The African Court on Human and Peoples’ Rights in Issa Konate v. The Republic of Burkina Faso, Application No. 004/2013 ordered Burkina Faso to repeal its provisions on criminal defamation, and pointed out that: In order to consider the need for a restriction on freedom of expression, the Court notes that such a need must be assessed within the context of a democratic society; it also notes that this assessment must ascertain whether that restriction is a proportionate measure to achieve the set objective, namely, the protection of the rights of others. ….The Court is of the view that freedom of expression in a democratic society must be the subject of a lesser degree of interference when it occurs in the context of public debate relating to public figures. Consequently, as stated by the Commission, “people who assume highly visible public roles must necessarily face a higher degree of criticism than private citizens; otherwise public debate may be stifled altogether”. In ALTUG TANKER AKCAM V TURKEY application no. 27520/07 25th October 2011 where the Applicant complained that the existence of Article 301 of the Turkish Criminal Code interfered with his right to freedom of expression, the Court held that in determining whether the contested legislation is in itself compatible with the Convention’s provisions, Article 301 of the Turkish Criminal Code and the criminal investigation commenced against the applicant does not meet the “quality of law” required by the court’s settled case-law, since its unacceptable 42