The European Court of Human Rights has held that a measure limiting the right to manifest freedom of thought, conscience and religion1 will be proportionate to a legitimate aim2 if it is justified in the circumstances of the case by a pressing social need3, and that in assessing whether a restriction is proportionate to the legitimate aim pursued 'very strict scrutiny' must be applied4. Examples of measures which have been found by the Court to be proportionate to legitimate aims include a ban on teachers and other public servants wearing a religious headscarf5; the expulsion of a pupil for
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