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Bias and Religious Truth-Seeking in Proselytization Restrictions: An Atypical Case Study of Singapore

Published online by Cambridge University Press:  16 April 2015

Jianlin Chen
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Abstract

Proselytisation restrictions are typically subjected to two objections. First, these restrictions curtail religious liberty and impede religious truth-seeking. Second, these restrictions tend to favour politically dominant religions and discriminate against minority religions. The restrictions on offensive religious propagation in Singapore thus present an interesting departure in which sanctioned religions are not politically marginalised religions, whereas protected religions include numerical minority religions that are socially, economically, and politically disadvantaged. This article utilises the atypical case study of Singapore to highlight the limitations of the two typical objections toward proselytisation restrictions. In particular, the emphasis on religious truth-seeking underpinning these objections is premised upon a distinct set of religious worldviews not shared by the majority of religions in Singapore. This article posits that if religious truth-seeking is no longer the accepted normative goal, then there may be circumstances in which some limited and even-handed restrictions on offensive religious propagation are sufficiently justified on the grounds of social peace and harmony.

Keywords

freedom of religionProselytization restrictionsreligious harmonySingapore
Type
Article
Information
Asian Journal of Comparative Law , Volume 8 , 2013 , pp. 1 - 65
Copyright
Copyright © Faculty of Law, National University of Singapore 2013

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References

Assistant Law Professor (University of Hong Kong), JSD Candidate (University of Chicago), LLM (University of Chicago), LLB (University of Singapore). Admitted to the bar in New York and Singapore.

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5 Infra III.B.

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12 Infra V.A.

13 Infra V.B.

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63 Singapore Department of Statistics, Census of Population 2010 Statistical Release 1: Demographic Characteristics, Education, Language and Religion (2011) at viii.

64 The ancestry of Peranakans and Eurasians can be traced back to the fifteenth-century Malacca Sultanate. Peranakans are descendents of Chinese traders and local Malay women, while Eurasians are the direct offspring of Malacca’s Portuguese conquerors who married local women: Koh, Jaime & Ho, Stephanie, Culture and Customs of Singapore and Malaysia (Greenwood Press, 2009) at 3–4 Google Scholar. For census purpose, the ethnicity is as declared by the individuals and does not necessarily reflect the historical ancestry.

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69 For example, the Maria Hertogh court case in 1950 sparked riots by Muslims against Christians, especially the Europeans and Eurasians. Maria Hertogh was a Dutch-Eurasian who was baptized as a Catholic but was later raised as a Muslim by a Muslim family after her parents was arrested by the Japanese during the Second World War. She went through a marriage ceremony with a Muslim but the court annulled the marriage and sent her to a Catholic convent. Given the colonial context, it is not surprising that the Malay Muslim population perceived the court judgment as imposing of European cultural, racial and religious supremacy: see Tong, Chee Kiong, Rationalizing Religion: Religious Conversion, Revivalism, and Competition in Singapore Society (Koninklijke Brill, 2007) at 232 CrossRefGoogle Scholar; Eng, Kuah-Pearce Khun, State, Society and Religious Engineering: Towards a Reformist Buddhism in Singapore (Eastern Universities Press, 2003) at 142–143 Google Scholar. The Malay-Chinese riots in the 1964 similarly reflected the inextricable nature of race and religion in Singapore’s socio-political dynamics. Racial tension was already strained over whether Malays should be granted special rights as indigenous people, but the flash point was alleged the religious insults during the Muslim’s possession in celebration of the Prophet Mohammed birthday: Tong, Chee Kiong, Rationalizing Religion: Religious Conversion, Revivalism, and Competition in Singapore Society (Koninklijke Brill, 2007) at 232–233 CrossRefGoogle Scholar; Hang, Tey Tsun, “Excluding Religion from Politics and Enforcing Religious Harmony – Singapore-Style” (2008) 2008 S.J.L.S. 118, 121Google Scholar; Eng, Kuah-Pearce Khun, State, Society and Religious Engineering: Towards a Reformist Buddhism in Singapore (Eastern Universities Press, 2003) at 143.Google Scholar

70 Arti Mulchand, “Religion: The big switch” The Straits Times (9 August 2008).

71 Pre-independence population census by the Colonial government had included religious affiliation till 1931, when the persistent close correlation between race and religion render enquires of little value. Collection on religious affiliation data was only resumed in 1980: Tong, Chee Kiong, Rationalizing Religion: Religious Conversion, Revivalism, and Competition in Singapore Society (Koninklijke Brill, 2007) at 58–59.CrossRefGoogle Scholar

72 Singapore Department of Statistics, Census of Population 2010 Statistical Release 1: Demographic Characteristics, Education, Language and Religion (2011) at 13.

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74 Lim, Richard, “Buddhism’s Draw is No Longer as a Folk Religion” The Straits Times (20 May 20 2005)Google Scholar; Tong, Chee Kiong, Rationalizing Religion: Religious Conversion, Revivalism, and Competition in Singapore Society (Koninklijke Brill, 2007) at 89.CrossRefGoogle Scholar

75 “Four in Five Young People Here Believe in Religion” The Straits Times (3 September 2008).

76 Singapore Department of Statistics, Census of Population 2010 Statistical Release 1: Demographic Characteristics, Education, Language and Religion (2011) at 14.

77 Xueying, Li, “Reaping a rich harvest of converts” The Straits Times (16 July 2005)Google Scholar; Chew, Phyllis Ghim-Lian, “Religious Switching and Knowledge Among Adolescents in Singapore” in Eng, Lai Ah ed., Religious Diversity in Singapore (Institute of Southeast Asian Studies, 2008) at 381 Google Scholar, 388–390.

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79 Tong, Chee Kiong, Rationalizing Religion: Religious Conversion, Revivalism, and Competition in Singapore Society (Koninklijke Brill, 2007) at 62 CrossRefGoogle Scholar. Also, 97.1% of Indians were “born into their religion”: Ibid., at 84.

80 Tong, Chee Kiong, Rationalizing Religion: Religious Conversion, Revivalism, and Competition in Singapore Society (Koninklijke Brill, 2007) at 81 CrossRefGoogle Scholar.

81 Constitution of the Republic of Singapore (1999 Rev. Ed.), art. 15(4).

82 Chin, Daryl, “Ex-foes link up to promote religious tolerance” The Straits Times (21 November 2010)Google Scholar; Hussain, Zakir, “Religious harmony: 20 years of keeping the peace” The Straits Times (24 July 2009)Google Scholar (noting various government pronouncement about aggressive proselytisation).

83 Maintenance of Religious Harmony Act (Cap. 167A), s. 8.

84 Rajah, Jothie, “Policing Religion: Discursive Excursions into Singapore’s Maintenance of Religious Harmony Act” in Nicholson, Penelope (Pip) & Biddulph, Sarah eds., Examining Practice, Interrogating Theory: Comparative Legal Studies in Asia (Martinus Nijhoff, 2009) at 267 Google Scholar, 276–277.

85 Maintenance of Religious Harmony Act (Cap. 167A) at s. 16.

86 Ibid., at ss. 12 &18. The Elected President is an position set up in 1991 to serve as institutional check on the parliamentary executive over various public finance and public administration matters. The Elected President is elected in a national election and served a four-year term. The efficacy of the independent check provided by the Elected President is arguable given that the position has been occupied by individuals that are perceived as formerly affiliated or otherwise sympathetic to the ruling party: see Li-ann Thio, “Lex Rex or Rex Lex? Competing Conceptions of the Rule of Law in Singapore” (2002) 20 UCLA Pac. Basin L.J. 1, 15–22 & 50–53. It is also worth pointing out that the this ouster clause has yet to be tested in courts.

87 Tong, Chee Kiong, Rationalizing Religion: Religious Conversion, Revivalism, and Competition in Singapore Society (Koninklijke Brill, 2007) at 247 CrossRefGoogle Scholar; M. Nirmala, “Govt reins in religious leaders” The Straits Times (12 May 2001) at 1.

88 Maintenance of Religious Harmony White Paper (Cmd 21 of 1989), para. 5.

89 Nirmala, M., “Govt Reins in Religious Leaders” The Straits Times (12 May 2001).Google Scholar

90 Ibid.; Hill, Michael, “The Rehabilitation and Regulation of Religion in Singapore” in Richardson, James T. ed., Regulating Religion: Case Studies from Around the Globe (Kluwer Academic, 2004) at 343 CrossRefGoogle Scholar, 356.

91 Though the process is not secret. Section 15 requires the publication of the restraining order in the Government Gazette: Maintenance of Religious Harmony Act (Cap. 167A) at s. 15.

92 Nirmala, M., “Keeping faith – And celebrating differences” The Straits Times (12 May 2001) at H10.Google Scholar

93 Ibid.

94 Mathews, Mathew, “Accommodating Relationship: The Church and State in Singapore” in Bautista, Julius & Lim, Francis Khek Gee eds., Christianity and the State in Asia (Routledge, 2009) at 193 Google Scholar (although this could also be due to the perception that less aggressive evangelistic strategy is more successful in the long term).

95 Shuxin, Zhou, “Ge zhongjiao tuanti linxiu: chuanjiao xu zhunzhong bieren zhongxiao xingyang [Various religious organisation leaders: Must respect others’ religious belief during proselytization]” Lianhe Zaobao (11 February 2010).Google Scholar

96 Tan, Debbie, “Agree to Disagree: Conversations on Conversion”, online: <www.conversion.buddhists.sg> (last visited 1 February 2013) at 18.+(last+visited+1+February+2013)+at+18.>Google Scholar

97 Neo, Jaclyn Ling-Chien, “Seditious in Singapore! Free Speech and the Offence of Promoting Ill-Will and Hostility Between Different Racial Groups” (2011) S.J.L.S. at 353–355 Google Scholar (discussing the historical origin of the Sedition Act).

98 Ibid., at 354–355.

99 Sedition Act (Cap. 290), s. 4.

100 Ibid., at s. 3(3).

101 Lim, Lydia, Hussain, Zakir & Han, William, “Drawing the line on racist remarks” The Straits Times (24 September 2005)Google Scholar; Neo, Jaclyn Ling-Chien, “Seditious in Singapore! Free Speech and the Offence of Promoting Ill-Will and Hostility Between Different Racial Groups” (2011) S.J.L.S. at 356–357.Google Scholar

102 Kin, Chong Chee, “Racist bloggers jailed” The Straits Times (8 October 2005).Google Scholar

103 Ibid. (“one comment compared the Muslim religion to Satanism”).

104 Low, Aaron, “Online or off, if it fans hatred, govt will act” The Straits Times (18 September 2005).Google Scholar

105 Penal Code (Cap. 224), s. 298A.

106 Penal Code (Amendment) Bill, Parliament No. 11 Hansard Vol. 15 (2007) (Ho Peng Kee); Penal Code (Cap. 224) at s. 298.

107 Penal Code (Amendment) Bill, Parliament No. 11 Hansard Vol. 15 (2007) (Ho Peng Kee).

108 Ibid. (Ho Peng Kee).

109 Ibid. (Zaqy Mohamad; Ong Kian Min; Muhammad Faishal Ibrahim; Charles Chong; Lim Biow Chuan).

110 Ibid. (Teo Ho Pin).

111 Internal Security Act (Cap. 143).

112 Ibid., at s. 8B. After the Court of Appeal (the highest court) held that an illegally, irrationally or procedurally improper exercise of government power would trigger judicial review even for the broadly defined discretion of detention powers under the Internal Security Act, the Constitution and the Internal Security Act were amended to revert the law to the doctrine prior to that decision: Silverstein, Gordon, “Singapore: The Exception that Proves Rules Matter” in Ginsburg, Tom & Moustafa, Tamir eds., Rule by Law: The Politics of Courts in Authoritarian Regimes (Cambridge University Press, 2008) at 73 CrossRefGoogle Scholar, 79–81; Thio, Li-ann, “Lex Rex or Rex Lex? Competing Conceptions of the Rule of Law in Singapore” (2002) 20 UCLA Pac. Basin L.J. at 18, 58–63.Google Scholar

113 Shuaib, Farid Sufian, “Controlling Political Communication in the Blogosphere: Business as Usual in Malaysia” (2011) 16(1) Comms. L. 27, 28–29 Google Scholar (discussing similar laws in Malaysia).

114 Supra note 112.

115 Tan, Kevin Y.L., “Constitutionalism in Times of Economic Strife: Developments in Singapore” (2009) 4 Nat’l Taiwan U.L. Rev. 115 Google Scholar, 122; Nam, Tae Yul, “Singapore’s One-Party System: Its Relationship to Democracy and Political Stability” (1969) 42(4) Pacific Affairs 465 CrossRefGoogle Scholar, 472–473.

116 Thio, Li-ann, “Control, Co-optation and Co-operation: Managing Religious Harmony in Singapore’s Multi-ethnic, Quasi-Secular State” (2006) 33 Hastings Const. L.Q. at 240.Google Scholar

117 Lim, Lydia & Xueying, Li, “The legacy of 1987” The Straits Times (7 July 2007)Google Scholar; Tong, Chee Kiong, Rationalizing Religion: Religious Conversion, Revivalism, and Competition in Singapore Society (Koninklijke Brill, 2007) at 239 CrossRefGoogle Scholar.

118 Between 2001 and 2002, 36 people were detained by the ISD under the Internal Security Act for alleged involvement in planning a radical Islamist terrorist attack on Singapore: Febrica, Senia, “Securitizing Terrorism in Southeast Asia: Accounting for the Varying Responses of Singapore and Indonesia” (2010) 50(3) Asian Survey 569 CrossRefGoogle Scholar, 576–577. In February 2007, a law graduate was detained under the Internal Security Act for training for a militant jihad: Kwek, Ken, “Learn about Islam from credible sources” The Straits Times (16 June 2007).Google Scholar

119 Public Prosecutor v. Ong Kian Cheong [2009] SGDC 163.

120 Chong, Elena, “Couple admitted sending out tracts” The Straits Times (6 December 2008).Google Scholar

121 Public Prosecutor v. Ong Kian Cheong [2009] SGDC 163, at para. 4; Chong, Elena, “Couple go on trial for sedition” The Straits Times (5 December 2008).Google Scholar

122 Chong, Elena, “Couple go on trial for sedition” The Straits Times (5 December 2008).Google Scholar

123 Public Prosecutor v. Ong Kian Cheong [2009] SGDC 163, at paras. 4 & 16.

124 Ibid., at para. 6; Chong, Elena, “Couple go on trial for sedition” The Straits Times (5 December 2008).Google Scholar

125 Public Prosecutor v. Ong Kian Cheong [2009] SGDC 163, at paras. 17–19. This resulted in three visits by the couple to the MDA. In the third visit, the couple took home the tracts which were not found objectionable by MDA, though the couple denied being told why the tracts were detained. The wife also claimed that the husband “was not paying attention and occupied himself looking at the posters displayed in the office” when she was talking to the MDA officer: Ibid., at paras. 17–19. The couple had approached the case with a diminished role of the husband in the activities, i.e. involved only in the physical activity of posting: Ibid., at paras. 27, 43 & 61.

126 Ibid., at paras. 25–27 & 29–32; Chong, Elena, “Accused says he had not read offensive comics” The Straits Times (30 January 2009).Google Scholar Direct mailing as a means of spreading the gospel messages has been an established strategy of Christian evangelicalism in Singapore: Eng, Kuah-Pearce Khun, State, Society and Religious Engineering: Towards a Reformist Buddhism in Singapore (Eastern Universities Press, 2003) at 279–280.Google Scholar

127 Chong, Elena, “‘20,000’ tracts mailed over 7 years” The Straits Times (7 April 2009).Google Scholar

128 Public Prosecutor v. Ong Kian Cheong [2009] SGDC 163, at para. 35.

129 The couple testified that they did not identify themselves as senders on the envelopes because they did not see the need to communicate at all with the tract recipients: Ibid., at paras. 26 & 32. The judge agreed with the public prosecutor that the anonymity was intended to avoid detection: Ibid., at paras. 73 & 83.

130 Chong, Elena, “Couple admitted sending out tracts” The Straits Times (6 December 2008).Google Scholar

131 Quek, Carolyn, “Tracts ‘no different from da vinci code’” The Straits Times (11 March 2009).Google Scholar

132 Public Prosecutor v. Ong Kian Cheong [2009] SGDC 163, at paras. 55–56; Chong, Elena, “Booklets available in store, says lawyers” The Straits Times (29 January 2009).Google Scholar

133 Public Prosecutor v. Ong Kian Cheong [2009] SGDC 163, at paras. 28, 33; Chong, Elena, “Accused says he had not read offensive comics” The Straits Times (30 January 2009).Google Scholar Section 6(2) of the Sedition Act provides an affirmative defence of ignorance of publication’s seditious tendency, if there was no “want of due care or caution.”

134 Public Prosecutor v. Ong Kian Cheong [2009] SGDC 163, at para. 33 (The couple provided evidence by way of photographs taken in November 2008 of the tracts being sold at a local bookstore, although the judge noted that the couple had been ordering the tracts directly online from Chick Publications since 2000, and thus did not believed the couple’s defence that the offensive tracts were purchased at the local bookstore.).

135 Public Prosecutor v. Ong Kian Cheong [2009] SGDC 163, at paras. 44–66, 86; Quek, Carolyn, “Seditious tract duo jailed eight weeks” The Straits Times (11 June 2009).Google Scholar

136 Singh, Khushwant, “Jailed for ‘wounding feelings’ of Muslims” The Straits Times (7 August 2010).Google Scholar

137 Ibid.

138 Ibid.

139 See Abbas, Ahmad Nizam Bin, “The Islamic Legal System in Singapore” (2012) 21 Pac. Rim L. & Pol’y J. 163 Google Scholar, 167–171 (discussing the function and structure of MUIS).

140 Singh, Khushwant, “Jailed for ‘wounding feelings’ of Muslims” The Straits Times (7 August 2010).Google Scholar

141 The case was mentioned in passing in Neo, Jaclyn Ling-Chien, “Seditious in Singapore! Free Speech and the Offence of Promoting Ill-Will and Hostility Between Different Racial Groups” (2011) S.J.L.S. at 363.Google Scholar

142 Feng, Yen, “ISD calls up pastor for insensitive comments” The Straits Times (9 February 2010).Google Scholar For a background of Pastor Rony Tan, see Durai, Jennani, “The man behind the controversy” The Straits Times (9 February 2010).Google Scholar

143 Feng, Yen, “ISD calls up pastor for insensitive comments” The Straits Times (9 February 2010).Google Scholar

144 Ibid.

145 Ibid.

146 “ISD Acts” The Straits Times (9 February 2010).

147 Ibid.

148 Hou, Chua Hian, “Racist facebook postings: Three youths won’t be charged” The Straits Times (13 February 2010).Google Scholar

149 “Pastor’s Apology” The Straits Times (9 February 2010).

150 “ISD Acts” The Straits Times (9 February 2010).

151 Grace Chua, “Leaders of buddhist, taoist groups urge restraint” The Straits Times (9 February 2010) (Singapore Buddhist Federation’ secretary-general, Venerable Kwang Phing: “It is good that the authorities have looked at this matter, but this is a matter of national concern. We want to appeal to the public and the authorities to make sure there is no second time”; Singapore Taoist Federation chairman Tan Thiam Lye: “If (Pastor Tan) is sincere, we accept his apology, and hope this sort of thing does not happen again.”). See also Zhengjiang, Yang, “Mushi daoxian xianlan bugou chengyi [Apology by pastor is clearly not sufficiently sincere]” Lianhe Zaobao (13 February 2010)Google Scholar (a member of the public writing to the Chinese press opining that the online apology is not sufficiently sincere).

152 Feng, Yen, “Buddhist, Taoist leaders accept pastor’s apology” The Straits Times (10 February 2010)Google Scholar.

153 Feng, Yen, “Pastor: I’ve let many people down” The Straits Times (16 February 2010)Google Scholar.

154 Feng, Yen, “Buddhist, Taoist leaders accept pastor’s apology” The Straits Times (10 February 2010)Google Scholar.

155 Feng, Yen, “ISD looks into clip of sermon which mocked Taoist beliefs” The Straits Times (15 June 2010)Google Scholar.

156 Ibid.

157 Ibid. (statement by the Ministry of Home Affairs).

158 Ibid.

159 Feng, Yen, “New creation pastor apologises for ‘indiscretion’” The Straits Times (16 June 2010)Google Scholar.

160 Ibid.

161 Feng, Yen, “Pastor says sorry and gains a friend” The Straits Times (17 June 2010)Google Scholar.

162 Ibid.

163 Feng, Yen, “Different faiths to gather at Taoist festivity” The Straits Times (1 December 2010)Google Scholar.

164 E.g., Jaclyn Ling-Chien Neo, “Seditious in Singapore! Free Speech and the Offence of Promoting Ill-Will and Hostility Between Different Racial Groups” (2011) S.J.L.S.; Li-ann Thio, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S; Zewei, Zhong, “Racial and Religious Hate Speech in Singapore: Management, Democracy, and the Victim’s Perspective” (2009) 27 Sing. L. Rev. Google Scholar

165 Chin, Daryl, “Ex-foes link up to promote religious tolerance” The Straits Times (21 November 2010)Google Scholar; Hussain, Zakir, “Religious harmony: 20 years of keeping the peace” The Straits Times (24 July 2009)Google Scholar.

166 Tong, Chee Kiong, Rationalizing Religion: Religious Conversion, Revivalism, and Competition in Singapore Society (Koninklijke Brill, 2007) at 267 CrossRefGoogle Scholar.

167 Thio, Li-ann, “Control, Co-optation and Co-operation: Managing Religious Harmony in Singapore’s Multi-ethnic, Quasi-Secular State” (2006) 33 Hastings Const. L.Q. at 238 Google Scholar; DeBernardi, Jean, “Asia’s Antioch: Prayer and Proselytism in Singapore” in Hackett, Rosalind I.J. ed., Proselytization Revisited: Rights Talk, Free Markets and Culture Wars (Equinox, 2008) at 258 Google Scholar.

168 DeBernardi, Jean, “Asia’s Antioch: Prayer and Proselytism in Singapore” in Hackett, Rosalind I.J. ed., Proselytization Revisited: Rights Talk, Free Markets and Culture Wars (Equinox, 2008) at 259–260 Google Scholar; Thio, Li-ann, “Control, Co-optation and Co-operation: Managing Religious Harmony in Singapore’s Multi-ethnic, Quasi-Secular State” (2006) 33 Hastings Const. L.Q. at 238.Google Scholar

169 “Foolhardy to Take Harmony for Granted” The Straits Times (25 July2009) (Senior Minister and Coordinating Minister for National Security S. Jayakumar).

170 Thio, Li-ann, “Control, Co-optation and Co-operation: Managing Religious Harmony in Singapore’s Multi-ethnic, Quasi-Secular State” (2006) 33 Hastings Const. L.Q. at 237.Google Scholar

171 Penal Code (Amendment) Bill, Parliament No. 11 Hansard Vol. 15 (2007) (Ho Peng Kee).

172 Scolnicov, Anat, The Right to Religious Freedom in International Law (Routledge, 2011) at 206–207 Google Scholar; Mahoney, Kathleen, “Hate Speech, Equality, and the State of Canadian Law” (2009) 44 Wake Forest L. Rev. 321 Google Scholar, 325–326. See also Barnett, Brett A., Untangling the Web of Hate: Are Online “Hate Sites” Deserving of First Amendment Protection? (Cambria Press, 2007) at 134 Google Scholar (observing that religious speech was “a major component of the vast majority of the sampled hate sites.”).

173 Public Prosecutor v. Ong Kian Cheong [2009] SGDC 163, at para. 6.

174 Ibid., at para. 35.

175 Jack T. Chick, Set Free (Chick Publications, 2007), online: <http://www.chick.com/reading/tracts/1037/1037_01.asp> (last visited 1 February 2013).

176 Supra III.C.3 & III.C.4.

177 Feng, Yen, “ISD looks into clip of sermon which mocked Taoist beliefs” The Straits Times (15 June 2010)Google Scholar. The church reported that the church “stop reproducing” the particular sermons after the church reviewed their archive for insensitive materials after the Pastor Tan incident (February 2010), although the third party who uploaded the clip told the press that he received the materials from a Christian whom he presumed is the adherent of the New Creation church in May 2010: Ibid.

178 Xueying, Li & Kwek, Ken, “Say Aaah…men” The Straits Times (15 October 2005)Google Scholar.

179 Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S at 506–508.Google Scholar

180 Ibid., at 485–486; Thio, Li-ann, “Constitutional ‘Soft’ Law and Management of Religious Liberty and Order: The 2003 Declaration on Religious Harmony” (2004) S.J.L.S. at 422.Google Scholar

181 Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 485–488.Google Scholar

182 Ibid., at 485.

183 Thio, Li-ann, “The Passage of a Generation: Revisiting the Report of the 1966 Constitutional Commission” in Thio, Li-ann & Tan, Kevin Y.L. eds., Evolution of a Revolution: Forty Years of the Singapore Constitution (Routledge-Cavendish, 2009) at 7 Google Scholar (“In its genesis, the Singapore Constitution was not a product of mature deliberation or a broad-based popular, consultative process.”).

184 Ibid., at 11–12.

185 While statistics on the English literacy of the population during that period is not readily available, it is telling that even after nearly two decades of concerted government efforts in promoting the English language, only 33.7% are literate in English in the 1970 population census, and 56.6% indicating comprehension of English in a 1975 survey: Gopinathan, S., “Singapore Language Policies: Strategies for a Plural Society” (1979) 1979 Southeast Asian Affairs 280 CrossRefGoogle Scholar, 282; Kuo, Eddie C.Y., “Multilingualism and Mass Media Communications in Singapore” (1978) 18(10) Asian Survey 1067 CrossRefGoogle Scholar, 1068.

186 “Report of the Constitutional Commission 1966” in Lee, Kevin Tan Yew et al., Constitutional Law in Malaysia & Singapore (Malayan Law Journal, 1991)Google Scholar, Appendix D, para. 14.

187 Ibid., at para. 38.

188 “Federation of Malaya Constitutional Commission, 1956–1957 Report” in Lee, Kevin Tan Yew et al., Constitutional Law in Malaysia & Singapore (Malayan Law Journal, 1991)Google Scholar, Appendix A, para. 162 (It was a one-liner: “And we recommend (art 11) that freedom of religion should be guaranteed to every person including the right to profess practice and propagate his religion subject to the requirements of public order, health and morality, and that subject also to these requirements, each religious groups should have the right to manage its own affairs, to maintain religious or charitable institutions including schools, and to hold property for these purposes (art 12).”). The main debate on religion is about whether Islam should be designated as the state religion: Ibid., at para. 169.

189 Neufeldt, Robert W., “To Convert or Not to Convert: Legal and Political Dimensions of Conversion in Independent India” in Baird, Robert D. ed., Religion and Law in Independent India, 2nd ed. (Manohar, 2005) at 383–388 Google Scholar; Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 494–496 Google Scholar; Prasad De, Krishna, Religious Freedom Under the Indian Constitution (Minerva Associates, 1977) at 46–47 Google Scholar. See also Mahajan, Gurpreet, “Religion and the Indian Constitution: Questions of Separation and Equality” in Bhargava, Rajeev ed., Politics and Ethics of the Indian Constitution (Oxford University Press, 2008) at 297 Google Scholar (discussing the broader political backdrop and issues underpinning the Indian constitutional debate of religion).

190 “Report of the Constitutional Commission 1966” in Lee, Kevin Tan Yew et al., Constitutional Law in Malaysia & Singapore (Malayan Law Journal, 1991)Google Scholar, Appendix D, para. 38.

191 See Thio, Li-ann, “‘It Is a Little Known Legal Fact”: Originalism, Customary Human Rights Law and Constitutional Interpretation” (2010) 2010 S.J.L.S. 558 Google Scholar, 569–570 (arguing for originalism in judicial interpretation of the Singapore Constitution). C.f., Jen, Yap Po, “Constitutionalising Capital Crimes: Judicial Virtue or ‘Originalism’ Sin?” (2011) 2011 S.J.L.S. 281 Google Scholar (rebutting Thio on the normative desirability of originalism in the context of Singapore).

192 Neufeldt, Robert W., “To Convert or Not to Convert: Legal and Political Dimensions of Conversion in Independent India” in Baird, Robert D. ed., Religion and Law in Independent India, 2nd ed. (Manohar, 2005) at 388–398 Google Scholar (discussing the relevant legislature at the three Indian provinces and the subsequent upholding by the courts); Baird, Robert D., “Traditional Values, Government Values, and Religious Conflict in Contemporary India” (1988) 1988 B.Y.U.L. Rev. 337 Google Scholar, 351–354 (discussing the relevant legislature at the three Indian provinces and the subsequent upholding by the courts); Huff, James Andrew, “Religious Freedom in India and Analysis of the Constitutionality of Anti-Conversion Laws” (2009) 10 Rutgers J.L. & Religion 3, 7–13 Google Scholar & 35–44.

193 Tey, Tsun Hang, “Judicial Internalizing of Singapore’s Supreme Political Ideology” (2010) 40 Hong Kong L. J. 293, 320 Google Scholar; Thio, Li-ann, “Control, Co-optation and Co-operation: Managing Religious Harmony in Singapore’s Multi-ethnic, Quasi-Secular State” (2006) 33 Hastings Const. L.Q. 209–210.Google Scholar

194 Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S at 502.Google Scholar

195 Ibid., at 504.

196 Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S at 504–505.Google Scholar

197 Goh, William, “Constant vigilance the answer” The Straits Times (11 February 2010)Google Scholar; Jungang, Wu, “Quebao zhongjiao hexie de youxing zhi shou [The visible hand that ensures religious harmony]” Lianhe Zaobao (10 February 2010)Google Scholar.

198 Feng, Yen, “Buddhist, Taoist leaders accept pastor’s apology” The Straits Times (10 February 2010)Google Scholar; “Need to deal with such problems quickly: PM” The Straits Times (16 February 2010); Beng, Kor Kian, “Don’t trivialise beliefs of others: SM Goh” The Straits Times (14 February 2010)Google Scholar.

199 Hou, Chua Hian, “Racist facebook postings: Three youths won’t be charged” The Straits Times (13 February 2010)Google Scholar.

200 Supra III.B.2.d.

201 Supra III.C.4.

202 Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 503.Google Scholar See also Thio, Li-ann, “Relational Constitutionalism and the Management of Religious Disputes: the Singapore ‘Secularism with a Soul’ Model” (2012) Oxford J. L. & Religion 1, 19–20.Google Scholar

203 “What Others Say About the Incident” The Straits Times (10 February 2010).

204 “Statements from Buddhist and Taoist Federations and DPM Wong Kan Seng” The Straits Times (10 February 2010).

205 DeBernardi, Jean, “Asia’s Antioch: Prayer and Proselytism in Singapore” in Hackett, Rosalind I.J. ed., Proselytization Revisited: Rights Talk, Free Markets and Culture Wars (Equinox, 2008) at 265 Google Scholar.

206 Eng, Kuah-Pearce Khun, State, Society and Religious Engineering: Towards a Reformist Buddhism in Singapore (Eastern Universities Press, 2003) at 272–277.Google Scholar

207 DeBernardi, Jean, “Asia’s Antioch: Prayer and Proselytism in Singapore” in Hackett, Rosalind I.J. ed., Proselytization Revisited: Rights Talk, Free Markets and Culture Wars (Equinox, 2008) at 266–267 Google Scholar; Hussain, Zakir, “Religious harmony: 20 years of keeping the peace” The Straits Times (24 July 2009)Google Scholar.

208 Hussain, Zakir, “Religious harmony: 20 years of keeping the peace” The Straits Times (24 July 2009)Google Scholar (“Ms Angie Monksfield, president of the Buddhist Fellowship, told Insight that the notice [about MHRA and notifying authorities] was put up ‘in response to members’ complaints [of unwanted proselytization and idol-smashing]…We’ve received complaints for years; we finally decided to do something about it.”).

209 Nirmala, M., “Keeping faith – And celebrating differences” The Straits Times (12 May 2001)Google Scholar.

210 Feng, Yen, “Pastor says sorry and gains a friend” The Straits Times (17 June 2010)Google Scholar; Feng, Yen, “Buddhist, Taoist leaders accept pastor’s apology” The Straits Times (10 February 2010)Google Scholar.

211 Bibas, Stephanos & Bierschbach, Richard A., “Integrating Remorse and Apology into Criminal Procedure” (2004) 114 Yale L. Rev. 114 Google Scholar, 114.

212 Sloane, Robert D., “The Expressive Capacity of International Punishment: the Limits of the National Law Analogy and the Potential of International Criminal Law” (2007) 43 Stan. J. Int’l L. 39 Google Scholar, 86; Sarnoff, Susan, “Restoring Justice to the Community: A Realistic Goal?” (2001) 65-JUN Fed. Probation 33 Google Scholar, 34.

213 Lester, Gillian, “Can Joe the Plumber Support Redistribution? Law, Social Preferences, and Sustainable Policy Design” (2011) 64 Tax L. Rev. 313 Google Scholar, 373. See Minow, Martha, “Education for Co-existence” (2002) 44 Ariz. L. Rev. 1, 13–15 Google Scholar (discussing the relatively successful integration experimental program in Israel for Jews and Palestinian Arab).

214 Mathews, Mathew, “Negotiating Christianity with Other Religions: The Views of Christian Clergymen in Singapore” in Eng, Lai Ah ed., Religious Diversity in Singapore (Institute of Southeast Asian Studies, 2008) at 571 Google Scholar, 581–582.

215 Lester, Gillian, “Can Joe the Plumber Support Redistribution? Law, Social Preferences, and Sustainable Policy Design” (2011) 64 Tax L. Rev. at 373.Google Scholar

216 Bibas, Stephanos & Bierschbach, Richard A., “Integrating Remorse and Apology into Criminal Procedure” (2004) 114 Yale L. Rev. at 143.Google Scholar

217 Febrica, Senia, “Securitizing Terrorism in Southeast Asia: Accounting for the Varying Responses of Singapore and Indonesia” (2010) 50(3) Asian Survey at 573–581 CrossRefGoogle Scholar; Hang, Tey Tsun, “Excluding Religion from Politics and Enforcing Religious Harmony – Singapore-Style” (2008) 2008 S.J.L.S. at 120–125.Google Scholar

218 Adams, Russell, “Tensions still on boil in mosque fight” Wall Street Journal (13 September 2010) at A5 Google Scholar; Bravin, Jess & Kendall, Brent, “Supreme court wades into funeral protests” Wall Street Journal (9 March 2010) at A2.Google Scholar

219 Supra II.B.2.a & II.B.2.d.

220 Hwa, Ang Peng, “All S’poreans have role, not just leaders” The Straits Times (11 March 2010)Google Scholar.

221 Thio, Li-ann, “Constitutional ‘Soft’ Law and Management of Religious Liberty and Order: The 2003 Declaration on Religious Harmony” (2004) S.J.L.S. at 423 Google Scholar; Thio, Li-ann, “Control, Co-optation and Co-operation: Managing Religious Harmony in Singapore’s Multi-ethnic, Quasi-Secular State” (2006) 33 Hastings Const. L.Q. 239.Google Scholar

222 Thio, Li-ann, “Relational Constitutionalism and the Management of Religious Disputes: the Singapore ‘Secularism with a Soul’ Model” (2012) Oxford J. L. and Religion at 22–24 Google Scholar; Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 513.Google Scholar

223 Infra V.D.

224 Hang, Tey Tsun, “Excluding Religion from Politics and Enforcing Religious Harmony – Singapore-Style” (2008) 2008 S.J.L.S. at 137 Google Scholar; Thio, Li-ann, “Control, Co-optation and Co-operation: Managing Religious Harmony in Singapore’s Multi-ethnic, Quasi-Secular State” (2006) 33 Hastings Const. L.Q. at 233.Google Scholar

225 Supra III.A.

226 Tan, Alex, “Double standards: In sedition case and DBS charity tie-up” The Straits Times (9 December 2008)Google Scholar (citing examples of the Da Vinci Code and Richard Dawkin’s The God Delusion and arguing that “it is disheartening that this action [of maintaining the fragile religious balance] is not applied universally to all. There seems to be a greater tolerance of ‘attacks’ on Christianity than other major religions”). Although it is worth noting that Martin Scorsese’s film, The Last Temptation of Christ, was previously banned in Singapore for offending Christian’s sensitivities: Tan, Eugene K. B., “Keeping God in Place: The Management of Religion in Singapore” in Eng, Lai Ah ed., Religious Diversity in Singapore (Institute of Southeast Asian Studies, 2008) at 67 Google Scholar.

227 Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 505.Google Scholar See also Thio, Li-ann, “Relational Constitutionalism and the Management of Religious Disputes: the Singapore ‘Secularism with a Soul’ Model” (2012) Oxford J. L. and Religion at 20.Google Scholar

228 Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 512.Google Scholar See also Thio, Li-ann, “Relational Constitutionalism and the Management of Religious Disputes: the Singapore ‘Secularism with a Soul’ Model” (2012) Oxford J. L. and Religion at 20.Google Scholar

229 Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 512 Google Scholar (“[l]eaders of majority religious groups must demonstrate a sense of proportion, tolerance and forgiveness, towards leaders from minority religions who commit acts or make statements they find offensive, but who show genuine contribution”).

230 Thio, Li-ann, “Relational Constitutionalism and the Management of Religious Disputes: the Singapore ‘Secularism with a Soul’ Model” (2012) Oxford J. L. and Religion at 1 nn. 1 & 19.Google Scholar See also Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 503 Google Scholar (“The response of representatives of majority religious groups.”).

231 One possible reason is that she was merely following the categorisation used in the table in the executive summary of the Singapore census 2010, which has a category “Buddhism/Taoism” with a sub-categories of “Buddhism” and “Taoism.” Other religions such as “Christianity”, “Islam” exist as independent category without any sub-category: Singapore Department of Statistics, Census of Population 2010 Statistical Release 1: Demographic Characteristics, Education, Language and Religion (2011) at 13. No particular reason or significance is attached to this categorisation by the census report. In the actual table, “Buddhism” and “Taoism” are independent categories, with “Taoism” including traditional Chinese beliefs: Ibid., at 154–155.

232 Koh, Jaime & Ho, Stephanie, Culture and Customs of Singapore and Malaysia (Greenwood Press, 2009) at 32 Google Scholar; Tamney, Joseph B. & Hassan, Riaz, Religious Switching in Singapore: A Study of Religious Mobility (Select Books, 1987) at 6.Google Scholar

233 Unlike the Pastor Rony Tan incident, the Buddhist Federations was not involved in Pastor Mark Ng incident. Pastor Mark Ng only went to the Taoist Federations to apologise.

234 Singapore Department of Statistics, Census of Population 2010 Statistical Release 1: Demographic Characteristics, Education, Language and Religion (2011) at 16.Google Scholar

235 Ibid., at 159–160.

236 Singapore Department of Statistics, Census of Population 2010 Statistical Release 2: Households and Housing (2011) at xi.Google Scholar

237 Geok, Leow Bee, Census of Population 2000: Advance Data Release (2001) at 38.Google Scholar

238 Clammer, John, The Sociology of Singapore Religion: Studies in Christianity and Chinese Culture (Chopmen, 1991) at 25 Google Scholar; Eng, Kuah-Pearce Khun, State, Society and Religious Engineering: Towards a Reformist Buddhism in Singapore (Eastern Universities Press, 2003) at 269 Google Scholar.

239 Singapore Department of Statistics, Census of Population 2010 Statistical Release 1: Demographic Characteristics, Education, Language and Religion (2011) at 16.Google Scholar

240 Ibid., at 159–160.

241 Geok, Leow Bee, Census of Population 2000: Advance Data Release (2001) at 38–40.Google Scholar The underrepresentation is even more severe in the 1960s and 1970s: Clammer, John, Singapore: Ideology Society Culture (Chopmen, 1985) at 122–123.Google Scholar

242 With a population ratio of 10.9%, Taoists only made up 5.3% of those holding university degrees and 6.4% of those residing in private property. Buddhists, with 33.3% of the population, made up 23.6% of those holding university degrees and 11.5% of those residing in private property: Singapore Department of Statistics, Census of Population 2010 Statistical Release 1: Demographic Characteristics, Education, Language and Religion (2011) at 16 Google Scholar & 159–160.

243 See Thio, Li-ann, “Recent Constitutional Development: of Shadows and Whips, Race, Rifts and Rights, Terror and Tudungs, Women and Wrongs” (2002) 2002 S.J.L.S. 328, 329–334 Google Scholar (discussing Singapore parliamentary system).

244 Holmes, Sam, “In Singapore, faith debate simmers as election nears” Wall Street Journal (7 May 2011) at A9.Google Scholar

245 Ibid.; “Li zongli: Zhengfu juebu yunxu guanyuan zhongjiao xingyang yingxiang zhengce [PM Lee: The government absolutely does not permit the religious faith of government officials to affect policy]” Lianhe Zaobao (17 April 2011) at 10.

246 Mathews, Mathew, “Accommodating Relationship: The Church and State in Singapore” in Bautista, Julius & Lim, Francis Khek Gee eds., Christianity and the State in Asia (Routledge, 2009) at 187 Google Scholar; DeBernardi, Jean, “Asia’s Antioch: Prayer and Proselytism in Singapore” in Hackett, Rosalind I.J. ed., Proselytization Revisited: Rights Talk, Free Markets and Culture Wars (Equinox, 2008) at 257.Google Scholar

247 Lim, Lydia, “Religion should help people cope with change: PM” The Straits Times (23 June 2003)Google Scholar; Xueying, Li & Lin, Keith, “Does god get in the way of social cohesion” The Straits Times (21 October 2006)Google Scholar.

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249 Tan, Jason, “The Politics of Religious Knowledge in Singapore Secondary Schools” in Cornbleth, Catherine ed., Curriculum Politics, Policy, Practice: Cases in Comparative Context (State University of New York Press, 2000) at 77 Google Scholar, 97 n.1.

250 Eng, Kuah-Pearce Khun, State, Society and Religious Engineering: Towards a Reformist Buddhism in Singapore (Eastern Universities Press, 2003) at 282 Google Scholar (the first Buddhist mission secondary school was set up in 1984 to complement the existing two Buddhist mission primary schools); Tamney, Joseph B. & Hassan, Riaz, Religious Switching in Singapore: A Study of Religious Mobility (Select Books, 1987) at 43 Google Scholar.

251 Constitution of the Republic of Singapore (1999 Rev. Ed), art. 15(4); Xueying, Li & Kwek, Ken, “Say Aaah…men” The Straits Times (15 October 2005)Google Scholar.

252 Tan, Jason, “The Politics of Religious Knowledge in Singapore Secondary Schools” in Cornbleth, Catherine ed., Curriculum Politics, Policy, Practice: Cases in Comparative Context (State University of New York Press, 2000) at 80 Google Scholar; Ling, Trevor, “Religion” in Sandhu, Kernial Singh & Wheatley, Paul eds., Management of Success: the Moulding of Modern Singapore (Singapore: Institute of Southeast Asian Studies, 1989) at 692 Google Scholar, 701. The Ministry of Education saw the need to “remind” missions schools in 1992 of the prohibition against compulsion in religious services: Devan, Janadas, “Secularism – Not from theory but bloody history” The Straits Times (24 November 2007)Google Scholar.

253 Tong, Chee Kiong, Rationalizing Religion: Religious Conversion, Revivalism, and Competition in Singapore Society (Koninklijke Brill, 2007) at 102 CrossRefGoogle Scholar; Tamney, Joseph B. & Hassan, Riaz, Religious Switching in Singapore: A Study of Religious Mobility (Select Books, 1987) at 12–13 Google Scholar; Clammer, John, Singapore: Ideology Society Culture (Chopmen, 1985) at 38 Google Scholar; Eng, Kuah-Pearce Khun, State, Society and Religious Engineering: Towards a Reformist Buddhism in Singapore (Eastern Universities Press, 2003) at 268 Google Scholar.

254 Ling, Tan-Chow May, Pentecostal Theology for the Twenty-First Century: Engaging with Multi-Faith Singapore (Ashgate, 2007) at 10 Google Scholar.

255 “Taoists Agree on Common Festive Day” The Straits Times (30 April 2001) at H3.

256 Tong, Chee Kiong, Rationalizing Religion: Religious Conversion, Revivalism, and Competition in Singapore Society (Koninklijke Brill, 2007) at 249 CrossRefGoogle Scholar; Eng, Kuah-Pearce Khun, State, Society and Religious Engineering: Towards a Reformist Buddhism in Singapore (Eastern Universities Press, 2003) at 196–197 Google Scholar. For general discussion of the curriculum, see Thio, Li-ann, “Control, Co-optation and Co-operation: Managing Religious Harmony in Singapore’s Multi-ethnic, Quasi-Secular State” (2006) 33 Hastings Const. L.Q. at 219–221 Google Scholar; Tan, Jason, “The Politics of Religious Knowledge in Singapore Secondary Schools” in Cornbleth, Catherine ed., Curriculum Politics, Policy, Practice: Cases in Comparative Context (State University of New York Press, 2000)Google Scholar.

257 Neo, Jaclyn Ling-Chien, “The Protection of Minorities and the Constitution: A Judicious Balance?” in Thio, Li-ann & Tan, Kevin Y.L. eds., Evolution of a Revolution: Forty Years of the Singapore Constitution (Routledge-Cavendish, 2009) at 234 Google Scholar, 247.

258 Neo, Jaclyn Ling-Chien, “Seditious in Singapore! Free Speech and the Offence of Promoting Ill-Will and Hostility Between Different Racial Groups” (2011) S.J.L.S. at 364–365.Google Scholar

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260 Neo, Jaclyn Ling-Chien, “The Protection of Minorities and the Constitution: A Judicious Balance?” in Thio, Li-ann & Tan, Kevin Y.L. eds., Evolution of a Revolution: Forty Years of the Singapore Constitution (Routledge-Cavendish, 2009) at 254 Google Scholar; Thio, Li-ann, “‘She’s a Woman But She Acts Very Fast’: Women, Religion and Law in Singapore” in Whiting, Amanda & Evans, Carolyn eds., Mixed Blessings: Laws, Religions, and Women’s Rights in the Asia-Pacific Region (Martinus Nijhoff Publishers, 2006) at 268 Google Scholar. The exemption is subject to meeting government education standards for secular subjects such as English, Maths and Sciences. For a discussion of the historical evolution of Madrasah, see Buang, Sa’eda, “Religious Education as Locus of Curriculum: A Brief Inquiry into Madrasah Curriculum in Singapore” in Eng, Lai Ah ed., Religious Diversity in Singapore (Institute of Southeast Asian Studies, 2008) at 342 Google Scholar.

261 Osman, Ahmad, “Boosting integration in aftermath of tudung row” The Straits Times (10 February 2002)Google Scholar; Thio, Li-ann, “Recent Constitutional Development: of Shadows and Whips, Race, Rifts and Rights, Terror and Tudungs, Women and Wrongs” (2002) S.J.L.S. at 364 Google Scholar; Thio, Li-ann, “Control, Co-optation and Co-operation: Managing Religious Harmony in Singapore’s Multi-ethnic, Quasi-Secular State” (2006) 33 Hastings Const. L.Q. at 214–215.Google Scholar

262 Thio, Li-ann, “Constitutional ‘Soft’ Law and Management of Religious Liberty and Order: The 2003 Declaration on Religious Harmony” (2004) S.J.L.S. at 428 Google Scholar; Thio, Li-ann, “Control, Co-optation and Co-operation: Managing Religious Harmony in Singapore’s Multi-ethnic, Quasi-Secular State” (2006) 33 Hastings Const. L.Q. at 218 Google Scholar; Clammer, John, Singapore: Ideology Society Culture (Chopmen, 1985) at 45 Google Scholar.

263 Neo, Jaclyn Ling-Chien, “The Protection of Minorities and the Constitution: A Judicious Balance?” in Thio, Li-ann & Tan, Kevin Y.L. eds., Evolution of a Revolution: Forty Years of the Singapore Constitution (Routledge-Cavendish, 2009) at 247 Google Scholar; Thio, Li-ann, “‘She’s a Woman But She Acts Very Fast’: Women, Religion and Law in Singapore” in Whiting, Amanda & Evans, Carolyn eds., Mixed Blessings: Laws, Religions, and Women’s Rights in the Asia-Pacific Region (Martinus Nijhoff Publishers, 2006) at 268 Google Scholar; Tan, Eugene K. B., “Keeping God in Place: The Management of Religion in Singapore” in Eng, Lai Ah ed., Religious Diversity in Singapore (Institute of Southeast Asian Studies, 2008) at 62 Google Scholar.

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267 Mahlmann, Matthias, “Free Speech and the Rights of Religion” in Sajó, András ed., Censorial Sensitivities: Free Speech and Religion in a Fundamentalist World (Eleven International Publishing, 2007) at 41 Google Scholar, 67; Teitel, Ruti, “Militating Constitutional Democracy: Comparative Perspectives” in Sajó, András ed., Censorial Sensitivities: Free Speech and Religion in a Fundamentalist World (Eleven International Publishing, 2007) at 71 Google Scholar, 77.

268 Rougeau, Vincent D., Christians in the American Empire: Faith and Citizenship in the New World Order (Oxford University Press, 2008) at 101–109 CrossRefGoogle Scholar; Chandhoke, Neera, Beyond Secularism: The Rights of Religious Minorities (Oxford University Press, 1999) at 143–165.Google Scholar

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270 Zewei, Zhong, “Racial and Religious Hate Speech in Singapore: Management, Democracy, and the Victim’s Perspective” (2009) 27 Sing. L. Rev. at 52–53 Google Scholar & 56.

271 Muslims made up 13 of the 99 members of parliament: <http://www.parliament.gov.sg/list-of-current-mps> (last visited 20 July 2012).

272 Available at: <http://www.cabinet.gov.sg/content/cabinet/appointments.html> (last visited 20 July 2012).

273 Supra II.B.

274 DeBernardi, Jean, “Asia’s Antioch: Prayer and Proselytism in Singapore” in Hackett, Rosalind I.J. ed., Proselytization Revisited: Rights Talk, Free Markets and Culture Wars (Equinox, 2008) at 256–257 Google Scholar; Ling, Tan-Chow May, Pentecostal Theology for the Twenty-First Century: Engaging with Multi-Faith Singapore (Ashgate, 2007) at 22 Google Scholar; Xueying, Li, “Reaping a rich harvest of converts” The Straits Times (16 July 2005)Google Scholar; Mathews, Mathew, “Negotiating Christianity with Other Religions: The Views of Christian Clergymen in Singapore” in Eng, Lai Ah ed., Religious Diversity in Singapore (Institute of Southeast Asian Studies, 2008) at 585–590.Google Scholar

275 DeBernardi, Jean, “Asia’s Antioch: Prayer and Proselytism in Singapore” in Hackett, Rosalind I.J. ed., Proselytization Revisited: Rights Talk, Free Markets and Culture Wars (Equinox, 2008) at 257 Google Scholar; Mathews, Mathew, “Negotiating Christianity with Other Religions: The Views of Christian Clergymen in Singapore” in Eng, Lai Ah ed., Religious Diversity in Singapore (Institute of Southeast Asian Studies, 2008) at 585–586 Google Scholar. For observations and critique of the evolution of American Christians’ attitude towards missions and proselytisation, see Greenberg, Brad A., “How missionaries lost their chariots of fire” Wall Street Journal (2 July 2010)Google Scholar at W9.

276 Mathews, Mathew, “Accommodating Relationship: The Church and State in Singapore” in Bautista, Julius & Lim, Francis Khek Gee eds., Christianity and the State in Asia (Routledge, 2009) at 188 Google Scholar; Ling, Tan-Chow May, Pentecostal Theology for the Twenty-First Century: Engaging with Multi-Faith Singapore (Ashgate, 2007) at 21–23.Google Scholar

277 Chua, Edmond, “Bishop says preaches must watch sermon content, presentation” Christian Post (Sing. ed.) (23 September 2010)Google Scholar, online: <http://sg.christianpost.com/dbase.php?cat=church&id=2594> (last visited 1 February 2013); “Christianity: Winning Others or Helping Others Win?” Christian Post (Sing. ed.) (28 June 2010), online: <http://sg.christianpost.com/dbase/editorial/732/section/1.htm> (last visited 1 February 2013).

278 Ng, Nathanael, “Be sensitive, but do not compromise: Pastor” Christian Post (Sing. ed.) (23 February 2010)Google Scholar, online <http://sg.christianpost.com/dbase.php?cat=church&id=2444> (last visited 1 February 2013) (Cornerstone Community Church senior pastor Rev. Yang Tuck Yoong: “When preaching the Gospel, we must not dilute, adulterate or compromise on the potency of the Word; because it’s Truth,”); Roland Chia, “Christians do not hold that all religions are the same” Christian Post (Sing. ed.) (17 February 2010), online: <http://sg.christianpost.com/dbase/editorial/593/section/1.htm> (last visited 1 February 2013); Huat, Tan Cheng, “What would Jesus do (WWJD)?” Christian Post (Sing. ed.) (15 March 2010)Google Scholar, online: <http://sg.christianpost.com/dbase/editorial/604/section/1.htm> (last visited 1 February 2013) (“A series of happenings in recent weeks [Pastor Rony incident is in February 2010] drives me to rethink if our faith has reached such a point where the fear of imposing our views on others has gradually led us to a state where we do not profess clearly what we believe in.”).

279 Supra IV.A.

280 Supra IV.A.

281 Supra V.A.

282 Tan, Kevin Y.L. & Thio, Li-ann, Constitutional Law in Malaysia and Singapore (Butterworths, 1997) at 876 Google Scholar; Thio, Li-ann, “Constitutional ‘Soft’ Law and Management of Religious Liberty and Order: The 2003 Declaration on Religious Harmony” (2004) S.J.L.S. at 422.Google Scholar

283 Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 490 Google Scholar & n. 38.

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299 Supra III.A.

300 Tong, Chee Kiong, Rationalizing Religion: Religious Conversion, Revivalism, and Competition in Singapore Society (Koninklijke Brill, 2007) at 192 CrossRefGoogle Scholar & 267–268; Clammer, John, The Sociology of Singapore Religion: Studies in Christianity and Chinese Culture (Chopmen, 1991) at 74–77 Google Scholar; Eng, Kuah-Pearce Khun, State, Society and Religious Engineering: Towards a Reformist Buddhism in Singapore (Eastern Universities Press, 2003) at 283 Google Scholar.

301 Supra notes 289–293 and accompany text.

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304 Claerhout, Sarah & Roover, Jakob De, “Conversion of the World: Proselytization in India and the Universalization of Christianity” in Hackett, Rosalind I.J. ed., Proselytization Revisited: Rights Talk, Free Markets and Culture Wars (Equinox, 2008) at 53 Google Scholar, 65. For a discussion on the exclusivity under Islam, see Sharkey, Heather J., “Muslim Apostasy, Christian Conversion, and Religious Freedom in Egypt: A Study of American Missionaries, Western Imperialism, and Human Rights Agendas” in Hackett, Rosalind I.J. ed., Proselytization Revisited: Rights Talk, Free Markets and Culture Wars (Equinox, 2008) at 139 Google Scholar, 141.

305 Claerhout, Sarah & Roover, Jakob De, “Conversion of the World: Proselytization in India and the Universalization of Christianity” in Hackett, Rosalind I.J. ed., Proselytization Revisited: Rights Talk, Free Markets and Culture Wars (Equinox, 2008) at 65 Google Scholar. See generally Nigosian, S.A., World Religions: A Historical Approach, 3rd ed. (Bedford/St. Martin’s, 2000) at 414–419 Google Scholar (discussing how the different religions differ in their conceptions of religious path and goals).

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308 Conkle, Daniel O., “Religious Truth, Pluralism, and Secularization: The Shaking Foundations of American Religious Liberty” (2011) 32 Cardozo L. Rev. at 1764–1765 Google Scholar (noting how Buddhism’s de-emphasis of universal truth contributes to its more tolerant attitude towards other faith).

309 See generally Cho, Francisca, “Leaping into the Boundless: A Daoist Reading of Comparative Religious Ethics” (1998) 26(1) The Journal of Religious Ethics 139 Google Scholar (discussing and noting Taoism nuanced approach towards truth, reflecting at page 163 “[T]aoist view of reality which avers that knowledge is never fixed.”).

310 Claerhout, Sarah & Roover, Jakob De, “Conversion of the World: Proselytization in India and the Universalization of Christianity” in Hackett, Rosalind I.J. ed., Proselytization Revisited: Rights Talk, Free Markets and Culture Wars (Equinox, 2008) at 63–64 Google Scholar (“Islam and Christianity are each other’s rivals in the restoration of divine truth, while the Hindu, Buddhist and Jain traditions are idolatry or false religion.”); Ling, Tan-Chow May, Pentecostal Theology for the Twenty-First Century: Engaging with Multi-Faith Singapore (Ashgate, 2007) at 22–23 Google Scholar; DeBernardi, Jean, “Asia’s Antioch: Prayer and Proselytism in Singapore” in Hackett, Rosalind I.J. ed., Proselytization Revisited: Rights Talk, Free Markets and Culture Wars (Equinox, 2008) at 265 Google Scholar; Eng, Kuah-Pearce Khun, State, Society and Religious Engineering: Towards a Reformist Buddhism in Singapore (Eastern Universities Press, 2003) at 272–277.Google Scholar

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313 Chua, Grace, “Leaders of Buddhist, Taoist groups urge restraint” The Straits Times (9 February 2010)Google Scholar.

314 “We Need to Focus More on Common Spaces” The Straits Times (21 October 2006).

315 “Foster Harmony” The Straits Times (3 May 2009).

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317 Claerhout, Sarah & Roover, Jakob De, “Conversion of the World: Proselytization in India and the Universalization of Christianity” in Hackett, Rosalind I.J. ed., Proselytization Revisited: Rights Talk, Free Markets and Culture Wars (Equinox, 2008) at 69 Google Scholar.

318 Thio, Li-ann, “Control, Co-optation and Co-operation: Managing Religious Harmony in Singapore’s Multi-ethnic, Quasi-Secular State” (2006) 33 Hastings Const. L.Q. at 202.Google Scholar

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320 Hill, Michael, “The Making of a Moral Panic: Religion and State in Singapore” in Beckford, James A. & Richardson, James T. eds., Challenging Religion (Routledge, 2003) at 114 CrossRefGoogle Scholar, 125. See also Thio, Li-ann, “Control, Co-optation and Co-operation: Managing Religious Harmony in Singapore’s Multi-ethnic, Quasi-Secular State” (2006) 33 Hastings Const. L.Q. at 202.Google Scholar

321 E.g., Hinshaw, Drew, “Nigeria torn by rising religious violence” Wall Street Journal (12 January 2012) at A12 Google Scholar; Barta, Patrick, “Suicide attack strikes Church in Indonesia” Wall Street Journal (26 September 2011) at A10.Google Scholar

322 Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 493.Google Scholar

323 Neo, Jaclyn Ling-Chien, “Seditious in Singapore! Free Speech and the Offence of Promoting Ill-Will and Hostility Between Different Racial Groups” (2011) S.J.L.S. at 371–372.Google Scholar

324 Ibid., at 365–372.

325 Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 488.Google Scholar

326 One material distributed in the Ong Kian Cheong case stated that there is a “very dangerous religion called ‘Islam’” that is “spreading into our neighborhood” (emphasis original): Jack T. Chick, Little Bride (Chick Publications, 2004), online: <http://www.chick.com/reading/tracts/1054/1054_01.asp> (last visited 1 February 2013).

327 Mathews, Mathew, “Accommodating Relationship: The Church and State in Singapore” in Bautista, Julius & Lim, Francis Khek Gee eds., Christianity and the State in Asia (Routledge, 2009) at 188 Google Scholar; Ling, Tan-Chow May, Pentecostal Theology for the Twenty-First Century: Engaging with Multi-Faith Singapore (Ashgate, 2007) at 21–23.Google Scholar

328 Mathews, Mathew, “Accommodating Relationship: The Church and State in Singapore” in Bautista, Julius & Lim, Francis Khek Gee eds., Christianity and the State in Asia (Routledge, 2009) at 188 Google Scholar.

329 Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 493.Google Scholar

330 Mathews, Mathew, “Negotiating Christianity with Other Religions: The Views of Christian Clergymen in Singapore” in Eng, Lai Ah ed., Religious Diversity in Singapore (Institute of Southeast Asian Studies, 2008) at 581–582 Google Scholar; Xueying, Li, “Clergy ‘wary of inter-faith talks’” The Straits Times (3 September 2008)Google Scholar.

331 Ling, Tan-Chow May, Pentecostal Theology for the Twenty-First Century: Engaging with Multi-Faith Singapore (Ashgate, 2007) at 21 Google Scholar.

332 DeBernardi, Jean, “Asia’s Antioch: Prayer and Proselytism in Singapore” in Hackett, Rosalind I.J. ed., Proselytization Revisited: Rights Talk, Free Markets and Culture Wars (Equinox, 2008) at 261 Google Scholar.

333 Ho, Andy, “Interfaith dialogue: Why some clam up” The Straits Times (18 September 2008)Google Scholar; Mathews, Mathew, “Accommodating Relationship: The Church and State in Singapore” in Bautista, Julius & Lim, Francis Khek Gee eds., Christianity and the State in Asia (Routledge, 2009) at 193 Google Scholar.

334 For a detailed discussion of the activities (including political activities) of Focus of the Family in the US: see Gilgoff, Dan, The Jesus Machine: How James Dobson, Focus on the Family and Evangelical America are Winning the Culture War (St Martin’s Press, 2007)Google Scholar.

335 Chua, Grace, “DBS’ charity tie-up draws flak” The Straits Times (5 December 2008)Google Scholar.

336 Ibid.

337 E.g., Edmond Chua, “Militant secularists demand Rony Tan’s arrest” Christian Post (Sing. ed.) (11 February 2010), online: <http://sg.christianpost.com/dbase.php?cat=church&id=2563> (last visited 1 February 2013); Thio, Li-ann, “Control, Co-optation and Co-operation: Managing Religious Harmony in Singapore’s Multi-ethnic, Quasi-Secular State” (2006) 33 Hastings Const. L.Q. at 225 Google Scholar n. 170.

338 In the press statement, the Taoist charity emphasised that the society is “happy that people from diverse cultural and religious backgrounds feel comfortable using our services,” “aim[s] to provide culturally-sensitive services that our clients’ values and beliefs,” and “all our Centres and Homes observe equally the festivals of Christmas, Hari Raya, Deepavali, Confucius’ birthday, Vesak Day and Lao Zi’s birthday”: “Society aims to serve singaporeans of all backgrounds” The Straits Times (22 December 2008).

339 Latif, Asad, “Warriors at the front line of tolerance” The Straits Times (15 November 2004)Google Scholar (Buddhist Lodge donated a third of its $3 million raised fund to Muslim, Hindu and Christian organisations); Hao, Yap Kim, “Hongbao giveaway boosts inter-faith cooperation” The Straits Times (14 January 2003)Google Scholar (“Buddhist Lodge sought the participation of Jamiyah Singapore and Hindu Endowments Board in the planning and distribution” of hongbao – red packets containing money); Fang, Chin Soo, “Monk’s $ 100,000 gift to Catholics” The Straits Times (16 May 1999) at 3 Google Scholar (donating to the Catholic Canossian Missions, and other Muslim and Hindu groups).

340 “3,200 Gather in a Festive Feast for All” The Straits Times (15 February 1999) at 1 (Food were blessed by religious leaders from seven major faiths.).

341 San, Mak Mun, “Happy meals” The Straits Times (9 November 2003)Google Scholar.

342 “Religion Still Relevant, Says President” The Straits Times (19 May 2000) at 3.

343 Hussain, Zakir, “Mosques feed 1,000 needy S’poreans” The Straits Times (14 July 2008)Google Scholar (Muslim organisations providing vegetarian option in the distribution of free meals).

344 Mansor, Enon & Ibrahim, Nur Amali, “Muslim Organizations and Mosque as Social Service Providers” Eng, Lai Ah ed., in Religious Diversity in Singapore (Institute of Southeast Asian Studies, 2008) at 459 Google Scholar, 464–470.

345 Chua, Edmond, “Christians must respect beliefs of non-Christians, theologian stress” Christian Post (Sing. ed.), (28 April 2010)Google Scholar, online <http://sg.christianpost.com/dbase.php?cat=education&id=787> (last visited 1 February 2013); “What Others Say About the Incident” The Straits Times (10 February 2010).

346 Oon, Clarissa, “Talk and let live” The Straits Times (3 February 2010)Google Scholar.

347 Supra V.B. See generally Mathews, Mathew, “Negotiating Christianity with Other Religions: The Views of Christian Clergymen in Singapore” in Eng, Lai Ah ed., Religious Diversity in Singapore (Institute of Southeast Asian Studies, 2008).Google Scholar

348 Chua, Edmond, “Bishop says preaches must watch sermon content, presentation” Christian Post (Sing. ed.) (23 September 2010)Google Scholar, online: <http://sg.christianpost.com/dbase.php?cat=church&id=2594> (last visited 1 February 2013); “Christianity: Winning Others or Helping Others Win?” Christian Post (Sing. ed.) (28 June 2010), online: <http://sg.christianpost.com/dbase/editorial/732/section/1.htm> (last visited 1 February 2013).

349 Mathews, Mathew, “Accommodating Relationship: The Church and State in Singapore” in Bautista, Julius & Lim, Francis Khek Gee eds., Christianity and the State in Asia (Routledge, 2009) at 193 Google Scholar.

350 Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 513.Google Scholar

351 Neo, Jaclyn Ling-Chien, “Seditious in Singapore! Free Speech and the Offence of Promoting Ill-Will and Hostility Between Different Racial Groups” (2011) S.J.L.S. at 354 Google Scholar; Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 493.Google Scholar

352 Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 488.Google Scholar

353 Sharma, Arvind, Problematizing Religious Freedom (Springer, 2011) at 221 Google Scholar; Farr, Thomas F., “The Widow’s Torment: International Religious Freedom and American National Security in the 21st Century” (2009) 57 Drake L. Rev. at 862 Google Scholar; Kyriazopoulos, Kyriakos N., “Proselytization in Greece: Criminal Offense vs. Religious Persuasion and Equality” (2004) 20 J.L. & Religion at 169.Google Scholar

354 See Shah, Dian Abdul Hamed & Sani, Mohd Azizuddin Mohd, “Freedom of Religion in Malaysia: A Tangled Web of Legal, Political, and Social Issues” (2011) 36 N.C. J. Int’l L. & Com. Reg. 647 Google Scholar, 664–669 (discussing the conversion restrictions in Malaysia).

355 Sharma, Arvind, Problematizing Religious Freedom (Springer, 2011)Google Scholar; Sharkey, Heather J., “Muslim Apostasy, Christian Conversion, and Religious Freedom in Egypt: A Study of American Missionaries, Western Imperialism, and Human Rights Agendas” in Hackett, Rosalind I.J. ed., Proselytization Revisited: Rights Talk, Free Markets and Culture Wars (Equinox, 2008) at 141 Google Scholar.

356 Neo, Jaclyn Ling-Chien, “Seditious in Singapore! Free Speech and the Offence of Promoting Ill-Will and Hostility Between Different Racial Groups” (2011) S.J.L.S. at 365–366.Google Scholar

357 C.f. DeBernardi, Jean, “Asia’s Antioch: Prayer and Proselytism in Singapore” in Hackett, Rosalind I.J. ed., Proselytization Revisited: Rights Talk, Free Markets and Culture Wars (Equinox, 2008) at 258 Google Scholar (“Although apostasy is not considered to be an offense in Singapore, nonetheless on conversion Singaporean Malay Christians reportedly experience social stigma and ostracism.”).

358 Berkwitz, Stephen C., “Religious Conflict and the Politics of Conversion in Sri Lanka” in Hackett, Rosalind I.J. ed., Proselytization Revisited: Rights Talk, Free Markets and Culture Wars (Equinox, 2008) at 216 Google Scholar; Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 510.Google Scholar

359 See Olmedo-Bustos v Chile, Inter-American Court of Human Rights (Ser. C) No. 73 (2001). C.f. Scolnicov, Anat, The Right to Religious Freedom in International Law (Routledge, 2011) at 195–196 Google Scholar (disagreeing with the court’s narrow interpretation of right to religious belief).

360 Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 493 Google Scholar; Farr, Thomas F., “The Widow’s Torment: International Religious Freedom and American National Security in the 21st Century” (2009) 57 Drake L. Rev. at 862.Google Scholar

361 Supra IV.A.

362 See Neo, Jaclyn Ling-Chien, “Seditious in Singapore! Free Speech and the Offence of Promoting Ill-Will and Hostility Between Different Racial Groups” (2011) S.J.L.S. at 361–364.Google Scholar

363 Thio, Li-ann, “Relational Constitutionalism and the Management of Religious Disputes: the Singapore ‘Secularism with a Soul’ Model” (2012) Oxford J. L. and Religion at 19–21 Google Scholar; Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 504–505.Google Scholar

364 Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 505.Google Scholar

365 Ibid., at 513.

366 Ibid.

367 Thio, Li-ann, “Relational Constitutionalism and the Management of Religious Disputes: the Singapore ‘Secularism with a Soul’ Model” (2012) Oxford J. L. and Religion at 19–20.Google Scholar

368 Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 493.Google Scholar

369 See Koppelman, Andrew, “Corruption of Religion and the Establishment Clause” (2009) 50 Wm. & Mary L. Rev. at 1843 Google Scholar (discussing overlapping consensus as a political mechanism to cope with religious pluralism). See generally Rawls, John, “The Idea of an Overlapping Consensus” (1987) 7(1) Oxford J. Legal Stud. 1.CrossRefGoogle Scholar

370 Koppelman, Andrew, “Corruption of Religion and the Establishment Clause” (2009) 50 Wm. & Mary L. Rev. at 1875–1876 Google Scholar; Stronks, Julia K., Law, Religion, and Public Policy: A Commentary on First Amendment Jurisprudence (Lexington Books, 2002) at 40–41.Google Scholar

371 Thio, Li-ann, “Contentious Liberty: Regulating Religious Propagation in a Multi-Religious Secular Democracy” (2010) S.J.L.S. at 489 Google Scholar (“[Religious propagation] may be justified on several grounds, resting on the premise that law considers a religion a good thing, deserving protection.”).

372 E.g., Thio, Li-ann, “Between Eden and Armageddon: Navigating ‘Religion’ and ‘Politics’ in Singapore” (2009) 2009 S.J.L.S. 265 Google Scholar, 379 (“this [exclusion of religious perspective in public debate] would discriminate against the more than 80% of Singaporeans with Singaporeans with religious affiliation in voting, taking part in elections and debating public issues.”); Meng, Vincent Chia Wei, “Govt should consider carefully the moral value system of the majority before making decision” The Straits Times (26 July 2007)Google Scholar, Online Forum (“According to Statistics Singapore, the majority of Singaporeans are not atheists, agnostics or secular humanists without religious affiliations… Within our multi-religious society, a common consensus on this issue can only be achieved by being mindful of the morality of the religious majority.”).

373 For two recent discussions on the political and legal status of non-religious persons, see Tebbe, Nelson, “Nonbelievers” (2011) 97 Va. L. Rev. 1111 Google Scholar (arguing for a polyvalent approach towards non-believers where the courts’ handling of non-believers under religious freedom law should be context sensitive towards the different values and considerations animating the particular law); Corbin, Caroline Mala, “Nonbelievers and Government Speech” (2012) 97 Iowa. L. Rev. 347 Google Scholar (arguing that government religious speech violates the Establishment Clause as such speech undermines the equality and liberty of nonbelievers).