be covered.964 ‘Teaching and ‘practice’ includes being able to choose religious leaders, schools and texts.965 6. Limitations on one’s manifestation must satisfy the requirements of legality, necessity and proportionality and non-discrimination. The restrictions should only be applied for a specific purpose. In this context, if limitations are imposed in order to protect morals, the Human Rights Committee has noted that such limitations ‘must be based on principles not deriving exclusively from a single tradition’.966 7. Therefore requiring a Sikh to wear safety head gear in his employment may be justified on the basis that this protected him from injury and electric shock.967 8. The manifestation of religion and belief in practice does not always include actions or behaviour that are merely motivated by the belief system. Therefore to be able to rely upon a right to manifest a belief in practice, the applicant must show that it is a 'necessary part' of the practice.968 Conscientious objection 9. Many human rights treaties do not provide express protection for conscientious objection. However, the European Court has recently recognised the existence of the right, provided it is based on religious grounds. The State can provide an alternative to military service.969 The Human Rights Committee has noted that the right could be provided under the ICCPR, Article 18, ‘inasmuch as the obligation to use lethal force may seriously conflict with the freedom of conscience and the right to manifest one’s religion or belief. When this right is recognized by law or practice, there shall be no differentiation among conscientious objectors on the basis of the nature of their particular beliefs; likewise there shall be no discrimination against conscientious objectors because they have failed to perform military service’. 970 However, sentencing an individual to nine months imprisonment for not wearing a uniform as part of military service was not a violation of Article 18 ICCPR.971 10. No difference should be made between conscientious objectors on the basis of their particular religion or belief.972 Alternatives to military service should be the same length of time.973 964 Ibid. However, see European Court, Dogru v France, 4 March 2009. Ibid. 966 Human Rights Committee, General Comment No.22, CCPR/C/21/Rev.1/Add.4 (1993), para 8. 967 Communication 208/1986, Sing Bhinder v Canada, 9 November 1989. 968 European Court, X v UK. 969 European Court, Bayatyan v Armenia, 7 July 2011. 970 General Comment, No.22, CCPR/C/21/Rev.1/Add.4 (1993), para 11. 971 Communication 682/1996, Westerman v Netherlands, UN Doc.A/55/40, p.41. 972 Communication 402/1990, Brinkhof v Netherlands, 27 July 1993. European Court, Thilimmenos v Greece, 6 April 2000. 973 Communication 689/1996, Maille v France, 10 July 2000. 965 153