Compendium of Standards, Good Practices and Recommendations from military service.285 Accordingly, conscientious objectors could be required to perform civilian service instead of compulsory military service, and had no right to be exempted from substitute civilian service. It is noteworthy that, at the time of this ruling, in 1966, many Council of Europe states retained compulsory military service. Later judgments found that, where states recognized conscientious objection, they were required to do so in a way that was not discriminatory. Article 14 of the Convention prevents discrimination in the enjoyment of Convention rights on any ground, including “religion, political or other opinion”. Thus, differences in the length of alternative service relative to the period of conscription that cannot be objectively justified may breach Article 14.286 Nonetheless, the Court stopped short of requiring states to make alternative service available for conscientious objectors. Additionally, in a series of cases brought against Turkey, the European Court of Human Rights found that the liability of conscientious objectors in that country to repeated prosecution for military offences based on their refusal to serve constituted a form of civil death or being made an outlaw. This could then amount to degrading treatment in violation of Article 3 of the Convention.287 Finally, in 2011, after acknowledging that legal recognition of conscientious objection was now available in most Council of Europe states, the Grand Chamber, in Bayatyan v. Armenia,288 reversed the Court’s initial position and determined that a right to conscientious objection could be deduced from Article 9 on the right to freedom of religion or belief (see Box 8.1). 285 A series of decisions confirmed that whether states chose to recognize conscientious objection was discretionary: European Court for Human Rights, X. v. the Federal Republic of Germany (Application no. 7705/76, decision of 5 July 1977); Conscientious Objectors v. Denmark (Application no. 7565/76, decision of 7 March 1977); A. v. Switzerland (Application no. 10640/83, decision of 9 May 1984); N. v. Sweden (Application no. 10410/83, decision of 11 October 1984); Autio v. Finland (Application no. 17086/90, decision of 6 December 1991), Peters v. The Netherlands (Application no. 22793/93, decision of 30 November 1994); Heudens v. Belgium (Application no. 24630/94, decision of 22 May 1995); and GZ v. Austria (Application no. 5591/72, decision of 2 April 1973). 286 European Court for Human Rights, Autio v. Finland (Application no. 17086/90, decision of 6 December 1991); Julin v. Finland (decision of 6 December 1991 [unpublished]); Raninen v. Finland (Application no. 20972/92, decision of 7 March 1996), para. 55. 287 European Court for Human Rights, Ülke v. Turkey (Application no. 39437/98, judgment of 24 January 2006), paras 62-64. The practice has also been criticized by the UN Human Rights Committee and the UN Working Group on Arbitrary Detention (UN OHCHR, 2012, op. cit., note 273, pp. 34-36). 288 European Court for Human Rights, Bayatyan v. Armenia (Application no. 23459/03, judgment of 7 July 2011). 131