In our view, a requirement to show one’s face before entering the classroom would be equally effective as far as identity issues are concerned (to the extent these are of concern outside of an examination situation). This would curtail the students’ freedom of religion much less. The teaching of tolerance and understanding for all religions may reduce issues relating to children’s safety and the educational needs of other children.387 Further, issues relating to the equality of women may be better tackled in a manner other than restricting students’ rights to manifest their religious beliefs for instance via education.388 Teachers wearing religious symbols In our view, it may be legitimate to distinguish between teachers and students wearing religious symbols. The rationale for the distinction between the rights of teachers and the rights of students to wear religious symbols is that it is part of students’ freedom of religion to wear religious symbols and this freedom can be constrained if they are taught by people wearing religious symbols.389 Since education must be child-centred, the restraint of teachers’ liberty to wear religious symbols may be acceptable. In Dahlab v. Switzerland, the ECHR upheld the Swiss government’s right to require a Muslim teacher to remove her headscarf because the ordinance did not target the complainant’s religious beliefs, but rather aimed to protect the freedom of others as well as public order.390 It has also been held by the European Court of Human Rights that employers can impose limits on an employee’s rights if the employment is voluntarily accepted.391 Any restrictions should, however, be the minimum 386 See McGoldrick Human Rights and Religion: The Islamic Headscarf Debate in Europe at 214 and 225. 387 McGoldrick Human Rights and Religion: The Islamic Headscarf Debate in Europe at 80 and 268. 388 Council of Europe, Document 8270 27 November 1998 Committee on Culture and Education, Religion and Education, http://assembly.coe.int/Main.asp?link=/Documents/WorkingDocs/Doc98/EDO C8270.htm (last accessed on 6 March 2007) at para 10, McGoldrick Human Rights and Religion: The Islamic Headscarf Debate in Europe at 268. 389 See McGoldrick Human Rights and Religion: The Islamic Headscarf Debate in Europe at 282 - 283. 390 European Court of Human Rights Dahlab v. Switzerland Application No 42393/98, ECHR 2001-V. 391 McGoldrick Human Rights and Religion: The Islamic Headscarf Debate in Europe at 283; Kalac v Turkey application No 20704/91, (1999) 27 EHRR 252, and Ahmed and Others v UK Application No 22954/93, (2000) 29 EHRR I. 124