ABSTRACT
Although many international and regional human rights instruments guar antee rights related to freedom of religion or belief,4 none attempts to define
the term “religion.” There was one major international effort to explain the underlying rights protected under the concept of religion or belief,3 and the U N Human Rights Committee issued an important General Comment on the scope of freedom of religion or belief within the International Covenant on Civil and Political Rights.6 Nevertheless, the term “religion” remains undefined as a matter of international law. The absence of a definition of “religion” is not peculiar to international human rights conventions; most national constitutions also include clauses on freedom of religion without defining “religion.”7 Thus we are presented, on the one hand, with impor tant provisions guaranteeing fundamental rights pertaining to religion, but on the other hand the term itself is left undefined. O f course, the absence of a definition of a critical term does not differentiate religion from most other rights identified in human rights instruments and constitutions. However, because religion is much more complex than other guaranteed rights, the difficulty of understanding what is and is not protected is significantly greater.8
