Asfaw Berihun Abreham*

The evolvement of trade mark protection and the place morality

and religious value in granting trade mark in Ethiopian laws

Abstract

This article focuses on the evolvement of trade mark protection and grounds used

by the Ethiopian intellectual property office in granting trademark in relation to

religious values and beliefs and there places in general. This article also needs

answer form intellectual property office what constitute religious values from trade

mark aspect and the reason behind it left from define public morality .father more,

this article argues that religious has to be free in business from use trademark

even though our trademark law protect religious identity for the sole reason that

consumer perception and deficiency(drought of strong trademark law that provide

the writer has also strong stand religious identity not to be subject of litigation on

matter trade mark. According to Mark P. McKenna, the writer has similar position

as stating goal of trademark law that is to improve the quality of information in the

marketplace and thereby reduce consumer search costs with the mission they hold.

Brief history of Trade mark

Protection of trademark is dates back to time immemorial and

ancient peoples use different marks, symbol or sign to

distinguish their property and objects from their neighbors.1

During that time, the initial purpose of trademark protection

was not to show commercial origin of product rather to

indicate owner ship over certain object or goods.2 The ancient

1*Asfaw Berihun Abreham LLB student in Haramaya university college of law .I would like to thanks to Silesh Badise ,Lecturer at Haramaya University by his sacrificing his precious time for helpful feedback I received. Silesh Badise , Haramaya University, lecture note2 Ibid no1

Roman time was the stepping-stones in which people started to

distinguish their property and goods from similar products and

goods based on commercial origin of goods. With the

development of commercial trade, peoples come to identify

their products from other similar product on the market. Later

in the middle Ages, France began to require painters to

register their mark in accordance with the 1426 Ordinance of

the Corporation of Painters of Bruges; whereby if they failed

to register their mark, it was considered a punishable

offence.3 Then, the protection and use of trademark widely

spread in the medieval period in 16th century when guilt

system was there and local guilt has engaged in producing

products to market.4 With the growth of trade over period of

time then significance of trademark also increased. Initially

trademark used in local level and as trade and commerce

develops it; goes beyond borders .The protection also develop

and reach its apex in 18th and 19 century with industrial

revolution.5 In the mid 19 century that trade mark protections

was rather considered as property right. Property interest was

can be passed by the decision of the court in UK as well as in

US. That was subsequently followed legislation which

recognized protection of trade mark as intellectual property.

In1870 the first legislation ware adopted both in UK as well

as in US but more importantly the 1905 trade mark act of US

was known to the first important legislation protection of

trade mark as property right. This legislation also replaced

by the current enforceable law called land home act. Land home

3 See pdf Public Order and Morality as Grounds of Refusal .European Concept and Comparative Approach4 Ibid no 25 Ibid no 2

act in US was enacted in 1946 and which is still basic trade

mark of US.6

The legal history of trade mark in our county till 2006 we

didn’t have any specific legally legislated law that provided

for protection of trade mark as property right.7 Trade mark

protection was based on the relevant provision of tort law

based on ground of unfair competition .The requirement in

those date was to proof existence of harmful confusion. The

product was that time was un authorized use of mark by the

competitors’ and consumers are mislead harmful confusion

crated and peoples was mislead by the products of other

producer thinking that they are buying product of trade mark

owner therefore in order to solve the harmful confusion such

act was prohibited, injection and other remedy was granted

particularly the civil code and the provision of commercial

law used as legal base of protection of trade mark. Although

the protection of intellectual property is at infant stage

particularly, in the area of trade mark just like other

development, know how to wards the protection of trade mark

gradually develops with development of transaction. In other

country like USA and other European country they have

different types of trademarks such as well known mark,

collective mark, trade name, certification mark, service

mark8, marks which consist of smell …etc to used to

distinguish there product from other however, in Ethiopia

still we don’t have such kinds mark even the rest

6 Ibid no 37 Ibid no 48 Well known mark refers Marks that are considered to be well-known in the market and as a result benefit fromstronger protection. . Certificate mark is Marks used to distinguish goods or services that comply with a set of standards and have been certified by a certifying authority. Collective Marks used to distinguish goods or services produced or provided by members of an association..

intellectual property are protected within the domain of trade

mark due to lack of subsequent and separate legislation which

enables them to be protected either of above enumerated kinds

of mark. Today purpose of trade mark is can be shown;

From perspective of trade mark owner it protects

the good will of the trade mark owner and

repetition of the business.9

From public interest point of view has the purpose

of avoid harmful confusion that occurs to the

consumer and misleading things which affect the

consumer choice on quality of goods and services

Avoid consumer search cost and minimize consumer

performance.

Ensure protection of investment against free rider.

Generally trade mark protect the interest of the

producer and the public at large (the consumer) no

to be misled.

Promote trade competition.10

Enable consumers to identify a product (whether a

good or a service) of a particular company so as to

distinguish it from other identical or similar

products provided by competitors.11

1. Trade mark definition

9 From perspective of trade mark owner it protects the good will of the trade mark owner otherwise other competitor can use that trade mark in which substantial investment will be made and it may out cast the real owner of the mark form the market .10Commentators that produce the same product compete on the market in order to stay in the market and will help the consumer to choice the best product other than poor product produced by other competitor.11 /www.wipo.int/edocs/pubdocs/en/sme/900/wip.pub-900.pdf Consumers who are satisfied with a given product are likely to buy or use the product again in the future. For this, they need to be able to distinguish easily between identical or similar products.

Article 2(12) defined trade mark as any visible sign which

helps to distinguish between similar goods of one person and

those of other including services. It could be word, personal

name, colors, shape, letter, symbol numerals…etc should

capable to distinguish between similar goods and services

regarded as trade mark.12 The same as trips agreement also

define as any sign or combination of sign which distinguish

products and services from other similar product from market.

Unlike Ethiopia, an increasing number of countries also allow

for the registration of less traditional forms of trademarks,

such as, single colors, sounds three-dimensional signs (shapes

of products or packaging), audible signs (sounds) or olfactory

signs (smells)movable images.

The Ethiopian trade mark proclamation no 501/2006 article 5(1)

state that “any trade mark that is capable of clearly

distinguishing goods and services of a person from other

person shall be eligible for registration”. However, this

proclamation simply enumerated by way of listing that could be

used for trade mark; for instance words, letters, symbols and

etc. These methods more or less help and minimize the burden

of the office.

.

1.1. System of trade mark protection

How trademark can be protected? Trade mark can be protected

on the bases of either registration or by prior use trade mark

for long period of time.13

1.1. 2. Based on registration 12 Article 2(12)of trade mark proclamation 13 See Chapter two fields of intellectual property protection page 77(protection of trade mark right)

When trademark rights have been established based on a formal

registration, the rights as granted are said to be

"registration-based." When trademark rights are established

based on actual use, the rights that are effectively granted

are said to be "used-based."14In US prior to land home act

and the 1905 trade mark protection prior use was the major

system used as protection of mark but after land home act

registration system come in to effect it widely spread and

registration system also used by different country. The

Ethiopia trade mark proclamation abounded use as system of

protection and under article 8 of the trade mark proclamation

lists out the requirements for registration of trade mark.

Perhaps to fit the said requirement of registration, it should

pass four steps.

I) filing of the application,

ii) Examination,

iii) Publication, opposition, and (IV) registration

Trademark Registration has its own benefit than ‘’use based’’

among those benefit to registering a trademark will provide

stronger protection, particularly in case of conflict with an

identical or confusingly similar trademark.15It has the

importance to acquire the exclusive right to use the trade

mark throughout the territory and helps to promote the goods

and/or services that it produces. This registered mark will

have also protected legally and will deter others from trying

to imitate the registered mark or benefit from its success.

Beside to this once the mark is registered it helps in advance

14 See Amino, page 118; Shibuya, page 1; Toyosaki, page 349; and Ono-Sodan, page 815 http/www.wipo.int/edocs/pubdocs/en/sme/900/wip.pub-900.pdf

to sue infringement comes if a business or person uses the

same or a ‘confusingly similar’ mark on the same or similar

goods/service. Generally, registered trade mark adds value to

business in the form of ‘goodwill’ that can increase

substantially over time as the mark becomes established in the

market. Even though it has enormous advantage registration has

also short coming.

1.1.3. Based on use’’

Unlike registration based prior use is one of system in which

trade mark protected specially, in Europe , USA and other

common law country follow ‘use ‘for protection of trade mark.

In fact rule based system is there, it difficult for the party

to proof who used the mark first than other and the burden of

proof lies on the trade mark owner if other party uses it for

similar product. This system more or less shifts the burden of

proof on the parties where dispute arise. Even though use is a

means of trade mark protection it is veneralable to be used in

other country after the mark acquire huge fame since trade

mark is territorial and different country use different system

for protection of mark. Particularly USA used both systems

though it varies from state to state. Unlike other country in

case of Ethiopia use is not requirement for protection of

trade mark only based up on registration. Where the trade mark

fulfills the requirement of distinctiveness and even without

prior use, trade mark will be protected by Ethiopian

intellectual property up on registration. While the Ethiopian

intellectual office is going to register that trade, trade

mark will pass two assessments for the purpose

i. Examination before registration(ex-officio

examination); this examination is going to be done

by Ethiopian intellectual office by its own

initiation to determine whether the mark which is

going to register is necessarily be moral and non

offensive mark. While doing this, if the office

acquires the mark immoral the office stands right

for refusal of registration.

ii. After examination (post examination) this

examination on the other hand is going be done after

registration. Particularly it applies to control any

outcome drives from the registered mark. This helps

to prohibit already the registered mark, if the

office got it is against public morality and so

forth. No matter how this is the fact ,the Ethiopian

trade mark proclamation state under article …

particularity article …said that if the registered

mark is contrary to public policy and against

accepted principle of morality meaning words which

have bad sense on the mindset of the people such as

words which indicate racial image (inferiority and

superiority),slave trade ,words/image with religious

connotation may crate bad feeling on the general

society in this case the office will not bound to

register the said mark. Although the concept of

public policy and morality are contentious issue the

EIPO raise objection even in actual use of the mark.

Article 6 of the proclamation the ETPO will examine

whether those excluded as in admissible or not? The

application will fail from being registered

1.2. Basic feature of trade mark

Save as its basic purpose trade mark has its own feature

pursuant to article 6(1) cum art 5 provide that trademarks

that are not capable of distinguishing goods or services of a

person from those of other persons shall not be eligible for

registration.16 Descriptive is one of the features of trade

mark that every mark should hold these are trademarks that are

likely to deceive or mislead consumers as to the nature,

quality or geographical origin of the product. Otherwise

consumers are susceptible and likely to cause confusion by the

product t which has identical or similar mark found in the

market. Trade mark could also be distinctive. Distinctiveness

I mean that the customer able to enough to identify in a

simple manner. In other word a mark is distinctive by ‘nature

or nurture’ when the prospective purchaser of the product

knows it refers to a particular source and not to

another.17Using trade mark of its distinctive feature,

consumers abide preferably on memorable mark that customers

associate with quality products or services. Then Customers

will be more likely to buy the well known mark product or

service again and refer the others in order to distinguish and

satisfy whether it fit the product with the prescribed money.

A strong mark therefore helps a business both gain and retain

16 Ethiopian intellectual property teaching material 17 www.camtrademarks.com/index.php?q=node/44

its customers. In Ethiopia context trade mark may not be able

to be registered if it is likely to mislead, confuse or mark

Contains offensive a representation, or an imitation of any

representation, or words like His/her Majesty or any member of

the Royal family, or words Contains a representation of a

flag, armorial bearing, insignia, orders of chivalry or state

emblem Suggests endorsement or licence by a particular person

or organisation. But in other jurisprudence

2. Why public morality?

To define what do we mean by morality is little bit difficult

and even philosophers have been attempting to provide answers

to this question for thousands of years.18 Morality is defined

by the Oxford dictionary as “a degree of conformity to moral

principles (especially good); that which includes the totality

of the accepted norms which are deeply rooted in a particular

culture. Bentham and Kant believed society needs

protection.19Even though ,there damnation towards morality is

deferent. Bentham, a Utilitarianist, believed in the

principles of pleasure and pain whereby morality and

legislation needed to balance pleasure over pain. 20 His

thinking was, “if a majority if big enough and their dislike

is strong enough then the offending material should be

banned,” thereby establishing the ‘happiness’ principle.21 The

literal definition of morality is that morality is the human

attempt to define what is right and wrong about our actions

and thoughts, and what is good and bad about our being that we

18 www.wikipdea19 GREIC-Cher- yl (Public Order and Morality as Grounds of Refusal. European Concept and Comparative Approach)20 Id no1921 Ibid no 20

are. The determination of the morality or immorality of a mark

is made in the context of the contemporary attitudes of the

general public.22Morality by itself is not static because as

times go and society’s attitude change as a matter of days or

weeks even single day peoples attitude shift gradually. This

is why the concept by itself loses clear cut definition of it.

However it is better to keep the concept of morality in mind.

Surprisingly, ‘public policy’ and ‘morality’ are not defined

in this particular trade mark proclamation. Marks qualify the

requirements set out by IP office or not. The first IP

convention which is held in Paris (here after called Paris

convention states that a trade mark can be denied

registration by being declared contrary to public order or

morality which will invalidate the registration of the trade

mark. In this particular treaty they agreed up on the member

states to refuse mark registration if it holds morality issue.

2.1. Morality in light of religion

A society is a fragile thing. Millions of people who are a mixture of ethnicities,

religions and cultures are attempting to live together harmoniously. With so many

differences it is sometimes difficult to not offend someone; some people offend a

certain group on purpose, but many times it can be by accident. Saying or doing

something which you consider to be funny may actually insult or cause harm to

someone nearby whom accidently overhears or oversees the action. This is a

consequence of so many people living in close proximity to each other, and as such

people must know that there are rules which must be adhered to and if broken

what the consequences will be.23Therefore in order to accommodate this value the

22 www.wikipdea23Cheryl Greig Public Order and Morality as Grounds of Refusal. European Concept and Comparative Approach

government of the whole nation should play significant role in determining the

morality and values of its country.24

Ethiopia is one of the countries that have multi culture and

multi religion. Ethiopia just like India and Nigeria has

various ethnic groups live in together harmoniously. In

Ethiopia lot of religious are also found such as Islam,

Christian, and protestant and as if one together. Within this

sphere, to protect the common values of culture and religion

is must. Religion exists in the past and in the present of

human being and it is one of the basic phenomenon's that will

continue to exist in the future. Religion has played and will

continue to play a major role in determining what is immoral

or not.25 The two largest religions in Ethiopia are Islam and

Christianity. Although these two religions are largest, all

religions’ are considered there in determining whether trade

mark is offensive or not. Religion has been an integral part

in the way society has developed and therefore the laws which

govern the societies have developed to meet the needs and

requirements of the society.26Now a day, the world is moving

away from religious guide line to be ruled rather they are

continued to be governed laws which is set by their own

selves. Even though counties are there which not far and

escape to be governed by religious belief. In Ethiopia

Religion has deeply rooted and they played great role in the

development of morality concept. Particularly among other the

two dominant religion Islam and Christian religion influence

is high on the concept of morality due to its historical

24 Ibid 2325 www.Wikipedia 26 Ibid 25

attachment. If fact, it is not to diminish other religion but

they have their own influence for the development of morality

in one and in other way round. No matter how concept of

secularism developed gradually after cursed still the concept

of morality is big deal which is not be answered yet. In order

to protect the religious values particularly in the area of

trade mark the government should be there in order to

arbitrate religious beliefs and values from being offended

using trade mark which have no attachment from its merit27.

Religious symbols and names are not used to advertise products

or services which have no relationship the product with

religious value. Based on this fact different scholars oppose

the use of religious values for registration of trade mark

such as goods and services used for water, non-alcoholic

drinks, alcoholic beverages, tobacco a mark and smokers’

article28.

2.2. How objection will be raise and what are the main

reasons for rejecting an application?

In what situations do religious followers sue for

trademark infringement based on public morality? As can

be stated under article 8 once the intellectual property

office accept the mark then the next step is publication

on Gazetta or news paper having nationwide circulation at

the cost of the applicant and this system also paves the

way any interested person to apply for the invalidation

27 Ibid 2628 132 Johannes Paul II Trade mark Application Number: 958280

of trade mark as per article 12 of trade mark

proclamation. While the interested parties do such

measure he/she is obliged to the prescribed pay fee even

if he is unable to afford. Where no opposition is made on

the parts of any interested party then, the mark will be

registered automatically without any precondition as per

article 15 of trade mark proclamation. Generally where

the mark is likely to undermine current religious, family

or social values from the point of view it is subject of

rejection.

2.2.1. What if certain mark contravenes the acceptable

morality concept?

Words and illustrations that are considered to violate

commonly-accepted norms of morality and religion are generally

not allowed to be registered as trademarks. Surprisingly the

Ethiopian trade mark law is left from defining what constitute

commonly morality and religious value. Art.6 (1) (d)

provides that the trademark that is contrary to public order

and /or morality shall be inadmissible for a trademark

registration29.but the question is what about marks that

registered prior to this current legislated law.

2.3. Measurement of Standards for application of trade

mark

In Ethiopia lot of trade mark had been registered by the

office even till now particularly the former office while

registering those marks it wasn’t follow guiding principle and

29 See Intellectual property law

system which is used by the current trend even it doesn’t

gave due care for public policy and morality issue. Typical

example for this was St. George beer of course using saint

names as whole for mark contravene the public policy of

specific group of community or not might be a question since

public policy by its very nature subjective. For certain group

it will be against morality and for the other may not. Despite

the fact that the concept of morality antagonize through the

passage of time, different scholars agreed up on the granting

of trade mark that has to be measured by the reasonable man

standard (consumer) in any case. The case of St. George Beer

before it takes the current structure specially the mark which

is used before, it was shocking for the society to imagine by

letting alone the rest that was because the embodied feature

of the bottle and cover as well has the picture which is

perfectly similar with Christian followers use to worship on

their church. Of course different argument is there, any ways

Christian peoples purchase the picture from *market and fix on

wall to worship and pray standing over the picture in their

home. Beside to this the religion by itself makes religious

celebration during day of 23 every month even Ark is there

when it is year celebration. However the beer which is known

by the so called name St. George by using the mark it provides

beer to its consumer. From its establishment till now the

consumer use it. Particularly, when the consumer intoxicated

by such drag after use the bottle might have high probability

to be broken with the image it hold and to be dropped in

rubbish area. Still such difficulty is there. Still it is

debatable anyhow the thought is there Christians are dinging

the said alcohol which is St. Georg. However, the issue of

morality is subjective there is the so called trade mark St.

Gorge is used for beverage. Having to this, in Ethiopia

history specially the Christian people look and attach the day

23 as victory day apart from the religious point of view

specially the day 23 was memorized when the Ethiopian –Italy

war is at issue this is because the war between Ethiopia and

Italy was held on 23, 1898 and surprisingly Italy left from

the soil of Ethiopia on the day of 23.beside to this different

writers as well looks the day 23 as victory day for instance

the well known Ethiopian writer Hadis Alemayehu on his book

FIKIR ESKE MEKABIR(Life on to death) used the day 23 as

victory particularly the one who plays the character of Fet

awrari Meshesh. Others writers also in one and in other way

round attaché St. George as victory that is why peoples give

name for their children saying Geyorgis /George. Again

although it is not subject of my discussion in Ethiopia we can

also find Foot ball team named by St. Gorge, this Football

team also sponsored by the owner of St. George beer here St.

George foot ball club has many supporters like Ethiopian

coffee FC and they see St. George as victory even though

Muslim fellows are there. If this is the fact, the question is

why the Ethiopian intellectual office and ministry of trade

grant name which has religious back ground of course we may

see other names other than trade mark in Ethiopia such as St.

Merry university, St. Paul hospital and other but the above

two marks have different from other .why? Let say St. George

FC make game with one of club found in Ethiopian in this case

if he lost point or beat by other team, peoples might think

that how St. George! And automatically attach it with

religious point of view; it is in abstract sense. In other

country they used saint names for trade mark and trade name as

well but if the office believe that it is against morality

there is high probability to be ruled in their favor of public

at large the office by its own motion and consequently if the

owner wish to exist in the market he may change the entire

name, face and marketing strategy of his business and proceed.

If no, he stops there. Here St. George has been operating as a

legitimate business since then and continues everlasting in

such away. Still no application is filled for invalidation of

the mark. On the other hand, the EIPO is not yet raise this

issue saying that the mark is contrary to accepted principle

of morality. Nevertheless, when we see the issue of homo

sexual particularly in Europe it was so extreme even to think

about it other than doing unlike today. Unfortunately at the

times go and peoples thought tremendously changed it become to

the day to day activity in doing so. The same things happen in

Ethiopia the case of St. George once up on time it had been

seen as TABBO to drink the beer even peoples were so shy to

eat lunch out of home especially in hotel. Peoples also

terrify for not to lose the throne of the sky ’’who knows the

sky’. Trademark in the context of religion is strong if we see

it in abstract sense but reality is not just what we see and

believe. What so ever when we see from very duty of

intellectual office it is just to assesses and make sure that,

does public interest involve there or not, then after it will

ban or register the mark. Even the office will be successful

because Ethiopia didn’t recognize a “prior user” and no one

can raise defense to a claim trademark as of right even if it

immoral. As a principle trademarks are used in business and

other organizations to create an identity in the minds of

consumers and it need protection through written law but the

EIPO has no any rule which used as guiding principle. If it is

so, there will be other attempts to register marks with

religious name no one can prohibit using other saint names

even names of caliphate as trade mark. Religion is not market

where we purchase mark and symbols and pictures for use rather

religion is where worship and pray is held as well love and

respect is preached. Of course According to trade mark

proclamation under article 7 it stated, once the applicant

filed his application the proclamation says the Ethiopian

intellectual property office will examine whether those trade

mark qualified for registration or not. For registration the

intellectual property after the formal applicant is enter to

EIPO other examination will be proceed but it doesn’t have a

means testes which is going to used for evaluation purpose.

For Such as words which have religious symbols or names Jesus

as trademarks is likely to undermine/offend religious value

and sentiments. Names of the God (Waqa), even Goddesses etc.

However the jurisprudence of other country shows that where

the office believes that there is public interest is there

even after registration they will ban from registration. As

can be stated under article 8 of trade mark proclamation for

registration of trade mark first application has to be made to

Ethiopian intellectual property office in the prescribed form

with application fee. in any cost the ground of objection for

registration of mark should not being non distinctiveness

rather the office has to bother whether a trademark is moral

must be judged while keeping in mind the goods or services in

relation to which the mark is to be used, using the same

approach as is applicable when the distinctiveness of a sign

3. Trademark Requirements

Trade mark registration requirements are very helpful in

determine what kinds of trade mark is eligible for protection

under Ethiopian law .However the Ethiopian trade mark

proclamation nowhere dictate the requirements to determine

certain mark is eligible or qualified for protection of trade

mark. However different countries have basic requirements to

grant for protection of trade mark. For instance in UK

During examination of a trade mark application, the UK-IPO

and/or OHIM can refuse to register a trade mark on the basis

of so called absolute grounds, that is, that the mark:30

Cannot be graphically represented in a way that is clear,

precise, self-contained, easily accessible, intelligible,

durable and objective.

Is devoid of any distinctive character.

Consists exclusively of signs which designate the kind,

quality, quantity, intended purpose, value, geographical

origin, the time of production of goods or of rendering

of services or other characteristics of goods or

services.

Consists exclusively of signs which have become customary

in the current language or in the bona fide and

established practices of the trade.

301Patents, trademarks, copyright and designs in UK (England and Wales): overview

These absolute grounds objections may be overcome by filing

evidence of distinctiveness acquired through use.

A sign may also be refused by the UK-IPO and/or OHIM if it:

Consists exclusively of a shape which results from the

nature of goods, is necessary to obtain a technical

result, or which gives substantial value to goods.

Is contrary to public policy or accepted principles of

morality.

Is of such a nature that it would deceive the public.

Is prohibited for use under UK or EU law.

It is a specially protected emblem (for example, flags,

royal representations, and so on).

Has been applied for in bad faith (in the UK only).

Conclusion

Ethiopian Government and even other countries also have to

improve rules about which world can be accepted as a trademark

name. The EIPO required dealing with issues of taste and

decency, in addition to the more common issues of

distinctiveness and likelihood of confusion. However, in an

attempt to answer the original question in relation to place

of morality and offensive words the Ethiopian EIPO was

reluctant in looking forward for solution and I would suggest

that the EIPO has to find the available remedy otherwise just

like of example I give above the case St .George and other

similar shocked trade mark may be appear for registration even

it may use without registration till the EIPO raise it this

objection. At this juncture the issue will go just apart from

private nature but also in public settings. even one may come

up tomorrow for registration of supplied the wine for others

to drink in the name of Jesus or in the Prophet Mohammed .of

course some of the attitudes here are quite contrary to saint

George example and they attach alcohol as no connotation and

drinking alcohol in the name of saint George interpreted as

actions for not evil or sin. This actually happens all the

times. Any ways strictly speaking, religion is a controversial

area and care must be taken not to offend the followers,

therefore it is better strictly before criticism. Of course

some of the attitudes here are quite contrary to saint George

example and they attach alcohol as no connotation and drinking

alcohol in the name of saint George interpreted as actions for

not evil or sin. This actually happens all the times. Any ways

strictly speaking, religion is a controversial area and care

must be taken not to offend the followers, therefore it is

better strictly before criticism. The examiner had rejected

the mark on the basis that it was liable to offend a

significant portion morality.