and are hired and fired only by the state (Kühle, 2011).
Other than Denmark and Greece, all of the countries in this category are Muslim-majority
countries. They all financially support Islam, usually legislate at least some of its precepts (though
less than countries in the religious states category), and financially support the religion. They also
tend to control the country’s Muslim religious institutions more strongly than does Denmark.
For example, most of them take part in the process to appoint clergy. Their governments are also
more independent from religious influence than are the countries in the religious state category.
Thus, while there is a deep relationship between religion and state, the state clearly has more
power in this relationship.
For example, Morocco’s constitution declares Islam the state religion and that the king is the
guardian of the faith. While strongly supporting Islam, the government is in firm control of Islam
in the country. The Ministry of Endowments and Islamic Affairs (MEIA) controls the content of
preaching in mosques, religious publications, religious education, and broadcast religious material.
Mosques are closed after prayer time to prevent them being used for political purposes. The
government monitors Muslim groups and places restrictions on individuals and groups when it
deems their actions exceed the bounds of acceptable religious or political activity. More than 1,000
Islamist militants are held in Moroccan jails. In November 2009 the MEIA dismissed 34 imams
for breaking rules that prohibit religious leaders’ participation in political events. In 2014 it
strengthened these rules, prohibiting religious leaders from participating in any political activity
or taking any public political stance.4
Active state religion: These countries have and substantially support an official religion but engage
in relatively minimal regulation and control of that religion. For example, Article 62 of Iceland’s
constitution declares “the Evangelical Lutheran Church shall be the State Church in Iceland and,
as such, it shall be supported and protected by the State.” However the Church itself is largely
autonomous from the state. While Iceland’s president is nominally the head of the Church, in
practice the Church is run by its own officials. The government funds the Church primarily through
a church tax that is collected from all citizens and is used to fund all registered religious associations.
Cambodia’s constitution similarly declares Buddhism the official religion. It provides some
support for the training of Buddhist priests. It also engages in some minimal regulation of religion
by prohibiting places of worship from being used for political purposes and barring clergy from
being members of political parties.
States with no official religion

! States with no official religion have the same policy options as those which have official religions.
They can support, enforce, control, and regulate religion. However, the lack of an official religion
allows for more freedom when considering these options, and results in a very wide range of
policies, ranging from countries with very pro-religion policies to countries that strongly repress
religion. I divide these policies into ten categories, which are based on the extent to which the
government is supportive, neutral, or hostile to religion.
Preferred religions describes a situation where a state does not declare an official religion but, in
practice, singles out one religion and one religion alone for support and benefits not given to any
other religion, in a manner similar to states which have an official religion. The actual level of
support can vary considerably.
Ireland presents a good example of this type of policy. While Ireland has no official religion,
the government is strongly interconnected with Catholicism. The Preamble of Ireland’s
Constitution states “In the Name of the Most Holy Trinity, from whom is all authority and to
Whom, as our final end, all actions, both of men and States must be referred,” and “We, the
people of Eire, Humbly acknowledging all our obligations to our Divine Lord, Jesus Christ, Who
sustained our fathers though centuries of trial . . .” Some aspects of Catholic doctrine are, or until
recently were, also law in Ireland. Pubs are not permitted to open on either Good Friday or
Christmas Day. Abortion is illegal except to save the life of the mother, and until 1995 divorce
was prohibited, and is currently permitted only after a lengthy separation period. The majority
of Ireland’s public school system is run by the Catholic Church, most of the other schools are
Protestant, and only about 4 percent are non-denominational.5 While most countries in this category
provide significant financial support for their preferred religion, other than for education this does
not occur in Ireland. This arrangement is particularly common in Latin America where 12 countries
follow this type of policy. Argentina, Belize, Chile, Ecuador, El Salvador, Guatemala, Haiti, Panama,
Paraguay, Peru, and Venezuela prefer Catholicism, while the Bahamas supports Protestant
Christianity.
Multi-tiered preferences, one religion constitutes a more complicated policy. This type of policy
favors a single religion above all others, but among the non-preferred religions there is a tiered
hierarchy of preferences. That is, some of these other religions receive more benefits than others.
Romania’s 2006 Law on the Freedom of Religion and the General Status of Religious
Denominations established this type of policy. The law names 18 denominations as “recognized”
religions. These religions receive state financial support, especially for clergy and for building and
maintaining places of worship. They also have the right to establish schools, and to teach religious
beliefs in public schools where they have a sufficient number of adherents. However, in practice,
the Romanian Orthodox Church receives more funds and is more closely connected to the
government. It is also the only religious organization which receives government funds for its
overseas activities. The 2006 law establishes two additional tiers for religious groups. “Religious
associations” are legal entities but do not receive government funding and receive only limited
tax exemptions. Religious associations can apply to become recognized religions if they remain
in the country for 12 years and have a membership of at least 0.1 percent of Romania’s population.
Becoming a recognized religion requires an act of parliament. Religious associations must have
300 citizen members and must submit members’ personal data. “Religious groups” are groups of
people who share the same religion but have no legal status, receive no tax exemptions, and may
not engage in profit-making activities.6
A multi-tiered preferences, multiple religions policy is similar to the above policy except the top
tier is occupied by more than one religion both officially and in practice. Austria’s 1998 Federal
Law on the Legal Status of Religious Confessional Communities established a three-tiered system
which provides a good example of this type of policy. Currently, 16 religions occupy the highest
tier—religious societies. These religions must be present in the country at least 20 years, ten of
which must be as a “confessional society” (the next tier) and represent at least 0.2 percent of
Austria’s population. They may receive funds from Austria’s religion tax, offer religious education
in public schools, bring in non-EU religious workers without securing work or residence permits,
and are exempt from property taxes. “Confessional communities” are recognized legal entities
but do not receive funds from the state and are not exempt from property taxes. To apply for
this status a group must have at least 300 members. The final official tier is “legal associations,”
which are recognized as legal entities but not specifically as religions. There is an unofficial fourth
tier which consists of groups which hold none of these three statuses and are considered by the
state to be dangerous sects or cults. Such groups might be monitored or restricted by the state.
Also because they are not recognized legal entities they may not buy or rent property.7
Cooperation is a policy where the government has only two tiers, (1) religions it recognizes and
treats roughly the same and (2) all other religions. Belgium, for example, recognizes six religions
as well as secular humanism. Recognized religions receive financial support from the government,
mostly for clergy, religious education, and places of worship. Other religions are generally not
restricted but receive no government support.
A supportive policy, where all religions in a country are supported equally, is rare and found in
only six countries. Senegal, despite having a large Muslim majority, supports all religions in the
country—primarily Islam and Christianity—equally. The government funds maintenance and repairs
for places of worship, religious charities, and special events for all religions. It funds the Hajj as
well as Christian pilgrimages. Senegal’s government is among the small minority of governments
which engages in no religious discrimination against religious minorities as measured by the RAS
project.
Accommodation is a policy where the government maintains separation of religion and state but
has a positive attitude toward religion. As discussed in more detail in Chapter 12, the exact definition
of separation of religion and state is disputed, but in this case it means that these governments
neither substantially support nor restrict religion. However, none of these countries maintain this
separation absolutely. That is, they come close to having full separation but they still engage religion
in some small way. For example, in many parts of the US, alcohol cannot be purchased on Sundays,
and religious charitable organizations can compete for government funding to provide social services.
The last four categories all involve states which have negative attitudes toward religion. A total
of 15 countries, about 8.2 percent of countries covered by the RAS dataset, fit into these categories,
so hostility to religion in the twenty-first century is considerably less common than positive and
neutral policies.
Separationist policies maintain separation of religion and state but have a negative attitude toward
religion. These countries tend to restrict religion’s presence in public spaces as part of this policy.
France is a classic example of this form of policy. While France does not substantially restrict
religion in the private sphere, it does significantly restrict religion in public. France’s 1958
constitution declares the state secular, and the 1905 Law on the Separation of Church and State
guarantees freedom of religion but allows restrictions in the interest of public order and prohibits
the display of religious symbols on public buildings except for houses of worship, cemeteries, or
museums. The law also prohibits the republic from recognizing or subsidizing a religion. A 2004
law prohibits students and employees in public schools from wearing conspicuous religious
symbols, including the Islamic headscarf, Jewish skullcap, Sikh turban, and large Christian crosses.
From the French perspective wearing such symbols in a public school is to aggressively bring
one’s religion into a secular public space. Recently, the issue of ultra-modest clothing for Muslim
women has been particularly controversial. A 2011 law bans covering one’s face in public, a law
widely recognized as prohibiting Muslim women from wearing the burqa or niqab. There have
also been cases where local governments in France have banned the wearing of full body
swimsuits, known as burkinis, at public beaches and pools.
Nonspecific hostility is a policy where the government heavily restricts religion as part of a larger
policy of restricting all organizations that might be considered a challenge to the state. As
Sarkissian (2015) points out, leaders in autocratic states often fear religion because it provides a
venue or organization for the opposition and therefore they restrict it. Accordingly, under this
policy, religious organizations are restricted in a manner similar to other organizations which the
authorities consider to be potential bases for opposition. Currently only Cuba, which severely
restricts all religion in the country, is the only country which has this type of policy.
State controlled religion, negative attitude. This is a policy where the state sets up a religious
organization or multiple religious organizations, which it supports and controls. However, this
religion is not the official religion of the state and the purpose of these state-controlled organizations
is not to support religion but to limit it. Essentially, the state has a negative attitude toward religion,
but realizes that it is unable to eliminate religiosity among its citizens and has therefore created a
framework where religious activity can take place but only under strict government control. As
I discuss in more detail below, supporting religion is one of the most effective means to control
religion.
China provides a good example. The government recognizes five “patriotic” religious
organizations for Buddhism, Taoism, Islam, Catholicism, and Protestantism. Religious activities
under the auspices of these organizations is legal but heavily supervised and monitored by the
State Administration of Religious Affairs and the Public Security Bureau. The leaders of these
organizations are expected to have a close working relationship with the government, and their
salaries are often paid by the government. The government also funds activities by these
organizations. While small religious groups outside the framework of these organizations are
sometimes overlooked, as they get larger they are pressured to join one of these five organizations.
Specific hostility is a policy where the state is ideologically opposed to religion. All religious
organizations and expressions of religion are repressed to at least some extent, specifically because
they are religious. While currently only North Korea fits in this category, before 1990 much of
the communist bloc followed this type of policy.
Official policy in comparative perspective

! As presented in Table 10.2, the distribution of states within these categories is interesting, and
perhaps surprising, to some observers. States which either declare an official religion or without
an official declaration effectively prefer one religion over all others constitute just over half of the
countries in the world. When we add countries which give preference to a finite numbers of
religions over others this increases to 68.8 percent, over two-thirds of the countries in the world.
Thus, support for religion in a manner that privileges one or a finite number of religions is the
norm not the exception.
Of course there are some differences across categories of countries. While Muslim-majority
countries are more likely to support Islam as an official religion, Christian majority countries are
more likely to support Christianity without declaring it the official religion. Non-Christian, non-
Muslim countries are the most likely to have neutral policies toward religion, either treating all
religions equally or maintaining separation of religion and state.
That being said, it is clear that governments are heavily involved in religion, either supporting
it or restricting it. Less than one in five governments maintains separation of religion and state
while not being hostile to religion.
! MOTIVATIONS FOR SUPPORTING RELIGION
In the previous section I discuss the larger picture dividing government religion meta-policy into
13 categories. However, the devil is in the details. The actual process of supporting religion is far
more specific than simply choosing one of these meta-policies. As I discuss in detail below I identify
TABLE 10.2 DISTRIBUTION OF OFFICIAL RELIGION POLICY IN 2014
MAJORITY RELIGION ALL

CASES
CHRISTIAN ISLAM OTHER
Religious State 0.0% 21.5% 0.0% 6.0%
State Controlled, Positive 1.9% 21.6% 0.0% 7.1%
Active State Religion 8.7% 13.7% 10.3% 10.4%
All official religion categories 10.7% 56.9% 10.3% 23.5%
Preferred Religion 20.4% 9.8% 6.9% 15.3%
Multi-Tiered, One Religion 15.5% 5.9% 13.8% 12.6%
All no official religion but support one 35.9% 15.7% 20.7% 27.9%
All which officially or unofficially prefer one
religion over others 46.6% 72.6% 31.0% 51.3%
Multi-Tiered, Multiple Religions 6.8% 0.0% 3.4% 4.4%
Cooperation 15.5% 7.8% 13.8% 13.1%
All preferring multiple religions 22.3% 7.8% 17.2% 17.5%
All which officially or unofficially prefer one
or multiple religions 68.9% 80.4% 48.2% 68.8%
Supportive 2.9% 2.0% 6.9% 3.3%
Accommodation 23.3% 7.8% 27.6% 19.7%
All neutral policies 26.2% 9.8% 34.5% 23.0%
Separationist 4.9% 2.0% 0.0% 3.3%
Nonspecific Hostility 0.0% 0.0% 3.4% 0.5%
State Controlled, Negative 0.0% 7.8% 10.3% 3.8%
Specific Hostility 0.0% 0.0% 3.4% 0.5%
All hostile policies 4.9% 9.8% 17.1% 8.2%
52 specific ways a government can support religion within its borders. I discuss these 52 policies
in more detail in the next section.
In practice every country in the world supports religion through at least two of these policies.
This includes even the countries that are the most hostile to and repressive of religion. In fact, as
I discuss in more detail in Chapter 11, most countries which support religion also restrict it. This
is because the motivations for supporting and restricting religion are complex. The motivations
for supporting religion can be placed into six categories. It is important to emphasize that these
categories are not mutually exclusive, and most countries support religion for more than one reason
on this list.
Religious belief, ideology, and worldviews: As I discuss in more detail in Chapter 4, religious beliefs
can motivate political behavior. One of these behaviors is the desire to support one’s religion
through government policy. This can occur because politicians are motivated in this manner. It
can also occur as a result of the religious motivations of constituents and lobby groups who pressure
politicians to support religion.
Religion as culture: Many countries regard a specific religion or sometimes multiple religions as
an integral part of their culture. These countries often support these religions as part of a larger
policy to support and protect national culture. For example, a government might provide for the
maintenance and upkeep of religious buildings such as churches, not because they are churches
but because they are considered historical or cultural landmarks.
Religion provides a public good: Many see religion as beneficial to a society. As I discuss in more
detail in Chapter 7, many politicians support religion because it lowers the costs of ruling by
helping maintain a more orderly and law-abiding society. That is, by supporting morality, religion
can reduce anti-social behavior and encourage believers to support the government. In addition,
religious institutions often provide public goods like charity welfare, education, and even healthcare
that is largely supported by the institutions’ own resources and voluntary donations. Given this,
supporting religious institutions in engaging in these tasks can be seen as a rational, efficient, and
effective government policy.
Tradition and inertia: Many government policies exist today because they existed yesterday. That
is, when there is a longstanding policy or tradition of supporting a religion or religions, even if
the original motivations for that policy are no longer relevant, it will often remain in effect out
of sheer inertia or the strength and legitimacy of the tradition.
Legitimacy: As I discuss in more detail in Chapter 5, religion is a potent source of legitimacy.
Governments will often support religion in return for the legitimacy which this can lend to
a government.
Control: This last motivation for supporting religion is perhaps the most complex and likely
the most common. Even those states that ideologically support religion tend to regulate it. As I
discuss in more detail in Chapter 11, there are multiple reasons why a government might want
to control, restrict, or regulate religion, and one of the most effective ways to accomplish this is
to support religion.
This is because supporting religion is inexorably intertwined with controlling it. When a
government supports a religious institution, that institution becomes at least partially dependent
on the government. This makes it more susceptible to government influence, even if control is
not the motivation for the policy of support. When a religious institution is dependent upon a
government for at least part of its funding, for example, the implied threat of the removal of that
support can make that institution more open to government influence.
Kühle (2011) argues that this dynamic exists on the five Nordic states of Denmark, Finland,
Iceland, Norway, and Sweden. All of these countries are supportive of Christianity in general and
the Lutheran Church in particular, with all of them financially supporting the Church and all of
them, except Norway as of 2017 and Sweden, declaring this Church their official religion. Because
of this, these governments often interfere in “internal” religious issues. For example, these
governments have successfully pressured their national churches to change their doctrines on issues
such as gay marriage and the ordination of women.
As I discuss in more detail in Chapter 3, other countries use this policy more explicitly.
Kyrgyzstan, Uzbekistan, Tajikistan, and Turkmenistan all set up government-supported versions
of Islam for the express purpose of controlling Islam in their countries. These institutions are under
tight government control, and all Islamic activities outside the auspices of these organizations is
repressed. All of this makes support an excellent tactic for governments that wish to control religion
(Cosgel and Miceli, 2009: 403; Demerath, 2001: 204; Grim and Finke, 2011: 207). In fact, this is
likely the major motivation for the state-controlled religion negative attitude policy that I discuss above.
Given this, the act of supporting religion does not necessarily mean that a state’s primary
motivation is to support religion. Motivations are often complex and difficult to unravel.
Understanding a state’s motivation for its religion policy requires a contextual analysis of its overall
policy and statements made by leaders and government representatives, and such analyses are often
inconclusive. However, supporting religion does demonstrate that a state considers religion
important in some manner—sufficiently important that the government wants to support it, restrict
it, or both.
! TYPES OF SUPPORT FOR RELIGION
As I note above, I identify 52 specific ways governments in practice support religion, which can
be placed into five distinct categories. As delving into each of these 52 policies in depth is beyond
the scope of this textbook,8 I focus this discussion on five larger categories into which these 52
policies can be placed, and discuss those specific policies which are particularly common or
important. These five policy categories are:
1. Legislating religious precepts. Policies in this category make religious laws or doctrine the law
of the land or in some other way require citizens to abide by religious doctrines or law.
2. Institutions which enforce religion focus on the presence of government departments or bodies
whose purpose is to enforce religion.
3. Funding religion represents the government allocating funds from its budget or otherwise
directing money to fund religious institutions.
4. The entanglement of government and religious institutions represents a blurring of the lines between
government and religious institutions.
5. Other forms of support are all of those forms of support which do not fit into the other four
categories.
All of the 52 specific policies are listed in Tables 10.3, 10.4, and 10.5 and are organized into
these five categories. These tables also show how common each of these policies are, both in
general and within states based on their official religion policy. In order to keep matters from
getting too complicated, I simplify the official religion policies discussed in the first section of this
chapter into five categories:
1. Hostile—specific hostility, state controlled–negative attitude and separationist.

2. Neutral—accommodation and supportive.
3. Multiple preferred—multi-tiered–multiple religions and cooperation.
4. One preferred—multi-tiered–one religion and preferred religion.
5. Official religion—the three official religion categories.
I use these categorizations of official religion in this section of the chapter in order to
demonstrate that all countries support religion. This support is present even in countries that are
hostile to religion or countries which officially maintain a neutral stance or separation of religion
and state meta-policies.
Legislating religious precepts

! Legislating religious precepts means that the government through law or some other form of policy
enforces religious precepts, laws, or doctrines. More specifically, these governments base some
aspects of law or policy on Holy Scriptures such as the Bible or Koran or some other source of
religious theology. Put differently, the apparatus of the state is used to require a country’s
population to comply with the tenets of a religion. The policies in this category represent the
religious laws or doctrines which the government enforces.
This is a relatively unambiguous form of support that is usually motivated, at least in part, by
belief in the validity of the religious doctrine which is enacted into policy. I subdivide the 21
types of policy in this category into three sub-categories: (1) laws on relationships, sex and
reproduction, (2) laws restricting women, (3) other laws which enforce religious precepts. All of
these types of policies are listed in Table 10.3.
Laws on relationships, sex, and reproduction are important because most human beings will at
some point in their lives marry, have sex, and have children. These activities are central elements
of our lives. Religious precepts influence some aspect of these matters in 142 (77.6%) countries.
The most common type of policy in this category is restrictions on abortion which is present in
118 (64.5%) countries. All of these countries restrict abortion on demand. A smaller number of
countries restrict abortion in other circumstances, including for social (62.3%) or economic (62.8%)
reasons, in cases of incest (49.7%) or rape (48.6%), in cases where the pregnancy threatens the
mental health (42.1%) or physical health (32.8%) of the woman, and when the life of the woman
is threatened (4.9%).
The second most common religiously motivated policy in this category is restrictions on
homosexuals. This type of policy specifically makes it illegal to be a homosexual or engage in
homosexual sex: 72 (39.3%) countries restrict homosexuality in this manner.
Religious laws are used in 35 (19.1%) countries to define personal status, also known as family
law; 30 of these countries are Muslim-majority countries. Standard interpretations of Sharia (Islamic)
family law generally contain the following types of provisions. Men can divorce their wives with
little difficulty and without cause. However, women usually encounter significant difficulty in
divorcing their husbands without the husband’s consent. In some cases, divorce without the
husband’s consent is impossible. While Muslim men may marry non-Muslim women, Muslim
women are often not allowed to marry non-Muslim men. In cases of divorce in these mixed
marriages, the non-Muslim women are rarely given custody of their children. The children are
considered Muslims, and it is often illegal to raise them as members of another religion. Sharia
law allows men to have up to four wives, though many Muslim-majority states prohibit polygamy.
There are certainly exceptions to this as not all Muslim-majority states use Sharia law for family
law and inheritance, but those that do tend to follow some interpretation of these general principles.
The second sub-category of religious legislation, restrictions on women, is less common and found
mostly in Muslim-majority countries where Islam is the official religion. Among the 26 countries
where Islam in the official religion, only Bangladesh, Djibouti, Morocco, Oman, Tunisia, and
Western Sahara do not engage in any of the four types of restrictions on women listed in Table
10.3. Only Afghanistan and Saudi Arabia engage in all of them as they are the only countries
which do not allow women to be in public places unescorted by a male relative. Gaza, Iran, Libya
(pre-civil war), and Qatar engage in all of the other three types of restrictions.
The final sub-category is other types of laws. While all of them enforce an aspect of religion,
they do not fit into either of the above sub-categories. With the exception of blue laws—laws
requiring businesses to close on religious holidays or the Sabbath, and other types of restrictions
on these days—most of these laws are nearly exclusively found in Muslim-majority countries.
The most common form of support in this sub-category is when states use religious law to determine
matters of inheritance. All 26 states where Islam is the official religion do this. This has important
implications because, while there are various interpretations of the Islamic laws of inheritance, all
of them disadvantage female heirs.
Another relatively common form of support are bans on conversion away from Islam. In Sudan,
Iran, and Saudi Arabia this can bring the death penalty. In Afghanistan there is technically no
death penalty for conversion away from Islam but converts can be sentenced to death for the
crime of apostasy. In Yemen, apostasy is also punishable by death but this sentence is never applied.
Converts are usually put in jail until they renounce their conversion. In Egypt, conversion is not
TABLE 10.3 PERCENTAGE OF COUNTRIES WHICH SUPPORT RELIGION—LEGISLATING RELIGIOUS PRECEPTS IN 2014
TYPE OF SUPPORT OFFICIAL GOVERNMENT POLICY ALL

CASES
HOSTILE NEUTRAL MULTIPLE ONE OFFICIAL
PREFERRED PREFERRED RELIGION
Relationships, Sex, and Reproduction

Marriage and divorce can only occur under religious auspices 0.0% 0.0% 6.3% 11.8% 62.8% 19.1%
Automatic government recognition for marriages performed by clergy 0.0% 23.8% 21.9% 41.2% 55.8% 33.9%
Restrictions on interfaith marriages 0.0% 0.0% 3.1% 7.8% 62.8% 17.5%
Restrictions on premarital sex 0.0% 4.8% 0.0% 2.0% 37.2% 10.4%
It is illegal to be a homosexual or engage in homosexual sex 20.0% 42.9% 31.3% 25.5% 65.1% 39.3%
Prohibitive restrictions on abortion 26.7% 73.8% 46.9% 62.7% 83.7% 64.5%
Restrictions on access to birth control 0.0% 4.8% 3.1% 3.9% 0.0% 2.7%
At least one in this category 40.0% 83.3% 62.5% 78.4% 95.3% 77.6%
Laws restricting women
Women may not go out in public unescorted 0.0% 0.0% 0.0% 3.9% 4.7% 2.2%
Required religious attire or modesty laws beyond bans on public nudity 0.0% 0.0% 6.3% 3.9% 23.3% 7.7%
Female testimony in court is given less weight than male testimony 0.0% 0.0% 3.1% 3.9% 46.5% 12.6%
Restrictions on women other than those listed above 13.3% 4.8% 6.3% 3.9% 32.6% 12.0%
Other types of laws
Dietary laws: limits on producing/importing/selling/consuming specific foods 0.0% 0.0% 3.1% 0.0% 37.2% 9.3%
Restrictions or prohibitions on the sale of alcoholic beverages 0.0% 0.0% 3.1% 3.9% 51.2% 13.7%
Laws of inheritance defined by religion 0.0% 9.5% 12.5% 11.8% 65.1% 23.0%
Religious precepts used to define crimes or set punishment for crimes 0.0% 0.0% 3.1% 3.9% 25.6% 7.7%
The charging of interest is illegal or significantly restricted 0.0% 0.0% 0.0% 2.0% 9.3% 2.7%
Required rel. attire or modesty laws for men beyond bans on public nudity 0.0% 0.0% 0.0% 2.0% 14.0% 3.8%
Restrictions on conversions away from the dominant religion 6.7% 0.0% 3.1% 7.8% 46.5% 14.2%
Restrictions on public music or dancing beyond the usual zoning restrictions 0.0% 0.0% 0.0% 3.9% 14.0% 4.4%
Closing of businesses on religious holidays, the Sabbath, or its equivalent 0.0% 11.9% 9.4% 7.8% 34.9% 14.8%
Other restrictions on activities on rel. holidays, the Sabbath, or its equivalent 0.0% 7.1% 15.6% 4.0% 37.2% 14.2%
At least one type of legislating religious precepts 53.3% 95.2% 81.9% 78.4% 100.0% 84.2%
Average number of types of legislating religious precepts 0.667 1.833 1.781 2.177 8.093 3.295
illegal but converts are often arrested, harassed, and sometimes tortured by the police until they
renounce their conversion. In addition, the government refuses to change their religion on official
documents.
Overall, while legislating religious precepts is far more common in states with official religions,
especially when that official religion is Islam, 154 (84.2%) states engage in this practice to at least
some small extent. This includes 39 of 42 (95.2%) states which are neutral on the issue of religion
and eight of the 15 (53.3%) of the states which are hostile to religion. Among the non-Muslim
majority states, blue laws, and restrictions on abortion and homosexuals are the most common
form of support. This demonstrates that the dynamics of support for religion can be different
across religious groups, while at the same time showing that at least some religious precepts influence
the laws of most of the countries in the world.
Institutions which enforce religion

! The presence of government institutions or laws which enforce religion is the least common form
of support, with only 69 (37.7%) countries (see Table 10.4) having at least one such institution
or law. This form of support is distinguished from the religious laws in the previous section in
that it represents an official mechanism of support, rather than the content of that support. For
example, religious courts generally use religious law in order to arrive at their judicial decisions.
While the content of their decisions are based on religious law, the courts themselves are a
mechanism to enforce that law. Similarly, a religious police force is a mechanism to enforce religious
laws but, as is true of most police forces, they do not make the laws they enforce.
Most countries which have policies or laws based on religion enforce them exclusively though
their regular courts and police forces and have no separate religious courts or police. This makes
religious courts and police a significant form of support for religion. It represents a specific allocation
of resources to religion. Police have numerous laws to enforce and finite resources. This means
they often have to prioritize enforcing some laws over others. A religious police force has no such
mixed priorities and focuses exclusively on enforcing religious laws.
Courts similarly need to balance legal priorities (Beatty, 2001; McConnell, 1992). For example,
protecting religion from criticism might be balanced against another principle such as free speech.
A general court might rule in favor of either of these principles. A religious court will nearly
always prioritize prosecuting blasphemers over freedom of speech.
While all four types of this category of support are more common in countries with official
religions, most (86.0%) of which engage in at least one of these types of support, they are also
present in states without official religions, with the exception of states that are categorized as hostile
to religion. The most common form of support are blasphemy laws. These laws protect the majority
religion and/or religious figures from at least some forms of criticism or insult. While in extreme
cases such as Pakistan, Afghanistan, Iran, and Saudi Arabia, certain forms of blasphemy can result
in a death sentence, in many countries these laws, while on the books, are enforced sporadically
if at all.
Religious censorship laws are similar except that they focus on the printed word. While
blasphemy laws can be applied to the printed word, these countries have specific laws or policies
which review publications and the internet for banned speech. Of the 37 countries which have
this type of policy, 26 have Muslim majorities. However, several Christian majority states
including Finland, Greece, Guyana, Malta, Poland, Russia, and the Ukraine have this type of law
as do four other non-Muslim majority states—India, Myanmar, Singapore, and Thailand.
TABLE 10.4 PERCENTAGE OF COUNTRIES WHICH SUPPORT RELIGION—INSTITUTIONS WHICH ENFORCE RELIGION AND
FUNDING RELIGION IN 2014

CASES
Institutions or Laws which Enforce Religion
Blasphemy laws, or any other restriction on speech about majority 0.0% 7.1% 15.6% 23.5% 76.7% 29.0%
religion or religious figures
Censorship of press or other publications on grounds of being anti-religious 0.0% 7.1% 3.1% 13.7% 60.5% 20.2%
Presence of a police force or other government agency which exists solely 0.0% 0.0% 3.1% 5.9% 16.3% 6.0%
to enforce religious laws
Presence of religious courts with jurisdiction over family law and inheritance 0.0% 7.1% 15.6% 15.7% 58.1% 22.4%
Presence of religious courts with jurisdiction over matters of law other than 0.0% 2.4 3.1% 3.9% 20.9% 7.1%
family law and inheritance
Average number of types of enforcement 0.000 0.238 0.406 0.628 2.33327 0.874
Funding Religion
Government funding of religious primary/secondary schools or religious 13.3% 45.2% 68.8% 68.6% 62.8% 57.4%
education programs in non-public schools
Government funding of seminary schools 13.3% 2.4% 21.9% 31.4% 46.5% 25.1%
Government funding of religious education in colleges or universities 33.3% 7.1% 21.9% 29.4% 44.2% 26.8%
Government funding of religious charitable organizations 0.0% 16.7% 40.6% 35.3% 27.9% 27.3%
Government collects taxes on behalf of religious organizations 0.0% 0.0% 18.8% 11.8% 25.6% 12.6%
Official government positions/salaries/other funding for clergy 20.0% 11.9% 37.5% 43.1% 69.8% 38.3%
Direct general grants to religious organizations 6.7% 9.5% 43.8% 37.3% 39.5% 30.1%
Funding for building, maintaining, or repairing religious sites 53.3% 19.0% 56.3% 64.7% 79.1% 55.2%
Free air time on television or radio is provided to religious organizations 13.3% 28.6% 31.3% 37.3% 48.8% 35.0%
on government channels or by government decree
Funding or support for religious pilgrimages such as the Hajj 33.3% 9.5% 9.4% 13.7% 37.2% 19.1%
Funding for religious organizations or activities other than those listed above 20.0% 11.9% 21.9% 29.4% 30.2% 23.5%
Average number of types of funding 2.067 1.619 3.719 4.020 5.116 3.514
These blasphemy and censorship laws are important, even if enforced only on occasion. They
demonstrate to a country’s population that there are potential consequences for speaking against
the country’s majority religion and religious officials. When combined with religious courts and
religious police, the forms of support in this category become even more significant. They define
what can and cannot be said about religion and what type of government officials will be enforcing
religious laws. They also make it very clear that the government is taking a strong position in
support of a religion.
Nilay Saiya (2016) argues that blasphemy laws have a substantial influence on civil society and
the balance of power between religious moderates and radicals. In a study of terrorism in Muslim-
majority countries, Saiya argues that these laws, while ostensibly passed to protect Islam from being
“insulted” actually coerce religious conformity, and silence opposing religious views, turning a
religion that is traditionally diverse into a homogeneous one. These laws tend to undermine
moderates, strengthen radicals, and essentially legalize, or at least give legitimacy to discrimination
and persecution against minority religions:
Rather than control the forces of extremism, blasphemy laws appease and encourage them.
The result, expectedly, is that states that attempt to curry favor with radicals emboldens them
to take matters into their own hands; eventually such countries fall prey to violence carried
out by those same radicals.
(Saiya, 2016: 5)
This occurs because blasphemy laws, instead of protecting religion from insult or offense,
provide extremists with a pretext for attacking those believed to be guilty of blasphemy.
Terrorists invoke these very laws to silence those who threaten their ideology and to justify
their violence towards the accused.
(Saiya, 2016: 13)
While Saiya focuses on blasphemy in Muslim-majority countries, arguably, all of the types of
support in this category have the potential to have similarly profound impacts on society regardless
of a country’s majority religion.
Funding religion
! Government funding for religion is the most common type of support. It is also particularly
important for at least two reasons. First, governments have finite resources, and the decision to
fund religion means prioritizing religion over some other competing demand on the government’s
money. This makes it a very tangible form of support for religion. Second, funding religion is a
form of support that is, in particular, associated with government control of religion. Government
funds often come with conditions. Even if there is no explicit quid pro quo, dependence on
government funds can make religious institutions vulnerable to government influence. For
example, if a government funds religious education, the government will likely have some input
into the specific content of that religious education. This can include approval of the curriculum,
textbooks, and teachers. This can, in turn, influence which interpretation of a religion becomes
dominant in a country.
Despite the strings attached, many religious institutions accept this funding. Religion is not
free, and financial resources are necessary for religious institutions to thrive or even just survive.
Returning to the example of religious education: while accepting government funding for that
education may allow some government influence on a religious institution and the content of
that education, it also furthers a central goal of most religious institutions, namely, educating more
people about their religion and hopefully in doing so reinforcing and increasing active membership.
Perhaps this is why the funding of religious education in private schools is the most common
form of funding.
The second most common form of funding is for places of worship. This form of funding can
also include elements of control. For example, Mexico’s 1917 constitution declares all religious
property to belong to the state. This remained in effect until a 1992 amendment to the constitution.
As a result of this, all religious property built before 1992 is maintained at state expense. France’s
1905 law on the Separation of Church and State creates a similar arrangement for religious property
built before 1905. In other cases, the support aspect is more dominant. For example, Venezuela’s
concordant with the Catholic Church specifies that monies will be allocated “to run and contribute
for the implementation of building works and conservation of churches, seminaries and places for
the celebration of worship.” Costa Rica, the Dominican Republic, and Panama similarly provide
funds for the maintenance and repair of Catholic churches.
An interesting form of support is religious taxes. This is different from all other types of funding
where governments fund religions out of the general budget. Here governments collect a separate
tax that specifically funds religious institutions. While 11 of these countries are Muslim-majority
countries (Brunei, Gaza, Indonesia, Kuwait, Lebanon, Malaysia, Oman, Pakistan, Saudi Arabia,
Sudan, and Yemen), the other 12 are all European states with Christian majorities. In some cases
this tax is compulsory. In Austria, there is a tax of 1.1 percent of income for the country’s 13
officially recognized religions. It is compulsory for Catholics. In Belgium, the tax is mandatory,
but tax-payers can direct their tax to a designated religion. In Germany and Finland the tax is
compulsory only for members of recognized religious communities. One must officially leave the
religious community to be exempt from the tax.
In some countries, the tax is voluntary. In Italy, taxpayers can designate some of their taxes to
be sent to certain recognized religions. In Portugal and Spain, taxpayers can designate a portion
of their income taxes to the Catholic Church. In Hungary, they can do so for any registered
religion. In Sweden, taxpayers may choose to divert the tax to the religious group of their choice
or receive a tax reduction. In Switzerland, the issue is decided by the canton’s government. In
some cantons, the church tax is voluntary, in others a person opting to not pay the church tax is
forced to leave the Church, or the tax may be non-negotiable (Robbers, 2001).
Religion is funded in 166 (90.7%) countries in some manner. A majority of states in each
category based on official religion policy fund religion in some manner, and a clear majority of
104 (59.6%) countries engage in at least three of the 11 types of funding examined here which
are listed in Table 10.4.
While very common, funding religion is not always an exclusive form of support. Of those
countries which fund religion, only 36 (19.7%) countries fund one religion exclusively. This includes
countries like Brunei, Chad, Gaza, Iran, Jordan, Kuwait, Saudi Arabia, Tajikistan, Turkmen-
istan, and Uzbekistan which support Islam exclusively. It also includes Orthodox Christian-
majority countries such as Belarus and Moldova, Catholic-majority countries like Andorra,
Ecuador, El Salvador, Haiti, Peru, and Poland, and Buddhist-majority countries such as Cambodia,
Laos, and Mongolia. The other 130 countries fund more than one religion; 57 (31.1%) fund a
single religion more than others, but still fund other religions on a lesser basis; 48 (26.3%) fund
several religions more than others; 25 (13.7%) fund all religions equally. All of these categories
are religiously heterogeneous.
Funding religion is not only the most common form of support for religion, it is also increasing
dramatically. Each of the 11 categories of support listed in Table 10.4 was present in substantially
more countries in 2014 than it was in 1990. This is a clear demonstration of the increasing
involvement of government in religion.
The entanglement of government and religious institutions

! In 1971, in the case of Lemon vs. Kurtzman, the US Supreme Court established rules to define
the practical meaning of separation of religion and state in US law. One of the principles that the
government must maintain, according to this ruling, is that a law cannot result in “excessive
entanglement” between government and religion. Yet, as shown in Table 10.5, 120 (65.6%)
governments have policies which entangle them with religion. In this context, I define
entanglement in a narrower manner than US courts who would likely consider most of the forms
of support for religion discussed here as excessive entanglement, and limit this category to policies
which blur the lines between government and religious institutions or officials.
The most common form of entanglement is the presence of a government religion department:
105 (57.4%) countries have such a department. While each country’s religion department is unique,
these departments can potentially advocate, regulate, control, fund, and enforce religion. Some
of these departments are small and have limited powers. For example, South Korea has a Religious
Affairs Office in the Ministry of Culture, Sports and Tourism that aims to promote religious
harmony. Some departments have a more substantial influence. The Czech Republic’s Department
of Churches and Religious Societies of the Ministry of Culture is in charge of registering religious
groups and distributing funds to registered groups.
Jordan provides an interesting example for the entanglement policies as it has four of the policies
in the entanglement category. Jordan’s Ministry of Religious Affairs and Trusts controls most matters
with regard to Islam. It manages Islamic institutions and the construction of mosques. It also appoints
imams, provides mosque staff salaries, manages Islamic clergy training centers, and subsidizes certain
activities sponsored by mosques. It also grants permission to “unofficial clerics” who want to deliver
sermons. The head of the department that manages Sharia affairs (a cabinet-level position) appoints
Islamic law judges, with the approval of the prime minister and the monarch. The head mufti is
appointed by royal decree and, since 2006, has a rank equal to the rank of a minister.9
Jordan’s constitution states that its king must be a Muslim from birth. A small percentage of
parliamentary seats are reserved for Christians, as are some positions in the upper levels of the
military. Christians are prohibited from running outside of these designated seats, although they
are also eligible to compete for the seats reserved for national list candidates. Thus, in Jordan, the
entanglement level is high. The government, through its religion department, controls the
country’s Islamic institutions, and government officials, both elected and unelected, may only serve
if they belong to the correct religion.
Entanglement is increasing considerably over time from 96 (52.5%) countries having at least
one of these types of entanglement in 1990 to 120 (65.6%) in 2014.
Other forms of support for religion

! There are an additional nine types of support for religion that do not fit well into any of the
above categories. Yet this category is important because 174 (95.2%) countries have at least one
of these policies.
TABLE 10.5 PERCENTAGE OF COUNTRIES WHICH SUPPORT RELIGION—ENTANGLEMENT AND OTHER FORMS OF SUPPORT

CASES
The Entanglement of Government and Religious Institutions
Some religious leaders are given immunity, diplomatic status, or passports 0.0% 2.4% 3.1% 15.7% 2.3% 6.0%
Official government ministry or department dealing with religious affairs 80.0% 19.0% 53.1% 62.7% 83.7% 57.4%
Certain government officials are also given an official religious position 6.7% 0.0% 0.0% 0.0% 18.6% 4.9%
Certain religious officials are given a government position 6.7% 0.0% 0.0% 2.0% 11.6% 3.8%
Some or all government officials must meet religious requirements 0.0% 0.0% 9.4% 2.0% 48.8% 13.7%
Seats in legislature or cabinet are granted, at least in part, by religion 0.0% 2.4% 12.5% 2.0% 27.9% 9.8%
Average number of types of entanglement 0.933 0.238 0.718 0.843 1.930 0.956
Other Forms of Support for Religion
Religious education is present in public schools 13.3% 54.8% 78.1% 74.5% 95.3% 70.5%
Presence of official prayer sessions in public schools 0.0% 16.7% 18.8% 17.6% 20.9% 16.9%
Public schools are segregated by religion or separate public schools exist 0.0% 7.1% 3.1% 11.8% 14.0% 8.7%
for members of some religions
The presence of religious symbols on the state’s flag 20.0% 4.8% 9.4% 13.7% 62.8% 23.0%
Religion listed on state identity cards or other government documents 13.3% 0.0% 6.3% 1.8% 30.2% 12.6%
Registration process for religious organizations which is different from the 93.3% 42.9% 68.8% 62.7% 53.5% 59.6%
registration process for other non-profit organizations
Burial is controlled or overseen by religious organizations or clergy 13.3% 0.0% 6.3% 3.9% 20.9% 8.2%
Blasphemy laws protecting minority religions or religious figures 0.0% 7.1% 18.8% 19.6% 37.2% 19.1%
Other religious prohibitions or practices that are mandatory 20.0% 9.5% 18.8% 27.5% 30.2% 21.9%
Average number of types of other support 1.733 1.486 2.281 2.431 3.651 2.404
At least one type pf support (all types) 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%
Average number of all types of support 5.400 5.357 8.969 10.098 21.116 11.016
The most common of the “other” types of support is religious education in public schools.
This policy is popular and becoming more common. In 1990, 114 (62.3%) countries had some
form of religious education in their public schools. By 2014, this had increased to 129 (70.5%).
This is not a policy that is unique to states which support religion or non-Western states. As
shown in Table 10.5, other than countries hostile to religion, a majority of states in every category
of official religion policy have religious education in at least some of their public schools, as do
all Western democracies other than the US and France. Thus, religious education in public schools
is the norm, not an exception.
This type of policy is a critical form of support. While private schools are an option in most
countries, most children are educated in public schools. In a large majority of these schools
worldwide, religion is taught in the same place children learn math, science, and history. Official
state policy is that children are taught religion, at the government’s expense, as part of their normal
curriculum. This is perhaps one of the most important avenues for exposing the next generation
to religion outside the family and religious institutions. It gives those religions which are taught
in the schools an aura of legitimacy, and can stigmatize children who belong to religions other
than those taught in public schools or those whose parents exempt them (when possible) from
religious education.
There is significant diversity in how religion is taught in public schools. There are three issues
that are of particular importance. First, are the classes mandatory? In 61 countries, these classes are
optional. Students who do not take these classes may have a free period or may be required to
take some other topic such as ethics, morals, philosophy, or culture. In 22 countries, the classes
are technically mandatory, but there is some formal process whereby students or their parents
can ask to opt out of the classes. In 23 countries, only some students have the option of opting
out. Usually this means the classes are in the majority religion and members of the majority reli-
gion must take these classes but members of other religions can request to opt out of the class.
In Greece, for example, classes in Orthodox Christianity are mandatory, but students of other
religions are exempt upon parental request. However, as there are no other activities at the time
of these classes, these minority students often have to stay in the classroom during these religion
classes. Finally, in 23 countries religion classes are mandatory and no one may opt out. With the
exceptions of Armenia, Laos, Namibia, Nicaragua, and Sri Lanka, all of these countries have Muslim
majorities.
The second issue is in what religion or religions are the classes? The implications of religion classes
in public schools differ depending on how many religions are taught. Whether the classes are
mandatory or optional, if some religions are taught but others for which there are a sufficient
number of students are not, this is a strong and potentially divisive form of support for religion.
In a manner that is very clear to students, the government is declaring which religions are “in”
and which religions are “out.” Only 37 countries which offer religious education in public schools
do so for all religions for which there are students. In most countries where there are such classes,
public schools offer them only in some religions (58) or only in one religion (34).
The final issue is who teaches the religion classes? In a majority of 89 countries the teachers are
hired in the same manner as teachers of other topics, but in 40 countries, they are clergy or appointed
by religious institutions. This is particularly common in Catholic-majority Western democracies.
In nine of the ten such states—Andorra, Austria, Belgium, Ireland, Italy, Liechtenstein,
Luxembourg, Portugal, and Spain, Catholic priests or someone else sent by the Church come to
the classrooms to teach Catholicism in public schools. The only exception is Malta. None of these
countries make the class mandatory with no way to opt out, and all of them except Malta offer
classes in at least some other religions.
! CONCLUSIONS
This chapter focuses on how governments deal with religion on a general level and the extent
and nature of government support for religion. While the devil is in the details, there are three
general concepts that are important to remember.
First, few governments are neutral with regard to religion. Most choose one or some religions
over others or are generally hostile to religion. Even the minority of countries with officially neutral
policies still effectively provide some support for religion.
Second, as shown in Tables 10.3, 10.4, and 10.5, support for religion is the norm. While the
motivations for this may vary, all countries support religion to at least some extent. Japan and
Uruguay engage in two types of support apiece and all other countries engage in at least three.
Third, as official government policy singles out a few or one religion for special treatment,
governments, on average, more strongly support religion. However, there are exceptions. For
example, Liechtenstein’s constitution declares the Catholic Church the state church but only engages
in three types of support: it restricts abortions, funds both Catholic and Protestant churches, and
has religious education in its public schools. Sudan, which has no official religion but clearly prefers
Islam, engages in 29 types of support. Turkmenistan which is hostile to religion still engages in
11 types of support, mostly in the context of its policy of supporting official religious institutions
in order to control Islam within its borders.
! DISCUSSION QUESTIONS
1. What would you say the official religion policy is in your country? Does it have any
policies which deviate from the principles of that official religion policy?
2. How do you think your country’s official religion policy influences religion in your
country?
3. How does your country support religion? Is this support exclusive to one religion or
do multiple religions enjoy this support?
4. What is your opinion on the level and types of support for religion in your country?
Do you think there should be changes in this policy and if so what changes?
! NOTES
1 BBC News, School Crucifixes Do Not Breach Human Rights, March 18, 2011. www.bbc.co.uk/news/
world-europe-12791082.
2 U.S State Department Report on International Religious Freedom, 2009; www.state.gov/j/drl/
rls/irf/2009/127287.htm.
3 A detailed description of Kuwait’s political system, Carnegie Institute Endowment for International Peace,
carnegieendowment.org/2010/07/29/kuwait/gca3; Trenwith, C. (10 July 2014) 19 people arrested
for eating in public on Ramadan, ArabianBusiness.com.
4 Spiegel (2015); “Morocco Dismantles Suspected Terror Cell” (June 20, 2010) AlArabiya.net;
“Morocco Prevents Religious Leaders from Participating in Politics” (July 3, 2014) Al-Arabiya.
http://english.alarabiya.net/en/News/middle-east/2014/07/03/Morocco-prevents-religious-leaders-
from-participating-in-politics.html.
5 Religion News Service, Ruling May Force Ireland to Revamp Catholic School Monopoly, by Jennifer Collins,
January 29, 2014. www.religionnews.com/2014/01/29/ruling-may-force-ireland-revamp-catholic-
school-monopoly/, US Department of State International Religious Freedom Report, 2013;
www.state.gov/j/drl/rls/irf/religiousfreedom/index.htm#wrapper.
6 Law 489/2006 on the Freedom of Religion and the General Status of Denominations, Published in
the Official Journal, Part I, issue #11/08 Jan. 2007.
7 Federal Law of Austria concerning the Legal Status of Religious Belief Communities viewed on
Religion and Law Research Consortium online: www.religlaw.org/common/document.view.
php?docId=427 (in German); http://host.uniroma3.it/progetti/cedir/cedir/Lex-doc/At_l-98.pdf (in
English).
International Coalition for Religious Freedom. Online: www.religiousfreedom.com/; United States
Department of State, International Religious Freedom Report for 2013 www.state.gov/j/drl/rls/irf/
religiousfreedom/index.htm#wrapper.
8 For a detailed discussion of these policies, see Fox (2015).
9 The Washington Post, “To Counter Rise Of Islamic State, Jordan Imposes Rules On Muslim Clerics,”
by William Booth and Taylor Luck, November 9, 2014; www.washingtonpost.com/world/
middle_east/to-counter-rise-of-the-islamic-state-jordan-imposes-rules-on-muslim-clerics/2014/
11/09/4d5fce22-5937-11e4-bd61-346aee66ba29_story.html; The Hashemite Kingdom of Jordan,
History of the Fatwa Department; http://aliftaa.jo/ShowContentEn.aspx?Id=74#.VsrlIX1961s.
! FURTHER READING
Fox, Jonathan Political Secularism, Religion, and the State: A Time Series Analysis of Worldwide Data, New
York, NY: Cambridge University Press, 2015. (Chapters 3 and 4)
Kühle, Lene “Concluding Remarks on Religion and State in the Nordic Countries” Nordic Journal of Religion
and Society, 24 (2), 2011, 205–213.
Minkenberg, Michael “Religion and Public Policy: Institutional, Cultural, and Political Impact on the
Shaping of Abortion Policies in Western Democracies” Comparative Political Studies, 35 (2), 2002,
221–247.
11 Government religion
policy 2: restrictions,
regulation, control and
discrimination
At the beginning of Chapter 10 I list four categories of government religion policy. Chapter 10
addresses the first two—the overall structure of religion policy or meta-religion policy, and how
governments support religion. This chapter focuses on how governments restrict religion. As I
note in Chapter 10, these policies fall into two major categories: policies which seek to regulate,
restrict, or control all religion in the country including the majority religion, and policies which
restrict only minority religions. This is a critical distinction. Policies which are quite similar can
have extremely different implications depending on whether the policy’s targets include the majority
religion or target only minority religions.
For example, what if a state restricts the building of places of worship? The implications are
different if this applies to all religions including the majority religion on one hand, and on the
other hand, if it applies only to minority religions. The former indicates a country that is hostile
to religion in general, and the latter indicates a country that supports or at least does not restrict
the majority religion but is hostile to at least some minority religions.
It is also important to emphasize that none of these policies are incompatible with supporting
religion. In fact, since all countries in the world support religion in at least some small way, all
states which engage in policies which restrict religion also support religion, some of them to a
considerable extent.
Restrictions placed on the public observance of religious practices such as publicly observing
a religious holiday demonstrates both of these principles. If this restriction only applies to religious
minorities in general or perhaps only to certain religious minorities, this does not indicate that
the government is anti-religion in general. This is demonstrated by the fact that this restriction
does not apply to the majority religion.
That support for religion is compatible with discrimination against religious minorities is not
surprising. States which have an official religion may wish to support this monopoly by restricting
other religions. Pakistan, which strongly supports Islam, the country’s official religion, restricts
the public expression of religion by its Ahmadi minority. While the Ahmadis consider themselves
Muslims, many Muslims, including those in power in Pakistan, consider the Ahmadis a heretical
sect. Because of this, Ahmadis in Pakistan may not call themselves Muslims, have inscriptions
from the Koran in their mosques or on their graves, or read the Koran in public, among many
other restrictions. Since 1983 they may not even hold conferences or gatherings. Malaysia, another
state where Islam is the official religion, has similarly arrested Ahmadis and Shia Muslims for
participating in festivals and prayer.
Why supporting majority religion is compatible with policies intended to control, restrict, or
regulate the majority religion is more complicated. As I note in Chapter 10, the very act of
supporting religion includes elements of control. In addition, the motivations for regulating,
controlling, and restricting religion, which I discuss in more detail below, are varied and complex,
but many of them are compatible with a desire to support the same religion or religions which
are controlled, restricted, or regulated.
Given all of this, in this chapter I address the treatment of minority religions and the treatment
of religion in general separately.
! REGULATION, RESTRICTION, AND CONTROL
Regulation, restriction, and control of religion in this context means that a government by law
or practice places some form of limitation on all religion in the country, and this specifically includes
the majority religion. In Chapter 10, I discuss the overlap between support and control, noting
that when a country supports a religion this inevitably involves an element of control. Thus, when
a country has a policy of supporting religion, the motivations may be mixed. This is not the case
with policies which control, regulate, or restrict religion. Although countries can engage in policies
of control while at the same time supporting religion, these policies are themselves a clear indication
of a desire to regulate, control, or restrict religion.
I identify three potential types of motivation for engaging in this type of policy. The first is
ideological. There are two basic types of ideological reasons for restricting, regulating, or
controlling religion. Some countries have national ideologies which are explicitly anti-religious.
Communism is likely among the most clear-cut example of an anti-religious ideology. Marx
considered religion a “false consciousness” which was used by rulers to distract workers from their
true interests. Other countries subscribe to secular ideologies which can play a similar role. France’s
secular ideology, which I discuss in more detail in Chapter 12, explicitly relegates religion to the
private sphere and is a less extreme type of anti-religious ideology. Other forms of secular ideology
simply hold that politics and religion should not mix. While secular ideologies remain common,
countries with officially anti-religious ideologies are becoming less common.
Second is a fear of religion’s political power. While, as Gill (2008) points out, religion can be
a useful tool for politicians, and for this reason political leaders often choose to support religion,
many politicians do not want to support religion in a manner that enables religious actors to compete
with them for political power. Gill comments, “While religion is often an ally in the pursuit of
power, once power has been secured, religion can become an unwelcome constraint in the quite
different processes of state administration.” Because of this, the regulation of religion is often “an
effort to coopt and nullify it as an independent power base” (Demerath and Straight, 1997: 44).
This is even more likely to occur if religious institutions are seen as supporting the opposition,
or if the opposition successfully finds another way to gain support from religion.
Third, religion is one of the creators of civic culture. Thriving democracies need a strong civil
society where citizens are interested in and participate in politics. Religious organizations are one
among many formats where this type of civil society can be built, sustained, and thrive. However,
autocratic governments, for precisely this reason, tend to restrict any elements of civil society that
are out of their control. This includes any religious organizations which are independent of the
state (Sarkissian, 2015).
I divide policies which restrict, control, and regulate religion into four categories based on
what is restricted:
1. The ability of religious institutions and clergy to participate in politics.

2. The ability of religious institutions to be autonomous from the government, to function, or
even to exist in matters other than politics.
3. The ability of individuals or groups to engage in basic religious practices, rites, and ceremonies.
4. Other types of restrictions which do not fit into the above three categories.
As I did in Chapter 10, I provide tables which show what percentage of states have each of the
29 specific types of control, regulation, and restriction of religion classified into these categories.
I also examine this controlling for the government’s official religion policy, dividing countries by
their meta-religion policy into the same five categories as I use on the discussion of religious
support in Chapter 10.
Restrictions on religion’s political role
! Policies which erect a barrier between religion and politics are common and are most likely
motivated by a fear of religion’s potential political influence. As shown in Table 11.1, 107 (58.5%)
countries have at least one of the five policies in this category. But only two, Vietnam and Myanmar,
both autocratic Asian states, have all five. While Myanmar’s 2008 Constitution recognizes the
“special position of Buddhism as the faith professed by the great majority of the citizens of the
Union,” it also severely restricts political activity by clergy. Like the earlier 1974 Constitution,
the 2008 Constitution prohibits members of religious orders from being elected to the House of
Representatives and from voting. It also specifies that freedom of religion does not include any
economic or other secular activity,1 which effectively bans any type of association other than one
that is specifically for religious activity from being associated with a religion. The government
only recognizes nine Buddhist monastic orders, which are under the authority of the State Monk
Coordination Committee. All others Buddhist orders are banned. Other laws prohibit members
of religious orders from joining political parties. Religious organizations are subject to censorship
and review by the Ministry of Religious Affairs.
These types of polices are also present in many states which strongly support religion. For
example, Algeria’s constitution declares Islam the official religion and also bans religious political
parties, though in practice the government allows moderate Islamic political parties to run in
elections. The government must approve all imams who lead prayers in mosques, monitors mosques
for militant activity or provocation of violence, screens sermons before they are delivered publicly,
and often provides approved sermon topics.
While these types of restrictions are most common in autocracies, there are also democracies
which engage in this type of practice. For example, Mexico has been traditionally an anti-clerical
state and historically has placed many restrictions on religion in general. While in 1992,
constitutional amendments eased some of these restrictions, limitations on the role of religion in
politics remain strong in Mexico’s constitution. The constitution clearly states that “ministers of
religion may not hold public offices.” Nor may they
join together for political purposes nor proselytize in favor of certain candidate, party or political
association or against them. Neither may they oppose the laws of the Nation or its institutions,
nor insult patriotic symbols in any form, in public meetings, in worship or in religious literature.
The formation of any kind of political group with a name containing any word or other
symbol related to any religion is strictly prohibited. No meeting of a political character may
be held in churches or temples.2
TABLE 11.1 PERCENTAGE OF COUNTRIES WHICH RESTRICT, REGULATE, AND CONTROL THE MAJORITY RELIGION, 2014

CASES
Restrictions on Religion’s Political Role
Restrictions: religious political parties 66.7% 40.5% 21.2% 39.2% 30.2% 36.6%
Restrictions: religious trade associations or other civil associations 13.3% 4.8% 3.1% 11.8% 2.3% 6.6%
Restrictions: clergy holding political office 60.0% 7.1% 6.2% 21.6% 9.7% 15.8%
Restrictions or monitoring of sermons by clergy for political content 66.7% 9.5% 12.5% 13.7% 58.1% 27.3%
Restrictions: clergy/religious organizations engaging in political speech 66.7% 23.8% 21.8% 29.4% 48.8% 34.4%
or propaganda or on political activity in or by religious institutions
Average number of restrictions on religion’s political role 2.733 0.857 0.656 1.157 1.488 1.208
Restrictions on Religious Institutions
Restrictions/harassment of majority religion members/organizations who 66.7.% 7.1% 15.6% 25.5% 48.8% 28.4%
are outside the state-sponsored/recognized ecclesiastical framework
Restrictions: formal religious organizations other than political parties 60.0% 4.8% 6.2% 13.7% 23.3% 16.4%
Restrictions: access to places of worship 60.0% 2.4% 31.% 9.8% 14.0% 10.4%
Foreign religious organizations must have a local sponsor or affiliation 6.7% 9.5% 6.2% 9.8% 9.3% 8.7%
Heads of religious organizations (e.g. bishops) must be citizens of the state 20.0% 0.0% 12.5% 17.6% 2.3% 9.3%
All practicing clergy must be citizens of the state 26.7% 0.0% 0.0% 5.9% 0.0% 3.8%
The government appoints clergy or approves/influences clerical appointments 73.3% 0.0% 12.5% 21.6% 61.5% 28.4%
Other than appointments, the government legislates/influences internal 40.0% 0.0% 3.1% 19.6% 51.2% 21.3%
aspects of religious institutions/organizations
Laws governing the state religion are passed by the government or require 26.7% 0.0% 0.0% 5.9% 39.5% 13.1%
the government’s approval
Average number of restrictions on religious institutions 3.600 0.238 0.594 1.294 2.488 1.399
In the case of Myanmar and Algeria, the restrictions on religion and politics are likely motivated
by a fear of religion’s political power. Algeria’s government also likely wants to prevent a recur-
rence of the religiously motivated and extremely violent civil war that occurred in the 1990s. In
a sense this is also true of Mexico since the origins of its anti-clerical ideology came from similar
motivations, along with the belief that the Catholic Church was hindering social and economic
progress. But it has since developed into a secularist ideology independent of this original
motivation.
For a listing of the rest of the types of regulation, control, and restrictions in this category, see
Table 11.1.
Restrictions on religious institutions

! Policies restricting, regulating, and controlling religious institutions are those that limit religious
institutions in a manner beyond just restricting their ability to engage in politics. Rather these
policies somehow limit the institution itself or its ability to act autonomously, even in matters
having nothing to do with politics. As I discuss in more detail in Chapter 6, religious institutions
are of critical importance to maintaining a religion’s theology and continuity over time so this
type of restriction can be a very serious one.
This type of policy is common and is found in a slight majority of 97 (53.0%) countries. Not
surprisingly, it is particularly common in the countries that are most hostile to religion (93.7%).
It is least common in countries with neutral polices, and as countries become more supportive
of religion, this type of policy becomes more common. This is further evidence that supporting
religion and controlling it are intimately intertwined.
Among the seven policies in this category listed in Table 11.1, the policy of appointing clergy
or somehow taking part in the appointment process is the most common, and illustrative of this
dynamic. For example, China’s State Administration for Religious Affairs controls the appointment
of clergy in all five recognized religions in China, even Catholic bishops. Similarly, the governments
of Azerbaijan, Tajikistan, Turkmenistan, and Uzbekistan, all former-Soviet Muslim-majority
countries with policies which are hostile to religion, appoint all imams in mosques in their countries.
In these countries the clear goal of this policy is to keep religion in check by controlling who
will be its leaders. This can be an effective tactic to prevent a religious institution from becoming
an independent political actor.
Yet countries which strongly support religion also take part in appointing clergy. For example,
Greece declares the Greek Orthodox Church its official religion and Greece’s president officially
appoints all bishops of the Church, though usually those suggested by the Church hierarchy are
appointed. The government similarly appoints the muftis—Islamic leaders—in the city of Thrace.
Greece’s government also has the power to modify the Church’s charter and suspend noncompliant
synods (church councils). Many Middle Eastern countries where Islam is the official religion,
including Algeria, Egypt, Gaza, Jordan, the Palestinian Authority, and Tunisia, also appoint all
imams. Thus, even countries which strongly support religion, also seek to control its institutions.
However, these religious institutions benefit from a monopoly within their religion in return, as
all of these countries restrict Islamic organizations outside state control. Egypt, for example, allows
private mosques, but essentially places them under the same type of control as the government-
supported mosques.
For a listing of the rest of the types of regulation, control, and restrictions in this category, see
Table 11.1.
Restrictions on religious practices

! Restrictions on the religious practices which are placed on all religions, including the majority
religion, is the least common form of regulation, restriction, and control. Perhaps this is because
restricting the practice of a religion is not an efficient measure for controlling religion. As shown
in Table 11.2, the seven policies in this category are present in only 64 (35.0%) countries. While
these polices can be found in countries which support religion, they are most common in countries
which are hostile to religion.
With the exception of the persecution of conscientious objectors, the Muslim-majority former
Soviet republic of Uzbekistan engages in all of these types of policy. Any Islamic religious activity
that takes place outside of the state-approved religious framework can lead to arrest on the grounds
of religious extremism. Muslims who pray in unregistered mosques, study Islam with private
teachers, or who are followers of imams who fall out of favor with the government can be jailed
on charges of religious extremism. Family members of “extremist” group members are also often
imprisoned without evidence or due process. The government enforces restrictions against many
expressions of Islamic faith. For instance, the Uzbek police often arbitrarily forces men who wear
beards to shave against their will. Until 2012, there were reports of female students being
punished and sent home from school for wearing hijabs. While the government does not officially
ban children from attending mosque, officials frequently pressure parents and religious communities
not to allow them to attend and school-aged boys who attend mosques risk expulsion from school.
The government similarly discourages traditional Muslim weddings. There are strict restrictions
on Ramadan, including bans on traditional meals which break the fast. Only seven government-
controlled or registered religious organizations may publish or import religious literature (an
interdenominational Bible Society, the Muslim Board of Uzbekistan, two Islamic centers, and
organizations representing the Russian Orthodox, Full Gospel, Baptist, and Roman Catholic faiths).
While Uzbekistan is an extreme example, it is illustrative of the nature of the countries which
significantly ban religious practices. These countries, which include Azerbaijan, Tajikistan,
Turkmenistan, Uzbekistan, China, North Korea, and Vietnam are all countries which are hostile
to religion in general. Most countries with neutral or positive attitudes toward religion tend to
engage in few if any of these restrictions. Thus, the motivation for this type of policy is likely
more extreme than a simple desire to counter religion’s power. Rather, it is more often motivated
by hostility to the concept of religion itself.
For a listing of the rest of the types of regulation, control, and restrictions in this category see
Table 11.2.
Other types of regulation, restriction, and control
! This category is for all types of regulation, restriction, and control that do not fit into the other
categories. They are listed in Table 11.2. Three of the categories measure government control
over religious education. In total, 67 (36.6%) countries control the content of religious education
in public schools or other forums. As I discuss in more detail in Chapter 10, in these countries
the government in some manner controls the content of religious education in the country and,
in some cases the teachers themselves.
Another common form of control is state ownership of religious property. In these 51 (27.8%)
countries, the government owns some or all of the religious property in the country. To be clear,
this does not mean religious property such as national monuments or chapels in government
TABLE 11.2 PERCENTAGE OF COUNTRIES WHICH RESTRICT, REGULATE, AND CONTROL THE MAJORITY RELIGION, 2014

CASES
Restrictions on Religious Practices

Restrictions: public observance of religious practices/holidays/Sabbath 66.7% 4.8% 6.2% 13.7% 4.7% 12.6%
Restrictions: religious activities outside of recognized religious facilities 73.3% 14.3% 6.2% 13.7% 9.3% 16.4%
Restrictions: the publication or dissemination of written religious material 73.3% 2.4% 3.1% 9.8% 9.3% 12.0%
People are arrested for religious activities 46.7% 0.0% 0.0% 0.0% 0.0% 3.8%
Restrictions: religious public gatherings that are not placed on other types 40.0% 2.4% 3.1% 3.9% 2.3% 6.0%
of public gathering
Restrictions: the public display of religious symbols 60.0% 0.0% 9.4% 7.8% 11.6% 11.5%
Conscientious objectors to military service are not allowed alternative 33.3% 4.8% 0.0% 11.8% 11.6% 9.8%
service and are prosecuted
Average number of restrictions on religious practices 3.933 0.286 0.281 0.608 0.488 0.721
Other Regulation, Restriction, or Control of Religion
Arrest/detention/harassment of religious figures/officials/party members 66.7% 0.0% 3.1% 11.8% 23.3% 14.8%
Restrictions: public religious speech 54.4% 4.8% 6.2% 5.9% 7.0% 9.8%
Restrictions: religious-based hate speech 46.7% 38.1% 68.7% 52.9% 58.1% 53.0%
Control/influence over religious education in public schools 0.0% 11.9% 21.9% 17.6% 65.1% 26.8%
Control/influence over religious education outside of public schools 60.0% 4.8% 12.5% 21.6% 39.5% 23.5%
Control/influence over religious education in universities 46.7% 0.0% 0.0% 5.9% 16.3% 9.3%
State ownership of some religious property or buildings 33.3% 9.5% 18.7% 25.5% 48.8% 27.8%
Other forms of regulation, restrictions or control 90.3% 21.4% 43.7% 44.1% 46.5% 43.7%
Average number of other types of regulation, restriction, or control 4.000 0.905 1.750 1.863 3.047 2.077
At least one type of regulation, restriction, or control 100.0% 88.1% 96.9% 94.1% 97.7% 94.5%
Mean level number of types of regulation, restriction, or control 14.267 2.286 3.281 4.921 7.512 5.404
buildings or military bases but religious places of worship that are intended for general use by
citizens. This is particularly common in conservative Muslim states such as Brunei, the Maldives,
and Saudi Arabia. In these cases, the countries support these institutions, but also clearly seek to
control them. However, this type of policy is also present in other types of states. As noted in
Chapter 10, Mexico and France’s governments own all religious property in their countries built
before a certain date, based on historical anti-clerical laws passed in the context of establishing a
secularist official religion policy. Also many former communist countries including Latvia,
Macedonia, and the Ukraine still own many religious buildings which were seized during
communist rule. The original seizures were clearly a form of control as well as motivated by a
secularist ideology, but the failure to return all of these buildings to the appropriate religious
organizations once these policies had changed is often a matter of historical inertia.
For a listing of the rest of the types of regulation, control, and restrictions in this category see
Table 11.2.
Regulation, restriction, and control in comparative perspective
! Overall, all but ten countries engage in at least one form of regulation, restriction, and control
of religion and these countries—Andorra, Argentina, the Dominican Republic, Italy, Japan,
Namibia, the Solomon Islands, South Africa, and South Sudan—are not exactly the list many
would expect. All of them other than Japan are Christian-majority and all of them other than
Cameroon have no official religion. However, only two of them are Western democracies.
This demonstrates that regulating, restricting, and controlling religion is the norm for all categories
of countries. As I discuss in more detail in Chapter 10, all countries support religion in at least
some small way, and supporting religion is inextricably intertwined with controlling religion. The
extent of policies which control, regulate, and restrict religion, combined with the ubiquity of
government support for religion, is further evidence of this complex relationship between support
and control.
! RELIGIOUS DISCRIMINATION IN THEORY
While, as I discuss in Chapter 13, terms like “religious discrimination” and “religious freedom”
are contested and have multiple meanings, for the purposes of this discussion I define religious
discrimination as restrictions placed by the government on the religious practices or institutions
of minority religions that are not placed on the majority religion. This focus on minorities
distinguishes it from the policies discussed in the previous section of this chapter, which focus on
restrictions placed on all religions including the majority religion. It also restricts the discussion
to types of discrimination related directly to religion.
Why do states discriminate against religious minorities?

! There are multiple potential motivations for a government policy of religious discrimination and
it is often far easier to recognize discrimination than to identify the motivation behind that
discrimination. While this list is by no mean exhaustive, as there are many context-specific and
idiosyncratic reasons to discriminate, I identify 14 common reasons for governments to discriminate
against religious minorities. While there is some overlap between the categories, each is a
motivation which is somehow distinct and different from the others.
Belief and ideology is perhaps the most obvious explanation. Religions by their nature believe
that they have exclusive access to universal truths and are intolerant of competing truths: “Those
who believe there is only One True God are offended by the worship towards other Gods” (Stark,
2003: 32). Thus, exclusive religious beliefs are not compatible with tolerance toward other religions,
and governments which are associated with a specific religion are, for this reason, likely to restrict
religious minorities.
Religious monopolies: As I discuss in more detail in Chapter 7, rational choice theorists also examine
the motivations of religious actors to engage in various policies, but focus less on ideology and
more on power politics and how religious organizations maintain a religious monopoly. While
this motivation does not rule out ideological motivations it focuses more on institutional power
and how religions try and dominate the religious market. Put differently, this type of explanation
focuses on the mechanics of competition between religious institutions for resources and
congregants, and does not directly address what motivates these institutions to engage in this
competition. To the extent that motivations are addressed, the focus is on the desire for institutional
hegemony rather than ideological hegemony or, in other words, the focus is on material concerns
rather than spiritual ones.
Human rights and liberal values: As I discuss in more detail in Chapters 12 and 13, the belief in
the universality of human rights and other liberal values have been described as a religion. It is
certainly a universal value system that can compete and clash with religion (Freeman, 2004). Many
religions, and most often minority religions, are seen as supporting activities and values incompatible
with this value system. This can result in restrictions targeted at stopping these “unacceptable”
practices or, in some cases, targeting the minority religion itself as a consequence of these
practices. In these cases, the majority religion is seen as compatible, or at least as more compatible,
with liberal values such as religious freedom and women’s rights than the minority religion in
question. Essentially this is an ideological explanation similar to the religious belief and ideology
explanation, but it focuses on secular rather than religious beliefs as motivating discrimination.
Nationalism and protection of culture: Many countries have policies intended to protect their
indigenous culture, and this culture includes religion. Nationalist ideologies tend to support the
idea that a country belongs to that country’s nation and no other. While nations can include more
than one religion, there are always those that are considered historically part of the nation and
those that are new and non-indigenous. Finke (2013: 303) argues similarly that “many national
and cultural identities are so closely interwoven with or against selected religions that ensuring
religious freedoms for all is perceived as challenging the cultural identity as a whole.” As noted
in Chapter 10, Austria has a policy of preferring religions which have a long history in the country.
This is also true of several former Soviet bloc countries including Hungary, Latvia, and Lithuania,
which officially designate certain indigenous religions as traditional or historical religions, and are
more likely to restrict religions considered small and new to the country.
Anti-cult policies: Many countries monitor and restrict cults. There is no agreed-upon definition
of a cult, but many definitions include the groups’ small size, newness, dangerous or violent practices,
and that they are led by a charismatic leader (Appleby, 2000; Grim and Finke, 2011: 47–48). In
practice, countries which designate groups as cults tend to follow Thomas’s (2001: 529) definition:
“There is . . . [an] informally defined universe of religions and spiritualties. Those which fall outside
of this universe are stigmatized as cults.” This kind of law is becoming more common, even in
European countries such as Belgium and France, both of which maintain a list of cults which
mostly consists of religious groups that are small (though they may be large in other countries)
and new to the country.
Objectionable practices: While this motivation of religious discrimination overlaps with each of
the above motivations it deserves separate consideration. When a religious minority engages in a
practice that is considered objectionable by the majority, this can attract discrimination. The practice
can be considered objectionable because it violates the state’s secular or religious ideology, or it
can violate some other cultural, political, or social norm. For example, in militantly secular countries
such as France wearing the traditional Muslim headcovering for women or modest bathing suits
such as the “burkini” can be considered an objectionable practice, while in conservative Muslim
countries such as Saudi Arabia, refusal to wear such garb is considered objectionable.
Conflict: Religion often overlaps with ethnicity in that ethnic minorities are also often religious
minorities. Discrimination against ethnic minorities is common in the context of ethnic conflict
(Gurr, 1993; Horowitz, 1985). Accordingly, ethno-religious minorities which are engaged in conflict
with the state are likely to be targets for religious discrimination.
Perceived security threats: It is clear why governments will take actions that are meant to counter
a perceived security threat. If a religious minority included members who posed such a threat
because they supported a foreign enemy or engaged in terrorism, for example, it is understandable
why a government would enact or activate policies to neutralize the threat. However, it is not
clear why this would lead to religious discrimination. With perhaps the exception of restricting
religious institutions that are actively engaged in the threatening behavior, restricting religious
practices and institutions is unlikely to increase security but likely to anger the minority and increase
the likelihood that they’d oppose the state.
Securitization theory posits that when an issue or group, such as a religious minority, is perceived
as a security threat is becomes “securitized” (Laustsen and Waever, 2000; Mabee, 2007). When
this happens, extraordinary policies that are usually considered outside the pale can become
legitimized. While this can include policies directly related to increasing security, such as police
activities, surveillance, anti-immigration measures, and detention, it can also include religious
discrimination. This is because the hysteria surrounding the securitized minority can reach levels
where even irrational policies that in no way increase security can be justified (Cesari, 2009).
Political reasons: Religious minorities are often perceived as a political threat that is not strictly
a security threat. For example, when a religious minority grows in size this can be accompanied
by increasing political clout, which can be seen as a threat to the political power and prerogatives
of the religious majority (Grim and Finke, 2011: 46).
History: Religious conflict is often long-lasting to the extent where no one alive today
remembers a time when there was no conflict. In cases like these, the historical cycle of violence
and enmity can motivate discrimination. Also, on a more general level, one of the best predictors
of discrimination that occurs today is whether it occurred in the past.
Instrumentalism and mobilization: As I discuss in more detail in Chapter 6, religion, especially
religious institutions, can be the basis for political mobilization. However, religious institutions
are not the only entities capable of using religion to mobilize people for political action. Politicians
can also “activate” religion in this manner. Politicians can see using religious ideology and identity
as a useful path to power, or see scapegoating religious minorities as a useful way to assign or
deflect blame for political, economic, and social problems.
Societal attitudes: Prejudice against minorities of all kind including religious minorities is present
in most countries. These societal attitudes can easily translate into government policy (Grim and
Finke, 2011).
Religious identity: As I discuss in Chapter 3, many argue that certain religions tend to be more
violent than others. While this theory is contested and problematic, to the extent that it is true
these arguments can also apply to religious discrimination.
General causes of discrimination: While this discussion has thus far touched upon many political
motivations for discrimination which can be more widely applicable, all of the motivations for
religious discrimination discussed thus far are specific to religion or discussed in the specific context
of religious discrimination. Yet the political science literature includes a wide discussion of causes
of discrimination against minorities in general, much of which is applicable to religious
discrimination which focuses on religious minorities. For example, non-democracies discriminate
more than democracies, often in order to prevent any form of civil society which can oppose the
government to form. This applies to religious minorities (Sarkissian, 2015).
All of these potential motivations for discrimination are complex. Most cases of discrimination
are the result of multiple motivations from this list as well as motivations that may be unique to
the case at hand. To make matters more complicated, it is often difficult to discern all of these
motives. However, identifying the discrimination itself is far more straightforward. The next section
of this chapter discusses how governments restrict religious minorities and the extent to which
these policies are common.
! RELIGIOUS DISCRIMINATION IN PRACTICE
Of the 183 countries in the RAS dataset, 162 (88.5%) engage in religious discrimination—defined
as restrictions placed on the religious practices or institutions of at least one religious minority
within its borders, that are not placed on the majority religion. I divide the 36 types of
discrimination into four categories:
1. The ability of individuals or groups to engage in basic religious practices, rites, and ceremonies.
2. The ability of religious institutions and clergy to be autonomous from the government, to
function or even to exist in matters other than politics.
3. Restrictions on conversion to a minority religion and proselytizing by members of minority
religions.
4. Other restrictions which do not fit into the above categories.
As I did in Chapter 10 and for the discussion of regulation of the majority religion earlier in this
chapter, I provide tables which show what percentage of states have each of the 36 specific types
of religious discrimination classified into these categories. I also examine this controlling for the
government’s official religion policy, dividing countries by their meta-religion policy into the
same five categories as I use on the discussion of religious support in Chapter 10.
Restrictions on religious practices
! There are few elements of religion more basic and essential than practicing that religion. Yet
restrictions on the right to practice religion by minority religions are common. At least one of
the 12 types of policies restricting religious practices of minority religions that are not placed on
the majority religion listed in Table 11.3 is present in 110 (60.1%) countries. This is far more
common than restrictions on the religious practices of all religions which, as noted above, occurs
in 64 (35.0%) countries.
TABLE 11.3 PERCENTAGE OF COUNTRIES WHICH DISCRIMINATE AGAINST MINORITY RELIGIONS, 2014

CASES
Restrictions on Religious Practices
Restrictions: public observance of religious practices/holidays/Sabbath 73.3% 11.9% 18.7% 29.4% 55.8% 33.3%
Restrictions: private observance of religious practices/holidays/Sabbath 53.3% 4.8% 15.6% 15.6% 15.7% 18.0%
Forced observance of religious laws of another group 20.0% 3.8% 12.5% 17.6% 41.8% 19.7%
Restrictions: materials necessary for religious rites/customs/ceremonies 40.0% 0.0% 0.0% 7.8% 7.0% 7.1%
Restrictions: circumcisions or other rite of passage ceremonies 0.0% 0.0% 3.1% 0.0% 0.0% 0.5%
Restrictions: observing dietary laws / access to religiously appropriate food 0.0% 0.0% 6.2% 2.0% 14.0% 4.9%
Restrictions: the ability to write/publish/disseminate religious publications 66.7% 4.8% 12.5% 21.6% 48.8% 26.2%
Restrictions: the ability to import religious publications 60.0% 2.4% 6.2% 13.7% 46.5% 21.3%
Restrictions: access to religious publications for personal use 33.3% 0.0% 3.1% 7.8% 34.9% 13.7%
Restrictions: the observance of religious laws concerning marriage and divorce 13.3% 0.0% 3.1% 7.8% 34.9% 12.0%
Restrictions: the observance of religious laws concerning burial 40.0% 7.1% 15.6% 17.6% 34.9% 20.8%
Restrictions: the wearing of religious symbols or clothing 26.7% 9.5% 18.7% 15.7% 20.9% 16.9%
Average number of restrictions on religious practices 4.267 0.452 1.156 1.588 3.628 1.951
Restrictions on Religious Institutions and the Clergy
Restrictions: building, leasing, repairing/maintaining places of worship 73.3% 16.7% 59.4% 52.9% 72.1% 51.9%
Restrictions: access to existing places of worship 46.7% 3.4% 31.2% 49.0% 39.5% 32.8%
Restrictions: formal religious organizations 60.0% 16.7% 28.1% 27.5% 27.9% 27.9%
Restrictions: the ordination of and/or access to clergy 46.7% 2.4% 15.6% 17.6% 27.9% 18.6%
Minority religions must register to be legal or receive special tax status 60.0% 7.1% 46.9% 64.7% 51.2% 44.8%
Restricted access of minority clergy to jails 26.7% 7.1% 25.0% 33.3% 16.3% 21.3%
Restricted access of minority clergy to military bases 6.7% 2.4% 21.9% 43.1% 30.2% 24.0%
Restricted access of minority clergy to hospitals & other public facilities 6.7% 0.0% 28.1% 27.4% 9.3% 15.3%
The most common type of discrimination in this category is restrictions on the public
observance of religious practices, a type of restriction which can be found in 61 (33.3%) countries,
exactly one-third of the countries in the RAS study. This type of restriction is particularly important
because one of the most basic elements of religion involves practicing one’s religion in public
without fear of sanction or reprisal.
Restrictions on public religious practices can include severe restrictions, such as in Saudi Arabia
where any public religious expression other than that of the state-supported version of Sunni Islam
is banned. In Qatar, unregistered groups such as Hindus, Buddhists, and Bahai may only worship
privately in their homes, registered Christian groups may only worship in government-approved
areas. The restrictions can also be more limited. For instance, in Greece modern pagans—a group
seeking to revive the worship of the Greek Gods—are not allowed to worship in many of the
country’s ancient temples.3 Similarly, a number of African countries, such as Kenya and Zimbabwe,
ban practices associated with witchcraft.
Some religious practices are also banned in private as well as in public by 33 countries (18.0%).
For example, Belarus’s 2002 Law on Freedom of Conscience and Religious Organizations
prohibits religious observance for unregistered groups, both in public and in private. Kazakhstan
similarly prohibits worship, even in private homes by unregistered groups, and actively raids homes
where such illegal worship is suspected to take place. Both of these countries refuse registration
to a substantial number of minority religious organizations.
Restrictions on religious publications are another important form of restriction. Most religions
depend upon the availability of religious texts such as the Bible and Koran for basic religious
worship and practice. Religious publications are restricted in some manner by 53 (29.0%)
countries. This includes 48 (26.2%) which restrict the ability to write, publish, and disseminate
religious publications, 39 (21.3%) which restrict their importation, and 25 (16.9%) which restrict
them even for personal use. This practice is most common among Muslim-majority states, 31 of
which engage in at least one of these practices. Among Muslim-majority states, the banning of
the publication of religious publications is harshest in the Persian Gulf, with Kuwait, Oman, Qatar,
and Saudi Arabia banning it altogether, and with all of the other states other than Bahrain placing
some restrictions on importing minority religious texts. For example, in Kuwait, non-Islamic
publishing companies are forbidden. Only one company, The Book House Company Ltd., is
permitted to import Christian religious materials into the country, including Bibles, videos and
CDS, for use by the country’s recognized churches. All imported material requires approval by
government censors. Occasionally, customs officials confiscate non-Islamic religious material
from private citizens upon their arrival.
Outside of the Gulf, only Comoros, Mauritania, and the Maldives place a near-total ban on
publishing non-Muslim religious materials. In the Maldives, religious minorities are also forbidden
from importing any non-Muslim religious materials, including symbols, statues, and publications.
Prohibited materials are taken and destroyed, usually by customs officials. However, non-Muslims
are allowed to bring personal copies of religious books into the country for personal use only.
Malaysia limits the use of certain words which are considered under the sole jurisdiction of
Islam in non-Islamic publications. While this is enforced sporadically, use of words such as Allah
(God), Baitullah (House of God), Solat (prayer), al-Kitab (Bible or Koran), wayhu (revelation), and
doa (prayer) can result in the banning of a non-Muslim religious publication (Harding, 2002;
Martinez, 2001; Yousif, 2004). In Morocco, there is no official law banning non-Muslim religious
literature; however, importing and displaying Bibles in French, English, and Spanish is generally
tolerated while Arabic versions are not.
Most countries which restrict the importation of religious publications are among those that
ban publication, though the restrictions on importation are sometimes less strict, as is the case
with Kuwait. Bans on religious publications for personal use—which usually involves individuals
bringing items such as a Bible with them as they enter the country are rarer. In most cases, this
is arbitrary behavior by customs or law enforcement officials who sometimes confiscate these
materials and sometimes do not. For example, the official policy in Saudi Arabia is that non-
Muslim foreign workers are allowed to bring in personal religious materials and to worship privately
in their homes. However, as noted above, there are multiple cases of religious police breaking
up such meetings and confiscating personal religious materials.
For a listing of the rest of the types of religious discrimination in this category, see Table 11.3.
Restrictions on religious institutions and the clergy

! Religious institutions and clergy are essential to most religions. While there are rare instances of
religions lacking either institutions or clergy, no significant religion of which I am aware lack
both. For instance, the Society of Friends (Quakers) have institutions but no clergy. Many animist
religions have clergy but no official institutions. As I discuss in Chapter 6, institutions and clergy
are essential to the practice of religion, its continuity, and passing the religion on from one generation
to the next, so restrictions of this sort are significant. As shown in Table 11.3, 123 (75.9%) countries
engage in at least one of the eight types of discrimination in this category.
The most common form of restriction is limitations placed upon the building, leasing,
maintaining, or repairing of places of worship which is present in 95 (51.9%) countries. This is a
very serious restriction because institutions of any sort, especially those intended to provide a place
for people to meet and engage in communal activities, require a physical location. There are a
wide variety of policies which limit places of worship.
On one end of the spectrum, these limitations can be severe. In Comoros, Somalia, Saudi
Arabia, and the Maldives, all Muslim-majority countries, all minority places of worship are effectively
banned. In other countries like Morocco and the Sudan, existing minority places of worship are
allowed but no new ones are permitted. In most other countries where this type of restriction
applies, at least some minorities may establish places of worship, though there may be some
difficulties in doing so.
The two most common types of difficulties are registration and permits. Many countries require
religious organizations to register before they may own or rent places of worship, but this only
becomes a form of discrimination when registration is denied. In Mongolia, for example, local
governments deny registration to minority religions for the specific purpose of restricting the number
of minority places of worship, particularly Christian churches. Hungary’s 2011 Religion Act changed
the criteria for registration and, as a result, numerous minority religious institutions were de-
registered. As a result of this, some of these organizations had property liquidated, rental leases
terminated, were forced to shut down schools they had been operating, and had to close down
charitable programs or other ministry activities they had been running.4
In most jurisdictions permits from local and sometimes national governments are required to
build or repair any structure. This allows local government to effectively restrict minority places
of worship on the pretense that they for some reason do not qualify for such a permit by delaying
these permits or by in some other manner making them difficult to obtain. This practice is found
in many Western democracies, particularly against mosques and places of worship for groups
who are considered cults. This includes Andorra, Australia, Austria, Belgium, Cyprus, Denmark,
France, Germany, Greece, Iceland, Italy, Malta, Spain, and the United States.
The following description of a blocked attempt to build a mosque in New Jersey is a typical
example:
They thought they had found the perfect place to build the first mosque and Islamic
community center in this city’s history: an empty 8,500-square-foot warehouse at the end
of a dead-end block, with room on its lot for 37 parking spots. But since paying $1 million
for the property in 2015, Waheed Akbar and his nonprofit group, Bayonne Muslims, have
faced an angry campaign by local residents, graffiti slurs outside their temporary prayer hall
and numerous zoning and planning hurdles. What seemed to be a possible end of the line
for the mosque came on Monday night, when after a heated, six-hour-long meeting at Bayonne
High School, the city’s zoning board did not approve the idea . . . The case is the latest of
many nationwide in which a local municipality has blocked the construction of a mosque
or Islamic school, ostensibly because of traffic, parking or zoning concerns. When federal
investigators have looked deeper into these cases, however, they have often discovered evidence
of discrimination.5
Another significant type of limitation is the limitation of clergy access to the military, hospitals,
and prisons. Religious individuals desire and often require clergy for spiritual guidance and for
the performance of essential religious rites and ceremonies. Limiting access to clergy in publicly
controlled institutions in which many people find themselves is, accordingly, a substantial burden.
In this manner, 54 (29.5%) countries restrict minority clergy, including 29 (21.3%) which restrict
access to jails, 44 (24.0%) which limit access to military bases, and 28 (15.3%) which limit access
to hospitals. For instance in Russia, the Russian Orthodox Church is given preferred access to
public institutions such as schools, hospitals, prisons, police, and the military forces. Nearly all
religious facilities in prisons are Russian Orthodox. Under an executive order, Muslims, Jews, or
Buddhists must make up 10 percent of a military unit before an official chaplain of that religion
can be appointed, and even when this requirement is met, chaplains are sometimes denied. In
Portugal, only Catholic priests are available full time in hospitals, prisons, and military bases.
Members of other religions must request special visits from their clergy. Registration can also be
an issue for clergy access. For instance, in Germany, only clergy from registered religions are given
access to the military, prison, and hospitals.
Restrictions on conversion and proselytizing

! Most religions, though not all of them, seek converts. These activities can be threatening to a
regime. Regimes which are generally hostile to religion do not like efforts to spread religion within
their borders. Also, on a more general level, the goal of a missionary is to convince people who
belong to other religions or no religion at all to join their religion. Religious communities usually
resent efforts to “poach” their members in this manner. In addition to this ideological motivation,
efforts to convert members of a country’s majority religion to another religion can be seen by a
government as an effort to alter the country’s demographics and undermine its indigenous culture.
Accordingly, it is not surprising that, as shown in Table 11.4, 122 (66.7%) countries restrict
proselytizing or conversion away from the majority religion in some manner.
TABLE 11.4 PERCENTAGE OF COUNTRIES WHICH DISCRIMINATE AGAINST MINORITY RELIGIONS, 2014

CASES
Restrictions on Conversion and Proselytizing

Restrictions: conversion to minority religions 143% 0.0% 0.0% 6.9% 53.5% 15.3%
Forced renunciation of faith by recent converts to minority religions 33.3% 0.0% 0.0% 3.9% 18.6% 8.2%
Forced conversions of people who were never members of majority religion 13.3% 0.0% 3.1% 6.9% 14.0% 6.6%
Efforts or campaigns to convert members of minority religion to the 40.0% 0.0% 3.1% 11.8% 27.9% 13.7%
majority religion which do not use force
Restrictions: proselytizing by legal residents to members of majority religion 73.3% 4.8% 15.6% 29.4% 67.4% 33.9%
Restrictions: proselytizing by legal residents to members of minority religion 60.0% 7.1% 12.5% 21.6% 27.9% 21.3%
Restrictions: proselytizing by foreign clergy or missionaries 86.7% 11.9% 34.4% 54.9% 72.1% 48.1%
Average number of restrictions on conversion and proselytizing 3.200 0.238 0.719 1.333 2.814 1.475
Other Restrictions
Restrictions: running religious schools and/or religious education in general 53.3% 3.4% 21.9% 23.4% 32.6% 33.0%
Mandatory education in the majority religion 13.3% 9.5% 3.1% 23.5% 60.5% 24.6%
Arrest/detention/harassment of religious figures/officials/party members 93.3% 7.1% 28.1% 29.4% 53.5% 35.0%
for activities other than proselytizing
Severe and willful failure to protect religious minorities against violence 6.7% 4.8% 12.5% 31.4% 32.6% 20.2%
or punish the perpetrators
State surveillance of minority religious activities 53.3% 14.3% 31.2% 31.4% 30.2% 29.0%
Custody of children granted to majority religion members on basis of religion 0.0% 2.4% 6.2% 7.8% 48.8% 14.3%
Declaration of some minority religions dangerous or extremist cults/sects 46.7% 71% 31.2% 25.5% 14.0% 21.3%
Anti-religious propaganda in (semi)official government publications 53.3% 2.4% 19.7% 27.5% 48.8% 27.3%
Restrictions: other types of observance of religious law 73.3% 23.8% 34.4% 31.4% 30.2% 33.3%
At least one type of restriction on minorities 93.3% 64.3% 90.6% 98.0% 97.7% 88.5%
Mean number of types of restrictions on minorities 14.667 1.976 6.281 8.392 12.670 8.077
The most common form of restriction is on foreign missionaries with 88 (48.1%) countries
restricting them in some manner. This practice is common across all types of states, including
32.6% of Christians-majority states, 70.0% of Muslim-majority states and 65.5% of other states.
For example, Denmark’s 2004 “Imam Law” mandates that all foreign religious workers obtain a
“religious residence” visa. In addition, these religious workers must be associated with a recognized
religion, be able to prove they have the qualifications for religious work, and be self-financing.
The law also limits the number of such visas based on the group’s population, and allows the
government to deny a visa if it feels that the applicant might be a threat to public security, safety,
health, decency, or order. This use of visas to limit foreign missionaries is common and can be
found in other European countries, including Austria, Belgium, France, Germany, Greece,
Ireland, Italy, Switzerland, and the UK.
Restrictions on conversion away from the majority religion are most common in Muslim-
majority countries, with 25 (49.0%) of these countries restricting conversion away from Islam as
opposed to no Christian-majority countries and three (10.3%) other countries. A 2007 Cambodian
directive specifically prohibits Christians from conducting door-to-door proselytizing and from
using financial incentives to encourage conversion. This does not apply to Buddhists, the country’s
majority religion. Six of 29 states in India have enacted anti-conversion laws. While Laos has no
law against converting away from Buddhism, authorities harass both converts and those who seek
to convert Buddhists.
Other types of religious discrimination

! This category is for all types of religious discrimination that do not fit into the other categories.
They are listed in Table 11.4. The most common type of discrimination in this category is the
arrest, harassment, or detention of religious minorities for activities other than proselytizing; 60
(33.0%) countries do this to at least one religious minority. This is most common in Muslim-
majority countries, with 30 (58.8%) of these countries engaging in this type of discrimination as
opposed to 21 (20.1%) Christian-majority countries and 13 (44.8%) other countries.
Eritrea is an example of a particularly harsh case. In 2002 it required all religious groups, other
than four recognized religions—the Eritrean Orthodox Church, the Evangelical (Lutheran)
Church of Eritrea, Islam, and the Roman Catholic Church—to register, or in some cases re-
register, and began severely harassing all non-registered groups. Authorities regularly harassed, fined,
arrested, and detained members of unregistered religious groups who practiced their religion. The
government closely monitored the activities and movements of unregistered religious groups.
Members of these groups and people otherwise associated with unregistered religions were
detained without due process, occasionally for long periods of time, sometimes by informally
charging them with threatening national security. “Religious offenders” were often held at detention
facilities and were subject to harsh conditions.
In 37 (20.2%) countries, the government fails to protect minorities from significant societal
violence. This does not mean the government failed to prevent all violence and discrimination
against minorities. Rather it means that, despite the presence of violence against at least one religious
minority in society, these governments did not make a sufficiently credible attempt to prevent
this violence. Governments have an obligation to protect all of their citizens from violence,
as well as other forms of societal discrimination, and the willful failure to do so is a form of
discrimination. Societal discrimination can take two forms: attitudes and actions. While attitudes
and actions are related, they are distinct. Negative attitudes toward religious minorities are usually
present, but when they translate into actions such as verbal acts, vandalism, and violence against
minorities, they become more politically significant. These types of societal actions are common
and present in 145 (79.8%) countries.
Religious discrimination in comparative perspective
! Overall, 162 (88.5%) countries engage in at least one of the 36 types of religious discrimination
discussed here, against at least one religious minority. Thus, like support for religion and the
regulation, control, and restriction of religion, religious discrimination is the norm and its absence
is the exception. The countries which fail to discriminate do not meet the Western democratic
stereotype that one would assume to be the case. Among Western democracies, only Canada has
no religious discrimination. The others are in Africa (Burundi, Cameroon, Congo-Brazzaville,
Lesotho, and Namibia), Latin America (Barbados, and Uruguay) and Asia (the Philippines, the
Solomon Islands, and Vanuatu). They also include Muslim-majority countries, all in Africa—Burkina
Faso, Djibouti, Niger, Senegal, and Sierra Leone.
As is the case for the regulation, restriction, and control of religion, religious discrimination is
most common and severe in countries hostile to religion. To be clear, as religious discrimination
is defined here as restrictions placed on minority religious institutions and practices that are not
placed on those of the majority religion, this means that these states significantly restrict religious
minorities above and beyond the restrictions they place on religion in general. That is, these
governments which are repressive of religion in general single out religious minorities for an extra
dose of repression above and beyond the general repression that occurs against the majority religion.
This is likely the result of a complex set of motivations for restricting religion in these countries.
Among countries not hostile to religion, those countries which more strongly support religion
engage in more religious discrimination. This suggests a strong influence for the ideological and
monopoly-based motivations for religious discrimination.
! CONCLUSIONS
This chapter deals with how governments restrict religion. Restrictions on religion, both the
majority religion and minority religions, are the norm. Only Namibia, Cameroon, and the Solomon
Islands do neither. In Chapter 10 I demonstrate that all countries support religion in some manner.
Thus, while the motivations for government religion policy are complex and vary from country
to country, no country fails to intervene in the religious economy in some manner, and most do
so to a considerable extent in multiple ways.
This clearly demonstrates that assumptions that separation of religion and state and religious
freedom are common, even if only in a subset of democratic liberal states, are flawed. In the next
two chapters I examine the issues of secularism and religious freedom in more detail.
! DISCUSSION QUESTIONS
1. Does your country limit the majority religion in any way? If yes, what type of limitations
does it place on that religion? Are the same limitations also placed on minority
religions? What do you think are the motivations for this policy?
2. Is there discrimination against religious minorities in the country where you live? If
yes, against which minorities? What types of discrimination? What do you think are
the motivations for this discrimination?
3. Are there any circumstances under which you think regulating, restricting, and
controlling religion in general in a country is acceptable? What about restrictions on
minority religions that are not placed on the majority religion?
! NOTES
1 Constitution of the Republic of the Union of Myanmar 2008, www.religlaw.org/common/
document.view.php?docId=5434.
2 Constitution of Mexico, Article 130, www.constituteproject.org/constitution/Mexico_2015.pdf?
lang=en.
3 M. Brunwasser, “The Greeks who Worship the Ancient Gods,” BBC News, June 20, 2013; Paris
Ayiomamitis, “Holy War Erupts as Unorthodox Greeks Revive Ancient Religion,” The Sydney Morning
Herald, January 23, 2007; Kim Gamel, “Zeus Worshippers Demand Access to Ancient Temple for Rare
Religious Ceremony,” Associated Press, January 19, 2007.
4 Baer, D. (18 March 2013) Testimony Concerning the Condition of Religious Freedom in Hungary, Submitted
to the U.S. Commission on Security and Cooperation in Europe (The Helsinki Commission).
5 Sharon Otterman, “Plans for a Mosque are Blocked in New Jersey,” New York Times, March 11, 2017.
! FURTHER READING
Koesel, Karrie J. Religion and Authoritarianism: Cooperation, Conflict, and the Consequences, New York, NY:
Cambridge University Press, 2014.
Sarkissian, Ani The Varieties of Religious Repression: Why Governments Restrict Religion, New York, NY: Oxford
University Press, 2015.

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10 Government religion

policy 1: official policies

! WHAT IS GOVERNMENT POLICY?

CATEGORY AND DEFINITION STATES IN THE CATEGORY

States with official religions

States with no official religion

Official policy in comparative perspective

! MOTIVATIONS FOR SUPPORTING RELIGION

TABLE 10.2 DISTRIBUTION OF OFFICIAL RELIGION POLICY IN 2014

MAJORITY RELIGION ALL

! TYPES OF SUPPORT FOR RELIGION

1. Hostile—specific hostility, state controlled–negative attitude and separationist.

Legislating religious precepts

TYPE OF SUPPORT OFFICIAL GOVERNMENT POLICY ALL

Relationships, Sex, and Reproduction

Institutions which enforce religion

TYPE OF SUPPORT OFFICIAL GOVERNMENT POLICY ALL

The entanglement of government and religious institutions

Other forms of support for religion

TYPE OF SUPPORT OFFICIAL GOVERNMENT POLICY ALL

! REGULATION, RESTRICTION, AND CONTROL

1. The ability of religious institutions and clergy to participate in politics.

Restrictions on religion’s political role

TYPE OF SUPPORT OFFICIAL GOVERNMENT POLICY ALL

Restrictions on religious institutions

Restrictions on religious practices

Other types of regulation, restriction, and control

TYPE OF SUPPORT OFFICIAL GOVERNMENT POLICY ALL

Restrictions on Religious Practices

Regulation, restriction, and control in comparative perspective

! RELIGIOUS DISCRIMINATION IN THEORY

Why do states discriminate against religious minorities?

! RELIGIOUS DISCRIMINATION IN PRACTICE

Restrictions on religious practices

TYPE OF SUPPORT OFFICIAL GOVERNMENT POLICY ALL

Restrictions on religious institutions and the clergy

Restrictions on conversion and proselytizing

TYPE OF SUPPORT OFFICIAL GOVERNMENT POLICY ALL

Restrictions on Conversion and Proselytizing

Other types of religious discrimination

Religious discrimination in comparative perspective

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