In order for an action to be protected under Article 9 it must comprise a 'manifestation' of a belief1 rather than simply have been motivated by it2: thus where an act is motivated by a religion or a belief as opposed to being a direct expression of that belief it will not be protected by Article 93. The European Court of Human Rights has held that manifestation of religion or belief may take several forms, namely worship, teaching, practice and observance, but it does not protect every act motivated or inspired by a religion or belief4. An act does
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