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Apostasy in Islam

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Apostasy in Islam (Arabic: ارتداد, irtidād or ridda) is commonly defined as the rejection of Islam in word or deed by a person who has been a Muslim.

The five major Madh'hab (schools of Islamic jurisprudence) agree that a sane male apostate must be executed.[1] A female apostate may either be put to death according to some schools, imprisoned according to others, or exempt from punishment according to the Hanafi school.[2] The Sharia laws governing apostasy are derived from the hadith traditions. According to Wael Hallaq nothing of the apostasy law are derived from the Qur'an, [3] although the jurist Al-Shafi'i interpreted the Quranic verse [Qur'an 2:217] as providing the main evidence for apostasy being a capital crime in Islam.[4]

Some contemporary Shi'a jurists, scholars, writers and Islamic sects have argued or issued fatwas that either the changing of religion is not punishable or is only punishable under restricted circumstances, but these minority opinions have not found broad acceptance among Islamic scholars.[5][6][7][8][9]

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[edit] Qur'anic reference

The Qur'an states that God (in Arabic, Allah) despises apostasy. See verses [Qur'an 3:72], [Qur'an 3:90],[Qur'an 16:106],[Qur'an 4:137] and [Qur'an 5:54] which deal with apostasy directly and which state that Allah will punish and reject apostates in the afterlife. Except 16:106-109, the verses that discuss apostasy all appear in surahs identified as Madinan and belong to the period when the Islamic state had been established.

W. Heffening states that in Qur'an "the apostate is threatened with punishment in the next world only," adding that Shafi'is interpret verse [Qur'an 2:217] as adducing the main evidence for the death penalty in the Qur'an. Wael Hallaq holds that "nothing in the law governing apostate and apostasy derives from the letter of the holy text."[3]

The dissenting Shia jurist Grand Ayatollah Hossein-Ali Montazeri, a significant Shi'a religious authority, states that the above verses do not prescribe an earthly penalty for apostasy.[10]

[edit] Sunni Hadith references

The Hadith (the body of quotations attributed to Muhammad and claimed eyewitnesses' accounts of Muhammad's life and deeds) includes statements that Muslim scholars such as Sheikh Muhammed Salih Al-Munajjid see as supporting the death penalty for apostasy. [4] Only those from Sahih Bukhari, which are considered reliable by most Sunni Muslims generally are given below:

  • "Allah's Apostle said, The blood of a Muslim, who confesses that none has the right to be worshipped but Allah and that I am His Apostle, cannot be shed except in three cases: In Qisas for murder, a married person who commits illegal sexual intercourse and the one who reverts from Islam (apostate) and leaves the Muslims." 9:83:17

References to additional hadith, that have been labeled Sahih by Sunni, from other Imams on the punishment of death for apostasy are:

4152-4155, 898-900; Kitab Al-Imara Chapter DCCLVI, Number 4490, p. 1015 from Muslim, Imam, Sahih Muslim: Being Traditions of the Sayings and Doings of the Prophet Muhammad as Narrated by His Companions and compiled under the Title Al-Jami'-Us-Sahih, Translated by 'Abdul H. Siddiqi, Vol. III.

Heffening holds that "in traditions, there is little echo of these punishments in the next world ... and instead, we have in many traditions a new element, the death penalty."[4] Wael Hallaq states the death penalty was a new element added later and "reflects a later reality and does not stand in accord with the deeds of the Prophet."[3] Montazeri believes that it is probable that the punishment was prescribed by Muhammad during early Islam - due to political conspiracies against Islam and Muslims, and not only because of changing the belief or expressing it. Montazeri defines different types of apostasy. He does not hold that a reversion of belief because of investigation and research is punishable by death, but prescribes capital punishment for a desertion of Islam out of malice and enmity towards the Muslim community.[11]

[edit] According to Tafsir

More recently, Sayyid Abul Ala Maududi, a noted controversial 20th century Islamic Scholar, argued that verses [Qur'an 9:11] of the Qur'an sanction death for apostasy. The argument given by Mawdudi[12] for these verses is:

"The following is the occasion for the revelation of this verse: During the pilgrimage (hajj) in A.H. 9 God Most High ordered a proclamation of an immunity. By virtue of this proclamation all those who, up to that time, were fighting against God and His Apostle and were attempting to obstruct the way of God's religion through all kinds of excesses and false covenants, were granted from that time a maximum respite of four months. During this period they were to ponder their own situation. If they wanted to accept Islam, they could accept it and they would be forgiven. If they wanted to leave the country, they could leave. Within this fixed period nothing would hinder them from leaving. Thereafter those remaining, who would neither accept Islam nor leave the country, would be dealt with by the sword." In this connection it was said: "If they repent and uphold the practice of prayer and almsgiving, then they are your brothers in religion. If after this, however, they break their covenant, then war should be waged against the leaders of kufr (infidelity). Here "covenant breaking" in no way can be construed to mean "breaking of political covenants". Rather, the context clearly determines its meaning to be "confessing Islam and then renouncing it". Thereafter the meaning of "fight the heads of disbelief" ([Qur'an 9:11]) can only mean that war should be waged against the leaders instigating apostasy."

Mawdudi's interpretation is supported by other Muslim writers. For example, Afzal ur-Rahman in Muhammad, Blessing for Mankind, Seerah Foundation, London, Revised Second Edition, 1988, p. 218 under "Apostasy" states:

"People who turn away from Islam and do not repent but wage war and create mischief in the land are also considered as murderers. "But if they break their oaths after making compacts and taunt you for your faith, you should fight with these ringleaders of disbelief because their oaths are not trustworthy: it may be that the sword alone will restrain them" ([Qur'an 9:12]). And in Surah Al-Nahl, "But whosoever accepts disbelief willingly, he incurs God's Wrath, and there is severe torment for all such people"([Qur'an 16:106])

However, there are also some scholars that reject Mawdudi's interpretation. S. A. Rahman (in Punishment of Apostasy in Islam, Institute of Islamic Culture, Lahore, 1972, pp. 10-13) concluded "that not only is there no punishment for apostasy provided in the Book but that the Word of God clearly envisages the natural death of the apostate. He will be punished only in the Hereafter...." (p. 54)

He continues and says that there is no reference to the death penalty in any of the 20 instances of apostasy mentioned in the Qur'an.

In his book on Punishment of Apostasy in Islam, Rahman declares the verse [Qur'an 2:256] to be "one of the most important verses of the Qur'an, containing a charter of freedom of conscience unparalleled in the religious annals of mankind . . .". He goes on to criticize the attempts by Muslim scholars over the ages to narrow its broad humanistic meaning and impose limits on its scope in their attempts to reconcile it with their interpretations of Muhammad's Sunna. However, Maqaalaat li'l-Shaykh Ibn Baaz [5] rejects the idea that 2:256 deals with apostasy, and claims that it only applied to non-Muslim dhimmis who were paying their jizya, and that it was subsequently abrogated.

[edit] What constitutes apostasy in Islam

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Atributes of apostasy according to some Muslims include:

[edit] Regarding monotheism and polytheism

[edit] Regarding prophethood of Muhammad

[edit] Regarding beliefs

In Islamic society apostasy must be determined by the testimony of two adult Muslim witnesses, in respectable standing, whose accounts agree. Also, any death penalty case has to be determined by the testimony of four adult Muslim witnesses, in respectable standing, whose accounts agree, for the execution to occur.

See also: Apostasy in Shafi tradition

[edit] Punishment for apostasy

[edit] Execution

Legal opinion on apostasy by a Fatwa committee concerning the case of a man who converted to Christianity: "Since he left the Islam, he will be invited to express his regret. If he does not regret, he will be killed pertaining to rights and obligations of the Islamic law."
Legal opinion on apostasy by a Fatwa committee concerning the case of a man who converted to Christianity: "Since he left the Islam, he will be invited to express his regret. If he does not regret, he will be killed pertaining to rights and obligations of the Islamic law."

In Islamic law (sharia), the consensus view is that a male apostate must be put to death unless he suffers from a mental disorder or converted under duress, for example, due to an imminent danger of being killed. A female apostate must be either executed, according to Shafi'i, Maliki, and Hanbali schools of Sunni Islamic jurisprudence (fiqh), or imprisoned until she reverts to Islam as advocated by the Sunni Hanafi school and by Shi'a scholars.[13]

[edit] Preferred form of execution

Most Islamic scholars agree that the appropriate punishment for apostasy is beheading. However, according to hadith, apostates sometimes were tortured to death. The caliph Umar II had apostates tied to a post and a lance thrust into their hearts. Mamluk Sultan Baybars II also practiced torture of apostates. A case is recorded when a woman who had apostatised was led through the streets of Cairo on an ass, then strangled in a boat in the middle of the Nile and thrown into the river. In modern times, followers of the Ahmadiyya sect in Afghanistan were stoned to death. The execution for apostasy was abolished in most Muslim lands in the 19th century either through European pressure or through the direct European rule; however, cases of imprisonment and deportation of apostates still occurred. Nevertheless, even nowadays renegades are not sure of their lives, as their Muslim relatives frequently try to kill them.[13]

Ideally, the one performing the execution of an apostate must be an imam.[13] At the same time, all schools of Islamic jurisprudence agree that any Muslim can kill an apostate without punishment.[14]

[edit] Applying law in the Muslims world

Most countries of the Middle East and North Africa maintain a dual system of secular courts and religious courts, in which the religious courts mainly regulate marriage and inheritance. Saudi Arabia and Iran maintain religious courts for all aspects of jurisprudence, and religious police assert social compliance. Sharia is also used in Sudan, Libya and Afghanistan. Some states in northern Nigeria have reintroduced Sharia courts. In practice the new Sharia courts in Nigeria have most often meant the reintroduction of relatively harsh punishments without respecting the much tougher rules of evidence and testimony. The punishments include amputation of one/both hand(s) for theft, stoning for adultery, and execution for apostasy. Many non-muslim views consider the punishments described above as harsh, but Islamic scholars argue, that if implemented properly, these punishments will serve as a deterrent to crime. In 1980, Pakistan, under the leadership of President Zia-ul-Haq, the Federal Shariat Court was created and given jurisdiction to examine any existing law to ensure it was not repugnant to Islam[4] and in its early acts it passed ordinances included five that explicitly targeted religious minorities: a law against blasphemy; a law punishing the defiling of the Qur'an; a prohibition against insulting the wives, family, or companions of the Prophet of Islam; and two laws specifically restricting the activities of Ahmadis, who were declared non-Muslims.

Under traditional Islamic law[15] an apostate may be given up to three days while in incarceration to repent and accept Islam again and if not the apostate is to be killed without any reservations. There are difference between the four schools in the various details on how to deal with the various aspects of imposing the penalties with respect to the material property and holdings of the apostate and in the status and rights of the family of the apostate. A distinction is also made between "Murtad Fitri", an apostate who was born of Muslim parents, and "Murtad Milli", an apostate who had converted into Islam initially. Some additional penalties and considerations that are mentioned are that a divorce is automatic if either spouse apostatize, an under age apostate is imprisoned till he reaches maturity and then he is killed, and the recommended execution is beheading with a sword. The examples of Apostasy given below show that these punishments are rarely carried out in toto at present, and also underline the problem in harmonizing the constitutional law and Islamic law in the various countries.

In the period of the early Islamic Caliphate, apostasy was considered treason, and was accordingly treated as a capital offense; death penalties were carried out under the authority of the Caliph, the most famous such incidents being the Martyrs of Cordoba. Today apostasy is punishable by death in the countries of Saudi Arabia, Qatar, Yemen, Iran, Sudan, Afghanistan and Mauritania. In Pakistan blasphemy is also punishable by death. Other punishments prescribed by Islamic law include the annulment of marriage with a Muslim spouse, the removal of children and the loss of all property and inheritance rights.

[edit] Contemporary accused apostates

The most prominent contemporary figure accused of apostasy (due to blasphemy) by individual scholars (including Ayatollah Khomeini, who was ruler of Iran at the time) was probably Salman Rushdie, for writing his book The Satanic Verses. However, this view has been rejected by some Muslim scholars both medieval (eg Sufyan al-Thawri) and modern (eg Hasan at-Turabi), who argue that the hadith in question should be taken to apply only to political betrayal of the Muslim community, rather than to apostasy in general.[16] These scholars argue for the freedom to convert to and from Islam without legal penalty, and consider the aforementioned Hadith quote as insufficient confirmation of harsh punishment; they regard apostasy as a serious crime, but undeserving of the death penalty.

In 2006 Abdul Rahman, an Afghan convert to Christianity "was charged with rejecting Islam" and "could have faced the death penalty ... but his case was dismissed after he was deemed mentally unfit to stand trial." [17] . He was freed from jail and flown to Italy given asylum by the Italian government because of "threats of violence against him" by Afghan Muslims "if he was not convicted."

[edit] Opposition to execution

Some modern Islamic writers, especially those belonging to the Ahmadiyya sect, the followers of which are deemed to be non-Muslims in many Muslim countries, have attempted to prove that the death penalty for an apostate is not mandatory in Islam.[13] S. A. Rahman, a former Chief Justice of Pakistan, argues that there is no indication of the death penalty in the Qur'an.[18] Abdullah Saeed and Hassan Saeed argue that the law of apostasy and its punishment by death in Islamic law conflicts with a variety of fundamentals of Islam. They contend that the early development of the law of apostasy was essentially a religio-political tool, and that there was a large diversity of opinion among early Muslims on the punishment.[19] Such views, however, are rejected by mainstream Muslim scholars.[13]

Medieval Muslim scholars (eg Sufyan al-Thawri) and modern (eg Hasan at-Turabi), have argued that the hadith used to justify execution of apostates should be taken to apply only to political betrayal of the Muslim community, rather than to apostasy in general.[20] These scholars argue for the freedom to convert to and from Islam without legal penalty, and consider the aforementioned Hadith quote as insufficient confirmation of harsh punishment; they regard apostasy as a serious crime, but undeserving of the death penalty.

Javed Ahmad Ghamidi, an Islamic scholar, writes that punishment for apostasy was part of Divine punishment for only those who denied the truth even after clarification in its ultimate form by Muhammad (see Itmaam-i-hujjat), hence, he considers it a time-bound command and no longer punishable.[2]

Muslims ascribing to the liberal movements within Islam oppose the death penalty as a punishment for Apostasy.

[edit] Justifications for the death penalty

Sayyid Abul Ala Maududi who summarizes what he sees as the most likely objections by critics as such:

Maududi claims that the misunderstanding and criticism arises because of a "fundamental misconception" about Islam:

If Islam is truly a "religion" in the sense that religion is understood at present, surely it would be absurd to prescribe the penalty of execution for those people who wish to leave it because of their dissatisfaction with its principles. It is not only a "religion" in the modern technical sense of that term but a complete order of life. It relates not only to the metaphysical but also to nature and everything in nature. It discourses not only on the salvation of life after death but also on the questions of prosperity, improvement and the true ordering of life before death.

Maududi also declares:

Whatever objections the critics pose regarding the punishment of the apostate, they make them bearing in mind only a single "religion" (madhhab). In contrast, when we present our arguments to demonstrate the validity of this punishment, we have in view no mere "religion" but a state which is constructed on a religion (din) and the authority of its principles rather than on the authority of a family, clan or people.

And since it is a state, Maududi declares it "has the right to protect its own existence by declaring those acts wrong which undermine its order", and proceeds to equate apostasy to treason. He then discusses the difference between a kafir, a dhimmi, and the appropriateness of death for them if they apostatize after conversion, and for those born of Muslim parents he states:

In any case the heart of the matter is that children born of Muslim lineage will be considered Muslims and according to Islamic law the door of apostasy will never be opened to them. If anyone of them renounces Islam, he will be as deserving of execution as the person who has renounced kufr to become a Muslim and again has chosen the way of kufr. All the jurists of Islam agree with this decision. On this topic absolutely no difference exists among the experts of shari'ah.

Maududi considers the threat of execution as not forcing someone to stay within the fold of Islam, but as a way of keeping those who are not truly committed out of the community of Islam. Maududi rejects the third criticism because unlike other religions which are free to exchange believers, Islam is "on whose ideas and actions society and state are constructed" cannot allow "to keep open its door that would spell its own ruin, the scattering of its own structure's parts, the stripping away of the bonds of its own existence", and he compares this to the treason penalty on the books of the U.S. and Britain. Maududi also rejects the charge of contradiction. In his words:

"There is no compulsion in religion" (la ikraha fi'd din: Qur'an [Qur'an 2:256]) means that we do not compel anyone to come into our religion.[2] And this is truly our practice. But we initially warn whoever would come and go back that this door is not open to come and go. Therefore anyone who comes should decide before coming that there is no going back.

Essentially the same arguments are sketched by the Shi'i Islamic author Sayyid Muhammad Rizvi in the brief article Apostacy (Irtidad) in Islam,[21] relying upon the opinions of some of the earlier scholars of Islam.

However, Ibn Warraq, in his article Apostasy and Human Rights, points out some earlier scholars of Islam who found support in the Qur'an for the death penalty for apostasy. He quotes al-Shafi (died 820 C.E.), the founder of one of the four orthodox schools of law of Sunni Islam that verse [Qur'an 2:217] meant that the death penalty should be prescribed for apostates, and Al-Thalabi and Al-Khazan concurred, and states that Al-Razi in his commentary on 2:217 says an apostate should be killed. Ibn Warraq also quotes commentaries by Baydawi (died c. 1315-1316) on [Qur'an 4:89] as "Whosoever turns back from his belief (irtada), openly or secretly, take him and kill him wheresoever ye find him, like any other infidel". Verse ([Qur'an 4:88]) reads:

"Why should ye be divided into two parties about the Hypocrites? ... They wish if you disbelieve as they disbelieved so that you would be alike. So do not take from among them allies until they emigrate in the way of Allah. But if they turn back, seize them and kill them wherever you find them. And do not take from among them any ally or helper," "Except those who join a group between whom and you there is a treaty or those who come to you with hearts restraining them from fighting you or fighting their people. And if Allah had willed, surely He would have given them power over you, so that they would have taken arms against you. Therefore, if they keep away from you and cease their hostility and offer you peace, God bids you not to harm them".

[edit] Apostasy in the recent past

The greatest threat to apostates in the Muslim world derives from individuals who take punishment into their own hands, because they know they will not be held accountable by the authorities. An example among many is the case of a Bangladeshi Murtad Fitri Christian evangelist who was stabbed while returning home from a film version of the Gospel of Luke.[22] Bangladesh does not have a law against apostasy, but the Imams in the mosques encourage the killing of all non-Muslims; so, someone was incited to kill the man. Many ex-Muslims in Great Britain have faced abuse, violence, and even murder at the hands of Muslims;[23] one estimate suggests there are 200,000 apostates in Britain. There are similar reports of violent intimidation of those electing to reject Islam in other Western countries.[24]

"In all the cases known to Amnesty International, these charges have been arbitrarily brought, founded solely on the individual's minority religious beliefs or on malicious accusations against individuals of the Muslim majority who advocate novel ideas. The available evidence indicates that charges were brought as a measure to intimidate and punish members of minority religious communities or non-conforming members of the majority community and that the hostility towards minority groups appeared in many cases compounded by personal enmity, professional envy or economic rivalry or a desire to gain political advantage" .[25]

An example of the passions and the feelings of extreme outrage that are evoked within the Muslim community is provided by Amnesty International's 2005 Report on Pakistan:

Other examples of persecution of apostates converting to Christianity have been given by the Barnabas Fund from Kuwait, Sudan, Iran, Yemen, Pakistan, Egypt, and Bangladesh. Barnabas Fund report concludes:

"The field of apostasy and blasphemy and related “crimes” is thus obviously a complex syndrome within all Muslim societies which touches a raw nerve and always arouses great emotional outbursts against the perceived acts of treason, betrayal and attacks on Islam and its honour. While there are a few brave dissenting voices within Muslim societies, the threat of the application of the apostasy and blasphemy laws against any who criticize its application is an efficient weapon used to intimidate opponents, silence criticism, punish rivals, reject innovations and reform, and keep non-Muslim communities in their place."

Similar views are expressed by the 'non-religious' International Humanist and Ethical Union.[27]

This article does not cite any references or sources. (June 2007)
Please help improve this article by adding citations to reliable sources. Unverifiable material may be challenged and removed.

[edit] See also

[edit] References

  1. ^ "Murtadd", Encyclopedia of Islam
  2. ^ a b Javed Ahmad Ghamidi. The Punishment for Apostasy, Renaissance, Al-Mawrid Institute, 6(11), November, 1996
  3. ^ a b c Encyclopedia of the Quran, Apostasy
  4. ^ a b c W. Heffening, in Encyclopedia of Islam
  5. ^ Grand Ayatollah Hossein-Ali Montazeri: "Not Every Conversion is Apostasy", by Mahdi Jami, In Persian, BBC Persian, February 2, 2005, retrieved April 25, 2006
  6. ^ What Islam says on religious freedom, by Magdi Abdelhadi, BBC Arab affairs analyst, 27 March 2006, retrieved April 25, 2006
  7. ^ Fatwa on Intellectual Apostasy, Text of the fatwa by Sheikh Yusuf Al-Qaradawi
  8. ^ S. A. Rahman in "Punishment of Apostasy in Islam", Institute of Islamic Culture, Lahore, l972, pp. 10-13
  9. ^ The punishment of apostasy in Islam, View of Dr. Ahmad Shafaat on apostasy.
  10. ^ Ayatollah Montazeri: "Not Every Conversion is Apostasy", by Mahdi Jami, In Persian, BBC Persian, February 2, 2005, retrieved April 25, 2006
  11. ^ Ayatollah Montazeri: "Not Every Conversion is Apostasy", by Mahdi Jami, In Persian, BBC Persian, February 2, 2005, retrieved April 25, 2006
  12. ^ ABUL ALA MAWDUDI. THE PUNISHMENT OF THE APOSTATE ACCORDING TO ISLAMIC LAW. Answering Islam. Retrieved on 2006-03-23.
  13. ^ a b c d e Heffening, W. "Murtadd". Encyclopaedia of Islam Online Edition. Ed. P.J. Bearman, Th. Bianquis, C.E. Bosworth, E. van Donzel and W.P. Heinrichs. Brill Academic Publishers. ISSN 1573-3912. 
  14. ^ Adbul Qadir Oudah (1999). Kitab Bhavan. ISBN 81-7151-273-9. , Volume II. pp. 258-262; Volume IV. pp. 19-21
  15. ^ according to Abdurrahmani'l-Djaziri's Kitabul'l-fiqh 'ala'l-madhahibi'l-'arba'a i.e. Apostasy in Islam according to the Four Schools of Islamic Law (Vol. 5, pp. 422-440) First English Edition (Villach): 1997
  16. ^ Islam & Pluralism - A Contemporary Approach. Islam Online. Retrieved on 2006-03-23.
  17. ^ "Afghan convert freed from prison", BBC News, March 28, 2006, retrieved April 11, 2006
  18. ^ S. A. Rahman (1986). Punishment of apostasy in Islam. Kazi Publ.. 
  19. ^ Saeed, Abdullah; Hassan Saeed (2004). Freedom of Religion, Apostasy and Islam. Ashgate Publishing. ISBN 0-7546-3083-8. 
  20. ^ Islam & Pluralism - A Contemporary Approach. Islam Online. Retrieved on 2006-03-23.
  21. ^ Apostacy (Irtidad) in Islam, by Sayyid Muhammad Rizvi, Al-Islam.org, retrieved April 11, 2006
  22. ^ "When Muslims Convert", by Daveed Gartenstein-Ross, Friday, March 4, 2005, Commentary magazine, 2005
  23. ^ Template:Cite news Others, however, take a public stand and are not afraid of anyone.
  24. ^ Why Must Ex-Muslims Live in Fear -- In America?. Human Events. Retrieved on 2006-03-23.
  25. ^ The death penalty under the blasphemy law. Persecution.org. Retrieved on 2006-03-23.
  26. ^ Pakistan. Amnesty International. Retrieved on 2006-03-23.
  27. ^ The fate of Infidels and Apostates under Islam, by Azam Kamguian, International Humanist and Ethical Union, June 21, 2005, retrieved April 11, 2006
  28. ^ Apostates from Islam: The Case of the Afghan Convert is Not Unique
  29. ^ Apostates from Islam: The Case of the Afghan Convert is Not Unique
  30. ^ Friedrich W. Affolter. The Specter of Ideological Genocide: The Bahá'ís of Iran. War Crimes, Genocide and Crimes Against Humanity, 1(1):59– 89, 2005.
  31. ^ Apostates from Islam: The Case of the Afghan Convert is Not Unique
  32. ^ Apostates from Islam: The Case of the Afghan Convert is Not Unique
  33. ^ Apostates from Islam: The Case of the Afghan Convert is Not Unique
  34. ^ Apostates from Islam: The Case of the Afghan Convert is Not Unique
  35. ^ Apostates from Islam: The Case of the Afghan Convert is Not Unique
  36. ^ Apostates from Islam: The Case of the Afghan Convert is Not Unique
  37. ^ State to appeal ruling that favours Egypt's Bahá'ís
  38. ^ Spiegel article, website
  39. ^ [1], [2], [3]

[edit] Further reading

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