Education and religion are indelibly linked: cultural precepts underpin education policies within the formal State education system, while education has a clear role to play in promoting tolerance. Clashes between religious beliefs and secular education pose problems for states as the current array of jurisprudence, particularly on Islamic dress in educational institutes, corroborates. This article will discuss the "headscarf cases" in an international context, seeking guidance on reconciling human rights and cultural diversity. In traditional legal style, resolution is often on a case-by-case basis in light of all the circumstances of each case. A stronger human rights approach by international and regional bodies would guide states as to the balance between religion and education, but it appears that political considerations will continue to characterise this debate.