Il contributo dei sistemi extraeuropei di tutela dei diritti umani alla realizzazione della libertà religiosa, tra convergenza normativa e specificità applicative

This contribution is devoted to enquiring the status of religious freedom in the different regional human rights protection systems. Though the amount of practice produced under the auspices of the European Court of Human Rights appears to be quantitatively more significant as well as qualitatively more articulated than other regional systems’ practice, a more careful scrutiny of the case-law of the Interamerican Court and Commission, on the one hand, and of the African Commission especially, on the other, reveals that the contribution of those mechanisms is just as interesting as the European case-law. Other regional human rights catalogues, such as the Arab Charter or the ASEAN Declaration, are also considered in so far as, though not yet accompanied by a properly jurisdictional human rights machinery, both nonetheless expressly provide for religious freedom. A comparative analysis of the relevant provisions and case-law of each system is thus performed and, based on the results, some tentative observations on current trends and future perspectives are formulated.