The inability to freely recount past history of apostasy, where there is complete freedom to practise and express current religious beliefs, does not amount to persecution for religious reasons within the meaning of the Refugees Convention. The S395 principle (that a decision-maker cannot require an applicant to modify behaviour to avoid persecution) does not extend to concealment of past insincere conversion where the applicant's current religious practice is unrestricted. A Tribunal finding that claims of apostasy would not be taken seriously, based on the applicant's obviously Christian name, appearance and background, is not jurisdictionally unreasonable.
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