ABSTRACT
This chapter focuses on the similarities and differences in legal understandings of "religion", and hence of religious persecution, in the United Kingdom and United States. The most common contexts in which religion has formed the basis of asylum claims in the UK, regarded as heretics by many other Muslims; and Falun Gong members claiming persecution by the Chinese government. Despite the increasingly broad definitions of religion developed by the Supreme Court, American approaches to religion-based asylum claims are often just as reliant on prejudicial stereotype as the Omoruyi decision in the UK. Whether it is an attractive religion is not for a pragmatic anthropological relativist to judge, but neither should that be a relevant consideration in legal decisions regarding the existence of persecution for a Refugee Convention reason. Conversion from Islam is against the law, punishable as apostasy, in theory by death. Iran recognizes Christians as a religious minority but discriminates against them in various ways.
