associations (for example, those advocating unconstitutional behaviour) from membership of the armed forces. This is because such political associations are regarded as lacking the commitment of other political parties to the constitutional order. The need for restrictions in public service on people with extremist views has, for example, been recognized as a justifiable ground for restricting civil and political rights under the European Convention for the Protection of Human Rights and Fundamental Freedoms.61 Equally, however, some countries (Germany, for example) take the view that the best education in democratic practice for members of the armed forces is active citizenship. They therefore impose minimal restrictions on political activities. Where restrictions are imposed on the political activities of members of the armed forces, it is clear that they should be no more than proportionate to the objectives of securing constitutional order or protecting military discipline. They should be legally grounded in a way that makes them transparent, predictable, and open to challenge. For example, a restriction on active participation in national politics may be justified by the need to separate the military and politics, but the case is weaker with regard to local politics, especially if there is no control or involvement of local authorities in military matters. The requirement for the appearance of neutrality may be served by codes restricting public identification in political parties (for example, prohibiting the wearing of uniforms at party meetings), rather than prohibiting participation as such. Restrictions may be relaxed after a member of the armed forces has left the service, and the case for restrictions is weaker when dealing with reservists rather than regular serving members of the armed forces. 2. International Human Rights Commitments The main rights at stake are the freedoms of expression (e.g., to express and communicate political views) and of association (e.g., to join a political party). In addition, the right to vote and stand for office are guaranteed by human rights treaties. The OSCE has consistently affirmed the importance of civil and political rights and of ensuring that they can be fully exercised.62 In Paris in 1990, the OSCE affirmed the right to freedom of association and peaceful assembly, and, at its Copenhagen conference the same year, it stressed the importance of the right to establish political parties. In Copenhagen, the OSCE also affirmed that: “Everyone will have the right to freedom of expression including the right to communication … [and the] freedom to hold opinions and to receive and impart information and ideas without interference by public authority and regardless of frontiers.”63 Further human rights commitments make clear that freedom of expression includes the rights to disseminate and publish views and information.64 61  During the Cold War, the Court was relatively uncritical of political restrictions on state employment against Communists. See Glasenapp v. Federal Republic of Germany, European Court of Human Rights, 28 August 1986, European Human Rights Reports, Vol. 9, 1987, p. 25, and Kosiek v. Federal Republic of Germany, European Court of Human Rights, 28 August 1986, European Human Rights Reports, Vol. 9, 1987, p. 328, where the Court found no violation of Art. 10 because it considered the real issue at the heart of the cases to be that of access to the civil service, which was not protected by the Convention (as it was then interpreted). Contrast Vogt v. Germany, European Court of Human Rights, 26 September 1995, European Human Rights Reports, Vol. 21, 1995, p. 205, however, where a teacher dismissed for actively campaigning for the Communist Party successfully invoked Art. 10. Restrictions on members of the armed forces would, however, be easier for a state to defend under limitations for national security under Arts. 10 and 11 of the ECHR. 62  Helsinki 1975 (Questions Relating to Security in Europe: 1. (a) Declaration on Principles Guiding Relations between Participating States – Principle VII); Madrid 1983 (Questions Relating to Security in Europe: Principles); Vienna 1989 (Questions Relating to Security in Europe: Principles). 63  Copenhagen 1990, para. 9.1. 64  Ibid., para. 10.1. 57 Handbook on Human Rights and Fundamental Freedoms of Armed Forces Personnel