Arabs Without God: Chapter 12

Chapter 12: Atheism and Islamophobia

FOR ARAB Muslims, abandoning religion is not simply a personal matter – it is a decision that also comes with political baggage. Besides the social and legal consequences of apostasy, ex-Muslims risk being condemned as stooges in battles that are not of their choosing.

Viewing ex-Muslims as the agents of some foreign power removes any need to take their philosophical arguments seriously. Thus when Palestinian Waleed al-Husseini was arrested for posting his atheistic thoughts on the internet, police checked his bank account on the assumption he was in the pay of Zionists. Similarly, an atheist who appeared on Egyptian television was asked whether he had contacts “with anyone abroad”, prompting him to deny that he was a spy.

There are also plenty of unsavoury organisations in western countries – especially on the far right – that seek to stir up prejudice against Muslims for racial or other motives, and who regard ex-Muslims as useful fodder for their cause. Former believers, unless they are careful, can easily find themselves paraded as trophies by Islamophobes.

In Europe, extremists of the political right focus especially on Islam in their campaigns against immigration, claiming that the continent is about to be taken over by Muslims. The “Stop Islamisation of Europe” movement, which originated in Denmark, calls for “a permanent stop to immigration from Muslim countries and a temporary stop from other countries”, along with “repatriation of disaffected Muslim and other immigrants and all immigrant criminals”.[i] The former leader of the British National Party, Nick Griffin, who claims that Britain and Ireland are being turned into “a Third World Islamic slum”[ii] has spoken nostalgically of “the traditional, upright, decent and honest Christianity that defended Europe from Islamic conquest, the Christianity of the Crusades and the Christianity of our forefathers”.[iii]

In the US, the far right also engages in fear-mongering about “Islamisation”. Robert Spencer’s Jihad Watch website, for example, has long promoted the idea that the essence of Islam is terrorism:

There is no distinction in the American Muslim community between peaceful Muslims and jihadists. While Americans prefer to imagine that the vast majority of American Muslims are civic-minded patriots who accept wholeheartedly the parameters of American pluralism, this proposition has actually never been proven.[iv]

Anti-Muslim sentiment was further fuelled by the huge exodus of refugees from the conflict in Syria and normalised to some extent with the election of Donald Trump as president of the United States.

At the opposite end of the political spectrum, ex-Muslims also face rejection by elements on the left that support Islamist movements under the guise of combating imperialism. The result is an Orientalist perspective where Islamists and religious conservatives are regarded as culturally authentic while those with a more progressive outlook are dismissed as westernised and agents of imperialism. Abuses based on religion that would never be accepted by leftists if applied in western countries are thus considered acceptable in an Arab context. Mariam Namazie of the Council of Ex-Muslims of Britain describes this as the politics of betrayal: “It’s a betrayal of the dissenters and victims of Islamism but also of the very principles that the left has historically defended” – social justice, egalitarianism, secularism, universalism, etc.[v]

Arabs Without God is available in paperback from Amazon (US) or Amazon (UK). It is also available in Arabic (online, free of charge) and in Italian under the title Arabi Senza Dio.

Namazie sees little difference between Islamists in the Middle East and the far right in the west. Even though the latter “attack mosques and people just because of their background and issue collective blame on entire populations”, Islamists and the far right both come from the same sort of background, she said:

Obviously there are variations, given the differences in power, but their politics and their philosophy and their politics of hate are quite similar to each other. So from our perspective we fight on both fronts, particularly in the west.

You can’t just fight one, particularly as the far right are scapegoating Muslims and immigrants. They are using the issue of sharia, the issue of apostasy laws – in a sense they are feigning support of apostates and women under Islam, whereas in fact they couldn’t care less about women and people in the Middle East and North Africa. And they are very happy to deport everyone and deny those very people that they show concern for the right to asylum and protection.[vi]

Like its British counterpart, the Ex-Muslims of North America organisation sees itself as standing between the two extremes: political Islam and its apologists on one side and the far right on the other – and resisting them both. A statement on its website headed “No Bigotry and No Apologism” explains:

There are those who propagate racist, bigoted and xenophobic ideas against Muslims, against anyone who comes from a Muslim background, and even against people who are not Muslim at all (e.g. Sikhs). These types of people (the bigots) tend to treat all Muslims (or all those perceived to be Muslim) as a monolith, a horde without internal differences or dissent.

On the other hand, there are those who react to the bigoted, xenophobic types by trying to justify the violent parts of Islam and the harsh actions of some Muslims. This second type (the apologists) often shields Islam and Muslims from any and all critique and scrutiny, even the kinds of critique and scrutiny they themselves apply to other ideologies like Christianity, Capitalism, Communism, and others.

As people who were raised Muslim, or converted to Islam of our own choice, and then left Islam because we could not believe in it any more, we stand between this polarity, and we refuse to cater to either the bigots or the apologists. We do not wish to promote hatred of all Muslims. We ourselves were Muslim. Many of our families and friends are Muslim. We understand that Muslims come in all varieties and we do not and will not partake in erasing the diversity within the world’s Muslims.

Most of us have researched and continue to research many of the world’s religions, and we are, as a group, very well-versed in the horrors committed by other religions throughout history. We reserve the right to focus on Islam because it is the religion with which we have the most experience, it is the religion in which many of us were raised, and the religion some of us who are former converts tried to believe in with all our hearts.

While we denounce the bigotry of those who promote their racist and xenophobic ideas under the guise of criticising Muslims, we also denounce the cultural and moral relativism of those who propagate the idea that all people of Muslim backgrounds are the same and want to follow Islam, and that Islam is somehow less capable of being scrutinised than other belief systems.[vii]

Defining Islamophobia

ONE OF the great challenges for ex-Muslims is how to criticise Islam without providing more fuel for western prejudice against Muslims as people.

The contentious term “Islamophobia” has existed for more than a century. Its first recorded use was in 1910 in French – as islamophobie, referring to the attitude of French colonial administrators. It does not appear to have been used in English until 1985 when Edward Said linked it to antisemitism, saying that “hostility to Islam in the modern Christian west has historically gone hand in hand” with antisemitism and “has stemmed from the same source and been nourished at the same stream”.[viii]

The term gained wider currency following a report by the Runnymede Trust in 1997, Islamophobia: A Challenge for Us All, which looked at attitudes towards Muslims living in Britain.[ix] The report aimed “to counter Islamophobic assumptions that Islam is a single monolithic system, without internal development, diversity and dialogue” and “to draw attention to the principal dangers which Islamophobia creates or exacerbates for Muslim communities, and therefore for the well-being of society as a whole”. A few years later “Islamophobia” also began to be used by various international bodies, including the United Nations.

It is important to mention this historical background because of false claims in the US that the term was coined by Islamists with the specific purpose of portraying themselves as victims. For instance, one misinformed article on a right-wing American website says:

The neologism “Islamophobia” did not simply emerge ex nihilo. It was invented, deliberately, by a Muslim Brotherhood front organisation, the International Institute for Islamic Thought, which is based in Northern Virginia.[x]

Although this is demonstrably untrue, the idea that Islamophobia doesn’t really exist and that the term was concocted to suppress free-ranging criticism of Islam continues to be propagated by sections of the American right.

Discussion of Islamophobia is further complicated by the lack of a generally accepted definition, and there are many without a political axe to grind who regard the term as problematic. The late Professor Fred Halliday suggested that “Anti-Muslimism” would be more accurate, since it usually refers to hostility directed against Muslims rather than Islam and its tenets. Robin Richardson, who edited the 1997 Runnymede report, later acknowledged the criticisms and offered a rather complex re-definition of Islamophobia as …

A shorthand term referring to a multifaceted mix of discourse, behaviour and structures which express and perpetuate feelings of anxiety, fear, hostility and rejection towards Muslims, particularly but not only in countries where people of Muslim heritage live as minorities.[xi]

Regardless of debates about the word “Islamophobia”, prejudice of the kind identified in the Runnymede report does exist and is usually not difficult to recognise. Typically, it involves sweeping and misleading generalisations about Islam and/or Muslims (along with others who are presumed to be Muslim) in order to portray them in a negative light. There is widespread agreement, though, that the term “Islamophobia” cannot sensibly be applied to genuine critiques of Islam as a religion. Tackling Islamophobia should not become a mandate for stifling free and fair comment, as the British-based Forum Against Islamophobia and Racism (FAIR) has made clear:

It is not Islamophobic to disagree or disapprove of Muslim beliefs, practices or actions. Indeed, within the Muslim community, both in Britain and globally, it is recognised that disagreements, discussions and debates are an important part of contemporary Islam and Muslim societies, and absolute requisites to maintain the relevance of Islam. Legitimate disagreement and criticism by non-Muslims, is therefore, not only expected but appreciated. However, we would urge that this is done sensibly and sensitively.[xii]

Unfortunately, this is sometimes also interpreted as a licence for crude forms of abuse. In a speech about Islam, Nick Griffin of the far-right British National Party said: “This wicked, vicious faith has expanded from a handful of cranky lunatics about 1,300 years ago till it’s now sweeping country after country before it, all over the world. And if you read that book [the Qur’an], you’ll find that that’s what they want.”[xiii]

Griffin was later tried on several charges of using words or behaviour intended or likely to stir up racial hatred but in court he denied the words were racist. He told the court: “There’s a huge difference between criticising a religion and saying this is an attack on the people who follow it. When I criticise Islam, I criticise that religion and the culture it sets up, certainly not Muslims as a group …” Following a retrial he was eventually cleared of all charges.[xiv]

There are certainly differences between race and religion. Race, for example, is inherited and unchangeable whereas religion is normally considered a personal choice – even if Muslim societies tend to regard it as inherited and unchangeable too. But it is necessary to recognise that a religion can be far more than a belief system; it is often also an identity and a cultural (and sometimes political) affiliation.

This is one of the reasons why the European Commission Against Racism and Intolerance defines racism as “the belief that a ground such as race, colour, language, religion, nationality or national or ethnic origin justifies contempt for a person or a group of persons, or the notion of superiority of a person or a group of persons”.

References to cultural “markers” such as religion, language or dress often become a substitute for more overt forms of racism. “Racism is almost never a direct discussion of something on explicitly racial grounds,” Hiba Krisht, an Arab atheist, pointed out during a discussion with other members of Ex-Muslims of North America (EXMNA):

Most racist attitudes are at the surface level not towards explicit races. Racist attitudes about single moms, rap music, food stamps, hoodies, football mascots abound. None of those are races per se. Racist discussions of them are reducible to generalised beliefs regarding the customs and communities of those who engage/partake in them.

Anti-Muslim bigotry is very, very much about race. Even discussion of white converts involves concepts of theft and seduction by brown people taking over white values. We do no one favours by hiding behind the “Islam is not a race” card …[xv]

In the west, she added, ex-Muslims face the same kind of prejudice as Muslims. “The racism that allows others to assume that we adopt Muslim sentiments or beliefs because of our ethnicities, and despite our actions and words, is the same racism that Muslims suffer from.”

Members of EXMNA were discussing what terminology to use in order to distinguish between “undue discrimination against Muslims and reasoned critique of Islam”. The reason for this, Krisht explained, was that “the term ‘Islamophobia’ has become a catch-all phrase used to silence legitimate critique of an ideology in addition to condemning bigotry towards Muslims, and the two concepts need to be differentiated, perhaps deserving their own neologisms”. The discussion failed to come up with a solution but for ex-Muslims this is clearly a difficult problem.

“I feel that criticism of any ideology should be OK but discrimination against people because of their beliefs is where I draw the line,” Egyptian Reem Abdel-Razek said. “It’s OK to criticise an idea but to discriminate against someone because he is a believer of that religion is what constitutes Islamophobia.” She added that she would not poke fun at people because of their religious style of dress. “I have friends that do things that are just sort of mocking and I feel that being outrageous just for the sake of it really accomplishes nothing.”

Not judging by appearances may be a good general principle – people have been questioned as terror suspects simply because they “looked” Arab or Muslim – but is it always wrong to do so? Within the general category of “Muslim appearance” certain styles of dress signal a certain way of thinking – and are meant to do so by those who adopt them. Kiran Opal, a co-founder of EXMNA, cited the example of a Muslim man in a thobe and a six-inch beard walking with two women in niqabs and six children behind him. When she sees a scene like that, Opal continued, “I do judge the people involved. I do think that they are living in a way that is oppressive to women, that is supremacist, that is abusive to LGBTQ people, to religious minorities … Does that mean I am Islamophobic?”[xvi]

Need for nuance

AS EX-MUSLIMS struggle to distance themselves from anti-Muslim bigotry, interventions by a number of prominent western atheists have been distinctly unhelpful. Richard Dawkins, for example, posted a controversial tweet saying:

All the world’s Muslims have fewer Nobel Prizes than Trinity College, Cambridge. They did great things in the Middle Ages, though.[xvii]

Although this was factually accurate, it is difficult to see a reason for posting it other than as a general disparagement of Muslims. The lack of scientific achievement by Muslims in modern times is a valid (and important) topic for discussion, and the explanations are complex,[xviii] but raising it on Twitter, where posts are limited to 140 characters, is scarcely an invitation to nuanced debate. Instead, it merely feeds anti-Muslim tropes. Dawkins also re-tweeted an article perpetuating the myth that the term “Islamophobia” was invented by the Muslim Brotherhood, though he deleted it shortly afterwards – apparently when he realised his mistake.[xix]

On his own website, where space is presumably not a limitation, Dawkins has made a habit of taking snide swipes at Islam without elaboration, such as “the menacing rise of Islam”,[xx] and suggesting that in Europe the word “multiculturalism” is “code for Islam”.[xxi] He has also said: “It is well arguable that Islam is the greatest man-made force for evil in the world today”,[xxii] and: “If you see a Muslim beating his wife, there would be little point in calling a policeman because so many of the British police are terrified of being accused of racism or ‘Islamophobia’.”[xxiii]

Dawkins, along with Sam Harris and the late Christopher Hitchens, is regarded as one of the “New Atheists” who are noted for their populist and strident – sometimes bellicose – attitude. In a critical article for Salon magazine, Nathan Lean wrote:

Though Dawkins, Harris and company have been around for years, their presence on the public scene used to be more muted. An atheist then was something you simply were. It wasn’t a full-time career. But in 2001 a man named Mohammed Atta and his Middle Eastern comrades decided to fly jetliners into the Twin Towers and everything changed … 

Until 9/11, Islam didn’t figure in the New Atheists’ attacks in a prominent way. As a phenomenon with its roots in Europe, atheism has traditionally been the arch-enemy of Christianity, though Jews and Judaism have also slipped into the mix. But emboldened by their newfound fervour in the wake of the terrorist attacks, the New Atheists joined a growing chorus of Muslim-haters, mixing their abhorrence of religion in general with a specific distaste for Islam …

Conversations about the practical impossibility of God’s existence and the science-based irrationality of an afterlife slid seamlessly into xenophobia over Muslim immigration or the practice of veiling. The New Atheists became the new Islamophobes, their invectives against Muslims resembling the rowdy, uneducated ramblings of backwoods racists rather than appraisals based on intellect, rationality and reason.[xxiv]

The problem with this approach, as the Australian writer/philosopher Russell Blackford has noted, is not only that it puts critics of Islam at risk of being tarred with the same brush as the extreme right but also that it helps to make the extreme right seem more respectable. One prominent American atheist, Sam Harris, has even gone so far as to say that “the people who speak most sensibly about the threat that Islam poses to Europe are actually fascists”.[xxv]

Blackford counters that “the extreme right benefits from the availability of politically respectable criticisms of Islamic thought and associated cultural practices.” This includes adopting what have traditionally been viewed as liberal causes, such as opposition to forced marriages, “honour” killings, female genital mutilation, and the enforcement of dress codes for women.

“There are reasons why extreme-right organisations have borrowed arguments based on feminism and secularism,” Blackford continues. “These arguments are useful precisely because they have an intellectual and emotional appeal independent of their convenience to extreme-right opportunists. Regardless of who uses these arguments, they plausibly apply to certain elements of Islam, or at least to attitudes and practices associated with it.”

At a practical level, Blackford suggests, “opponents of Islam who do not wish to be seen as the extreme-right’s sympathisers or dupes would be well-advised to take care in the impression that they convey. Where practical, they should explain their positions with as much nuance as possible, distance themselves from extreme-right figures making similar arguments, and avoid sharing platforms with them.” But he adds: “The words ‘where practical’ are important, because what is practical in, say, a philosophical essay may not be practical in a satirical cartoon, or even in a polemical book aimed at a popular audience. We mustn’t exclude the talents of people whose training or temperament does not suit hedged, half-apologetic communication. Nor must we always communicate in ways that most people find boring and bland. Beyond a certain point, there is too much disadvantage in walking on eggshells.”[xxvi]

Regardless of the reaction, some ex-Muslims argue that the New Atheists are saying things that need to be said – things that ex-Muslims themselves may not be in a position to say.

“You can make a lot of arguments that the approach they are taking is not the most intellectual, maybe not the most valid in a lot of ways, but, from the perspective that we are coming from, it doesn’t seem bigoted and it doesn’t seem racist in any way,” Sarah Haider of EXMNA said. Among ex-Muslims, the criticisms tend to come from those living in the west who “have adopted liberal sensibilities of being hypersensitive to bigotry, or anything that can be perceived to be bigotry,” she added. “Those who are not living in the western world or those that are recent immigrants are more likely to be happy with the kinds of things Dawkins and Harris are saying.” Haider continued:

Plenty of ex-Muslims have no problem with the so-called New Atheists, and believe precisely that kind of in-your-face approach is what is necessary. This is a point of contention within the community – and there are defenders on both sides. I would say very few believe that Sam Harris and Richard Dawkins are actually bigoted – the disagreement is often about the effectiveness of their tactics.

The argument goes: when someone is so steeped into the religion, only a shocking statement will get them to re-evaluate their beliefs. When I was a Muslim, I was constantly told that the Islam is the most progressive religion when it comes to women’s rights – something I actually believed and never bothered to verify myself (why would my imam lie to me?).

It was an encounter with a loud, abrasive atheist that actually got me to look into my beliefs and, as it turns out, he knew my religious texts better than I did. Did he offend me? Yes! Did he hurt my “religious feelings”? Yes. But I wouldn’t have left if it wasn’t for his aggression.[xxvii]

Freedom of expression necessarily includes, in the words of the European Court of Human Rights, a right to “offend, shock and disturb”. This does not mean people should feel free to say shocking and offensive things at the slightest opportunity, but there are occasions when they are entitled to do so. Without a right to offend, legitimate debate can be suppressed simply because someone claims to have been offended by it – and there have been plenty of examples in previous chapters of this book.

Alongside that, though, is a need for people with differing ideas and beliefs to co-exist in an atmosphere of pluralism, tolerance, non-discrimination and respect for each other’s rights. Although these conflicting demands may never be fully reconciled, the aim should be to strike as fair a balance as possible between them.

In 2008, a study by the Venice Commission (under the auspices of the Council of Europe) put forward some suggestions as to where that balance should lie.[xxviii] “It must be possible,” the commission said, “to criticise religious ideas, even if such criticism may be perceived by some as hurting their religious feelings.” It added that “an insult to a principle or a dogma, or to a representative of a religion, does not necessarily amount to an insult to an individual who believes in that religion”. Furthermore, insults to religious feelings should not be criminalised unless they contained incitement to hatred “as an essential component”.

The commission acknowledged that the dividing line between insulting speech and incitement to hatred is “often difficult to identify”. Relevant factors include the intention of the accused speaker or author, the effects of his or her action, the context in which the statement is made, the intended audience and whether the statement was made by someone acting in an official capacity.

The report also cautioned against over-reliance on the law as a means for combating hate speech, since it might raise expectations which could not be met and provide offenders with a propaganda victory by turning them into martyrs:

As is the case with other problems of society, it is not exclusively or even primarily for the courts to find the right balance between freedom of religion and freedom of expression, but rather for society at large, through rational discussions between all parts of society, including believers and non-believers.

On the question of race and religion, the commission accepted – up to a point – that there is a difference between racist insults and insults directed against followers of a religion. While noting that “this difference has prompted some to conclude that a wider scope of criticism is acceptable in respect of a religion than in respect of a race”, the commission said it should not become an excuse to unduly stretch the boundaries between “genuine ‘philosophical’ discussion about religious ideas and gratuitous religious insults”.

The word “gratuitous” appears several times in the commission’s report, and it can be quite a useful test for unacceptable speech. Another test is to ask whether the ideas being expressed “contribute to any form of public debate capable of furthering progress in human affairs”.[xxix] Not all ideas deserve to be circulated, the commission said:

Since the exercise of freedom of expression carries duties and responsibilities, it is legitimate to expect from every member of a democratic society to avoid as far as possible expressions that express scorn or are gratuitously offensive to others and infringe their rights.

Sensible self-censorship could help to strike a balance between freedom of expression and ethical behaviour. Refraining from uttering certain statements can be perfectly acceptable when it is done in order not to hurt gratuitously the feelings of other persons, whereas it is obviously unacceptable when it is done out of fear of violent reactions.

Freedom of expression must not “indiscriminately retreat” when facing violent reactions, the commission said. “The threshold of sensitivity of certain individuals may be too low in certain specific circumstances, … and this should not become of itself a reason to prevent any form of discussion.”

Arab non-believers include both activists and quietists. Unlike the New Atheists, some go out of their way to avoid causing offence. Badra, from Lebanon, said:

When I feel that I cannot exercise my rights fully, I may choose not to confront, because the price would be high and I do not like to be dragged into useless or unworthy battles. I always choose to leave. Not necessarily immediately, but at a certain point. By making use of this option, I think that I managed to have the life that I wanted, without hurting, or hurting as little as possible.

How far non-believers can go in asserting themselves depends on their personal circumstances, and living as an atheist in Saudi Arabia requires more compromises than in most places, as Omar Hadi explained:

The extremists will be offended by anything, but I don’t want to attack the community. I don’t fast, but I don’t eat during Ramadan in front of my mother because that will offend her and I love my mother. She suspects, but she never asks me and I never go out of my way to show her anything. In the same way that I respect my mother and don’t want to offend her, I don’t want to offend society.

Obviously there are some religious figures that are very popular … I think they are hypocrites and in it for the money and power, but at the same time I understand that they are highly respected by the majority of the population and I don’t want to offend anybody, so you just mind your own business and move on.

I also understand that this goes against the concept of freedom of speech and the right to offend. I understand that, but that’s the reality we live in.

© All rights reserved

Continue reading >>>


[i]. Enemies Not Allies: the Far Right. One Law For All, 2011.

[ii]. “A statement regarding Nick Griffin’s use of the term ‘Fenian’ from his MEP Constituency Office.” 18 October 2012.

[iii]. “Easter Message from BNP Chairman hits mark!” Stormfront, July 2006.

[iv]. Spencer, Robert: “2 Men, in New York and Florida, Charged in Qaeda Conspiracy.” Jihad Watch, 30 May 2005.

[v]. Siding With the Oppressor: The Pro-Islamist Left. One Law For All, 2013.

[vi]. Author’s interview, May 2014.

[vii]. “No Bigotry and No Apologism.”

[viii]. For more information about the history of the term “Islamophobia”, see: Richardson, Robin: “Islamophobia or anti-Muslim racism – or what? – concepts and terms revisited.” 2012

[ix]. Islamophobia: a challenge for us all. Runnymede Trust, 1997.

[x]. Berlinski, Claire: “Moderate Muslim watch: How the term ‘Islamophobia’ got shoved down your throat.” Ricochet, 24 November 2010.

[xi]. Richardson, Robin: op cit

[xii]. “Racism and Islamophobia.” FAIR website, undated.

[xiii]. “BNP leader said Islam was ‘wicked’.” Daily Mail, 3 November 2006.

[xiv]. Wainwright, Martin: “Islam is vicious, wicked faith, claims Griffin.” The Guardian, 26 January 2006.

[xv]. “Islamophobia? Muslimophobia? Anti-Muslim Bigotry? A discussion between Ex-Muslims on appropriate neologisms.” Hiba Krisht was using the name “Marwa” at the time of the blog post.

[xvi]. ibid

[xviii] . Whitaker, Brian: “The right answer or the wrong question?” The Guardian, 27 March 2004.

[xx]. is-still-going-strong/comments?page=1#comment_596425

[xxi]. crucifixes-angers-italy/comments?page=1#comment_411188

[xxiv]. Lean, Nathan: “Dawkins, Harris, Hitchens: New Atheists flirt with Islamophobia.” Salon 30 March 2013.

[xxv]. Harris, Sam: “Head-in-the-Sand Liberals.” Los Angeles Times, 18 September, 2006.

[xxvi]. Blackford, Russell: “Islam and ‘Islamophobia’ – a little manifesto.” The Hellfire Club blog, 30 June, 2011.

[xxvii]. Author’s interview and email exchange, July 2014.

[xxviii]. European Commission for Democracy through Law (Venice Commission): “Report on the relationship between freedom of expression and freedom of religion” CDL-AD(2008)026.

[xxix]. European Court of Human Rights, Gündüz v Turkey, 2003.