Federal Court Ruling in the Allah Case: What it Means?


Today, the Federal Court dismissed the Roman Catholic Church’s appeal in the Allah case. This was an outcome not unexpected judging by the trend of recent court decisions in such cases.

I was asked today what the Federal Court decision means. For example, does it change anything?

First, we must understand what the case was all about. The Roman Catholic Church in Malaysia (RC) puts out a bulletin called the Herald. All this time, it was published in English. They wanted a Malay language version and applied to the Ministry of Home Affairs (KDN) for a licence. KDN eventually said that a licence would be given but the word “Allah” must not to be used in the Malay language Herald. The RC disagreed and filed a case in the High Court to challenge the KDN decision. To justify their decision, KDN said that certain state enactments had banned non-Muslims from using the word Allah. The RC argued that the Malay-speaking Christians in Malaysia had used this word to refer to God hundreds of years before the prohibition existed and that the ban was unconstitutional in that it violated the rights of Christians to freedom of religion under Article 11 of the Constitution.

The High Court ruled in favour of the RC. In October last year, the Court of Appeal overturned the High Court decision. The RC then applied for leave to appeal to the Federal Court, the highest court in the land. What is this application for leave? According to the law, there is no automatic appeal from a decision of the Court of Appeal. There are 2 stages to contend with. First, the losing party must get leave or, in layman’s terms, permission to appeal. To get leave to appeal, certain criteria must exist. One of them is that the appeal involves interpretation of the Constitution. Secondly, once leave is granted, the Federal Court then hears the substantive appeal and decides whether the Court of Appeal had made a correct decision. There is no further appeal from the Federal Court.

It is fair to say that the Federal Court decision could be confined to its facts as argued by some quarters, namely, it just means that the KDN was justified in refusing a licence if the RC wanted to use the word Allah in the Malay language Herald. However, it is likely that courts will adopt a wider application of the Court of Appeal decision as seen in the recent decision in the SIB case in May when the Kuala Lumpur High Court refused to entertain SIB’s application for judicial review of KDN’s seizure of SIB’s Malay language Sunday School materials. The Judge had said that she was bound by the Court of Appeal decision and thus had to dismiss SIB’s application.

Coming back to the question: what changes have resulted from the Federal Court decison?

I would say none. The status quo started from October 2013 when the Court of Appeal overturned the High Court decision. In effect, it affirmed the validity of the ban against non-Muslims using the word Allah. Since October last year, the Bible Society of Malaysia (BSM) was raided and 321 Malay and Iban bibles were seized by the Selangor Islamic department (JAIS). So, the legal status from October last year to today when the Federal Court announced its decision has actually not altered.

Recently, the Attorney-General (AG) announced that the JAIS raid on BSM was wrong and that BSM had committed no offences that deserved prosecution. In spite of being challenged by the Selangor Islamic  Council (MAIS), the AG had affirmed his decision that no action will be taken against BSM. Even the Prime Minister called on all parties to respect the AG’s decision.

It should be noted that the AG’s decision was made during the regime of the Court of Appeal decision. As the Federal Court today chose not to touch the Court of Appeal decision, it means that things continue as they were since October last year. In other words, nothing had changed including the correctness of the AG’s decision.

To sum up, the reality in Malaysia today is as follows:

  • The finding by the Court of Appeal that state enactments banned non-Muslims from using the word Allah was not overturned and therefore still stands.
  • KDN would be justified in imposing the condition that the word Allah not be used when it issues publishing licences.
  • Non-Muslims may not use the word Allah in states that have laws banning its use. In states without such laws, non-Muslims are not banned from using the word, eg. Sabah, Sarawak, Federal Territory and Penang.
  • It is not an offence against such state enactments to import, print and use the Alkitab, the Malay language bible, even though the word Allah is used.

This is a quick response to the events of today. I will write more about the implications for Christians later.



The Nature of Forgiveness


Forgiveness is perhaps one of the most controversial of Christian duties. Easy to talk about but difficult to practice. 

Christians in Malaysia are angry over the way they are being treated. In the past few years, bibles have been seized, our religious vocabulary restricted, church buildings firebombed and the entire community villified and made the scapegoat for part of the nation’s ills. 

At a time like this, we struggle with Jesus’ teaching in his Sermon on the Mount. Surely, he was asking the impossible of us when he said:

“Love your enemies and pray for those who persecute you” (Matthew 5:44)

Jesus asked us to adopt a response under persecution that suggests weakness and encourages the persecutor:

“Do not resist an evil person. If someone strikes you on the right cheek, turn to him the other also … If someone forces you to go one mile, go with him two miles” (Matthew 5:39,41)

With some interpretive wizardry, perhaps we can make these verses say the opposite. But the logic of interpreting these words to mean an aggressive or retaliatory response breaks down when we look at Jesus’ own conduct when he himself was persecuted.

Jesus did not resist when he was arrested. Peter tried to prevent Jesus arrest by drawing a sword and injuring one of the arresting party. Jesus miraculously healed the injured man and rebuked Peter as follows:

“Put your sword back in its place, for all who draw the sword will die by the sword. Do you think I cannot call on my Father, and he will at once put at my disposal more than twelve legions of angels? But how then would the Scriptures be fulfilled that say it must happen in this way?” (Matthew 26:52-54)

During his trial before the Roman governor, Jesus made no defence but declared that he will not resist the Roman legal process he was subjected to. He said:

“My kingdom is not of this world. If it were, my servants would fight to prevent my arrest by the Jews. But now my kingdom is from another place” (John 18:36)

As he hung on the cross, Jesus prayed for his persecutors: those who conspired against him, who brought false charges against him and who perverted the law in order to slay him. Read what Jesus said:

“Father, forgive them, for they do not know what they are doing” (Luke 23:34)

Like every Christian, I was infuriated by JAIS’ raid on the Bible Society, the way my colleague and I were manhandled and hauled off to the police station and our sacred books unceremoniously bundled into vans used to transport khalwat offenders and transvestites. Two days after the event, I obtained my society’s mandate to take whatever legal action necessary. In the days that followed, as I reflected on Jesus Christ and on his teachings and example, it became clear that the greatest hurdle was not the systematic infringement of the Christian community’s  legal and constitutional right to freedom of religion. Our greatest enemy was ourselves and the demon threatening to possess us was the natural human urge to satisfy that bloodlust for vengeance. The defeat facing us not legal or political but spiritual. When we show a distorted and perverted picture of Jesus Christ and His Church to the nation, we would have lost everything.

The Spirit of God provides to God’s people in sufficient measure love, joy, peace, patience, kindness, goodness, faithfulness, gentleness and self-control (Galatians 5:22-23). 

The events of the past few days (viz. JAIS’ refusal to follow directives of the Attorney-General and the Menteri Besar to return the bibles) have caused many to question whether forgiving JAIS was premature or undeserved.

Christian forgiveness is unconditional. On the cross, Jesus Christ forgave his persecutors even though they were unrepentant and offered no apology. Jesus also knew the future. The night before, he warned his disciples that those who seek his death will also persecute his disciples in the future. Yet, he forgave these men knowing that their future actions will be undeserving of the kindness he showed them.

Christians forgive because it is the right and Christian thing to do. We also forgive because God through Jesus Christ forgave us of our sins and bestowed on us the privilege of being in God’s family.

“When you were dead in your sins … God made you alive with Christ. He forgave us all our sins … he took it away, nailing it to the cross” (Colossians 2:13-14)

As God has forgiven us, so we forgive those who sinned against us. We pray for them hoping that their wrongs will not blind them to the truth and preventing them from receiving God’s forgiveness and blessing of eternal life.

My last post suggested that JAIS be relieved of their appointment as enforcers of the 1988 Selangor anti-propagation law. This does not conflict with forgiveness. One can be forgiven of wrongdoing. But if possible the offender should not be placed in a position to continue doing wrong. For example, even a child molester can be forgiven but he should not be entrusted with the care of children.

Lastly, forgiving goes hand in hand with trusting God. Again, Jesus is the example:

“To this you were called, because Christ suffered for you, leaving you an example, that you should follow in his steps … When they hurled their insults at him, he did not retaliate; when he suffered, he made no threats. Instead, he entrusted himself to him who judges justly” (1 Peter 2:21,23)

Our trust in God was vindicated a few days ago when the AG announced his finding that BSM had broken no law, that the case be closed and the bibles be returned. JAIS is unable to accept the AG’s decision. Christians must be patient and continue to trust God that the solution that God wants to give to us will come about eventually.

Khalid, Show Them Who’s the Boss


The rejection of the Attorney-General’s decision by MAIS and JAIS and their refusal to return Bibles seized from BSM has precipitated a crisis in Selangor state (see link).

Firstly, there is now a crisis of confidence in the State government. A state department has declared its autonomy of the Menteri Besar and the State EXCO. They answer to no one. They have taken upon themselves to be infallible interpreters of the law to the extent that they reject the decision of the AG. In doing so, they have undermined the AG’s constitutional role as the final arbiter of all criminal investigations and prosecutions.

Secondly, MAIS and JAIS by their recent announcements have stated that they regard the Malay and Iban Bible to be in breach of Selangor law in spite of what the AG has said. The practical implication of this is that JAIS with the approval of MAIS will carry out further raids on BSM as they regard BSM as lawbreakers in spite of what the AG has said. Further, they will also raid churches that have and use the Malay or Iban bibles, arrest Christian pastors and priests and seize more bibles in spite of what the AG has said. It matters not that the AG will refuse to prosecute. MAIS and JAIS will continue to act on their own and in defiance of the law as interpreted by the AG until their exhibit rooms are filled with seized bibles. Christians and churches will live in fear of JAIS.

The MAIS and JAIS stand is unprecedented and a dangerous anomaly in modern government. There is no such thing as a government department that is not accountable and not subject to law as interpreted by those constitutionally appointed to interpret it.

Also, MAIS and JAIS’s recalcitrance have shown that they have become unqualified and unfit to enforce the Selangor Non-Islamic Religions (Control of Propagation Among Muslims) Enactment 1988. 

What can the State EXCO do? Clearly, they must protect the people of Selangor from an uncontrollable department. They can easily do this by revoking the Gazette Notification published in 1999 that appointed MAIS and JAIS officials as enforcement officers under the 1988 Selangor Enactment.

This incident have demonstrated the folly of appointing officers of one religion to police adherents of other religions. It is very clear that the job of enforcement should be given to secular authorities like the police to prevent religious bias from perverting the course of justice.

Enforcement  officers under the 1988 Selangor Enactment are appointed by the Ruler in council. This means that the Sultan of the State appoints the enforcement officers on the advice of the State EXCO. Thus, the revocation of such appointments are also on the same basis. 

Understanding the AG’s Decision


Was the Attorney-General’s decision not to charge the Bible Society of Malaysia for using the  word “Allah” in the Malay Bible founded on law and a proper interpretation of the law?

The AG concluded that the Malay Bible does not fall under Section 9(1) of the Non-Muslim Religions (Control of Propagation Amongst Muslims) Enactment 1988 of Selangor.

The key to understanding how the AG came to this conclusion lies in his use of certain terminology. His statement originally made in Bahasa Malaysia states as follows:

 “Keterangan menunjukkan buku-buku yang dirampas adalah Bible dalam versi Bahasa Malaysia dan Alkitab Berita Baik adalah himpunan buku Taurat, Zabur dan Injil yang merupakan buku asas penganut agama Kristian.”

Roughly translated into English:

 “The statements [recorded from witnesses] show that the confiscated books are the Bible in Bahasa Malaysia and the Alkitab Berita Baik is a compilation of the Torah, Psalms and Gospels which are the basic books of the Christian religion.”

The AG used the expression “buku asas … agama” (English: “basic religious book”). He could have used a variety of expressions to describe the Malay Bible, for example, buku suci (“holy book”). However, the term “buku asas agama” used by the AG was taken from the terminology found inside the 1988 Selangor Enactment itself. Let me explain.

Section 9(1) of Selangor Enactment No. 1 of 1988 states that “a person commits an offence if he in any published writing uses certain Quranic words (eg. “Allah”) to express or describe anything pertaining to a non-Islamic religion.

It should be noted that Section 9 prohibits a non-Muslim in a published writing or in a public speech from using the word Allah in a non-Islamic context. In the heat of the recent debate, it was commonly assumed that the use of the word Allah in the Al-Kitab is a contravention of Section 9. However, what has been overlooked is the intention of Selangor Enactment No. 1 of 1988 to recognise and give due respect to the holy books of non-Islamic faiths.

Section 2 of Selangor Enactment No. 1 of 1988 defines the word “publication” as follows:

“publication” includes any book, magazine, pamphlet, leaflet, sound-recording material, cinematograph films and any other material for reading, viewing or hearing howsoever produced

However, Section 2(2) and (3) further clarifies:

(2)       For the purpose of this Enactment, a publication shall be held to be one concerning a non-Islamic religion if it is considered by the followers or members of that religion to be a holy or fundamental book or one of the essential texts of that religion (hereinafter referred to as “basic religious book”) …

 (3)       Notwithstanding that a publication is a publication concerning a non-Islamic religion by reason that it falls under subsection (2), it shall not form the subject of an offence under this Enactment if the publication as a whole is in the interest of Muslim or the religion of Islam.

Thus, the Enactment in Section 2 recognised the existence of holy or fundamental books or essential texts of non-Islamic religions and classified them under the expression “basic religious book.”

The word “publication” as appears in the Enactment includes “basic religious books” and secondary religious writings of a non-Islamic nature. Thus, it is an offence under Section 7 to send any non-Islamic holy books to a Muslim. Similarly, it is an offence under Section 8 to distribute non-Islamic holy books in a public place to a Muslim.

When Section 9 created the offence of using banned words, it used the expression “published writing” like an article, a book or an internet blog. In other words, an individual (note: the words “a person”) cannot in contemporaneous writings like articles published in books, newspapers, magazines, internet, etc, use the word Allah with a non-Islamic reference.

However, Section 9 has no application to pre-existing non-Islamic holy books. If Section 9 intended to refer to holy books of non-Islamic religions, it would not have used the words “published writing” only but instead would have used or included the expressions created in Section 2, namely, “basic religious books.”

In creating the expression “basic religious books” in Section 2, the Enactment was recognising the existence of non-Islamic holy books like the Al-Kitab which predated the Enactment and indeed the foundation of Malaysia as a modern independent nation. Nothing in the Enactment seeks to prohibit non-Islamic holy books even if they contained the banned words. It only prohibited the sending or distributing of non-Islamic holy books to Muslims.

In fact, Section 2(3) even recognised the possibility of certain non-Islamic holy books as being “friendly” to Islam and provided a blanket exemption, namely, that “it shall not form the subject of an offence under this Enactment if the publication as a whole is in the interest of Muslim or the religion of Islam.” It is my understanding that Islam has traditionally recognised the holy books of the Christians, in particular, that there is a continuity in revelation from the Christian religion to the Islamic religion. However, this is an area for the experts to comment on.

Clearly, the Enactment does not intend to make holy books of non-Islamic religions as contraband articles. It does not prohibit the use of words like Allah in the holy books of non-Islamic religions like the Christian Al-Kitab or the Sikh Granth Sahib.

This view finds support from the recent Court of Appeal decision in Menteri Dalam Negeri & 8 lain lawan Titular Roman Catholic Archbishop of Kuala Lumpur [2013] 6 MLJ 468 commonly known as the Allah case. YA Dato’ Abdul Aziz Bin Abdul Rahim JCA said at page 505:

“Nevertheless, I think neither the historical evidence nor the fact that the word ‘Allah’ appears in Al-Kitab (which is the Malay version of the Bible) is a sufficient justification for the [Home Minister] not to consider imposing the prohibitive condition of the usage of the word ‘Allah’ in the Herald. The Al-Kitab and the Herald are two publications of entirely different character. The Al-Kitab is the Malay version of the Bible — so, it is obvious that it meant only for Christians. Moreover the Ministry of Home Affairs had already specified the condition that the Al-Kitab is to be used in churches and among Christians only; and that the words ‘BUKAN UNTUK ORANG ISLAM’ are to be printed clearly and conspicuously on the front page of the Al-Kitab. This condition is obvious from the Ministry’s letter dated 24 April 2007 to the respondent — in paras 10–12. Whereas the Herald is a newsletter or in the same category as a newspaper (albeit with restricted circulation) which is used or likely to be used as the mouthpiece for the Catholic church to disseminate informations on the activities of the Catholic church or Catholic congregations. It is acknowledged by learned counsel for the respondent that as of today the Herald is accessible online. This online accessibility means that the Herald can be read by anybody — be it Muslim or non-Muslim. For this reason, I am of the view that the permission given by the Ministry for the printing and publication of Al-Kitab in which the word ‘Allah’ appears cannot be treated in the same manner as the printing and publication of the Herald with the usage of the word ‘Allah’.”

The other two judges say nothing about the Al-Kitab but both say they agree in toto with Justice Abdul Aziz.

In conclusion, a careful reading of Selangor Enactment No. 1 of 1988 shows that neither the use of the word Allah in the Al-Kitab nor the use or possession of the Al-Kitab by Christians constitute offences under Selangor Enactment No. 1 of 1988.

This, I suggest, was the AG’s understanding and interpretation. That was why he used the expression “buku asas agama” which was the rough variation of the 1988 Enactment’s expression “basic religious book.” Recognising that the Al-Kitab is a basic religious book of the Christians, it was therefore logical for him to conclude that the Al-Kitab does not fall under Section 9 of the 1988 Enactment and that the use of the word Allah in the Al-Kitab does not constitute an offence at all.








Time for Malaysia to Close Ranks: End to Bible Issue


Just now a reporter called me and informed me that the Attorney-General has announced that no action will be taken in the case of the Malay Bibles seized from The Bible Society of Malaysia (see Malaysian Insider; Malay Mail Online). Thus, the case is closed. He asked me for my comment.

I told him that I am no longer President of BSM and that he should talk to BSM’s new president. He insisted that since the incident happened while I was President, he wanted to know how I feel about the latest development. I then obliged him with my personal comment which I reproduce below.

I have always believed that the Attorney-General will come to this conclusion. From the moment, JAIS raided BSM, arrested me and my colleague and seized 321 BM Bibles, we knew that JAIS had made a terrible mistake. Nevertheless, it has been a trying experience to endure 6 months of uncertainty of whether we are lawbreakers or law-abiding citizens until the nation’s highest legal officer confirmed that the Malay Bible did not breach any of the laws of Malaysia or its states (in my next post, I will provide the legal reasoning for this).

I thank God for the grace and fortitude that He has given to my colleagues in BSM and me to trust that God will bring about a just end to this controversy.

I now call upon all Christians in Malaysia to follow the teaching and example of our Lord Jesus Christ to forgive, put this incident behind us and go on with our duty as responsible citizens of Malaysia to build our nation on the foundation of peace and harmony.

I call on Christians to forgive JAIS. They were doing their job but they had wrongly interpreted the law. No one is perfect. Everybody makes mistakes. Let us forgive them just as Christ forgave us.

With the AG’s announcement, I now have an iron-clad case to sue JAIS for wrongly arresting me. Shall I do it? Of course not. I forgave JAIS a long time ago and have no intention to sue them or to punish them in any way. The AG’s announcement is better than any court judgment. There is nothing to be gained from a law suit except to satisfy a lust for vengeance. This is unchristian.

I hope the Church in Malaysia will put this incident behind us and concentrate on how God wants the Church to contribute to the life and the future of this nation.

Likewise, I call on JAIS to have the same spirit of goodwill to return the bibles quickly and implement the necessary measures in their administration to ensure that this incident will not be repeated.

Lessons from Terezin


It’s been one month since my last post. I stepped down as President of the Bible Society of Malaysia on May 10 after completing a maximum 5-year term. On the very next day, I flew to Munich to chair the annual meeting of the Global Council of Advocates International, the worldwide organisation of Christian lawyers. I managed to catch holidays in Salzburg and Prague and here I will tell a travel story.

A most moving experience happened in Prague, Czech Republic. Prague has the appearance of a fairy tale city. There is so much of glitz to see but what caught my imagination was a tour to Terezin Concentration Camp and a walk through the Jewish Quarter of Prague. During 11 idyllic days in scenic Europe, the discrimination against religious minorities in Malaysia was never far from my mind. I wanted to see a facet of Prague that dealt with how discrimination in their society festered until it led to tragedy.

The Jews came to Prague, capital of Bohemia, in the 10th century. They were resented by the local population. The reasons were many. They were ethnically and culturally different. Often, that is enough to raise fears. Perhaps, the key reason was economic. In spite of restrictions placed on Jews, they prospered. Retrictions on trading and commerce only served to spur the Jews to succeed to the extent that they became money lenders to Europe. Nobody loves a money lender. Shakespeare in his “Merchant of Venice” portrayed the Jew as an unscrupulous money lender.

Prague’s rulers confined the Jews to a ghetto. They could not live or trade outside a walled city. They had to be indoors by night. This restriction on their movement meant that they could not take their dead for burial outside of the ghetto.

Jewish cemetery, Prague.

Jewish cemetery, Prague.

The picture above is taken inside the Jewish Cemetery. Prague’s Jews had to bury all their dead in the cemetery even though it was fully used. Over a period of 300 years,  20,000 people were buried in a small cemetery meant for only a few thousand. Up to twelve persons were buried in one spot, one on top of another. Gravestones jammed up around each other marked a final resting spot shared by multiple corpses.

In 1389, the church spread a rumour that the Jews had desecrated the host (ie the wafer and the wine used in the Eucharist). Some children had thrown stones at the host as it was carried past the Jewish quarter in a Good Friday procession. The Jews were blamed by the Christians for offending the religious sensitivities of the Christians. It did not matter that it was not true. People believed it. Or rather, they wanted to believe that it was true. It reminded me of the news back home just before we left. At a conference in a university, Christians were blamed for various ills in the Muslim community. Does it matter that it was not true?

Anyway, on Easter the Christians of Prague attacked the Jews in their ghetto. 3,000 Jews were massacred. As a result many Jews left Prague. Later, Bohemia’s rulers would regularly issue decrees ordering Jews to leave Prague. Go back where you came from! This is a cry that is always heard wherever discrimination rears its ugly head. It was only during the rule of some of Prague’s liberal rulers that the Jewish population in Prague recovered. Yet, for Jews who stayed, they had to live with a host of discriminatory laws regulating their private and social lives, trade, education, etc.

The ultimate discrimination took place during the Second World War. Hitler decided that the Jews was a curse to the purity of Europe’s Aryan races and therefore shoud be exterminated. Prague played an important role in Hitler’s plans. All the treasures and artifacts plundered from the Jews all over Europe by the Nazi Armies were ordered to be sent to Prague. Hitler had planned to use Prague’s Jewish Quarter as a museum of the Jewish people after he had exterminted them. That is why the Jewish Museum in Prague which is spread out over half a dozen synagogues and ceremonial halls has the best collection of Jewish treasures and museum pieces.

The Nazis sent Prague’s 70,000 Jews to live in another ghetto, the walled city of Terezin about 60 kilometres north of Prague. Terezin was built one hundred years earlier to protect Prague from an invasion from the north by Prussia. The attack never came and a smaller fortress a few kilometres outside Terezin was used to hold political prisoners of the Austrian Empire. The Nazis used the bigger fortress, the walled city of Terezin, to house the Jews of Prague and the smaller fortress as a prison and transit point for moving up to 300,000 Jews to the extermination camps to the East like Auschwitz, Treblinka, etc. Throughout the war, Terezin housed up to 144,000 Jews transported from all over Europe. Over 33,000 died in Terezin while another 88,000 were eventually transported to the death camps.

Cell blocks of Terezin's smaller fortress

Cell blocks of Terezin’s smaller fortress

Among the prisoners of Terezin were 10,000 of Prague’s Jewish children. After the war, only 250 survived. The names of all the children who died are engraved on the walls of the school house in Terezin. Writings and drawings by the children adorn the museums there as a testimony to a people who continued to organise education, promote art and culture even though they knew that death was appoaching. When Terezin was liberated by the Soviet armies, over 60,000 of Prague’s Jews had perished. The Nazis cremated as many of the corpses as they could and dumped the ashes in the river. After the war, the incinerators continued to be used for months to cremate the rest of the dead.

Go on a tour of Terezin when you visit Prague. Let it bring you back to the reality of life in this world. Walk through the Jewish Quarter of Prague and see the ugliness of human nature behind the gold and gild of Prague’s towers and monuments.

The drawings and writings of Holocaust victims in their museums is a stark reminder of their existence and their sorrowful struggle against bigotry and discrimination. The movie “The Monuments Men” is based on the true story of a small squad of soldiers assigned to recover the art treasures of Europe looted by Nazi armies. George Clooney’s character gives a speech to his men about the importance of their mission: “They can kill people and destroy their cities. They may be gone forever. Their art is the only evidence that they have ever existed.”

Discrimination begins with a perception, a perceived threat from a minority to the majority’s way of life, identity or self-respect. This perceived threat becomes the basis for discriminatory laws and policies in the name of protection of the majority. The minority is then isolated, disempowered and regulated. The power of the media is called up every now and then to frighten people about the threat posed by the minority. Eventually, when people are told that even laws and policies cannot subdue the minority, the only solution (for the Nazis, the final solution) left is extermination.