Article 18 of the ICCPR distinguishes between the freedom to hold a particular belief, and the freedom to manifest that belief in conduct. It is clear from the different focuses of paragraphs (2) and (3) of article 18 that the freedom to hold a belief is broader than the freedom to act upon it.
The right to hold a belief is absolute - the State is not permitted to interfere with a person’s right to autonomously develop thoughts and a conscience.
But, as the European Court has stated, the right to freedom of religion ‘does not always guarantee the right to behave in public in a manner governed by that belief’ (Pichon and Sajous v France, App. No. 49853/99, Decision of 2 October 2001, p 5. See also Skugar and Others v Russia, App no. 40010/04, 3 December 2009).
Once a belief is manifested (that is, implemented) in action, it leaves the sphere of absolute protection, because the manifestation of a religious belief may have an impact on others. Article 18 recognizes four general categories of action through which belief may be manifested: worship, observance, teaching and practice. The latter category appears to be the broadest. Article 18 does not provide any further guidance about the level of connection required between an act and a belief for it to constitute a manifestation through ‘practice’.