which carries any overtones of gender inequality or subordination, or which imposes on its adherents any physical harm. 84 But practices such as FGM, coerced and polygamous marriage and compulsory restrictive dress codes are more or less damaging for those (generally or exclusively women) subject to them. The identification of many of these practices as 'religious' as distinct from 'cultural' is strongly contested, and privileging those accepted as 'religious', as distinct from merely 'cultural', increases the incentive to categorise them as 'religious' and thereby helps to perpetuate them. 85 The provision of religious exemptions may result in the expansion of 'religious' obligation and the reinforcement of religious hierarchies. 86 7. CONCLUSION: WHAT ROOM FOR PROTECTION OF RELIGIOUS BELIEF? I stated in the introduction to this paper that I would suggest an attenuated form of protection against discrimination on grounds of religion, this in addition to the freedoms guaranteed religious individuals by Article 9 of the European Convention. The additional protection which may be justified notwithstanding the concerns expressed above recognises both the similarities between some forms of religious hostility and racism, and the non-neutral state, and acknowledges the shortcomings of Article 9 as a shield to disadvantage suffered by persons of disadvantaged minority groups because of their religious affiliation (real or perceived). Dealing first with the issue of direct discrimination, one issue that springs to mind is the fact that in Northern Ireland the terms 'Catholic' and 'Protestant', in the context of arguments about justice and equality, have very little