AK and SK (Christians: risk) Pakistan CG  UKUT 00569 (IAC)
THE IMMIGRATION ACTS
Heard at Field House
On 16, 17, 19 and 20 June 2014
The Royal Courts of Justice
On 24 July 2014
Before UPPER TRIBUNAL JUDGE PETER LANE
UPPER TRIBUNAL JUDGE KEKIĆ Between AK
and SECRETARY OF STATE FOR
THE HOME DEPARTMENT Respondent Representation: For the Appellants: Ms S Jegarajah and Ms S Pinder, Counsel instructed by Wimbledon Solicitors For the Respondent: Mr S Walker, Senior Home Office Presenting Officer
1. Christians in Pakistan are a religious minority who, in general, suffer discrimination but this is not sufficient to amount to a real risk of persecution. 2. Unlike the position of Ahmadis, Christians in general are permitted to practise their faith, can attend church, participate in religious activities and have their own schools and hospitals. 3. Evangelism by its very nature involves some obligation to proselytise. Someone who seeks to broadcast their faith to strangers so as to encourage them to convert, may find themselves facing a charge of blasphemy. In that way, evangelical Christians face a greater risk than those Christians who are not publicly active. It will be for the judicial fact-finder to assess on a case by case basis whether, notwithstanding attendance at an evangelical church, it is important to the individual to behave in evangelical ways that may lead to a real risk of persecution. 4. Along with Christians, Sunnis, Shi’as, Ahmadis and Hindus may all be potentially charged with blasphemy. Those citizens who are more marginalised and occupy low standing social positions, may be less able to deal with the consequences of such proceedings. 5. The risk of becoming a victim of a blasphemy allegation will depend upon a number of factors and must be assessed on a case by case basis. Relevant factors will include the place of residence, whether it is an urban or rural area, and the individual’s level of education, financial and employment status and level of public religious activity such as preaching. These factors are not exhaustive. 6. Non state agents who use blasphemy laws against Christians, are often motivated by spite, personal or business disputes, arguments over land and property. Certain political events may also trigger such accusations. A blasphemy allegation, without more, will not generally be enough to make out a claim under the Refugee Convention. It has to be actively followed either by the authorities in the form of charges being brought or by those making the complaint. If it is, or will be, actively pursued, then an applicant may be able to establish a real risk of harm in the home area and an insufficiency of state protection.
7. Like other women in Pakistan, Christian women, in general, face discrimination and may be at a heightened risk but this falls short of a generalised real risk. The need for a fact sensitive analysis is crucial in their case. Factors such as their age, place of residence and socio-economic milieu are all relevant factors when assessing the risk of abduction, conversions and forced marriages. 8. Relocation is normally a viable option unless an individual is accused of blasphemy which is being seriously pursued; in that situation there is, in general, no internal relocation alternative.
TABLE OF CONTENTSParagraphs Abbreviations Introduction 1- 2
Format of the determination 4
Details of the appellants' claims 5-10
Procedural background and findings of the First-tier Tribunal 11-17
Evangelism and Christianity: definition and interpretation 18-19
Pakistan: map, general facts and information 20-36
The Pakistan Penal Code and the Blasphemy Laws 37-50
Relevant International Treaties 51
The Constitution 52-56
The Judicial System 57-62
The Police 63-66
Legal Aid Groups 67-72
Frequency of Blasphemy Allegations 73-87
The experts and other witnesses 88-96
Reports of incidents of harm to Christians and those
Religious Minorities from Pakistan (14 May 2012) 100-104
Christian Solidarity Worldwide (CSW). Briefing on
Pakistan: Religious freedom in the shadow of extremism
(June 2011) 105-111
Writenet Independent Analysis. Pakistan: The Situation
of Religious Minorities (May 2009) 112-117
Amnesty International Annual report on Pakistan for 2013 118
UK Home Office country of origin information service,
Pakistan report (August 2013) 119-131
Human Rights Watch report on Pakistan (2014) 132
Immigration and Refugee Board of Canada. Pakistan:
Situation of Christians in Pakistan including social
and government attitudes, treatment and rights
2010-2012 (14 January 2013) 133-138
Inter Press Service News Agency (23 October 2013) 139
US Commission for International Religious Freedom
report (2013) 140-141
The Federal Republic of Austria, Federal Asylum Agency
Fact Finding Mission report on Pakistan (June 2013) 142-154
Foreign and Commonwealth Office: Christians
in Pakistan (16 December 2013) 155-161
Foreign & Commonwealth Office. Human Rights
and Democracy report on Pakistan for 2012 (latest
update 31 December 2013 162-163
Human Rights Commission of Pakistan report for 2013 164-169
Australian Government Refugee Review Tribunal.
Issues Paper: Pakistan Militant Groups (January 2013) 170
Radio Free Europe: Pakistan religious leaders declare
attack on Christians un-Islamic (24 September 2013) 171-172
BBC news article (13 May 2014) 173
Other news articles 174
Summary of submissions 175-177
The starting point 178-185
The experts and other witnesses 186-206
The risk of false blasphemy allegations 207-215
Religious practice 216-218
Sufficiency of protection 225-226
Internal relocation 227-231
Women, Forced conversions and abductions 232-239
Country guidance 240-247
Our conclusions on the appellants 248-262
Appendices:Page Appendix 1: Decision on Rule 15(2A) application 81-82
Appendix 2: Evidence of AK 83-91
Appendix 3: Evidence of SK 92-100
Appendix 4: Evidence of Zimran Samuel 101-109
Appendix 5: Evidence of Asma Jahangir 110-114
Appendix 6: Evidence of Pastor Jeremy Sandy 115-116
Appendix 7: Evidence of Pastor Taylor-Black 117-118
Appendix 8: Evidence of Bishop Ijaz Inayat Masih 119-122
Appendix 9: Evidence of Pastor Waugh 123
Appendix 10: Evidence of Reverend Stuart Rodney Windsor 124-126
Appendix 11: Submissions for the respondent 127
Appendix 12: Submissions for the appellants 128-129
Appendix 13: Overview of Case Law 130-135
Appendix 14: Agreed Index of Materials 136-140
UPR: Universal Periodic Review of the Human Rights Council
USCIRF: United States Commission on International Religious Freedom
UNHCR: United Nations High Commissioner for Refugees
WAF : Women’s Action Forum
DETERMINATION AND REASONS
These appeals involve Christians in Pakistan. The appellants are a brother and sister who seek to establish that they would be at real risk from extremist groups if returned, whether to their home area or to other parts of the country. Their appeals were dismissed by a First-tier Tribunal Judge whose decision was set aside for re-making.
The respondent does not take issue with the appellants' claims that they are Christians by birth and that they practise their faith in the UK in evangelical churches.
The list of issues as agreed by the parties is:
(i) What is the risk of a false blasphemy allegation being levelled against the appellants as Christians?
(ii) What is the risk of forced conversion to Islam?
(iii) Is there serious discrimination faced by Christians in Pakistan which would amount to persecution?
(iv) What particular discrimination do Christian women face?
(v) Can Christian women expect a sufficiency of protection from the authorities against assault and rape?
(vi) Are Christians able to practise their faith?
(vii) What risk do Evangelical Christians face?
Format of determination
We begin by setting out the details of the appellants' claims and the procedural history that has brought them to this stage of the proceedings. Some basic facts and information on Pakistan and the legal framework are then set out so as to aid an understanding of the evidence and our conclusions. This is followed by a summary of the evidence by the experts and the other witnesses from churches here and in Pakistan and of the country material as it pertains to the various issues. We summarise the submissions of the parties and in the context of all the evidence make findings and give country guidance. We then apply it to the appellants. The determination concludes with appendices which set out details of the evidence and submissions and an Index of the materials.
Details of appellants' claims
The appellants are both Christians by birth. They are brother (AK) and sister (SK) born in Karachi in 1983 and 1987 respectively. AK is married to another Pakistani Christian; his wife and son remain in Pakistan with his in-laws. SK is single. The appellants’ parents, an older brother and older sister continue to live in Pakistan. It is claimed that the parents live in a 'safe house' provided by the church.
The appellants arrived here on 26 March 2011 with entry clearance as Tier 4 students valid until 28 June 2012. On 20 May 2011 they contacted the Asylum Screening Unit and claimed asylum at their appointments on 10 June 2011. Their case was that they both taught at a school founded by their parents. According to the appellants, on 21 October 2010 when teaching Dickens’ A Christmas Carol to his students, AK entered into a discussion with them about Jesus and Prophet Mohammed. This angered the students who reported him to their parents and that evening a group of them, including some extremists from the Sipah-i-Sahaba, visited the family home. AK was out but his parents and SK were present and were verbally and physically attacked. Threats were made against AK. Neighbours intervened to end the attack. AK was warned by his father on the telephone not to return home and he stayed at his grandmother’s house.
Although the appellants claim to have been in hiding, they both ventured out. AK went out on 2 November 2010. He was accosted by a group of individuals including a local Sipah-i-Sahaba member. He was beaten and when he regained consciousness he found himself in a hospital. He sustained injuries to the upper part of an ear and has marks on his shoulder and side. He spent a night in hospital and then moved to his uncle’s house. On 19 November 2010 he went out again but was spotted and chased by men on bikes. He managed to escape them. After this, he relocated to his in-laws’ home in Quetta with his wife and son.
SK went shopping on 7 November 2010 but was attacked by the Sipah-i-Sahaba member and three others. SK's mother and sister intervened and managed to stop the attack. On 24 November SK decided to visit her cousin but was against attacked by three men on motorbikes, including the Sipah-i-Sahaba member. A group of Christian scouts who happened to be passing by intervened to end the attack. She was taken to hospital and thereafter, she stayed with either a local pastor or Christian social worker in a nearby village and then moved to Sialkot.
Both the appellants then returned to Karachi for some months and when they obtained their visas they left Pakistan. Upon arrival here, they lived with Reverend Isaac William, a Pakistani pastor. A week or two after their arrival, they were informed by their father that on 27 March 2011, First Information Reports (FIRs) had been lodged, accusing them of blasphemy, that on 28 March a Fatwa had been issued by militants calling for their deaths and, on 29 March, the police had raided their family home. These events led to their eventual decision to claim asylum.
Both appellants have continued to practise their faith in the UK. AK is a member of Stockton on Tees Baptist Church and SK has joined Golding's Church in Loughton.
Procedural background and findings of the First-tier Tribunal
The appellants were both interviewed with respect to their claims. Their applications were refused on 7 July 2011 and they were served notices informing them that they were illegal entrants by virtue of having gained entry by deception (i.e. having no intention to study or to leave the UK). Whilst the respondent accepted they were Christians, she did not believe their accounts of what had happened to them. It was not accepted that AK taught English Literature or that the incident of 21 October, and hence the following incidents, had occurred. The respondent noted that despite claiming to be in fear of their lives in Karachi, both returned there for several months and left Pakistan from Karachi airport. It was also noted that they delayed in making an asylum claim until 10 June 2011. The respondent noted that the FIRs had allegedly been issued some five months after the claimed incident in October even though it was maintained that the Sipah-i-Sahaba had been after them since that time. The respondent observed that the FIR and other documents had been submitted late and not with the asylum application. She considered that a sufficiency of protection was available and that the appellants could relocate if they so wished.
On 25 July the appellants lodged appeals against the decision and their appeals were jointly heard by First-tier Tribunal Judge Aziz at Hatton Cross on 22 August 2011. Both appellants gave oral evidence. The judge dismissed the appeal by way of a determination promulgated on 7 September. His decision was challenged on the basis that the judge should have also considered the risk to the appellants solely on the basis of religious hostility; that the background evidence demonstrated that Christians faced a risk of forced conversion or death, violence, expulsion and discrimination; that the judge did not consider whether this met the persecutory threshold; and that he failed to determine the risk to the appellants as Christians who ran an English school1. Permission to appeal was granted on 27 September 2011. On 12 October the respondent in her rule 24 response indicated that she did not oppose the appeal and invited the Tribunal to determine the appeal with a limited continuance hearing to consider whether the appellants would be at risk because of their religion. It was pointed out that the findings of the judge on specific matters had not been challenged and should stand. On 31 October 2011 the decision was set aside.
The following findings of fact were made by the First-tier Tribunal:
1. Both appellants are from Pakistan and are Christians
2. They may well have been exposed to some level of societal and governmental discrimination in Pakistan
3. It was not credible that the appellants' family had founded an English grammar school or that AK was an English teacher
4. No weight could be attached to the FIR or Fatwa documents
6. The alleged attack on AK in November 2010 did not occur
7. SK's accounts of the two attacks on her lacked credibility
8. None of the claimed incidents of assault and ill treatment by members of the Sipah-i-Sahaba occurred.
These findings of fact of the First-tier Tribunal Judge were not the subject of challenge to the Upper Tribunal and we consider that they should stand, notwithstanding the setting aside of the determination.
The same is not true of the judge’s finding at paragraph 105 of his determination. This concerned the judge’s views of the consequences to a Christian of accusations of blasphemy brought by ‘a militant Islamic group’ and the capacity for bringing false charges of blasphemy.
These findings were obiter once the judge concluded that the appellants did not face any such charges or accusations. Furthermore, the present appeals have been re-heard partly in order for the Upper Tribunal to give country guidance on the risk to Christians in Pakistan, by reference to substantially greater evidence and argument than was before the First-tier Tribunal Judge.
On the second day of the hearing before us, Mr Walker on behalf of the Secretary of State made an application pursuant to Rule 15(2a) of the Upper Tribunal Procedure Rules to introduce certain evidence which had come to light by way of an internet search following the previous day's proceedings and the oral evidence of the appellants. The material in question consisted of a newspaper article from December 2011 in online form relating to criminal proceedings against Pastor William and his family. The application was opposed by Ms Jegarajah who argued that there had been an unreasonable delay in producing the evidence. Following submissions from the parties, we decided it would not be appropriate to admit the evidence and a written decision setting out our reasons was prepared and promulgated. It appears as Appendix 1.
Evangelism and Christianity
As the appellants have relied heavily on their position as evangelical Christians, it is helpful to consider what that means. Ms Jegarajah sets out the etymology of 'evangelical' in her skeleton argument. The word comes from the Middle English 'evangile' and, in turn, from the Greek 'euangelion'/'euangelos' meaning 'good news; bringing good news'. Evangelism should not solely be understood as attempted or actual conversion. According to Professor David W Bebbington, widely known for his definition of evangelicalism, referred to as the 'Bebbington quadrilateral'2, that is just one of the four main qualities used to define its convictions and attitudes. The other three are biblicism (a particular regard for the Bible and the belief that all essential spiritual truth is to be found within it), crucicentrism (a focus on the atoning work of Christ on the cross) and activism (the belief that the gospelneeds to be expressed in effort).
This view was confirmed by Pastors Sandy and Taylor-Black of Golding's and Stockton Churches respectively. Pastor Sandy's evidence was that Evangelism did not just concern church matters but encompassed one's entire life. He emphasised the importance of enhancing worship by good deeds and a lifestyle whereby a worshipper helped others in the community and embraced all cultures. If church members did not feel comfortable with sharing their faith with strangers, they were not berated for that; indeed there was no expectation on the Congregation to participate in the outdoor "table" work that the church engaged in. He explained that the aim of the church was to encourage personal independent evangelism where people were encouraged to lead a good life and share their faith as part of their lifestyle. Pastor Taylor-Black also emphasised the importance of support for the local community by way of practical help and service. He explained it was important to demonstrate genuine care and concern for others prior to any embarkation on a discussion of Jesus.
PAKISTAN: GENERAL FACTS AND INFORMATION
With a population estimated at over 187 million in 20123, Pakistan is the sixth most populous country in the world. Approximately, 95% of the population are Muslim (75% are Sunni and the rest are Shia). The remaining 5% includes 1.85% Hindus, 1.59% Christians and 0.22% Ahmadis, with 0.7% belonging to other religious minorities including Sikhs, Parsis, Jews, Baha’is and Jains4. Some sources, for eg, Writenet and the Ministry for National Harmony, put Christians first on the list of religious minorities with Hindus coming second. The US Commission for International Religious Freedom (USCIRF) report for 2006 reported that Christians were officially numbered at 2.09 million but, according the COI report, Christian groups claim to have four million members. Writenet reports that the numbers range somewhere between three million and 20 million but for the purposes of its report, it accepts the figure of between three and five million.
Pakistan became an independent state in August 1947 following the partition of British India. It consists of four provinces: Sindh, Punjab, Baluchistan and Khyber Paktunkhwa (formerly the North West Frontier Province), the Federally Administered Tribal Areas (FATA) as well as the Capital Territory of Islamabad5. The Pakistani administered area of the disputed Jammu and Kashmir region consists of Azad Kashmir and the Northern areas which have their own political and administrative structures.
Pakistan's principal cities (with estimated population in brackets) are the capital, Islamabad (800,000), Rawalpindi (1,406,214), Karachi (11,624,219) Lahore (6,310,888), Faisalabad (1,977,246) and Hyderabad (1,151,274). Islamabad hosts a large number of foreign diplomats, politicians and government employees. It is a modern city located in the north eastern part of the country and was built during the 1960s to replace Karachi as Pakistan's capital. It is the most well developed city in the country, has attracted people from all over the country and has the highest literacy rate. The percentage of Muslims in urban areas is 93.83%. Christians form the second largest group at 4.07% of the population. Gojra, in the Punjab, and scene of the 2009 riots against Christians, is a stronghold of the Lashkar-e-Jhangvi and its political wing formerly known as the Sipah-i-Sahaba.
The main ethnic groups are comprised of Punjabis (44.68%), Pashtuns/Pathans (15.42%) and Sindhis (14.1%). Although the national language of Pakistan is Urdu, 48% speak Punjabi as their mother tongue and 12% speak Sindhi. English is the official language spoken by the Pakistani elite and used in most government ministries6.
In development terms, Pakistan is ranked 125 out of 169 countries placing it in the lowest 30% globally. The adult literacy rate was last recorded at around 55.2% (in 2010) and 22.6% of citizens live below the poverty line with the proportion said to be significantly higher among minorities7. Pakistan allocated just below 2% of its GDP to education and ranks at 180 in terms of literacy out of 221 countries with 5.5 million children out of school with only Nigeria having more. Pakistan has the third highest number of illiterate adults in the world. There is a housing unit backlog of nine million and 33% of people live in accommodation with no drainage. Over one million are displaced due to internal conflict and national disasters.
Civilian rule returned to Pakistan in February 2008 when a coalition government formed by the Pakistan People's Party (PPP) and Nawaz Sharif's Muslim League defeated General Musharraf in Parliamentary elections. In a move to relinquish some of the powers accumulated by Pakistan's presidency for decades of successive military rule, Parliament unanimously passed the 18th Amendment in April 2010. This was aimed at restoring the system of Parliamentary democracy and introduced several limits on presidential powers.
There is evidence that the PPP/PML coalition government took steps to improve the situation for religious minorities. Some of these are summarised in the Christian Solidarity Worldwide (CSW) report and by the UNHCR8. Both reports were prepared before the government's defeat in the elections last year and include:
1. The declaration of a National Minorities Day to be celebrated on 11 August each year, the date of Jinnah's landmark speech to the constituent assembly of 1947. This was celebrated for the third time in 2013.
2. The creation of a 5% quota for minority applicants in federal government jobs and the eventual extension of this principle to the provincial level
3. The official celebration of festivals of ten religious minorities (including Christmas)
4. A 50% increase in the state development fund for minorities
5. The re-establishment of district level Interfaith Harmony committees
6. The establishment of a National Interfaith Council to promote religious diversity and tolerance
7. Remission during religious festivals of the sentences of prisoners from minority communities involved in minor crimes, a privilege already granted to Muslims
8. The introduction of four reserved minority seats in the Senate and seats for representatives from religious minorities in the provincial assemblies
9. The reservation of ten seats in the National Assembly (the lower House of Parliament)
10. The allocation of property rights to the minority population living in Islamabad's slums, a majority of whom are Christians
11. The construction of prayer rooms for non-Muslims in prisons across the country, previously only available in a handful of prisons
13. A plan for a National Commission for Minorities to review laws and policies relating to minorities and to investigate allegations of discrimination and abuse (to consist of two representatives each from the Christian and Hindu communities, a representative from the Sikh and one from the Parsi communities and two Muslims).
Further steps to promote interfaith understanding were taken by the government after the 2 March 2011 assassination of Shahbaz Bhatti, the Minister of Minorities Affairs and an outspoken Catholic critic of the blasphemy laws. The Ministry of Minorities Affairs was renamed the Ministry of National Harmony and Bhatti's brother, Paul, was appointed in his place. On 24 March 2011 the UN Human Rights Council passed a newly worded resolution introduced by Pakistan. It affirmed traditional human rights and called for a "global dialogue for the promotion of a culture of tolerance and peace at all levels, based on a respect for human rights and diversity of religions and beliefs".
These examples are described as clear signs that the senior echelons within the government were responding to the interests of minorities. CSW state that the coalition government was vocal in its dedication to minority rights in both international and domestic settings. We were not told that the new government had reversed any of these actions. Although in June 2013, the Ministry of National Harmony was merged with a larger ministry, the Ministry of Religious Affairs, there is nothing which would suggest that the new Ministry has not continued the tasks of its predecessor.
Pakistan's new government formed by the Pakistan Muslim League-N (PML-N) took office on 5 June 2013 following elections on 11th of May with Mamnoon Hussain as President and Nawaz Sharif as Prime Minister9. It was the first time in Pakistan's sixty six year history that power had transferred democratically between one civilian government and another after the completion of a full Parliamentary term. The elections are said to be among the most credible in Pakistan's history, representative of progress with an improved electoral register and the highest ever number of women and first-time voters. Voter turnout for women was an unprecedented 40% of all votes cast10 .
Historians report that the ancestors of most Pakistani Christians were oppressed low caste Hindus who converted to Christianity in the 1800s when European evangelists spread the Christian gospel on the subcontinent under British colonial rule11. The reports before us vary as to the distribution of the Christian population. Writenet reports that approximately 80% of Christians live in the Punjab, with around 14% in Sindh, 4% in Khyber Pakhtunkhwa and 2% in Baluchistan. Other reports, notably the USCIRF and the Austrian Fact Finding Mission report, put the percentage of Christian residents in the Punjab at ninety. There is consensus that they are based mainly in the central areas with almost half in Lahore and Gujranwala12. There are 54 Christian villages in Punjab and four in Sindh. In Lahore there are 50 Catholic Church schools along with schools of other Christian confessions. Islamabad is also home to a large number of Christian communities.
There are approximately 15 Sikh Gurdwaras in Pakistan, 50 Hindu temples and 500 Christian churches, of which 100 are still from the days of British rule. Lahore, alone, has 65 churches. New places of worship must register with the district administrative authorities and must be proportionate to the religious breakdown of the local population but there are reports that churches continue to be built.
According to information supplied by the Austrian Fact-Finding Mission Report, Catholics constitute approximately half of the Christians in Pakistan13. There are 116 Catholic parishes in as many districts14 and about 350 Catholic priests and 2000 nuns. The Catholic diocese of Karachi estimated that 120,000 Catholics lived in Karachi, 40,000 in the rest of Sindh, and 5000 in Quetta, Baluchistan15. Protestants who make up the other half of Christians are divided into the Church of Pakistan, a member of the Anglican Communion, which unites the Anglican, Methodist, Presbyterian and Lutheran churches, the United Presbyterian Church and the Salvation Army. There are also evangelical churches such as the Baptists, the Seven-Day Adventists, the Full Gospel Assemblies Church and the Pentecostal Church. Many small and independent church communities prosper in the slum areas.
There are Christian schools, missions, cemeteries, hospitals and leaders, some of whom are described as being very vocal. Due to the high quality of these schools, many of the students are from the majority Muslim population and indeed, the former President Musharraf attended a Christian school. Foreign missionaries continue to operate in the country. The largest Christian Mission group has engaged in Bible translation for the Church of Pakistan. An Anglican missionary group fielded several missionaries to assist the Church of Pakistan in administrative and educational work. Catholic missionaries work with persons with disabilities. Some Hindus have voluntarily converted to Christianity.
According to Writenet, Christians, along with Jews and Zoroastrians are treated by the Muslims as 'people of the book'16. It is reported that Pakistani Christians do not wear distinct dress; however, some have Anglicised Christian names. Masih (meaning Messiah) is a common Christian surname in Pakistan. Passports set out the holder’s faith. Identity cards do not. Some places also have their origins in Christianity. For example, the northern resort of Murree is a derivative of Mary.
Overall, it is reported that churches keep a low profile. For special occasions such as public worship assemblies and processions, police protection is provided. We did not see any reports suggesting that these have been targeted in any consistent way. Churches communicate with one another. A certain freedom of religion is present. Symbols such as the cross can be displayed. Marriages are governed by the Christian Marriage Act 1872 and the Christian Marriage and Divorce Act of 1869. Courts accept proof of Christian marriages from priests.
Christians are generally described as belonging to the poorest strata of society, largely uneducated and employed in menial jobs such as cleaning and domestic work. Bonded labour is also prevalent among Christians, mostly in the agricultural and in the brick, glass, carpet and fishing industries. According to reports, more than 1.8 million people are in bondage, mostly in Sindh and Punjab. However, the majority of such labourers are low caste Hindus.