Islamic community (Christine Schirrmacher describing the "liberal" position on apostasy); it should be enforced only if apostasy becomes a mechanism of public disobedience and disorder (fitna) (Ahmet Albayrak). In Islamic history, laws calling for severe penalties against apostasy (and blasphemy) have not been used to protect Islam, but "almost exclusively" to either eliminate "political dissidents" or target "vulnerable religious minorities", (Javaid Rehman) which is hardly something worthy of imitating. Executing apostates is a violation of the human right to freedom of religion, and somewhat hypocritical for a religion that enthusiastically encourages non-Muslims to apostatize from their current faith and convert to Islam. (Non-Muslims and liberal Muslims) Middle way At least some conservative jurists and preachers have attempted to reconcile following the traditional doctrine of death for apostasy while addressing the principle of freedom of religion. Some of whom argue apostasy should have a lesser penalty than death. At a 2009-human rights conference at Mofid University in Qom, Iran, Ayatollah Mohsen Araki, stated that "if an individual doubts Islam, he does not become the subject of punishment, but if the doubt is openly expressed, this is not permissible." As one observer (Sadakat Kadri) noted, this "freedom" has the advantage that "state officials could not punish an unmanifested belief even if they wanted to". Zakir Naik, the Indian Islamic televangelist and preacher takes a less strict line (mentioned above), stating that only those Muslims who "propagate the non-Islamic faith and speak against Islam" after converting from Islam should be put to death. While not speaking to the issue of executing apostates, Dar al-Ifta al-Misriyyah, an Egyptian Islamic advisory, justiciary and governmental body, issued a fatwa in the case of an Egyptian Christian convert to Islam but "sought to return to Christianity", stating: “Those who embraced Islam voluntarily and without coercion cannot later deviate from the public order of society by revealing their act of apostasy because such behavior would discourage other people from embracing Islam.” (The Egyptian court followed the fatwa.) In practice: historical impact From the Middle Ages to the early modern period The charge of apostasy has often been used by religious authorities to condemn and punish skeptics, dissidents, and minorities in their communities. From the earliest times of the history of Islam, the crime of apostasy and execution for apostasy has driven major events in the development of the Islamic religion. For example, the Ridda wars (civil wars of