This case determines that in general the risk of persecution for Christians expressing the living their faith in China is very low, indeed statistically virtually negligible. The Chinese constitution specifically protects religious freedoms and the Religious Affairs Regulations 2005 sets out the conditions under which Christian churches and leaders may operate within China. There has been a rapid growth in numbers of Christians in China both in the Free State Registered churches and the unregistered or house churches. Individuals move freely between state registered churches and unregistered churches according to their preference as to worship. There may be a risk of persecution serious harm or ill-treatment engaging international protection for certain individual Christians who choose to worship in an unregistered church and who conduct themselves in such a way as to attract the local authority’s attention to them or their political social or cultural views. However, unless such individuals are the subject of an arrest warrant, his name is on the black list or he has pending sentence such risk would be limited to the local area in which the individual lives.
In light of the wide variation of local officials responses to unregistered churches, individual Christians at risk in their local areas will normally be able to relocate safely elsewhere in China. Given the scale of internal migration and the vast geographical and population size of China, the lack of an appropriate Hukou alone will not render internal relocation unreasonable or unduly harsh.