official documents amounts to preventing Baha’is from manifesting their religion. In this sense, recording “Baha’i” on official documents is considered an act of manifesting the Baha’i faith. In their rejoinder, the Complainants resile from this argument on the argument that manifestation of religion cannot be at the behest of the State through its laws. 145. The Commission considers that the refusal to recognise the Bahá’í religion generally, and the refusal to recognise it by recording it in official documents implicates the freedom to practice religion in the forum externum. However, the basis for such a connection between recognition and manifestation cannot be what was advanced by the Complainants in their initial submissions. The Commission agrees with the Complainants that practice of religion cannot be at the behest of a requirement external to the individual’s forum internum such as State law. Manifestation of religion appertains to acts or ommissions which in the perception and internal religious convictions of the adherent are required by the precepts of his or her faith as held in the forum internum. The outward manifestation proceeds from and is dictated by the belief or faith held internally. 146. Recording one’s religion on official documents is not act dictated by religious convictions deeply held in the forum internum. It is an external requirement of State law. It is therefore not an act of manifestation of religion. Moreover, the European Court of Human Rights held in Sofianopoulos and other v Greece,26 that an identity card or similar official documents cannot be regard as a means or medium for adherents of any religion to manifest their religion. It can hardly be said that in requiring individuals to record there religion on official documents, the Respondent State intends to provide a medium for the practice or manifestation of religion. Conversely, the refusal to record “Bahá’í” cannot amount to a denial to manifest one’s religion. 147. An important distinction must be drawn between the relevance of State recognition or acknowledgement to the freedom to adopt or hold a given religion on the one hand, and the freedom to manifest or practice the religion. Even though the State may not recognise or acknowledge a given religion, individuals are still at liberty within their forum internum to embrace and hold such a religion. State recognition or acknowledgement of the religion is immaterial for these purposes. By contrast, State recognition or at least mere acknowledgement of the existence of a given religion is necessary for the State to respect and protect the free manifestation or practice of such religion by its adherents. 148. In turn, the refusal to recognise or acknowledge a religion implicates its free practice as the State may not respect acts of manifestation of the religion, or indeed 26 Sofianopoulos and other v Greece, n 22 above 28