Section 4 - People with a particular religious affiliation

People with a particular religious affiliation

NSW is a multicultural society, and this is also apparent through the wide variety of different religions recorded on the Census (the 2021 Census being the most recent). The purpose of this chapter is to:

provide a brief overview of the beliefs and court-relevant practices of the six most common religions in NSW, and
provide guidance about how judicial officers may take account of this information in court — from the start to the conclusion of court proceedings. This guidance is not intended to be prescriptive.

4.1 Some statistics¹

Last reviewed: May 2026

Table 4.1 shows the numeric breakdown of religious affiliations of the NSW population (8.07 million) and the percentage of the 2021 NSW population represented by each group.

Table 4.1 — Religious affiliation of NSW population²

Religious affiliation	Number of NSW residents	% of NSW population
Christian	3,844,453	47.6%
Muslim (practising Islam)	349,240	4.3%
Hindu	273,780	3.4%
Buddhist	222,770	2.8%
Sikh	47,165	0.6%
Jewish (practising Judaism)	40,249	0.5%
Other religions	40,035	0.5%
No religious affiliation	2,679,783	33.2%
Not declared/Inadequately described	574,688	7.1%
Total NSW population	8,072,163

Of the 47.6% (3.84 million) who identified as Christian in the 2021 Census, in descending order of affiliation, they further divided into the following sub-groups:³
- Catholic — 1.74 million (21.7% of the total population); 96.8% as Western (Roman) Catholic; the rest in denominations such as Maronite Catholic and other Eastern Catholic.
- Anglican — 960,305 (11.9% of the population).
- Uniting Church — 172,132 (2.1% of the population).
- Presbyterian and Reformed — 153,481 (1.9% of the population).
- Greek Orthodox — 134,326 (1.7% of the population).
- Baptist — 93,624 (1.2% of the population).
- Pentecostal — 71,624 (0.9% of the population).
- Maronite Catholic — 42,078 (0.5% of the population).
- Jehovah’s Witnesses — 23,388 (0.3% of the population) are.
- Seventh Day Adventist — 22,729 (0.3% of the population).
- Lutheran — 17,185 (0.2% of the population).
- Salvation Army — 11,080 (0.1% of the population).
- Latter-day Saints (Mormons) and Churches of Christ — the rest of the 47.6% identifying as Christian.
The religious affiliations of people born overseas or with recent overseas ancestry, whether from English-speaking countries or non-English speaking countries, are various and do not necessarily match the dominant religion within the particular overseas country. For example, Australians of Southeast Asian ancestry may be Buddhists, Christians, Hindus or Muslims. People of different ethnic backgrounds may have similar religious affiliations, for example, a practising Muslim may be of African, Asian, European, Middle Eastern or Indigenous origin.
There is also generally a wide diversity within religious groups dependent on such things as cultural factors and/or doctrinal differences. It is important not to make assumptions or stereotype. For example:
- Many religions include people for whom their religion is the critical defining factor in their values and the way they behave plus people for whom their religion is of a less significant defining influence or importance.
- Many religions also include a range of doctrinal differences, from the orthodox or fundamentalist (strict adherence to very specific religious rules) to a more relaxed or liberal approach.
- Key findings in trends from the 2021 Census are that, Australia-wide, Christianity decreased by more than 1 million people but is still Australia’s most common religion; Australia is becoming more religiously diverse and almost 10 million Australians reported having no religion.⁴

4.2 Some information⁵

Last reviewed: May 2026

This Section provides a brief overview of the beliefs and court-relevant practices of the six most common religions in NSW — in the order in which they are most commonly practised based on the 2021 Census.

As indicated in 4.1 above, some people who practise one of these six religions will not accept everything described below as conforming to their own beliefs. However, the information has been confirmed by representatives of the particular religion as representing a general understanding of that religion.

4.2.1 Christianity

Last reviewed: May 2026

As indicated at 4.1 above, there is a wide variety of Christian denominations or traditions practised in NSW. People who practise Christianity come from diverse origins. Many Christian denominations contain strands ranging from liberal to conservative.

The annual dating system used in Australia has its origins in Christianity — BC (before Christ) and AD (Anno Domini, literally “in the year of the Lord”, meaning in the years since the birth of Christ). Almost all public holidays in Australia derive from the Christian calendar of festivals, eg Easter and Christmas, and including the prior treatment of Sundays, the Christian sabbath day, as non-working days.

4.2.1.1 Main beliefs

Christians believe Jesus Christ is the son of God, and God and mankind were reconciled through the death and resurrection of Jesus Christ.⁶

Many Christians believe in the ethical principles listed in the Ten Commandments, given to Moses by God on Mount Sinai:

1.: To have no other God besides God
2.: To make no idols
3.: Not to misuse the name of God
4.: To keep the Sabbath holy
5.: To honour one’s parents
6.: Not to commit murder
7.: Not to commit adultery
8.: Not to commit theft
9.: Not to give false evidence
10.: Not to be covetous

There are no particular dietary requirements in most Christian denominations. However, Seventh Day Adventists are expected to be vegetarian and not drink alcohol. Fasting may occur during Lent — the 40 days leading up to Easter/the Resurrection of Jesus Christ. Some Christians may fast at times other than Lent.

4.2.1.2 Holy books and scriptures

The most important holy book for Christians is the Bible. It is made up of the “Old Testament” and the “New Testament”, both of which are collections of sacred writings. The various Christian denominations ascribe differing levels of importance to each Testament. The Old Testament is essentially shared with Judaism. The New Testament contains the gospels (or good news) about Jesus Christ.

4.2.1.3 Religious leaders

Christian religious leaders have various names depending on the denomination — for example, “priest” for Catholics and Orthodox Eastern European Christian denominations, “minister” for most of the other Christian denominations. They are responsible for conducting religious services and providing religious instruction and guidance.

There are strong leadership hierarchies in most Christian denominations with essentially many levels of ordained priests or ministers, with various titles, headed, for example, by the Pope in Catholicism and the relevant country’s Primate in Anglicanism. In some Christian denominations (for example, the Uniting Church), both ordained and non-ordained people can hold any role in the church leadership.

In some Christian denominations there are groups of religious sisters (or nuns) and religious brothers (or monks) who live relatively cloistered lives. Others live and work in the community, usually doing various forms of charitable type work.

4.2.1.4 Forms of worship and festivals

Christians tend to pray congregationally in a church of their particular Christian denomination — on Sundays and on religious festivals. Some denominations, such as Seventh Day Adventists, designate Saturday as their sabbath day rather than Sunday. Church services vary between denominations from highly ritualised with the relevant leaders dressed in religious garments to much less ritualised, with religious leaders wearing a clerical collar or a cross pinned onto a shirt as the only sign of their religious leadership, or wearing no particular distinguishing dress.

There are some Christian festivals that are celebrated by all Christian denominations, although they may be celebrated at slightly different times (for example, the Eastern European orthodox calendar runs approximately 14 days later than the standard Australian calendar).

There are many other festivals that have more or less significance depending on the particular Christian denomination. For example, some have many different saints’ days and some pay more attention to religious events, such as the Assumption of the Virgin Mary.

4.2.1.5 Relevant practices

The following are the practices of most impact in court situations:

Status of women — women generally have an equal status in Christian denominations. However, only some Christian denominations allow female religious leaders. For example, the Catholic church and the Sydney diocese of the Anglican church do not allow women to be priests.
Touching — there are no particular taboos on touching. Although note that there are some Christian denominations that forbid some forms of medical treatments — for example, Jehovah’s Witnesses will refuse blood transfusions and all other forms of treatment involving the use of donations from others.
Dress — priests and other ministers regularly wear some form of distinguishing religious dress, ranging from a full gown, to a clerical collar, or even a cross on a shirt collar. Some wear no distinguishing religious dress at all. Religious sisters (or nuns) and religious brothers (or monks) tend to wear less distinguishing religious dress than earlier times, although those in enclosed orders are more likely to wear gowns or habits.
Worship and festival times — see 4.2.1.4 above.

4.2.2 Buddhism

Last reviewed: May 2026

An individual may follow a Buddhist tradition having been born into it (“ethnic” Buddhists) or by making the choice to follow it (“converts”); heredity plays no role as such.⁷

There are three main Buddhist traditions:

1.: Theravada — with roots in Sri Lanka and Southeast Asia.
2.: Mahayana — prevalent in China, Japan, Korea, Taiwan, Vietnam, and India.
3.: Vajrayana — derives from Bhutan, Mongolia and Tibet, led by the Dalai Lama.⁸

There is diversity within Buddhism, but the various traditions agree about the key beliefs and practices outlined below.

4.2.2.1 Main beliefs

Buddhism is founded on the teachings of Siddhartha Gautama, “the Buddha” or “the Enlightened One”, who was born in 563BC near the present India-Nepal border. The Buddha realised all phenomena in life are impermanent and that the principal cause of suffering is the illusion of the substantial and enduring self. People will become wise, compassionate and free of prejudices and preconceived ideas once they have an “uncluttered and tranquil mind”.⁹

The Buddha’s enlightenment resulted in the four Noble Truths:

1.: That there is suffering.
2.: That suffering has a cause.
3.: That suffering has an end.
4.: That there is a path that leads to the end of suffering.¹⁰

The Eightfold Noble Path enables Buddhists to follow tenets of morality, concentration in mind and wisdom:¹¹

Morality is based upon the Five Precepts — not to destroy life, not to steal, not to commit improper sexual behaviour, not to lie or slander, and to refrain from alcohol and drugs which will distort the mind.
Concentration requires effort and mindfulness in all activities.
Wisdom requires understanding and thoughtfulness in relation to the Buddha’s teachings.

Buddhists do not believe in taking life and therefore many choose to be vegetarian — although this is at the individual’s discretion.¹²

4.2.2.2 Holy books and scriptures

Last reviewed: May 2026

There are numerous holy scriptures associated with the various forms of Buddhism. They are collectively known as the “Tripitaka” or Three Baskets, consisting of “Vinaya Pitaka” or monastic rules, the “Sutra Pitaka” or sermons and the “Abhidharma Pitaka” or higher philosophy.

The teachings of the Buddha are collectively known as the “Dharma” in Sanskrit, or the “Dhamma” in Pali (an ancient language primarily used by Theravada Buddhists), often translated as “the path”.¹³ Buddhism emphasises the practice of teachings, rather than reverence for holy books, but rather than study, the emphasis is on the practice of teachings.

4.2.2.3 Religious leaders

Last reviewed: May 2026

Monks, nuns and some lay people are regarded as spiritual leaders. Buddhist monks and nuns should always be addressed as “Venerable” or “Reverend”, never as “Mr” or “Miss”. This does not apply to persons guilty of murder or sexual offences as they are no longer considered to be monks or nuns and are prohibited from being re-ordained.

4.2.2.4 Forms of worship and festivals

Last reviewed: May 2026

Buddhists commonly practise meditation in the early mornings and evenings with a combination of chanting, prostration or silence.

Meditation does not need to be done in a Buddhist Temple, however many temples do offer services weekly and at festivals.¹⁴

The main Buddhist festival is called “Vesak” — the date of the Buddha’s birth, liberation or enlightenment and his passing away. The actual date varies within Asian cultures but usually coincides with the Full Moon of May.

Individuals may go into reclusive retreat, at which point they must have no contact with anyone.

4.2.2.5 Relevant practices

Last reviewed: May 2026

The following are the practices of most impact in court situations:

Status of women — women have an equal status in Buddhism.
Bowing — bowing with hands clasped in a prayer-like gesture (or sometimes with both hands folded over the heart) shows honour and respect, and is the proper way of greeting monks and people in authority.¹⁵
No direct eye contact — monks from Cambodia, Sri Lanka, Thailand, Laos and Burma usually must not look directly at a member of the opposite sex.¹⁶ They often shield their face with a fan to avoid this. This practice applies to Vietnamese nuns as well. There is no such rule for lay Buddhists — see Section 3 for cultural rules about this.
Touching — touching the head of any person, especially a monk, is seen as impolite.¹⁷ Theravada monks should never be touched by a female. They cannot give or receive any item directly from or to the hand of a female. The item should be placed in front of them for them to pick up. This rule does not generally apply to monks and nuns of the Mahayana tradition. Some cultures have sensitivities to touching people of the opposite sex.
Dress — monks and nuns must wear robes at all times. However, novices may be allowed to wear casual clothes at times. Robes vary in colour and may be maroon, saffron, grey, brown, yellow or black, depending on the local climate and culture. Monks and nuns either shave their heads or have very short hair. Lay Buddhists may wear or carry threaded beads called a mala around their wrists or necks.¹⁸
Worship and festival times — see 4.2.2.4 above.

4.2.3 Islam

Last reviewed: May 2026

The definition of “Islam” in Arabic means “submission” and refers to the submission to “Allah”, the Arabic word for “God”.¹⁹

It is incorrect to use the term “Muhammadanism”, which suggests the worship of Muhammad²⁰ and is considered forbidden. Islam places great emphasis on pure monotheism, and the idea of the “indivisibility” of God.

Muslims in Australia come from over 70 different countries and are therefore ethnically and culturally diverse.²¹ The largest Muslim ethnic groups in Australia are Lebanese and Turkish. Most Muslims in Australia were born in Australia and the vast majority are Australian citizens.

There are two main groups within Islam:

1.: Sunni
2.: Shi’a.

In most Muslim populations, the Sunni are the majority.²² The exceptions are in Iran and Iraq, where the Shi’a form the majority.

Historically the two groups differed over the successor to Muhammad and leadership of the Muslim community (the “Imam”): the Shi’ites believe the leader should be descended from Muhammad; whereas the Sunnis elect their leader from those who are pious and able to do the job effectively.²³ Today, however, the main difference between these groups stems from the different cultures and traditions the two groups have developed over the centuries.

There is another approach to Islam, known as Sufism. It is an approach typified by a range of different mystical attitudes, values and practices, not a particular school or sect, so it can be found among many different “branches” of Islam. There have also been identifiable Sufi groups at different times and in different places.

4.2.3.1 Main beliefs

Last reviewed: May 2026

Muslims believe in one unitary and omnipotent God — “Allah”. The ultimate purpose of humanity is submission to Allah in every aspect of life, including faith, family, peace, love and work.²⁴ Islam is strongly monotheistic and abhors both the attribution of divinity to any human and the notion that Allah might be divisible.

Islam teaches that prophets are sent by Allah to correct moral and spiritual behaviour. The prophets are human, and they provide an example for individuals and nations to follow.²⁵

Muslims believe that there have been many prophets (including Abraham, Moses and Jesus, among others) but that the final prophet was Muhammad, and that the Qur’an is the final revelation of God.

A belief in six Articles of Faith²⁶ is a requirement of every Muslim:

1.: One, unique, incomparable God (Allah).
2.: All the angels.
3.: All the Prophets and messengers of Allah, including Adam, Noah, Abraham, Moses, David and Jesus.
4.: All revealed books/scriptures of Allah.
5.: The Day of Resurrection and the Day of Judgment.
6.: Fate and Predestination.

The Five Pillars²⁷ (or duties) of Islam are regarded as central to the life of the Islamic community:

1.: The profession of faith (Al-Shahada) — “There is no God but Allah and Muhammad is his Prophet”.
2.: The five daily prayers.
3.: To pay alms to the poor (“zakat”). There are complex rules about how much, when and how alms should be given.
4.: Fasting in the month of Ramadan.
5.: The pilgrimage to Mecca (“hajj”), for all able-bodied Muslims, at least once, where reasonably possible.

Muslims are forbidden to eat certain animals and their products such as carrion and in particular, any pork product, except in life threatening situations. Animals that can be eaten are sheep, cattle, poultry, camel, goat and seafood, but only when they have been halal slaughtered, ie slaughtered in a prescribed way. Muslims must avoid toxins and harmful products, including drugs and alcohol. Food that fits the approved criteria and/or has been prepared in the approved way is called “Halal” food.

See under 4.2.3.4 for rules about fasting.

Understanding “jihad”²⁸

For non-Muslims, jihad can be misunderstood and controversial. The teachings of Islam are anti-violence. Muslims must not initiate violence or commit violence.

The word “jihad” in Arabic comes from the root “juhd”, meaning making an effort, hence “struggling” and “contending”. Military combat is not the essence of jihad.

In the Qur’an, jihad is used in two distinct ways, the greatest and the lesser jihad.

The greatest jihad refers to the inner struggle against the ego: this struggle is germane to all genuine spiritual paths, the goal of which is to purify the soul.

The lesser jihad refers to a just war in Islam, ie, military combat but only for the purpose of self-defence. While every Muslim is called upon to wage the greatest jihad, not everyone is called upon to wage the lesser. Military jihad is essentially defensive, not offensive or for the purposes of terrorism, and must be waged according to a methodology established for fighting in a humane way.

The renowned scholar of Islam, Shaykh Muhammad Al-Yaqoubi, has resoundingly refuted the ideology of the terrorist organisation ISIS, demonstrating that their ideology is aberrant and in total violation of Islamic law.²⁹

4.2.3.2 Holy books and scriptures

The Holy Qur’an is considered the final, unaltered and unalterable word of Allah,³⁰ as conveyed to Muhammad by the angel Gabriel and transmitted to his followers by Muhammad. Questioning it is viewed as a very grave error.

The Qur’an is seen as a universal guidebook. It includes some material that can be described as “codes of conduct on morality, nutrition, modes of dress, marriage and relationships, business and finance, crime and punishment, laws and government”.³¹

Much of it, however, relates to theology and metaphysics.

The “Sunna” comprises the “hadith”, which are thousands of recorded teachings and practices of the Prophet Muhammad, and are the second most important source of authority in Islam.³² There is a dispute as to which hadith are reliable and which are not.³³

The Qur’an and Sunna together provide the primary sources for the “Shari’ah” (meaning “the way”). This is a body of Islamic law comprising 1,400 years of highly sophisticated legal scholarship.

See further B Rauf, “After R v Bayda; R v Namoa (No 8)” for a discussion around the different textual interpretations of the Qur’an: “There are verses in the Qur’an which are open to interpretations of violence, just as there are verses in the Christian Bible, but they do not incite violence. Rather, it is violent people who incite violence; they use and misinterpret religious texts for their own purposes.”³⁴

4.2.3.3 Religious leaders

There is no priesthood or institutionalised universal “church” for most Muslims. For example, there are no “ordained” priests or leaders comparable to Bishops or the Pope in terms of authority within Sunni Islam. Religious leadership is usually consensual and authority is often informal and typically limited to a given group or community. “Alim” (singular) or “Ulama” (plural) are religious scholars who fulfil a similar role to priests in many other religions, but they are appointed by their own community, large or small. “Ustaz” or “Ustadz” means a “teacher”, usually an alim. “Imam” means leader and generally refers to a qualified religious leader (usually an alim) who leads the five daily prayers in the mosque. An Imam typically has extensive knowledge of the Islamic faith and is generally a respected person in the Muslim community.

4.2.3.4 Forms of worship and festivals

Muslims pray five times a day. Prayer is called “salah” and the times for salah are based on the position of the sun. There are five obligatory prayers for all adults starting from the age of puberty, which determines adulthood, with exceptions for those who are ill or women who are menstruating:

Fair — before sunrise
Dhuhr — when the sun has passed its highest point where shadow length is at its shortest
Asr — is offered when the shadow length has doubled
Maghreb — after the sun has set
Isha — is an hour and half after sunset

An additional mandatory prayer for men is the Friday Dhuhr, which is prayed in congregation at the mosque.

The ablution ritual, called wudu, is a precondition to prayer. During prayer, Muslims stand, bow and prostrate on the ground with their face towards the Ka’ba — a building located in the Grand Mosque in Mecca. Prayers are congregational and generally performed in a mosque — but can be performed individually, if necessary, at any clean and respectable place. A formal call to prayer is usually made from a minaret (tower) of a mosque, where congregational prayers are conducted, however the call to prayer can be made individually in any setting.

Muslim men pray at the mosque on Friday at midday, where a special congregational prayer and a sermon are delivered by the Imam. Women may choose, but are not obliged, to attend.³⁵

There are two main festivals in Islam. They can occur at any time during the calendar year:

Eid-ul-Fitr (breaking of the fast) — which signifies the end of the month of fasting called “Ramadan”. Ramadan is the ninth month on the lunar calendar.³⁶ It is the month during which the Qur’an was revealed to the Prophet Muhammad. Muslims must fast and abstain from sexual relations for 29 to 30 days.³⁷ The aim is to advance oneself spiritually, to consider the needs and difficult struggles of others and to develop oneself so as to become the best example for the rest of humanity.

Eid-ul-Adha (the feast of sacrifice) — which commemorates the sacrificing of a sheep by the prophet Ibrahim (Abraham). A Muslim sacrifices a sheep and shares it with the poor, neighbours and friends on that day.³⁸ The great pilgrimage to Mecca in Saudi Arabia is also observed at this time when Muslims from all over the world congregate to perform the obligations of the pilgrimage.

4.2.3.5 Relevant practices

The Australian National Imams Council (ANIC) has issued an “Explanatory Note on the Judicial Process and Participation of Muslims”³⁹ to give practical guidance on the etiquette and behaviours that Australian Muslims should observe when engaging in court processes. The note provides information for judicial officers on Islamic practices as they relate to matters which may be raised in connection with Muslims participating in court processes. The note has been described as “a powerful statement by the leadership of Islam in Australia concerning the approach to judicial proceedings”.⁴⁰ In R v Alou the offender’s lack of respect for the court touched on the issue of contrition and remorse and his prospects of rehabilitation.⁴¹

The following are the practices of most impact in court situations:

Status of women — men and women are both equal in Islam. Both are bound by the same obligation as to fasting, prayer, zakat and so on. While equal, men and women have different roles. Women have children; men are caretakers of women. Women can work however they don't have an obligation to spend their wealth on the family. A male however is obligated to do so.
Islamic marriage — the man must offer a dowry, called Marh. This is a mandatory element to the formation of the marriage contract.
Touching — Muslims eat with the right hand because that is in accordance with the teaching of the Holy Prophet Muhammad. The left hand should not generally be used to touch a holy book, or to greet a person. It is not permissible for a man to shake hands with a woman who is not close kin and vice versa.
Death and coronial inquests — as Muslims require an immediate burial to honour the deceased, it is important to ensure that families have access to spiritual support which can be sought from their selected Imam.
Dress — Islam prescribes a modest dress code for both men and women. This code stems from a prohibition on exposing parts of the body known as the “aurat”. The meaning of “aurat” is not universally agreed among Muslims and so there is no clear agreement on specifics of what constitutes “modest” dress. Generally, loose-fitting, non-transparent clothing and the covering of hair are requirements for women. There is diversity of opinion regarding the hijab (scarf or veil). Some Muslims believe women must cover their faces and heads, while others believe only the hair and head needs to be covered. There are also Muslims who believe it is not an Islamic requirement for women to wear veils.

There are various types of headwear for women. The hijab is a general term for a modest dress code and also specifies a scarf that covers the hair (the face is exposed). A chador is a full body cloak. A khimar covers the hair, neck and shoulders, but the face is visible. A niqab is a veil that covers the face showing only the eyes. The NSW Court of Appeal held in Elzahed v NSW [2018] NSWCA 103 at [32] that there was no unfairness in the trial judge dismissing an application a witness (a Muslim woman) made to give evidence wearing a niqab. The trial judge ruled that her judicial ability to assess the witness’ reliability and credibility would be impeded if the witnesses’ face was covered by a niqab. The Court of Appeal found the trial judge did not make an error in making this decision and dismissed the appeal (at [33]). Views on wearing or not wearing the hijab may be determined by cultural and ethnic background as much as by religious conviction or theory. In Australia, many Muslim women wear the hijab. Few wear the burqa (full face and body veil with a mesh grill for the eyes). Women who wear the hijab tend to do so in order not to display or expose their physical attractions to strangers and/or so as to maintain a moral dignity. Women who wear a face covering may remove their covering if required, although they may consider it a very serious matter and only remove it in exceptional circumstances.⁴²
Face covering — Section 13A of the Court Security Act 2005 provides that court security staff may require a person to remove face coverings for the purposes of identification unless the person has “special justification” (s 13A(4)), which includes a legitimate medical reason. Face coverings are defined as an item of clothing, helmet, mask or any other thing that prevents a person’s face from being seen. The court security officer must ensure the person’s privacy when viewing the person’s face if the person has asked for privacy. NSW police are also empowered to require removal of face coverings for identification purposes. Note the Court of Appeal’s decision in Elzahed v NSW [2018] NSWCA 103 that a trial judge did not make an error in ruling that a witness could not give evidence with her face covered by a niqab as this would impede the judge’s ability to assess the witnesses’ reliability and credibility.⁴³
Standing in court and bowing to the judicial officer — No prohibitions or restraints on a Muslim prevent them from standing up or lowering their head as a mark of respect to a judicial officer. The Australian National Imam’s Council (ANIC) has issued an “Explanatory Note on the Judicial Process and Participation of Muslims” to give practical guidance on the etiquette and behaviours that Australian Muslims should observe when engaging in court processes.

See Elzahed v Kaban⁴⁴ for a discussion on disrespectful behaviour in court (failing to stand for a judge when entering and leaving the court when presiding over the plaintiff’s civil proceedings at [65]–[90]) and the elements of the offence under s 200A District Court Act 1973 at [38], [41]–[48].
Worship and festival times — see 4.2.3.4 above.

4.2.4 Hinduism

Last reviewed: May 2026

Hinduism is one of the oldest religions in the world. Different communities in India have practised and evolved it over thousands of years. “Hindu” is a corruption of “Shindu”, the old name for the river Indus.⁴⁵

Hinduism is almost exclusively practised by people of Indian origin, although there are also many other religions practised in India, for example, Sikhism, Buddhism, Islam and Christianity.

Hindus believe that their religion is a continuous process — without beginning or end — preceding the existence of this earth and other worlds beyond.⁴⁶ Hinduism is sometimes called “Sanatan Dharma” — the Eternal Religion.

Hinduism is unique as a religion, as it has no single founder and no single book. It is based on the divine revelations contained in the ancient holy books called the Vedas. Hinduism has a number of denominations with variations in religious practices amongst its followers. For example, the Hindus of North India may have some practices that are not followed by those from Sri Lanka, and vice versa.

The seven major tenets of Hinduism are:⁴⁷

Atma — the soul or the divinity of the Self
Samsara — reincarnation, the cycle of birth and death
Karma — the cosmic law of action and reaction and is the governing law of samsara
Moksha — liberation from the cycle of birth and death (samsara)
Dharma — the right path, way or purpose, including the practice of non-violence (ahimsa paramo dharma) and tolerance of differences within itself and towards other religions (sanatan dharma)
Brahman — while there are many deities and Hindus will worship different gods, Brahma is the creator God and Brahman is the omnipresent, impersonal foundation and sustainer of all things who resides in the heart of every living being, thus all human beings are potentially divine and the aim of life is to realise this divinity within.

Beliefs may be related to the natural world in its countless manifestations with ancestors, the seasons and festivals all playing their part⁴⁸

Srishiti and pralaya — creation and dissolution: this reflects a concept of time as cyclical, not linear. Srishiti is the moment when creation is brought into a manifested world, and as the cycle completes, pralaya or dissolution occurs.

4.2.4.1 Main beliefs

The Hindu ethical code is exemplified by a saying: “‘Punya’ (virtue or good) is doing good to others; and ‘Papa’ (sin or evil) is harming others.”

Hindu scriptures give basic principles of moral, ethical and spiritual conduct applicable to all sections of society. One such list is found in the Vedas, the oldest holy book in Hinduism. The list comprises:

In addition, Kshama (forgiveness), Dhriti (steadfastness), Aarjava (honesty), Mitahara (moderation in diet).

Ahimsa — non violence
Satya — speaking the truth
Asteya — non stealing
Brachmacharya — celibacy/no selfish accumulation of resources
Shaucha — cleanliness
Tapas — austerity and perseverence
Aparighara — purity of mind and body
Swadhyaya — study of the Vedas
Santosh — contentment
Ishwara-pranidhana — acceptance of the Supreme.⁴⁹

The word “Om” is used in Hindu worship and is composed of three Sanskrit letters, “a”, “u” and “m”, which represent the Trinity of energies: “Brahma” the creator; “Vishnu” the preserver; and “Shiva” the destroyer. “Om” is recited before any chant, and Hindus believe it invigorates the body. The symbol for “Om” represents the universe.⁵⁰

Hindus do not believe in taking life, and traditionally most are vegetarian. Those who do eat meat will not eat beef or beef products, and this rule extends to any cooking utensils which may have been used for cooking non-vegetarian foods.⁵¹

Hindus often fast on the eleventh day of the Hindu calendar month and may also fast for a number of days during the year.

4.2.4.2 Holy books and scriptures

There are numerous Hindu holy books. The “Vedas” are the oldest and are written in Sanskrit. The Vedas are a treasure house of information on spiritual, material and social doctrine. The four Vedas are Rigveda, Yajurveda, Samveda and Atharvaveda. The Upanishads are the explanations of Vedas in a simple and practical form.

The “Laws of Manu” contain 2,685 verses of instruction.⁵²

Other holy texts are:⁵³

The Ramayana an epic that contains the life and deeds of Sri Rama.
The Mahabharata an epic that contains the lives of the Princes Pandavas and Kauravas and Lord Krishna. The Bhagavadgita, a most popular scripture from the Mahabharata, narrates a dialogue between Lord Sri Krishna and the warrior, Arjuna, on a battlefield. The central message of the Bhagavadgita is that the soul is immortal and that one should discharge one’s duty with total selfless dedication.

4.2.4.3 Religious leaders

Last reviewed: May 2026

There are two aspects of the Hindu religious leadership:

1.: Ritualistic — mainly male Hindu priests who conduct prayers in the temples and various religious ceremonies and rites. Some temples have female priests.
2.: Spiritual — there are both male and female holy persons of great wisdom, acquired through their devotion, dedication and austere living. The male spiritual person is called a Swami or a Guru. The female spiritual person is called a Mataji or Sanyasini or Pravarajika. They are revered because they provide religious discourses and guidance.

Hindu religious facilities are managed by leaders of the local community.

4.2.4.4 Forms of worship and festivals

Hindus are encouraged to pray at dawn and dusk, but the actual time is not critical.⁵⁴

Most Hindus worship at least once a day at sunrise. Worship times at Hindu Temples are generally in the morning and evening.

Hindus must wash thoroughly and change their clothes before praying.⁵⁵

Hindus also have shrines or designated rooms for worship at home, with pictures or small icons where an oil lamp and incense are burnt.⁵⁶

Hindu festivals are based on the lunar calendar. The main festivals are:⁵⁷

Makar Sankranti in January
Holi in February/March
Sivaratri in March (whole night vigil)
Ramnavami in April
Krishna Janmastmi in August/September
Navratri in September/October (10 day festival) and
Deepavali in October/November.

4.2.4.5 Relevant practices

The following are the practices of most impact in court situations:

Status of women — women are revered in Hinduism. While, traditionally, a woman’s role was a supportive one in the family and community, it has evolved over time due to the impact of globalisation and western influences.⁵⁸

Touching — a greeting in the form of “Namaste” is the most common practice. It suggests a respect from one soul to another soul. Body contact is avoided, not as a taboo, but as a cultural preference.

Dress — Hindu women put on glass bangles when they get married and do not remove them until their husband dies, at which point they are ceremoniously shattered. Breaking or removing these bangles is considered an extremely bad omen and would greatly distress a Hindu woman.⁵⁹ Married women also wear a mangal sutra or thali on a chain (which looks like a nugget) at all times. They also wear a red dot on their forehead.⁶⁰ Some Hindus wear a sacred thread around their bodies, passing diagonally across their body from the shoulder to about waist level. This is put on at an important religious ceremony and must never be removed.⁶¹ Men of one particular Hindu sect (Swami Narayan) may wear a necklace. Some Hindus wear a religious talisman on a chain as a protection from evil action by others. Traditional clothing is worn when participating in worship or religious festivals.⁶²

Worship and festival times — see 4.2.4.4 above.

4.2.5 Sikhism

Last reviewed: May 2026

Sikhs are Australia’s fastest-growing and fifth-largest religious group. Sikhism was founded in Punjab (an area which spans part of India and Pakistan) about 500 years ago by Guru Nanak, on the foundation that everyone is equal, regardless of caste, age, or gender.⁶³ According to 2021 Census data, approximately 0.8% of Australia’s population (210,400 people) are Sikhs.⁶⁴

4.2.5.1 Main beliefs

Sikhs believe in:

One God.
The teachings of the 10 spiritual masters — Gurus.
The holy book, the Guru Granth Sahib, which has the function of the living Guru (see Holy books and scriptures below).
The salvation and liberation from the cycle of reincarnation, which is achieved by meditation and service to others.

The five core articles of faith (“Panj Kakaar”) to be followed traditionally by both men and women include:

Kesh — uncut hair
Kangha — small wooden comb
Kara — iron or steel band worn on wrist of the dominant hand
Kachhehra — prescribed cotton undershorts
Kirpan — small, sheathed, curved blade-shaped object with handle.⁶⁵

Not every Sikh wears every one of these religious articles, though they all have deep spiritual and practical significance.

Broadly, there are two main “groups” in Sikhism:⁶⁶

Sahajdhari Sikhs: individuals who are not initiated, but whose faith consists of belief in the teachings of the religion, and wear some of the Panj Kakaar.
Amritdhari Sikhs (initiated): individuals who have taken part in a special ceremony called “Amrit Sanchaar” or “Khande di Pahul”, and are mandated to wear all of the Panj Kakaar at all times.

Membership of either of these groups is irrelevant to hierarchy, as Sikhs believe that everyone is equal and strongly oppose any form of discrimination.⁶⁷

Other than the Panj Kakaar, the “dastaar” is a prominent symbol of the Sikh identity. It is a type of turban which Sikhs wear as a part of their daily public dress. Sikh women will sometimes wear a “chunni” instead, which is a long scarf that covers the hair.⁶⁸

4.2.5.2 Holy books and scriptures

The principal scripture of the Sikh faith is the Guru Granth Sahib.⁶⁹

The Guru Granth Sahib is regarded by Sikhs as the final, eternal, and living Guru and is treated with utmost respect requiring strict protocols to prevent “Beadbi” (sacrilege). Taking the scripture to court is generally forbidden, and giving evidence by touching it is against Sikh tradition. Instead, affirmation is used. Alternatively, the Sundar Gutka, a daily prayer manual extracted from the Guru Granth Sahib may be used for taking an oath.⁷⁰

There are rules governing the Sundar Gutka which should be followed as far as possible:⁷¹

The book should be kept wrapped in a clean, neat cloth. The suggested colour of the cloth is orange or yellow.
It must not be left on a seat.
No-one should touch the book without first washing their hands, and any person holding the book must not have tobacco (or alcohol) in their possession. The book should only be directly handled by the witness.
Sikhs taking the oath will usually wash their hands and take off their shoes. They may also wear a small cloth, called a Patka, to cover the head if they are not wearing a turban.
The witness should then hold the Sundar Gutka in both hands while the oath is administered.

The form of oath suggested in the Equal Treatment Bench Book (UK) is: “I swear according to the Sundar Gutka (or by Almighty God) that the evidence I give shall be the truth, the whole truth and nothing but the truth.”⁷²

4.2.5.3 Forms of worship and festivals

Worship takes place at the gurdwara with ritual purification ceremonies. There are a number of holy days and festivals, many lasting for three days.

Many Sikhs are vegetarian, but if not, will choose to avoid Halal or Kosher meat. Strictly observant Sikhs will not take tobacco, alcohol, tea or coffee.

On death, the body is washed, dressed in new clothes and cremated, the closest male relative usually starting the cremation.⁷³

4.2.5.4 Religious leaders

Sikhism does not have a clergy or ordained religious leaders like priests, rabbis, or imams. The eternal, living Guru is the sacred scripture, the Guru Granth Sahib, which holds ultimate authority. While there are no human intermediaries, experienced community members (granthis) lead worship and care for the scripture. A scholar of Sikhism (gyani or giani) leads the congregation in prayer.⁷⁴

4.2.5.5 Relevant practices

The following are the practices of most impact in court situations:

Status of women — Sikh doctrine holds that men and women have equal potential for salvation and spiritual growth. Women are active participants in all religious and social activities, including leading congregations (Granthi), performing kirtan, and martial arts (Gatka).
Touching — it is a strong taboo to touch a Sikh’s hair or turban without permission. These are sacred articles of faith and part of a Sikh’s identity.
Dress — Sikhs may wear religious dress such as the dastaar in public and in the courtroom as a fundamental aspect of their faith.⁷⁵ The kirpan is more ambiguous as it may fall under the prohibition of “knives” (as defined in s 93IA of the Crimes Act 1900), or “offensive implements” (as defined in s 11B(3) of the Summary Offences Act 1988).⁷⁶ However, while the Summary Offences Act and Crimes Act make it an offence to carry a knife in a public place, carrying one for “genuine religious purposes” is recognised as a “reasonable excuse”: Summary Offences Act, s 11B; Crimes Act, s 93IB(1)–(3).⁷⁷

In NSW, an initiated Sikh student, for example, may wear a kirpan at school under strict conditions.⁷⁸

Carrying a kirpan (or any knife) for self-defence or the defence of another person is explicitly not a reasonable excuse: Crimes Act, s 93IB(4). The kirpan is not worn for self-defence, rather, it is carried to remind initiated Sikhs of their duty to uphold high moral values to help others at all times and for religious observance only.⁷⁹

While s 11C of the Summary Offences Act offers exemptions for genuine religious purposes, high security locations such as a court may require a kirpan to be removed or stored. Specifically, Court Security Act 2005 (NSW) s 8 stipulates that an individual must not be in possession of a restricted item (which includes knives within the meaning of Sch 1 of the Weapons Prohibition Act 1998) while on court premises, without a reasonable excuse. Sections 11 and 12 allow court security officers to confiscate or require individuals on court premises to surrender anything they perceive as an offensive implement. The religious obligation of a Sikh to wear a kirpan may not be considered a “reasonable excuse”. Some Australian jurisdictions, however, such as Queensland and the ACT, have allowed kirpans in courthouses — provided the wearer adheres to a strict set of rules, including 24-hour advance notifications, declarations to security, keeping the kirpan sheathed and secreted under clothing at all times.⁸⁰
Worship and festival times — see 4.2.5.3 above.

4.2.6 Judaism

Last reviewed: May 2026

Judaism is one of the world’s oldest religions.

Any person whose mother was a Jew is considered to be Jewish. Progressive communities may also accept descent through the father if the child is being brought up as a Jew. Conversion to Judaism is possible after a rigorous course of instruction. People usually convert to Judaism to ally themselves with the family they are marrying into or have married into.

In Australia, there are many different Jewish congregations ranging from progressive to ultra-orthodox traditions.

Jewish people believe in a single God who created the universe and continues to govern it. Moses received the Ten Commandments and the Torah from God on Mt Sinai. The Torah revealed the way God wished to be served, the basic principles of Judaism and instructions on how Jews should live.

4.2.6.1 Main beliefs

Judaism is based upon thirteen principles of faith:

1.: God created all things.
2.: There is only one God.
3.: God has no bodily form.
4.: God is eternal.
5.: We must pray only to God.
6.: All the words of the prophets are true.
7.: Moses was the greatest of the prophets.
8.: The Torah we have is the same that was given to Moses.
9.: The Torah will never change.
10.: God knows human deeds and thoughts.
11.: God rewards good and punishes evil.
12.: The Messiah will come to redeem Israel and the world.
13.: There will be a resurrection of the dead.

However, the more progressive Jewish traditions may dispute some of these principles.

The Sabbath, or Shabbat, is a holy day for Jews and extends from sunset on Friday to sunset on Saturday.⁸¹ Observing the Sabbath involves attending synagogue services on Friday evenings and family gatherings at home. Observant Jews are not allowed to work on the Sabbath or perform many non-arduous secular activities.

Kashrut (from the Hebrew meaning fit, proper or correct) states which foods can be eaten and how food is to be prepared. For example, meat (the flesh of birds and mammals) cannot be eaten with dairy. Separate utensils must be used for meat, as opposed to dairy. Kosher describes food prepared according to these standards.⁸²

Observant Jews eat only Kosher food. For example:

Certain animals must not be eaten, such as pork and rabbit, as well as birds of prey and catfish, sturgeon and shellfish.
The permitted animals, birds and fish must be killed in accordance with Jewish law. This involves slaughtering by a qualified person in a manner that is as pain free as possible. Certain parts of permitted animals must not be eaten.⁸³

4.2.6.2 Holy books and scriptures

Mitzvot are the 613 commandments that are contained in the Torah (the five Books of Moses) and include the Ten Commandments. The mitzvot have been expanded through interpretations by Jewish spiritual leaders. Jewish law (Halakhah) is comprised of the Torah and the interpretations. It covers theology, ethics, marriage, food, clothing, education, work and holy days.⁸⁴

4.2.6.3 Religious leaders

In Orthodox Judaism, only men can become rabbis; whereas liberal and progressive Jews accept women as rabbis and cantors.⁸⁵

The rabbi’s authority comes from extensive study, and a rabbi is considered to be a teacher, rather than an anointed priest. A cantor is used to read the Torah, as few modern Jews can read the poetic Hebrew.⁸⁶

4.2.6.4 Forms of worship and festivals

Observant Jews pray three times a day — morning, afternoon and evening — although spontaneous prayer may be offered at any time. Most Jews manage to fit these prayer times into their normal work schedule.

However, Sabbath and festival observance require special arrangements and consideration.

As indicated earlier, the holy day for Jews (when praying is most important) extends from sunset on Friday to sunset on Saturday.

Sabbath and festival worship is performed congregationally in a synagogue, where prayer takes place facing Jerusalem. In an Orthodox synagogue, men and women are separated — the women sit upstairs or behind a partition or grille — and services are conducted by males in Hebrew. In liberal and progressive synagogues, men and women sit together.

The most important festivals are:

Pessach (Passover) — lasts eight days and marks the deliverance of the Israelites from slavery in Egypt — usually in March or April.
Shavu’ot (Pentecost) — celebrates God’s giving of the Torah on Mount Sinai to the Jewish people always held 50 days after Passover — usually falls in May or June.
Rosh Hashanah (New Year) — the anniversary of the creation of the world — usually in September or October.
Yom Kippur (Day of Atonement) — a 25 hour fast and period of abstinence, spent largely in prayers for forgiveness. Yom Kippur is the holiest day in the Jewish year — usually in September or October.
Succot (Tabernacles) — recalls the journey of the Jews through the desert on the way to the Promised Land — held 5 days after Yom Kippur and lasts seven days — usually held around October.

4.2.6.5 Relevant practices

The following are the practices of most impact in court situations:

Status of women — although in Orthodox Judaism women have no formal role in the liturgy, the fact that being a Jew is determined through the matriarchal line is an important factor in family relationships.
Touching — handshaking is generally considered appropriate and acceptable. However, ultra-Orthodox or “Hasidic” Jews avoid all physical contact with non-family members of the opposite sex. They also limit other forms of association and conversation with them.
Dress — some Jewish men wear a “kippah” or “yarmulke” (religious skullcap) at all times. This is associated with the concept of reverence to God. Others wear the skullcap only during the Sabbath and on festivals. For reasons of integration, some Jewish men wear a hat rather than a “kippah” or “yarmulke”. Observant men also wear an undergarment with fringes on its corners, which are sometimes worn in a visible manner. Many observant married women keep their hair covered with a hat, scarf or wig. Ultra-Orthodox or “Hasidic” male Jews wear black, large hats, long “earlock” hair and beards.
Worship and festival times — see 4.2.6.4 above.

4.2.7 Other religions

Last reviewed: May 2026

For some practical information on the Baha’i religion, Aboriginal and Torres Strait Islander spiritualities and Maori spiritualities, see Religious and spiritual diversity guide for operational police, 4th edn, 2022, Australia New Zealand Policing Advisory Agency.

Otherwise, see 4.4.

4.3 Religious vilification and “hate crimes”

Last reviewed: May 2026

The incidence and/or intensity of religious vilification is often associated with specific events, such as an increase of Islamophobic incident reports after particular terrorist attacks or political rhetoric,⁸⁷ and reported antisemitic incidents during Israel-Gaza conflicts.⁸⁸ Reports of these kinds of incidents are captured by bodies such as the Jewish Board of Deputies or the Islamophobia Register.

Key legislation dealing with religious vilification and “hate crimes” includes the Anti-Discrimination Act 1977 (NSW), the Racial Discrimination Act 1975 (Cth) and the criminal offences found in:

Crimes Act 1900 (NSW) (Pt 3A, Div 8 and Div 8A)
Criminal Code (Cth) (Ch 5, Div 80, Subdiv C).

4.3.1 Anti-Discrimination Act 1977 (NSW)

Last reviewed: May 2026

Part 4BA Anti-Discrimination Act 1977 prohibits religious vilification. This Part came into effect on 12 November 2023 providing that complaints of religious vilification can be made about a public act that occurred on or after this date to Anti-Discrimination NSW.

Section 49ZE Anti-Discrimination Act 1977 (NSW) makes it unlawful for a person, by a public act, to incite hatred towards, serious contempt for, or severe ridicule of a person or group of persons on the ground the person/s:

has, or does not have, a religious belief or affiliation, or
engages, or does not engage, in religious activity.

A “public act” is defined in s 49ZD to include:

public communication including speaking, writing, printing, displaying notices, broadcasting, telecasting, screening and playing of tapes or other recorded material and conduct, and
conduct, including actions and gestures, and the wearing or display of clothing, signs, flags, emblems and insignia.

4.3.2 Racial Discrimination Act 1975 (Cth)

Last reviewed: May 2026

Religious discrimination is not, per se, made unlawful by the Racial Discrimination Act 1975. However the term “ethnic origin” in Pt II and IIA has been interpreted broadly in a number of jurisdictions to include Jewish and Sikh people.

Section 9 Racial Discrimination Act 1975 prohibits racial discrimination generally, making it unlawful for a person to do any act involving “a distinction, exclusion, restriction or preference based on race, colour, descent or national or ethnic origin, which has the purpose or effect of nullifying or impairing the recognition, enjoyment or exercise, on an equal footing, of any human right or fundamental freedom in the political, economic, social, cultural or any other field of public life”.⁸⁹ Further provisions in Pt II describe scenarios which would make racial discrimination unlawful, without limiting the generality of s 9, including:

Enjoyment of rights to equality before the law: s 10
Access to places and facilities: s 11
Land, housing and other accommodation: s 12
Provision of goods and services: s 13
Rights to join trade unions: s 14
Employment: s 15

More specifically, Pt IIA prohibits offensive behaviour based on racial hatred. It is unlawful to do an act, otherwise than in private, if the act is reasonably likely to offend, insult, humiliate or intimidate another person or a group of people, and at least one of the reasons for this act is because of the race, colour or national or ethnic origin of the other person or of some or all of the people in the group.⁹⁰ Acts in this category are not unlawful if said or done reasonably and in good faith for genuine artistic, academic or scientific purposes, or if it is fairly related to a matter of public interest.⁹¹

In the Explanatory Memorandum to the Racial Hatred Bill 1994 (Cth)⁹² (which introduced Pt II and IIA), the term “ethnic origin” is intended to be given its broadest meaning, as defined in King-Ansell v Police⁹³ and Mandla v Dowell Lee,⁹⁴ followed in Miller v Wertheim.⁹⁵ This definition involves consideration of a number of characteristics, a sufficient combination of which would distinguish a segment of the population from others. Essential considerations are a long, shared history of which the group is conscious as distinguishing it from other groups (and the memory of which the group keeps alive), and a cultural tradition of its own (including manners, and family and social customs) that is often, but not necessarily, associated with religious observance. Extra relevant considerations include, inter alia:

shared beliefs and traditions
common geographical origin
a common literature peculiar to the group
a common language (not necessarily peculiar to the group)
a common religion which is different from those surrounding the group, and
being a minority or an oppressed or a dominant group within a larger community.⁹⁶

Jewish and Sikh people have been recognised as having a common “ethnic origin” under the Racial Discrimination Act in Australia, allowing them protection under this legislation as an ethnic group.⁹⁷ However, Muslims have not yet been formally recognised by Australian courts as a distinct ethnic group under the Act for the purposes of unlawful racial discrimination.⁹⁸

4.3.3 Criminal offences of threatening or inciting violence

Last reviewed: May 2026

4.3.3.1 NSW offences

Last reviewed: May 2026

Section 93Z Crimes Act 1900 (NSW) creates an offence of publicly threatening or inciting violence on grounds of race, religion, sexual orientation, gender identity or intersex or HIV/AIDS status.

The elements of the offence are that a person:

1.: by a public act⁹⁹
2.: intentionally or recklessly threatens or incites violence towards another person or a group of persons
3.: on grounds that include that the other person has, or one or more of the members of the group have, a specific religious belief or affiliation.¹⁰⁰

Where an offence was partially or wholly motivated by hatred for or prejudice against a group of people to which the offender believed the victim belonged (such as people of a particular religion), the court is required to take this into account as an aggravating factor in the sentencing exercise.¹⁰¹

4.3.3.2 Commonwealth offences

Last reviewed: May 2026

Groups that are distinguished by religion are protected groups for the purposes of “hate crimes” offences in the Criminal Code Act 1995 (Cth), Ch 5, Div 80.

Chapter 5, Div 80, Subdiv C Criminal Code criminalises “advocating” force or violence against a targeted group, members of targeted groups and, in some cases, persons closely associated with targeted groups. Targeted groups can be distinguished by race, religion, sex, sexual orientation, gender identity, intersex status, disability, nationality, national or ethnic origin or political opinion: ss 80.2A(1)(c) and 80.2B(1)(d). Offences include:

recklessly advocating the use of force or violence against targeted groups, members of targeted groups or close associates: ss 80.2A and 80.2B¹⁰²

threatening force or violence against targeted groups, members of targeted groups or close associates: ss 80.2BA and 80.2BB
advocating or threatening damage to or destruction of real property (including a place of worship) or a motor vehicle owned or occupied by a member or close associate of a targeted group: ss 80.2BC and 80.2BD.

The fault element for each offence is whether the person who advocates the use of force or violence does so reckless as to whether force or violence will occur.¹⁰³

“Advocate” means counsel, promote, encourage or urge: ss 80.2A(6) and 80.2B(7).

It is also an offence to advocate force or violence against a group distinguished by race, religion or ethnic origin by causing damage to property (which includes minor damage such as painting a slogan on a building): s 80.2BE. The maximum penalty for an offence is imprisonment for 7 years, or imprisonment for 10 years if the use of force or violence would threaten the peace, order and good government of the Commonwealth.¹⁰⁴ This offence carries a mandatory minimum penalty of imprisonment for 12 months: Crimes Act 1914 (Cth), s 16AAA.

Any of these offences may be aggravated if the offender is a religious official or spiritual leader.¹⁰⁵

4.3.3.3 Other options

As well as the option for a religious vilification complaint to be made to Anti-Discrimination NSW, other ways to notify of religious vilification include:

Islamophobia Register — offers a secure and reliable service that allows people from across Australia to report any form of anti-Muslim abuse.
NSW Jewish Board of Deputies — provides a site for submitting details of incidents of an antisemitic nature that have been directed at individuals; or incidents that have seen/overheard in a public setting.

4.3.4 Criminal offences of inciting hatred (NSW)

Last reviewed: May 2026

In light of a rise in antisemitic incidents across Australia,¹⁰⁶ the NSW government introduced a number of legislative amendments in 2025 to toughen laws surrounding hate speech and protests. Section 93ZAA Crimes Act 1900 (NSW), introduced by the Crimes Amendment (Inciting Racial Hatred) Act 2025, creates an offence of intentionally, publicly inciting hatred on the ground of race.¹⁰⁷

The elements of the offence are that a person:

1.: by a public act¹⁰⁸
2.: intentionally incites hatred towards another person or a group of persons on the ground of race
3.: and the public act would cause a reasonable person that was the target of the incitement of hatred, or a reasonable person who is a member of a group of persons that was the target of the incitement of hatred, to fear harassment, intimidation or violence, or fear for the reasonable person’s safety.

See also, Commonwealth laws addressing antisemitism, hate crime and extremism at 4.3.5 below.

4.3.4.1 Places of worship

A place of worship is a building or other structure ordinarily used for worship, and includes a church, mosque, synagogue and temple.¹⁰⁹

In NSW, it is a criminal offence under s 214B(1) Crimes Act 1900 to, in or near a place of worship:

(a): without reasonable excuse, intentionally block, impede or hinder a person accessing or leaving, or attempting to access or leave, the place of worship, or
(b): harass, intimidate or threaten a person accessing or leaving, or attempting to access or leave, the place of worship

This offence carries a maximum penalty of 2 years imprisonment or 200 penalty units, or both.¹¹⁰ The conduct does not apply if it is part of an industrial dispute or occurs at/outside Parliament House.¹¹¹

4.3.4.2 Hate symbols

Publicly and knowingly displaying a Nazi symbol is an offence under s 93ZA Crimes Act 1900 (NSW).

There are separate penalties for individuals and corporations who commit this offence either on or near a synagogue, a Jewish school or the Sydney Jewish Museum, or elsewhere.¹¹²

In certain contexts, including:

in connection with Buddhism, Hinduism or Jainism, or
reasonably and in good faith for academic, artistic, educational or other public interest purposes,

displaying a swastika does not constitute the display of a Nazi symbol: ss 93ZA(2)–(3).

More generally, the public and knowing display of prohibited terrorist organisation symbols is an offence, with separate penalties for individuals and corporations.

It is only excusable if the display is done reasonably and in good faith for academic, artistic, educational or other public interest purposes.¹¹³

Similarly, in Ch 5, Div 80, Subdiv CA Criminal Code (Cth), it is an offence to publicly display and trade in prohibited symbols, as well as give the Nazi salute.

4.3.5 Commonwealth laws addressing antisemitism, hate crime and extremism

Last reviewed: May 2026

The Federal Government introduced the Combating Antisemitism, Hate and Extremism (Criminal and Migration Laws) Act 2026¹¹⁴ to expand and strengthen Commonwealth criminal offences to address the spread of hatred and extremism. The laws were introduced in response to the antisemitic terrorist attack at Bondi Beach on 14 December 2025. The Act increases penalties for hate crime offences, such as new aggravated penalties for preachers and leaders who advocate or threaten violence,¹¹⁵ and expands prohibited hate symbols offences. The Amendment Act also creates a fresh framework to enable organisations that engage in conduct constituting a hate crime to be listed as prohibited hate groups.

4.3.5.1 Hate crimes

Section 114A.3 Criminal Code provides a definition of “hate crime”, which means any of the following three things:

1.

prescribed offences, as listed in s 114A.3(1)(a), where the target group is distinguished by race or national or ethnic origin.

The offences are:

advocating or threatening force or violence against individuals or groups based on protected attributes (ss 80.2A–80.2BB));
advocating or threatening damage to property owned by protected persons or to places of worship (ss 80.2BC–80.2BE)¹¹⁶
publicly displaying prohibited symbols or giving Nazi salute (ss 80.2H and 80.2HA).¹¹⁷

2.

conduct that involves publicly inciting hatred of another person (the target) or a group of persons (the target group) because of their race or national or ethnic origin, which would, in all the circumstances, cause a reasonable person who is the target, or a member of the target group, to be intimidated, to fear harassment or violence, or to fear for their safety.¹¹⁸

3.

conduct, or threat of conduct, because of the offender’s belief that the target is a part of or is associated with a particular racial, national or ethnic origin, that involves one or more of the following:

(i): causing serious harm to a person (the targeted person);
(ii): causing serious damage to property (the targeted property);
(iii): causing a person’s (the targeted person) death;
(iv): endangering a person’s (the targeted person) life, other than the life of the person taking the action;
(v): creating a serious risk to the health or safety of a section of the public (the targeted persons).¹¹⁹

A “hate crime” explicitly includes conduct that “whether engaged in before or after this section commences”, where the conduct would have constituted an offence had the provision been in force at the time: Criminal Code, s 114A.3.

4.3.5.2 Prohibited hate groups

Certain groups can be prohibited as “hate groups” by the Governor-General, subject to the satisfaction of the Australian Federal Police (AFP) Minister that:

(a)

the organisation:

(i): has engaged in, prepared or planned to engage in, or assisted the engagement in, conduct constituting a hate crime; or
(ii): has advocated (whether or not in Australia) engaging in conduct constituting a hate crime, other than an offence against ss 80.2A, 80.2B, 80.2BC or 80.2BE (advocacy offences); and

(b)

specifying the organisation as a prohibited hate group is reasonably necessary to prevent social, economic, psychological and physical harm.¹²⁰

Offences regarding hate groups include:

directing the activities of a prohibited hate group: s 114B.1
membership of a prohibited hate group: s 114B.2
recruiting for a prohibited hate group: s 114B.3
training for a prohibited hate group: s 114B.4
funding or getting funds from a prohibited hate group: s 114B.5
providing support for a prohibited hate group: s 114B.6

As at 6 March 2026, the Australian Government listed Hizb ut-Tahrir as the first prohibited hate group under this legislation.¹²¹

4.4 The possible impact of religious affiliations in court

Last reviewed: May 2026

Appropriate account should be taken of the relevant religious affiliation of those attending court, people practising religions (particularly if they come from orthodox or conservative traditions within their religion), otherwise people may feel:

uncomfortable, resentful or offended by what occurs in court
that an injustice has occurred
treated unfairly and/or unjustly in some cases.

It should also be noted that members of religions with the most obvious dress differences, or the most deviation from the more common forms of Christianity practised in Australia, tend to be discriminated against on religious or ethno-religious grounds much more frequently than other people.¹²² This may make some of them more likely to name any perceived problem, or any perceived difference in treatment as being a form of religious discrimination, even when it is not. However, if you follow the guidance provided in 4.4, this should be less likely to occur.

These problems are likely to be compounded if the person also happens to be from an ethnic or migrant background, female, a child or young person, lesbian, gay or bisexual, transgender(ed), a person with a disability, or is representing themselves — see the relevant other Section(s).

Section 4.5, following, provides additional background information and practical guidance about ways of treating people with various types of religious affiliation during the court process, so as to reduce the likelihood of these problems occurring.

4.5 Practical considerations

4.5.1 Modes of address for religious leaders

Last reviewed: May 2026

Points to consider:

In most cases, religious leaders should be addressed by their particular religious leadership title followed, in most cases, by their family name.
However, to avoid offence, it is best to ask the particular religious leader what mode of address they would prefer.

4.5.2 Oaths and affirmations

Last reviewed: May 2026

Anyone who has the necessary competence¹²³ to present evidence in a court (including interpreters — see 3.3.1.7) must first be “sworn” in — as a means of ensuring that what they are about to say will be truthful. This can be done in the form of an oath (a solemn declaration of undertaking that calls upon a faith-based higher power) or an affirmation (secular equivalent). It is the person’s choice which they take.¹²⁴ “The important question of whether to affirm or swear an oath should be presented to all concerned as a solemn choice between two procedures which are equally valid in legal terms.”¹²⁵

The legality of administering an oath depends upon two matters:¹²⁶

1.: Whether the oath appears to the court to be binding on the witness’s conscience;¹²⁷
2.: If so, whether the witness considers it to be binding on his or her conscience.¹²⁸

It is irrelevant whether the witness observes a particular religion.

This means that:

In most cases, the standard oath (“I swear by Almighty God that the evidence I shall give will be the truth, the whole truth and nothing but the truth”, or for interpreters —“I swear by Almighty God that I will well and truly interpret the evidence that will be given and do all other matters and things that are required of me in this case to the best of my ability”)¹²⁹ will only be suitable for those who are Christians and who are happy to take an oath. It has generally stopped being the practice in most courts¹³⁰ for any person taking this oath to hold a copy of a religious text in their hand as they take the oath.
Some Christian witnesses, such as Quakers (the Society of Friends), Moravians and Separatists, prefer to make affirmations because they believe a religious oath sets a double standard of truthfulness, whereas they are duty-bound to tell the truth in all facets of life.¹³¹
For those who have no religion, or who do not wish to take an oath,¹³² the standard affirmation makes no reference to religion — “I solemnly and sincerely declare and affirm that the evidence I shall give will be the truth, the whole truth and nothing but the truth”, or for interpreters —“I solemnly and sincerely declare and affirm that I will well and truly interpret the evidence that will be given and do all other matters and things that are required of me in this case to the best of my ability.”¹³³
For those who practise other religions and who wish to take an oath it will almost always be possible to adapt the oath so that it fits with their religion, by substituting the name of their God(s) into the standard oath.¹³⁴

Their appropriate holy book should be available as required. It is not essential that a religious text be used in taking an oath and it has generally stopped being the practice in most courts. The “Explanatory note on the judicial process and participation of Muslims” issued by the Australian National Imams Council suggests a procedure for administering an oath upon the Holy Qur’an.¹³⁵

Section 24A of the Evidence Act 1995 (NSW)¹³⁶ provides that a person may take an oath even if the person’s religious or spiritual beliefs do not include a belief in the existence of a God. Section 24A provides that any such oath may be in the form prescribed by regulations. However, there are no prescribed regulations. This means that, for example, Buddhists and Hindus (who would generally expect to swear an oath in accordance with their particular holy book/scriptures as opposed to a God or Gods) will need to use the standard affirmation instead.¹³⁷
In most cases, the person’s legal representative or person calling the particular witness will have found out whether the person wishes to be sworn in on the basis of their religion or not. This should also ensure that the appropriate holy book is available if particularly required by that person. In other cases, the court may need to determine whether the person wishes to be sworn in on the basis of their religion or not. In which case, note that:
- Some witnesses may not realise that they are able to swear to tell the truth in a way which is appropriate for them, and if not guided about this may simply agree to take the standard oath, with or without the Bible.
- It is always best to state that it is important that the witness swears to tell the truth in the way that will be most meaningful. And that, for example, if they practise a particular religion that believes in a God or Gods, swearing to tell the truth in line with their religion (that is taking an oath) may be the most meaningful for them. If they reply that they want to swear to tell the truth in line with their religion, you will need to ask what religion they practise, and then if necessary, substitute the appropriate God or Gods — see 4.2 above.
- It is always important to respect the wishes of the particular person in their choice of whether to take an oath or make an affirmation.
It is also important not to assume that someone who refuses, or is unable, to take an oath is any less likely to tell the truth than someone who chooses to make an affirmation that makes no reference to religion.

4.5.3 Appearance, behaviour and body language

Last reviewed: May 2026

As indicated in the relevant Sections above, there are a number of different religious practices in relation to these aspects.

Points to consider:

Dress — No-one should ever be asked to remove their religious dress in open court. If it is necessary to see under someone’s religious dress, it will be necessary to check with that person, or with someone who can advise you of the appropriate religious practice, what can be done. For example, it may be possible to have someone of the same gender check this in a private room, or to go to your chambers with an additional support person agreed to by all concerned. If someone is wearing a hat in court it is always wise to check whether there is a religious reason for this, rather than immediately asking them to remove it. Section 13A of the Court Security Act 2005 provides that court security staff may require a person to remove face coverings for the purposes of identification unless the person has “special justification” (s 13A(4)) which includes a legitimate medical reason: see above at 4.2.3.5. Accommodation could be made for a witness or party to give evidence by alternative means, for example, from behind a screen. The Court of Appeal found in Elzahed v NSW [2018] NSWCA 103 that a trial judge did not make an error in ruling that a witness could not give evidence with her face covered by a niqab as this would impede the judge’s ability to assess the witnesses’ reliability and credibility.

As to the rights of initiated Sikhs to wear a kirpan (small, sheathed sword) in court, see 4.2.5.1.
Disrespectful behaviour in court — It is a punishable offence for a person to intentionally engage in disrespectful behaviour in any NSW court. This includes an accused person, defendant, party to, or person called to give evidence in proceedings before the court. The offence was introduced to bridge the gap between contempt and community expectations of behaviour in court.¹³⁸ The offence refers to behaviour which is disrespectful to the court or the judge presiding over the proceedings (according to established court practice and convention). The offender may be fined or face 14 days imprisonment if found guilty of the offence. The new offence does not affect any power with respect to contempt. Proceedings for contempt may be brought in respect of behaviour that constitutes a “disrespectful behaviour” offence, but a person cannot be prosecuted for both contempt and the offence for essentially the same behaviour.¹³⁹
No direct eye contact — as indicated above, there are some religions for which it is taboo for some people to look (particularly the opposite sex) direct in the eye. For these people, not looking someone in the eye will not necessarily have anything to do with their honesty or credibility.
Touching/standing too close — many religions have rules that members of the opposite sex who are not family members are not allowed to touch each other, or in some cases, stand too close to each other.
If you are unsure whether a particular behaviour trait is to be expected within a particular religion, or unsure how best to deal with it to ensure justice is both done and seen to be done — either ask the person’s legal representative (if they have one), or ask the person themselves, or consider whether the court needs to obtain “expert” advice from someone who has expert knowledge about the particular religion. Note that it may be hard to get the information you need from the person themselves as they may not feel it is their place to inform you, or they may not understand why you need the information, or they may be reluctant to give you the information for some other reason that is religiously or culturally appropriate to them.
All or some of these differences in appearance, behaviour and body language may need to be taken into account whenever you make any assessment based on the demeanour of a person with a particular religious affiliation.
If appropriate, you may also need to alert the jury to the fact that any assessment they make based on the demeanour of a person with a particular religious affiliation must, if it is to be fair, take into account any relevant religious difference. This may need to be noted early in the proceedings rather than waiting until you give your final directions to them — otherwise, their initial assessment of a particular person may be unfairly influenced by false assumptions, and may not be able to be easily changed by anything you say in your final directions to them.
As prescribed by law, you may also need to intervene if it appears that any cross-examination is unfairly or inappropriately alluding to any particular religious difference in appearance, behaviour or body language.¹⁴⁰

4.5.4 Language

Last reviewed: May 2026

Points to consider:

Use the appropriate language to describe any God(s) or religious values or practice. For example, always use “the” before any reference to the Buddha or the Dharma/Dhamma. This will avoid apparent blasphemy to Buddhists.
Do not use any form of discriminatory or discriminatory-sounding language — Be careful not to describe a religious practice as immoral or irrational, even when it is unlawful in NSW. For example, it would be inappropriate to state that it is immoral to follow a religious practice that denies a particular form of medical treatment. In the case where that belief extends to the treatment of a child, for example, the court may have jurisdiction to make an order contrary to the practice. In such a case, the court should explain its decision on the basis of its jurisdiction, rather than engaging in discussion of the morality or otherwise of the belief.
Be careful not to generalise about a particular religion. As is evident from 4.2 above, most, if not all, religions have many approaches and forms.
Treat everyone as an individual, and do not make statements that imply that all those from a particular religious background are the same, or likely to act in the same way. Never assume or imply that even what you suspect or know to be the majority way of behaving or thinking for a particular religious group, is the standard by which any individual member of that group should be judged.

4.5.5 The impact of religious values on behaviour relevant to the matter(s) before the court

Last reviewed: May 2026

In most cases, a person’s religion will have a certain amount of, if not critical, influence on their values, and therefore on how they behave.

In other words, any of the values implied within the descriptions of the various religions listed above could (depending on the matter before the court) be a major influence on the way in which a person who practises that religion behaves, has behaved, or presents themselves, their expectations or their evidence in court.

Points to consider:

Be careful not to let personal views about a particular religion’s views or practices (for example, its apparent attitude to the role of women, or the type and nature of its worship) unfairly influence your assessment or that of others.
Have the particular person’s religious values or practices been an influencing factor in the matter(s) before the court? Note for example, that in most religions homosexuality and/or “practising” homosexuals or lesbians are considered unacceptable at best and sinful at worst. In many religions sex before marriage is unacceptable and/or sinful. Although, be careful not to generalise about a particular religion and to check the particular person’s own religious values and practices.
If so, where possible, you may need to take appropriate account of these influences. For example, you may need to decide whether the law allows you to take account of any such influences first. If so, explain why any such influences can/should be taken into account, or cannot/should not be taken into account. You may also need to explain this in any direction you make to the jury during the proceedings or before they retire, and in your decision-making or sentencing — see 4.5.8.
The religious values and practices of a particular person need to be accorded respect, rather than disrespect, by everyone in court — while explaining and upholding Australian law where it conflicts with the particular value(s) or practice(s). For example, as prescribed by law, this may mean intervening if cross-examination becomes disrespectful, or if it simply fails to take account of a relevant religious difference.¹⁴¹
If you are unsure whether a particular behaviour is the result of an adherence to a particular religion, or unsure how best to deal with it to ensure justice is both done and seen to be done — either ask the person’s legal representative (if they have one), or ask the person themselves. But note that it may be hard to get the information you need from the person themselves as they may not feel it is their place to inform you, or they may not understand why you need the information, or they may be reluctant to give you the information for some other reason that is religiously or culturally appropriate to them.

4.5.6 Appropriate breaks for prayer and/or religious festivals

Last reviewed: May 2026

As indicated above, court times and holidays are generally more suited to those who practise any form of Christianity than those who practise a non-Christian religion.

If requested, wherever possible:

Make the appropriate allowances for those who need to pray at certain times of the day (for example, Muslims) — that is, have a break in proceedings.
Make the appropriate allowances for relevant holy days of the week and not insist that someone be called to give evidence on that day, or when they are meant to be at their place of religious worship.
Make the appropriate allowances for (particularly important) religious festivals and not insist that someone be called to give evidence during such times.

4.5.7 Directions to the jury — points to consider

Last reviewed: May 2026

As indicated at various points in 4.5, above, it is important that you ensure that the jury does not allow any ignorance of religious difference, or stereotyped or false assumptions about people practising (or not practising) a particular religion to unfairly influence their judgment.

In your final directions to the jury, you may need to remind them of any points in relation to these aspects that you alerted them to during the proceedings, and/or cover them for the first time now.

This should be done in line with the Criminal Trial Courts Bench Book or Local Courts Bench Book (as appropriate), and you should raise any such points with the parties’ legal representatives first.

For example, you may need to provide specific guidance as follows:

That they must avoid making stereotyped or false assumptions — and what is meant by this. For example, it may be wise to give them specific examples of religious stereotyping. It may also be wise to give them specific examples of making false assumptions based on their own religious practice or lack of it — for example, that it would be false and legally unfair to conclude that anyone who follows a particular religious norm that happens to conflict with their religious or other values (for example that people of the opposite sex should not generally touch each other in public), is therefore a strange person, untrustworthy or lacking in credibility.

On the other hand, that they also need to assess the particular person’s evidence alongside what they have learned in court about the way in which people from that religious background tend to behave, speak, and what they tend to value, as opposed to the way in which they themselves might act, or the way in which people from their own religion are expected to act. In doing this, you may also need to provide guidance on any legal limitations that exist in relation to them taking full account of any of these matters. And you may also need to be more specific about the particular religious aspects that they need to pay attention to.

4.5.8 Sentencing, other decisions and judgment or decision writing — points to consider

Last reviewed: May 2026

Your sentencing, decision(s) and/or written judgment or decision must be just in each individual case and consistent, and preferably be considered to be fair and non-discriminatory by everyone affected, or referred to, irrespective of their religion or lack of religion.¹⁴²

Points to consider:

In order to ensure that any person with a religious affiliation referred to or specifically affected by your sentencing, decision(s) and/or written judgment or decision also considers it/them to be fair and non-discriminatory, you may need to pay due consideration to (and indeed specifically allude to) any of the points raised in the rest of 4.5 (including the points made in the box in 4.5.7 immediately above) that are relevant to the particular case.¹⁴³
Whether to allow a victim impact statement to be read out in court.
Be particularly careful when dealing with any matter directly related to a particular religion — for example, a development application for an Islamic place of worship or educational facility — to ensure that the matter is, and is seen to be, assessed in a similar way to the way in which the matter would have been assessed if it were related to a Christian religion — while, at the same time, and only if appropriate, taking fair and reasonable account of any proven, different requirements that relate to the particular religion.

4.6 Further information or help

Last reviewed: May 2026

The following organisations can provide further information or expertise about the six most common religions briefly described in this Section. This information is current as of March 2025:

Christianity

NSW Ecumenical Council

— includes 18 Christian denominations
Level 7, 379 Kent Street
Sydney NSW 1230
Ph: (02) 9299 2215

Catholic Archdiocese of Sydney

Catholic Communications
Polding Centre, 133 Liverpool Street
Sydney NSW 2000
Ph: (02) 9390 5100

Anglican Church Diocese of Sydney

Suite 4, Level 5
189 Kent Street
Sydney NSW 2000
Ph: (02) 8267 2700
Email: gsoffice@anglican.org.au

Uniting Church of Australia — NSW/ACT Synod

222 Pitt Street
Sydney NSW 2000
PO Box A2178
Sydney South NSW 1235
Ph: (02) 8267 4300

Presbyterian Church of Australia

168 Chalmers Street
Surry Hills NSW 2010
Ph: (02) 9690 9333 or 1300 773 774
Email: general@pcnsw.org.au

Greek Orthodox — Archdiocesan District of NSW and ACT

242 Cleveland Street
Redfern NSW 2016
Ph: (02) 9690 6100

Apostolic Church Australia (Pentecostal)

National Administration Office
28/20 Enterprise Drive
Bundoora Vic 3083
Ph: (03) 9466 7999
Email: connect@actsglobal.church

Australian Christian Churches (Pentecostal)

State Office
Unit 408 (Level 4)
12 Century Circuit
Norwest NSW 2154
Ph (02) 9894 1555

Lutheran Church — NSW and District

215/20B Lexington Drive
Bella Vista NSW 2153
Ph: (02) 8660 1200

Jehovah’s Witnesses

PO Box 280
Ingleburn NSW 1890
Ph: (02) 9829 5600

The Salvation Army

NSW/ACT Divisional Headquarters
265 Chalmers Street
Redfern NSW 2016
Ph: (02) 9264 1711
Email: webmaster@aue.salvationarmy.org

Seventh-Day Adventist Church

Greater Sydney Conference
185 Fox Valley Rd
Wahroonga NSW 2076
Ph: (02) 9868 6522
Email: sydney@adventist.org.au

Buddhism

Buddhist Council of NSW

25/56-62 Chandos Street
St Leonards NSW 2065
Ph: (02) 9969 8893
Email: office@buddhistcouncil.org

Islam

Australian Federation of Islamic Councils

932 Bourke Street
Zetland NSW 2017
Ph: (02) 9319 6733
Email: admin@afic.com.au

Australian National Imams Council

Suite 3, 20 Worth Street
Chullora NSW 2190
Ph: 1300 765 940

Hinduism

The Hindu Council of Australia

17 The Crescent
Homebush NSW 2140
Ph: 1300 HINDUS
Email: info@hinducouncil.com.au

Sikhism

Australian Sikh Association Ltd

Gurdwara Sahib Glenwood
2–8 Meurants Lane
Glenwood NSW 2768
Ph: (02) 9622 6994
Email: info@asaltd.org.au

Judaism

NSW Jewish Board of Deputies

Level 2, 146 Darlinghurst Road
Darlinghurst NSW 2010
Ph: (02) 9360 1600
Email: mail@nswjbd.org.au

The following NSW government agency can provide information about the appropriate religious organisation(s) for any other religion.

Government agency

Multicultural NSW

Level 8, 56 Station Street East
Harris Park NSW 2150
Ph: (02) 8255 6767
Email: contact@multicultural.nsw.gov.au

4.7 Further reading

Last reviewed: May 2026

Australia New Zealand Policing Advisory Agency, A practical reference to religious and spiritual diversity for operational police, 2nd edn, 2002.

Australia New Zealand Policing Advisory Agency, Religious and spiritual diversity guide for operational police, 4th edn, 2022, accessed 20/3/2025.

Australian Bureau of Statistics, 2021 Census, accessed 20/3/2025.

Australian National Imams Council, “Explanatory note on the judicial process and participation of Muslims”, 2017, accessed 20/3/2025.

Multicultural NSW, accessed 20/3/2025.

“Participation of Muslims in court processes” (2018) 30(2) JOB 18.

Judicial College (UK), Equal Treatment Benchbook, July 2024 edn (updated February 2026), London, accessed 20/4/2026.

Supreme Court of Queensland, Equal Treatment Benchbook, 2016, Brisbane, accessed 17/2/2025.

B Rauf, “After R v Bayda; R v Namoa (No 8)” (2019) 31(9) JOB 81.

4.8 Your comments

The Judicial Commission of NSW welcomes your feedback on how we could improve the Equality before the Law Bench Book.

We would be particularly interested in receiving relevant practice examples (including any relevant model directions) that you would like to share with other judicial officers.

In addition, you may discover errors, or wish to add further references to legislation, case law, specific Sections of other Bench Books, discussion or research material.

Section 15 contains information about how to send us your feedback.

¹Unless otherwise indicated, the statistics in 4.1 are drawn from the Australian Bureau of Statistics, Census of population and housing, 2021, accessed 10/2/2025.

²Australian Bureau of Statistics, Cultural diversity: Census, 2021, accessed 20/3/2025.

³Drawn from the Australian Bureau of Statistics, Census of population and housing, 2021, compiled and presented by .id (informed decisions), New South Wales: Religion, accessed 20/3/2025.

⁴ABS, “Religious affiliation in Australia: exploration of the changes in reported religion in the 2021 Census”, released 4/7/2022, accessed 18/3/2025.

⁵The information in 4.2 is drawn from Australasian Police Multicultural Advisory Bureau, A practical reference to religious diversity for operational police and emergency services, 2nd edn, 2002, Australia New Zealand Policing Advisory Agency, Religious and spiritual diversity guide for operational police, 4th edn, 2022, accessed 20/3/2025, and the Supreme Court of Queensland, Equal Treatment Benchbook, Supreme Court of Queensland Library, Brisbane (2nd edn, 2016 and 3rd edn, 2026). The information has also been confirmed by representatives of the religions discussed.

⁶Australia New Zealand Policing Advisory Agency, Religious and spiritual diversity guide for operational police, 4th edn, 2022, p 48, accessed 20/3/2025.

⁷Supreme Court of Queensland, Equal Treatment Benchbook, 2016, see n 5, p 9.

⁸Australia New Zealand Policing Advisory Agency, Religious and spiritual diversity guide for operational police, 4th edn, 2022, p 37, accessed 20/3/2025; Supreme Court of Queensland, Equal Treatment Benchbook, 2026, see n 5, p 181.

⁹Australia New Zealand Policing Advisory Agency, Religious and spiritual diversity guide for operational police, 4th edn, 2022, p 37, accessed 20/3/2025.

¹⁰ibid.

¹¹Supreme Court of Queensland, Equal Treatment Benchbook, 2016, above n 5, p 9.

¹²ibid.

¹³Supreme Court of Queensland, Equal Treatment Benchbook, 2016, above n 5, p 10; B Schedneck, “What is Theravada Buddhism? A scholar of Asian religions explains”, The Conversation, 31 May 2023, accessed 20/4/2026.

¹⁴ibid.

¹⁵ibid; Australasian Police Multicultural Advisory Bureau, A practical reference to religious diversity for operational police and emergency services, 2nd edn, 2002, p 27.

¹⁶ibid.

¹⁷Australia New Zealand Policing Advisory Agency, Religious and spiritual diversity guide for operational police, 4th edn, 2022, p 42, accessed 20/3/2025.

¹⁸ibid.

¹⁹Supreme Court of Queensland, Equal Treatment Benchbook, 2016, above n 5, p 11.

²⁰When referencing Muhammad, “PBUH”, the shortened form of “Peace be upon him”, is used as a mark of respect.

²¹Supreme Court of Queensland, Equal Treatment Benchbook, 2016, above n 5, p 11.

²²ibid.

²³ibid.

²⁴ibid.

²⁵Australasian Police Multicultural Advisory Bureau, A practical reference to religious diversity for operational police and emergency services, 2nd edn, 2002, p 50.

²⁶For further information, see BBC, “Key beliefs in Islam”, accessed 30/4/2026.

²⁷Australia New Zealand Policing Advisory Agency, Religious and spiritual diversity guide for operational police, 4th edn, 2022, p 69, accessed 20/3/2025. For further information, see Islami City, The Five Pillars of Islam, accessed 20/3/2025. See also Judicial College (UK), Equal Treatment Benchbook, July 2024 edn (updated February 2026), London, accessed 20/4/2026.

²⁸Derived from HRH Prince Ghazi Bin Muhammad, A thinking person’s guide to Islam, White Thread Press & Turath Publishing, 2017, Ch 11.

²⁹Shaykh Muhammad Al-Yaqoubi, Refuting ISIS, Sacred Knowledge, 2016, 2nd edn, p 13.

³⁰Supreme Court of Queensland, Equal Treatment Benchbook, 2016, above n 5, p 12.

³¹ibid.

³²ibid.

³³See A Alomar, “Credibility of Sunnah” (2016) 18(4) European Journal of Law Reform 341.

³⁴B Rauf, “After R v Bayda; R v Namoa (No 8)” (2019) 31(9) JOB 81 at 83.

³⁵ibid, p 30.

³⁶Supreme Court of Queensland, Equal Treatment Benchbook, 2026, above n 5, p 191; Australia New Zealand Policing Advisory Agency, Religious and spiritual diversity guide for operational police, 4th edn, 2022, p 70, accessed 20/3/2025.

³⁷ibid.

³⁸ibid.

³⁹The note can be downloaded from the ANIC website, accessed 20/3/2025.

⁴⁰R v Alou (No 4) [2018] NSWSC 221 at [237]–[238] per Johnson J.

⁴¹R v Alou (No 4) [2018] NSWSC 221 at [236].

⁴²Australia New Zealand Policing Advisory Agency, Religious and spiritual diversity guide for operational police, 4th edn, 2022, p 72, accessed 20/3/2025.

⁴³Law Enforcement (Powers and Responsibilities) Act 2002 (LEPRA), Pt 3, Div 4, ss 19A–19C.

⁴⁴Elzahed v Kaban [2019] NSWSC 670

⁴⁵Judicial College (UK), Equal Treatment Benchbook, July 2024 edn (updated February 2026), p 313, accessed 20/4/2026.

⁴⁶Bhakti Marga Academy, Understanding Hinduism, accessed 20/1/2025.

⁴⁷ibid.

⁴⁸Judicial College (UK), Equal Treatment Benchbook, July 2024 edn (updated February 2026), p 314, accessed 20/4/2026.

⁴⁹Supreme Court of Queensland, Equal Treatment Benchbook, 2016, n 5, p 15–16.

⁵⁰ibid, p 31.

⁵¹Australia New Zealand Policing Advisory Agency, Religious and spiritual diversity guide for operational police, 4th edn, 2022, p 62, accessed 20/3/2025.

⁵²Supreme Court of Queensland, Equal Treatment Benchbook, 2016, above n 5, p 16.

⁵³ibid.

⁵⁴Australia New Zealand Policing Advisory Agency, Religious and spiritual diversity guide for operational police, 4th edn, 2022, p 61, accessed 20/3/2025.

⁵⁵ibid.

⁵⁶Supreme Court of Queensland, Equal Treatment Benchbook, 2016, above n 5, p 17.

⁵⁷ibid.

⁵⁸BBC, “Practices in Hinduism, women’s rights and inclusion”, accessed 18/3/2025.

⁵⁹ibid.

⁶⁰ibid, p 43.

⁶¹ibid.

⁶²ibid.

⁶³BBC, “What is Sikhism?”, accessed 20/4/2026.

⁶⁴Australian Bureau of Statistics, Census of Population and Housing: Census article — Religious affiliation in Australia, 2021, Table 4 — Religious Affiliation (Religious Groups), released 4/7/2022, accessed 13/4/2026.

⁶⁵Australian Sikh Civil Rights, “Panj Kakaar — 5 Ks”, accessed 13/4/2026; Judicial College (UK), Equal Treatment Benchbook, July 2024 edn (updated February 2026), p 321, accessed 20/4/2026.

⁶⁶Gayle Brewer, Jatinder Singh and Minna Lyons, “The lived experience of racism in the Sikh community” (2023) 39(11) Journal of Interpersonal Violence, 2415, 2417; Australian Sikh Civil Rights, “Amrit Sanchaar — Sikh initiation ceremony”, accessed 13/4/2026.

⁶⁷Australian Sikh Civil Rights, “Amrit Sanchaar — Sikh initiation ceremony”, accessed 13/4/2026; Sikh Coalition, “FAQ”, accessed 13/4/2026.

⁶⁸Australian Sikh Civil Rights, “Dastaar: The Sikh turban”, accessed 13/4/2026; National Sikh Organisation, “Dastar: The Sikh turban”, accessed 16/4/2026; SikhNet, “Chuni: The honor of a Sikh woman”, accessed 16/4/2026.

⁶⁹Judicial College (UK), Equal Treatment Benchbook, July 2024 edn (updated February 2026), p 322, accessed 20/4/2026.

⁷⁰The Sundar Gutka has been considered the appropriate form of a Sikh holy book to be used in courts in the UK. This convention seems to avoid difficulties over the rules regarding the handling of the Guru Granth Sahib outside a gurdwara (Sikh place of assembly and worship) by persons who are not qualified or authorised to do so: see Judicial College (UK), Equal Treatment Benchbook, July 2024 edn (updated February 2026), p 322, accessed 20/4/2026..

⁷¹Supreme Court of Queensland, Equal Treatment Benchbook, 2016, above n 5, p 38.

⁷²Judicial College (UK), Equal Treatment Benchbook, July 2024 edn (updated February 2026), p 322, accessed 20/4/2026.

⁷³Judicial College (UK), Equal Treatment Benchbook, July 2024 edn (updated February 2026), p 321, accessed 20/4/2026.

⁷⁴US Department of Homeland and Security, “FEMA: Engaging faith communities”, accessed 5/5/2026.

⁷⁵Although, note that in NSW there is no exemption to the requirement for electric scooter, bicycle and motorbike riders to wear helmets for Sikhs who wear turbans. Turban-wearing Sikhs are also required to wear hard hats on construction sites, as there is no formal exemption from workplace health and safety (WHS) regulations for religious headwear on building sites.

⁷⁶An “offensive implement” includes anything made or adapted for use for causing injury to a person, or anything intended by the carrier to be used for injury or menace to a person or to damage property: Summary Offences Act, s 11B(3). A “knife” includes a blade, but does not include a knife prescribed by the regulations: Crimes Act, s 93IA.

⁷⁷Australian Sikh Civil Rights, “New South Wales: Kirpans”, accessed 13/4/2026; ibid s 93IB(1)–(2).

⁷⁸See, eg, NSW Department of Education, “Knives in schools”, September 2021, accessed 16/4/2026.

⁷⁹Australian Sikh Civil Rights, “Frequently asked questions”, accessed 13/4/2026; The Sikh Coalition, “Sikhism and the Sikh kirpan fact sheet”, 22 October 2022, at https://www.sikhcoalition.org, accessed 16/4/2026.

⁸⁰See, for example, Practice Direction 2 of 2017 for the District Court of Queensland, and Amended Practice Direction 9 of 2014 for the Supreme Court of Queensland, and “ACT Law Courts Security Screening and Conditions of Entry” policy issued on 2 December 2024 (accessed 4/5/2026).

⁸¹Supreme Court of Queensland, Equal Treatment Benchbook, 2026, above n 5, p 196.

⁸²ibid, p 19–20.

⁸³Supreme Court of Queensland, Equal Treatment Benchbook, 2016, above n 5, p 20.

⁸⁴ibid, p 19.

⁸⁵Judicial College (UK), Equal Treatment Benchbook, July 2024 edn (updated February 2026), p 317, accessed 20/4/2026.

⁸⁶Australia New Zealand Policing Advisory Agency, Religious and spiritual diversity guide for operational police, 4th edn, 2022, p 81.

⁸⁷See further B Rauf, “After R v Bayda; R v Namoa (No 8)” (2019) 31(9) JOB 81.

⁸⁸See M Vergani and D Goodhardt, “We tracked antisemitic incidents in Australia over four years. This is when they are most likely to occur”, The Conversation, 2 April 2021, accessed 24/3/2026.

⁸⁹Racial Discrimination Act 1975 (Cth) s 9(1). Complaints lodged under the Racial Discrimination Act 1975 are investigated and conciliated by the Australian Human Rights Commission.

⁹⁰ibid, ss 18B, 18C.

⁹¹ibid, s 18D.

⁹² Explanatory Memorandum, Racial Hatred Bill 1994 (Cth), p 2.

⁹³[1979] 2 NZLR 531, 543 (Richardson J) (“King-Ansell”).

⁹⁴[1983] 2 AC 548, 562 (Lord Fraser) (“Mandla”).

⁹⁵[2002] FCAFC 156 (“Miller”).

⁹⁶King-Ansell v Police [1979] 2 NZLR 531; Mandla v Dowell Lee [1983] 2 AC 548.

⁹⁷See Miller v Wertheim [2002] FCAFC 156, citing with approval King-Ansell, ibid and Jones v Scully [2002] FCA 1080 at [113]; Mandla, ibid.

⁹⁸Note that the Explanatory Memorandum, Racial Hatred Bill 1994 suggests that Muslims are included in the expressions “race” and/or “ethnic origin”: Explanatory Memorandum, Commonwealth, House of Representatives, 10/11/1994, pp 2–3. However, courts have historically differentiated between religions like Judaism (recognised as having a common ethnic origin) and Islam, which is perceived as a universal faith comprised of many different races.

⁹⁹As defined in s 93Z(5).

¹⁰⁰Crimes Act 1900 (NSW), s 93Z(1)(b), inserted by Crimes Legislation Amendment (Racial and Religious Hatred) Act 2025, commenced on assent 2/3/2025.

¹⁰¹Crimes (Sentencing Procedure Act) 1999 (NSW), s 21A(2)(h).

¹⁰²Amended by Criminal Code Amendment (Hate Crimes) Act 2025 (Cth), commenced 8/2/2025.

¹⁰³Recklessness was introduced as the fault element by the Criminal Code Amendment (Hate Crimes) Act 2025 (Cth), commenced 8/2/2025.

¹⁰⁴As inserted by the Combatting Antisemitism, Hate and Extremism (Criminal and Migration Laws) Act 2026, Sch 1, Pt 5, s 26 commenced 22/1/2026.

¹⁰⁵Criminal Code (Cth), s 80.2DA, introduced via amendment by Sch 1, P t 1, s 7 Combatting Antisemitism, Hate and Extremism Act 2026, commenced 22/1/2026.

¹⁰⁶The surge in antisemitism has been attributed to the ongoing Israel-Gaza conflict, particularly in the aftermath of the 7 October 2023 attack on Israel; See P Buckley, “Antisemitic incidents across Australia since 2023 — timeline”, The Guardian, 21 December 2025, accessed 23/2/2026.

¹⁰⁷Section 93ZAA inserted by Crimes Amendment (Inciting Racial Hatred) Act 2025 (NSW), commenced 15/8/25.

¹⁰⁸As defined in s 93Z(5).

¹⁰⁹Crimes Act 1900 (NSW), s 214B(4).

¹¹⁰Crimes Act 1900 (NSW), s 214B, amended by Crimes Amendment (Places of Worship) Act 2025.

¹¹¹Crimes Act 1900 (NSW), s 214B(2).

¹¹²Crimes Act 1900 (NSW), s 93ZA, amended by Crimes Legislation Amendment (Racial and Religious Hatred) Act 2025.

¹¹³Crimes Act 1900 (NSW), s 93ZB, introduced by Terrorism and Other Legislation Amendment Act 2025.

¹¹⁴Commenced 22/1/2026.

¹¹⁵Criminal Code (Cth) ss 80.2BA and 80.2BB, BD, DA.

¹¹⁶Criminal Code (Cth), s 114A.3(1)(a)(i), introduced by Combatting Antisemitism, Hate and Extremism (Criminal and Migration Laws) Act 2026 (Cth), commenced 22/1/2026.

¹¹⁷Criminal Code (Cth), s 114A.3(1)(a)(ii), introduced by Combatting Antisemitism, Hate and Extremism (Criminal and Migration Laws) Act 2026 (Cth), commenced 22/1/2026.

¹¹⁸Criminal Code (Cth), s 114A.3(2), introduced by Combatting Antisemitism, Hate and Extremism (Criminal and Migration Laws) Act 2026 (Cth), commenced 22/1/2026.

¹¹⁹Section 114A.3(5) Criminal Code, introduced by Combatting Antisemitism, Hate and Extremism (Criminal and Migration Laws) Act 2026 (Cth), commenced 22/1/2026.

¹²⁰Criminal Code (Cth), s 114A.4(1), introduced by Combatting Antisemitism, Hate and Extremism (Criminal and Migration Laws) Act 2026 (Cth), commenced 22/1/2026.

¹²¹Australian National Security, “Listed prohibited hate groups”, accessed 19/03/2026.

¹²²See statistics and information contained in the Annual Reports of the Anti-Discrimination Board of NSW, accessed 10/4/2025.

¹²³Those reasonably objected to as incompetent to take an oath, or who appear to the court to be incompetent to take an oath, may make a declaration in the form of the Sixth Schedule to the Oaths Act 1900 (NSW): Evidence Act 1995 (NSW), s 13(1).

¹²⁴Evidence Act 1995 (NSW), ss 21–23.

¹²⁵Judicial College (UK), Equal Treatment Benchbook, July 2024 edn, (updated February 2026), pp 173, accessed 20/4/2026.

¹²⁶Supreme Court of Queensland, Equal Treatment Benchbook, 2016, above n 5, p 32.

¹²⁷Omychund v Barker (1744) 1 Atk 21; 26 ER 15.

¹²⁸R v Kemble (1990) 91 Cr App R 178 at 180.

¹²⁹Evidence Act 1995 (NSW), Sch 1; Oaths Act 1900 (NSW), s 11A.

¹³⁰Evidence Act 1995 (NSW), s 24(1).

¹³¹Supreme Court of Queensland, Equal Treatment Benchbook, 2026, above n 5, p 185.

¹³²Oaths Act 1900 (NSW), s 13.

¹³³Evidence Act 1995 (NSW), Sch 1.

¹³⁴Evidence Act 1995 (NSW), Sch 1.

¹³⁵Australian National Imams Council, “Explanatory note on the judicial process and participation of Muslims”, 2017, at [4], accessed 24/3/2025.

¹³⁶Evidence Act 1995 (NSW), s 24A.

¹³⁷Evidence Act 1995 (NSW), s 24A.

¹³⁸Second Reading Speech, Courts Legislation Amendment (Disrespectful Behaviour) Bill 2016, NSW, Legislative Council, Debates, 11 May 2016, p 9.

¹³⁹Supreme Court Act 1970 (NSW), s 131; District Court Act 1973 (NSW), s 200A; Local Court Act 2007 (NSW), s 24A; Coroners Act 2009 (NSW), s 103A. Land and Environment Court Act 1979, s 67A.

¹⁴⁰Note that s 41 of the Evidence Act 1995 imposes an obligation on the court to disallow a question if the court regards it as a “disallowable question” and is expressed in terms of a statutory duty whether or not objection is taken to a particular question: s 41(5). A “disallowable question” is one which is misleading or confusing (s 41(1)(a)), unduly annoying, harassing, intimidating, offensive, oppressive, humiliating or repetitive (ss 41(1)(b)), is put to the witness in a manner or tone that is belittling, insulting or otherwise inappropriate (s 41(1)(c)), or has no basis other than a stereotype: s 41(1)(d). A question is not a “disallowable question” merely because it challenges the truthfulness of the witness or the consistency or accuracy of any statement made by the witness (s 41(3)(a)) — or because the question requires the witness to discuss a subject that could be considered distasteful to, or private by, the witness: s 41(3)(b). Sections 26 and 29 of the Evidence Act also enable the court to control the manner and form of questioning of witnesses, and s 135(b) allows the court to exclude evidence if its probative value is substantially outweighed by the danger that the evidence might be misleading or confusing.

¹⁴¹see n 140.

¹⁴²See also Judicial Commission of New South Wales, Sentencing Bench Book, 2006, Sydney, and R v Henry (1999) 46 NSWLR 346 at [10]–[11].

¹⁴³See Pt 3, Div 2 of the Crimes (Sentencing Procedure) Act 1999 (NSW) and the Charter of Victims Rights (which allows the victim access to information and assistance for the preparation of any such statement). Note that any such statement should be made available for the prisoner to read, but the prisoner must not be allowed to retain it.

People with a particular religious affiliation

4.1 Some statistics1

4.2 Some information5

4.2.1 Christianity

4.2.1.1 Main beliefs

4.2.1.2 Holy books and scriptures

4.2.1.3 Religious leaders

4.2.1.4 Forms of worship and festivals

4.2.1.5 Relevant practices

4.2.2 Buddhism

4.2.2.1 Main beliefs

4.2.2.2 Holy books and scriptures

4.2.2.3 Religious leaders

4.2.2.4 Forms of worship and festivals

4.2.2.5 Relevant practices

4.2.3 Islam

4.2.3.1 Main beliefs

Understanding “jihad”28

4.2.3.2 Holy books and scriptures

4.2.3.3 Religious leaders

4.2.3.4 Forms of worship and festivals

4.2.3.5 Relevant practices

4.2.4 Hinduism

4.2.4.1 Main beliefs

4.2.4.2 Holy books and scriptures

4.2.4.3 Religious leaders

4.2.4.4 Forms of worship and festivals

4.2.4.5 Relevant practices

4.2.5 Sikhism

4.2.5.1 Main beliefs

4.2.5.2 Holy books and scriptures

4.2.5.3 Forms of worship and festivals

4.2.5.4 Religious leaders

4.2.5.5 Relevant practices

4.2.6 Judaism

4.2.6.1 Main beliefs

4.2.6.2 Holy books and scriptures

4.2.6.3 Religious leaders

4.2.6.4 Forms of worship and festivals

4.2.6.5 Relevant practices

4.2.7 Other religions

4.3 Religious vilification and “hate crimes”

4.3.1 Anti-Discrimination Act 1977 (NSW)

4.3.2 Racial Discrimination Act 1975 (Cth)

4.3.3 Criminal offences of threatening or inciting violence

4.3.3.1 NSW offences

4.3.3.2 Commonwealth offences

4.3.3.3 Other options

4.3.4 Criminal offences of inciting hatred (NSW)

4.3.4.1 Places of worship

4.3.4.2 Hate symbols

4.3.5 Commonwealth laws addressing antisemitism, hate crime and extremism

4.3.5.1 Hate crimes

4.3.5.2 Prohibited hate groups

4.4 The possible impact of religious affiliations in court

4.5 Practical considerations

4.5.1 Modes of address for religious leaders

4.5.2 Oaths and affirmations

4.5.3 Appearance, behaviour and body language

4.5.4 Language

4.5.5 The impact of religious values on behaviour relevant to the matter(s) before the court

4.5.6 Appropriate breaks for prayer and/or religious festivals

4.5.7 Directions to the jury — points to consider

4.5.8 Sentencing, other decisions and judgment or decision writing — points to consider

4.6 Further information or help

Christianity

Buddhism

Islam

Hinduism

Sikhism

Judaism

Government agency

4.7 Further reading

4.8 Your comments

4.1 Some statistics¹

4.2 Some information⁵

Understanding “jihad”²⁸