ࡱ> %` ~bjbj"x"x <@@e&UUUjlULUUUUtututu8uTv\Ubhvhv"vvvwww$(hhU~ww~~UUvvH~&UvUv~@UUv\v pJ1tu=Zݱ820bBp\U]wyNz |wwwق$wwwb~~~~UUUprUUUprUUUUUUUUU  FINAL SUBMISSION TO THE AUSTRALIAN HUMAN RIGHTS COMMISSION FREEDOM OF RELIGION AND BELIEF IN THE 21st CENTURY IN AUSTRALIA Contact: Anthony Farley Executive Director Catholic Commission for Employment Relations 1. Introduction 1.1 The Catholic Commission for Employment Relations (CCER) is an organisation established by the Bishops of New South Wales (NSW) and the Australian Capital Territory (ACT) to provide Catholic Church employers with employment relations advice, research and advocacy within the context of Catholic Social Teaching. CCER provides employment relations assistance to various agencies and institutions of the Church, including Parishes, Chanceries and other Diocesan employers, Religious Congregations, the Catholic education sector, a number of social welfare agencies, as well as a variety of employers within the health and aged care sector. CCER also acts as a spokesperson for the Catholic Church in NSW and the ACT in public policy debates concerning employment relations. 1.2 This submission is made by CCER in response to the 2008 discussion paper released by the 鱨վ (AHRC) on Freedom of Religion and Belief in the 21st Century. As many of the issues raised in the AHRCs discussion paper go beyond the scope of work performed by CCER on behalf of the Catholic Church in NSW and the ACT, this submission will not address all issues raised by the AHRC. This submission is concerned mainly with commenting on the recommendation made by the Human Rights and Equal Opportunity Commission (HREOC) in its 1998 Report entitled Article 18: Freedom of Religion and Belief (the 1998 Report) to introduce a Federal Religious Freedom Act and, more specifically, its proposed draft provisions in respect of religious freedom as contained in R4.1 of that report. 1.3 This submission begins by examining the issue of religious freedom from the perspective of human rights, Catholic Teaching and Australian law. The submission then outlines CCERs concerns in relation to the introduction of a Federal Religious Freedom Act in Australia, and in particular its concerns regarding the AHRCs proposed draft provisions in respect of religious freedom contained in R4.1 of the 1998 Report. 2. Background (a) Religious Freedom at the International Level 2.1 Religious freedom is a human right, the cornerstone of a just society, and the foundation for international peace and security. Ensuring that religious freedom can be freely exercised is an important social policy objective for pluralistic and democratic societies. 2.2 Internationally, various statements, documents and declarations by the United Nations have affirmed the significance of religious freedom. The rights of the human person include: - the right to freedom of thought, conscience and religion; - the right to manifest religion and belief, in private and in public, subject only to such limitations as prescribed by law and are necessary to protect public safety, order, health or morals or the fundamental rights and freedoms of others; - the right of parents to ensure that the religious and moral education of their children is in conformity with their own religious beliefs and convictions; - the right of religious bodies to be protected from undue intrusion by the State into their ethos, principles or conduct; and - the right for people to be protected from discrimination based on religion and belief in the area of employment, (and the obligation of the State to take effective measures to prevent and eliminate religious discrimination in all fields of civil, economic, political, social and cultural life). (b) Religious Freedom and Catholic Teaching 2.3 The teaching of the Catholic Church concerning religious freedom is largely consistent with the position adopted by the United Nations. The Catechism of the Catholic Church 1994 affirms: The right to the exercise of freedom, especially in moral and religious matters, is an inalienable requirement of the dignity of the human person. This right must be recognised and protected by civil authority within the limits of the common good and public order (CCC 1738). 2.4 More particularly, the Vatican II Declaration on Religious Freedom asserts: - that the human person has a right to religious freedom, including freedom of conscience; - that religious organisations have the right to govern themselves according to their own norms, subject only to just demands about public order. This includes being able to worship in public, to select, train, appoint and transfer their own ministers, to communicate with religious authorities and communities abroad, to erect buildings for religious purposes, to acquire and use funds or properties, to promote the special value of their doctrine in issues concerning society, to hold meetings and to establish educational, cultural, charitable and social organisations under the impulse of their own religious sense; - that parents have the right to determine the religious education of their children, including the right of parents to make a genuinely free choice about schools; - that governments have a duty to safeguard the religious freedom of its citizens; - that governments are to see there is not discrimination amongst citizens based on religion; and - that governments are to avoid possible abuses committed under the pretext of religious freedom, so that the rights of all citizens are safeguarded, and peace and public morality are appropriately guarded. (c) Religious Freedom in Australia 2.5 Australian Federal law upholds, in general terms, the foundational right of religious freedom. Section 116 of the Australian Constitution prohibits State sponsored religion, the imposition of religious law by civil authority, or the requirement of a religious test for qualification for any public office. The Commonwealth has also given effect to various international treaties and conventions, by enacting legislation using the external affairs power in the Constitution. For instance, the Human Rights and Equal Opportunity Commission Act 1986 (the HREOC Act) was enacted by relying upon this power in the Constitution. This legislation prohibits discrimination on the basis of religion in employment or occupation, but provides exemptions in respect to a particular job based on the inherent requirements of the job, or for employment in religious organisations where the distinction, exclusion or preference is made in good faith in order to avoid injury to the religious susceptibilities of adherents to that religion or creed. Similar legislation (and exemptions) exist in State and Territory law. 3. Submission Issue 1: Should a Federal Religious Freedom Act be implemented in Australia? 3.1 A Federal Religious Freedom Act should not be implemented in Australia for a number of reasons. These reasons are outlined below: 3.2 Firstly, the implementation of a Federal Religious Freedom Act is not the answer to guaranteeing or protecting religious freedom in Australia. It has been the experience of the Catholic Church that civil instruments that claim to protect religious freedom have on many occasions failed to protect the right of people to express their religious or ethical convictions. One example of this is the failure of the Victorian Charter of Rights and Freedoms to adequately protect the right of conscientious objection of Catholic doctors and other health professionals in the context of the compulsory referral for abortion. In this respect, CCER cites the 2009 submission of the Australian Catholic Bishops Conference. 3.3 Secondly, courts and tribunals have tended to interpret and apply various exemptions within State and Federal anti-discrimination legislation in a narrow way. This has limited both Catholic and other religious institutions ability to organise their activities and employ staff in a way that is consistent with their religious beliefs and practice. One example of this is the way in which the term inherent requirements within State and Federal anti-discrimination legislation has been interpreted which has resulted in religious organisations, including schools and hospitals, being effectively prevented from recruiting staff of the same faith at the service provision level. & 3.4 Thirdly, the implementation of a Federal Religious Freedom Act in Australia is counterintuitive in that such legislation is more likely to undermine religious freedom in Australia than protect it. This is likely to occur because the more legislation that is enacted which specifically defines rights and freedoms with respect to the practice of religion, the less flexibility there is for religious bodies to practise their religion in accordance with their own unique belief systems. 3.5 Finally, the constitutional validity of any proposed Australian Federal Religious Discrimination Act is questionable, particularly if such an Act sought to impose restrictions on religious bodies in respect of their ability to undertake their mission and work in an authentic way, consistent with their tenets. Section 116 of the Constitution states that the Commonwealth shall not make any law for prohibiting the free exercise of any religion. This provision means that no person shall be subject to penalties or any form of discrimination based on his or her religious beliefs. This applies, so that, whether a person is a religious believer or a non-believer, they are immune from laws which discriminate against or burden their beliefs or practices. The constitutional validity of any Federal Religious Freedom Act would need to be examined in greater detail should the AHRCs proposal be accepted by Government. CCER reserves its right to make submissions in this respect should this become necessary. Issue 2: The AHRCs Recommendation R4.1 (a) Extension of Freedom from Religious Discrimination to all Areas of Public Life 3.6 In its recommendation R4.1, the AHRC proposes that any Federal Religious Freedom Act should make discrimination on the ground of religion and belief unlawful in all areas of public life. The AHRC does not recommend any exemptions in this respect, except in the area of employment. 3.7 Currently, the provision in Federal legislation governing discrimination on the basis of religion contained at section 3 of the HREOC Act is limited to employment only. Therefore, extending this provision to all areas of public life represents a significant departure from the current legislation. CCER has concerns that such a departure would have a significant detrimental impact on religious bodies and the services they provide within the Australian community. The services that the Catholic Church currently provides within the Australian community encompass a number of areas of public life. A few examples of the wide range of Catholic services within the Australian community include: - Accommodation - (Catholic Aged Care facilities, Catholic Homeless Shelters and Catholic University Colleges etc); - Education - (Catholic Pre-Schools and Kindergartens, Catholic Schools and Universities); - Goods, Services and Facilities - (Catholic Hospitals, Catholic Charities Catholic Counselling, Refugee and Migrant Services etc); - Land - (Catholic Churches, Catholic Halls, Catholic Offices etc); and - Clubs - (Catholic Clubs). 3.8 Such services are not unique to the Catholic Church. There are also a number of other religious bodies who provide similar services. The AHRCs proposal has not put forward any exemptions for religious bodies to enable them to provide such services within the public arena in keeping with their beliefs and religious teachings. Without such exemptions, a religious bodys ability to provide such services would be severely compromised and potentially result in outcomes offensive to its fundamental beliefs and tenets. For example, under the AHRCs proposal if a Catholic parish were to refuse to lease out its hall to groups associated with the occult this would constitute religious discrimination and thus expose such a parish to prosecution. In this respect it is worthy to note that occultism is likely to satisfy the requirements for a religion, or if not, at least a belief under the AHRCs proposed legislation. 3.9 Therefore, any Federal Religious Freedom Act should not extend to legislate in respect of all areas of public life. Matters pertaining to religious discrimination concerning public life should continue to be regulated pursuant to Article 18 of the International Covenant of Civil and Political Rights (the ICCPR) which provides that freedom to manifest ones religion or beliefs may be subject only to such limitations as are prescribed by law and are necessary to protect public safety, order, health or morals or the fundamental rights and freedoms of others. 3.10 Alternatively, if the Government were to accept the AHRCs proposal and enact a Federal Religious Freedom Act, broad exemptions for religious bodies should be contained within any such Act to enable them to provide services in the public arena in a way that is consistent with their religious beliefs and practices. (b) R4.1 Provision 1 3.11 CCER has significant concerns regarding the AHRCs proposed exemption R4.1 Provision 1 which states that: A distinction, exclusion or preference in respect of a particular job based on the inherent requirements of the job should not be unlawful. Preference in employment for a person holding a particular religious other belief will not amount to discrimination if established to be a genuine occupational qualification. 3.12 CCER has compared this provision to the current provision contained within section 3 of the HREOC Act. CCER notes that there is considerable difference between the two provisions in that the AHRCs proposed R4.1 Provision 1 has added a further element to the already restrictive exemption for religious bodies contained within section 3 of the HREOC Act - that of genuine occupational qualification. 3.13 It is unclear what the AHRC means by the term genuine occupational qualification. On the face of it, it appears to refer to academic qualifications of a religious nature. If this is the case, it means that roles which contain inherent requirements that arguably only Catholic applicants would be able to perform and which would be exempt from discrimination under the current legislation, may not be exempt under R4.1 Provision 1. This is because although such roles may contain duties that can only be performed by Catholics, they may not always require academic qualifications of a religious nature. Examples of roles that arguably would be currently exempt from discrimination under section 3 of the HREOC Act, and which do not require academic religious qualifications, would include leadership and specialist religious roles within Catholic schools, such as Principals, Deputy Principals, Year Coordinators, and Religious Education and Ministry Coordinators. Other examples outside the education sector would include Chief Executive Officers, General Managers and other leadership positions within Catholic organisations such as charities, hospitals, aged care facilities etc. 3.14 It is imperative that leadership positions within Catholic organisations are held by Catholics because the purpose of such positions is to assist the Church to maintain and propagate its faith; per Madgwick J in Kerry Anne Hozack v The Church of Jesus Christ of Latter-Day Saints [1997] FCA 1300 (27 November 1997) (Hozack). However, as stated previously, such roles may not necessarily require academic qualifications of a religious nature and so may arguably not be protected by R4.1 Provision 1. 3.15 Section 3 of the HREOC Act has already been interpreted very narrowly and so to add a further requirement of genuine occupational qualification only serves to make the exemption contemplated by R4.1 Provision 1 even less accessible to religious bodies. In this respect it is noteworthy that the inherent requirements exemption contained within section 3 of the HREOC Act has been interpreted as only applying to leadership roles within religious bodies such as the Catholic Church but not general service roles. This is an untenable restriction of religious freedom because employees employed in Catholic agencies at all levels are there to perform the function of the Church, to model Catholic values and to present a Catholic world view. This is what enables Catholic agencies to retain a uniquely Catholic identity and in turn meet client needs in relation to the delivery of Catholic services. Therefore, Catholic, and other religious agencies, should be free to employ staff at all levels who adhere to the same faith without being exposed to claims of religious discrimination. As such CCER strongly rejects both the current narrow interpretation of the exemption contained within section 3 of the HREOC Act, and the even more restrictive exemption contemplated by R4.1 Provision 1. 3.16 Furthermore, if CCERs interpretation of R4.1 Provision 1 is correct, in that it requires academic qualifications of a religious nature, in respect of education, this provision is arguably in breach of Article 18(4) of the ICCPR which guarantees parents rights to ensure the religious and moral education of their children in conformity with their own convictions. CCER reserves its right to make more detailed submissions on this issue should this become necessary. (c) R4.1 Provision 2 3.17 CCER also has significant concerns regarding the AHRCs proposed exemption R4.1 Provision 2 which states that: A distinction, exclusion or preference in connection with employment as a member of the staff of an institution that is conducted in accordance with the doctrines, tenets, beliefs or teachings of a particular religion or creed, being a distinction, exclusion or preference required by those doctrines, tenets, beliefs or teachings made in good faith and necessary to avoid injury to the religious susceptibilities of adherents of that particular religion or that creed should not be unlawful provided that it is not arbitrary and is consistently applied. 3.18 CCER has also compared this provision to the current provision contained within section 3 of the HREOC Act. CCER notes that there are considerable differences between the provisions and, in particular, that the AHRCs proposed provision adds a number of elements to the already restrictive exemption for religious bodies contained within section 3 of the HREOC Act. Most notably, the AHRCs proposed provision contains the following additional requirements so that any distinction, exclusion or preference must be: (1) necessary to avoid injury to the religious susceptibilities of adherents of that faith (2) not arbitrary; and (3) consistently applied. 3.19 These additional limitations further restrict the already limited exemption contained within section 3 of the HREOC Act. This is because each of these additional elements would need to be proven before a respondent could successfully avail itself of the AHRCs proposed exemption, as Courts would interpret each qualification as a separate element to be satisfied. In effect, this places the judiciary in the position of defining a particular religious belief. Such a provision serves to only further undermine and restrict religious freedom rather than protect it and does not represent an appropriate balance between freedom of religion and freedom from discrimination. 3.20 In relation to the first additional element, necessity is difficult to establish without proof of actual injury to the religious susceptibilities of adherents of any given faith. This is because the term necessity refers to an imperative requirement, that is, a requirement that is not free so that a respondent has no choice but to take a particular course of action. In order to prove this, it is likely that a Respondent would be expected to show that failure to take that course of action would result in actual damage, otherwise the action may not be deemed necessary. In this respect, current case law interpreting the words injury to the religious susceptibilities of adherents has not required proof of actual injury. For example, Madgwick J held in Hozack that: the Church need only demonstrate that the decision was made in good faith for the purposes of avoiding injury to the religious susceptibilities of its adherents, not that any of its members were actually injured in such susceptibilities. 3.21 Therefore, by incorporating the element of necessity into R4.1 Provision 2, it is arguable that Courts and Tribunals will also require the avoidance of actual injury to the religious susceptibilities of adherents. As such, the requirement of necessity makes the exemption contained at R4.1 Provision 2 significantly more restrictive than the exemption that currently exists under section 3 of the HREOC Act and thus even more difficult for religious bodies, including the Catholic Church, to rely upon. 3.22 In relation to the second additional element pertaining to arbitrariness, the AHRCs current guidelines on religious discrimination state that where a distinction is applied capriciously, arbitrarily or randomly this would not constitute good faith. Therefore, given both R4.1 Provision 2 and section 3 of the HREOC Act already require religious entities to act in good faith and thus not make decisions in an arbitrary fashion, it is superfluous and unnecessarily onerous to refer to arbitrariness as a further and separate element within R4.1 Provision 2 in addition to the requirement to act in good faith. 3.23 In relation to the third element pertaining to consistency, CCER submits that because religion is based on belief and not just unified rules and regulations, there can be differing views within religious organisations, and among believers, as to the interpretation and application of religious doctrine and teachings. Given that religion is fundamentally a belief system that is based on faith, it therefore incorporates inconsistencies and diversities. This fact was acknowledged by Madgwick J in Hozack who said: No Church is entirely consistent in its practices, no institution, dependant on human beings, is. Mistakes, slips, compromises, failures of comprehension, even occasional infractions or the toleration of them in relation to values and doctrines, hardly indicate that the values and doctrines are not truly held. It is enough if the Church can show good faith; it need not show perfection. 3.24 Therefore, it is unreasonable to expect, and almost impossible for any religious organisation to establish, consistency across all religious entities and adherents in terms of how distinctions, exclusions or preferences may be made. As such, this additional element establishes an unrealistically high threshold, which religious bodies would never be able to attain. As such, it is arguable that religious bodies would be unable to ever rely upon the exemption contained at R4.1 Provision 2. Issue 4: Dispute Resolution Processes 3.25 At this stage, the AHRC has not put forward recommendations as to how disputes under any Federal Religious Discrimination Act would be adjudicated. CCER assumes that it is likely that such disputes would proceed through the Federal Court System, as is currently the case with the Sex Discrimination Act 1984, the Age Discrimination Act 2004, the Racial Discrimination Act 1975 and the Disability Discrimination Act 1992. Therefore, CCER has assumed that matters of alleged religious discrimination will not proceed by way of report to the Attorney General, as is currently the case under the HREOC Act. 3.26 If it is the case that matters of religious discrimination will proceed through the Federal Court, this could result in a situation where the Federal Court is placed in a position where it is regularly called upon to adjudicate and make decisions in respect of the interpretation and application of religious doctrine and social teaching. This should not be the role of the Court, as it is not the function of the Court to make theological and doctrinal determinations about the beliefs and practices of religious bodies or their adherents. CCER reserves the right to make more detailed submissions on this issue should the Federal Government choose to implement a Federal Religious Freedom Act in Australia. 4. Conclusion 4.1 In representing many Church employers in NSW and the ACT, it is CCERs position that in order to ensure the Catholic communitys right to free exercise of religion, agencies of the Church (including those established for educational, charitable, social and cultural purposes) need to be free to undertake their activities in a manner consistent with Catholic faith and practice. This includes being able to employ staff based on their religious affiliation, who are committed to supporting and promoting the Catholic mission and ethos of the organisation. Whilst the State has a duty to ensure the religious freedom of its citizens, due care must be taken that in pursuing this goal, it does not inadvertently create an environment that makes it difficult for religious bodies to undertake their mission and work in an authentic way, consistent with their tenets. Therefore, adequate exemptions need to exist for religious organisations to safeguard their right to define their own teachings and organise their internal affairs. The establishment of a Federal Religious Freedom Act will not protect the religious freedom of the Catholic community or other religious communities in Australia and will only serve to further restrict religious freedom in this country.  Article 18, International Covenant on Civil and Political Rights, 1966; Declaration on Elimination of All Forms of Intolerance and of Discrimination based on Religion and Belief 1981  See Note 2  See Note 2  The Declaration on Elimination of All Forms of Intolerance and of Discrimination based on Religion or Belief 1981 states that this involves the following rights: a) to worship or assemble in connection with a religion or belief, and to establish and maintain places for these purposes; b) to establish and maintain appropriate charitable or humanitarian institutions; c) to make, acquire and use to an adequate extent the necessary articles and material related to the rites and customs of a religion or belief; d) to write, issue and disseminate relevant publications in these areas; e) to teach a religion or belief in places suitable for these purposes; f) to solicit and receive voluntary financial and other contributions from individuals and institutions; g) to train, appoint, elect or designate by succession appropriate leaders called for by the requirements and standards of any religion or belief; h) to observe days of rest and to celebrate holidays and ceremonies in accordance with the precepts of ones religion or belief; and i) to establish and maintain communications with individuals and communities in matters of religion and belief at the national and international levels.  Declaration on the Elimination of All Forms of Intolerance and of Discrimination Based on Religion or Belief 1981  Declaration on Religious Freedom [Dignitatis Humanae], in The Documents of Vatican II, edited by Walter M. Abbott SJ, London: Geoffrey Chapman, 1966,pp 675-696.  Section 3 of the HREOC Act  For further discussion in relation to this issue please see paragraph 3.15 of this submission.  For another example of the way in which an exemption under anti-discrimination legislation has been narrowly interpreted and applied see OV and Anor v QZ and Anor (No 2) [2008] NSW ADT 115 (1 April 2008). In this case, the Tribunal interpreted the words injury to the religious susceptibilities of the adherents of that religion as referring too all adherents not just some or an unknown proportion, even though the Tribunal acknowledged that all adherents of a religion do not necessarily agree on all matters. For further discussion regarding the difficulty with such a narrow interpretation please refer to paragraphs 3.23 and 3.24 of this submission.  Lumb, R.D. The Constitution of the Commonwealth of Australia Annotated, 4th ed, 1986, published by Butterworths Pty Ltd , North Ryde, NSW, Australia at 367  For example, practitioners of paranormal or supernatural magic, witchcraft, sorcery wizardry, alchemy, voodoo, mysticism, devil worship etc.  Please refer to R2.5 of the 1998 Report where the AHRC recommends that the terms religion and belief in any proposed Religious Freedom Act should be given a wide meaning. See also Church of the New Faith v Commissioner for Pay Role Tax (Vic) (1983) 154 CLR 120, 29 ALR 65 where the High Court articulated a number of criteria to identify whether a belief system may constitute a religion under Australian law.  Although the ICCPR does not form part of Australian domestic law, Australias ratification of the ICCPR gives rise to a legitimate expectation that Government administrative decisionmakers will not violate its provisions; Minister for Immigration and Ethnic Affairs v Teoh (1995) 183 CLR 273. Furthermore, section 20(1)(3) of the HREOC Act provides that a complaint may be made to the AHRC alleging that an act or practice is inconsistent with or contrary to any human right. Human rights are defined in section 3 of the HREOC Act to mean the rights and freedoms recognised in the international instruments which are declared or scheduled to the HREOC Act. The ICCPR is scheduled to the HREOC Act. Therefore matters of alleged religious discrimination which relate to areas of public life, other than employment, are regulated by Article 18 of the ICCPR and subject to investigation by the AHRC - see Hanes v Human Rights and Equal Opportunity Commission (2007) 98 ALD 544; [2007] FCA 751.  That is section 3 of the HREOC Act  Macquarie Concise Dictionary, 3rd Edition, published by The Macquarie Library Pty Ltd, 2004  At page 3 and 4  At page 4     PAGE  PAGE 10  !DEJru     ! 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