151. In the same vein, the Human Rights Committee, in its “ General Comments nº 34 ”, noted that “Restrictions must be “necessary” for a legitimate purpose.” (see paragraph 33) 152. The African Court also maintained in the aforementioned case, Issa Konoté v. Burkina (para. 145) that in order to consider the need to restrict freedom of expression “[…] such a need must be assessed within the context of a democratic society" and … this assessment must ascertain whether that restriction is a proportionate measure to achieve the set objective namely, the protection of the rights of others.” 153. The same Court also underlined, in the aforementioned case, Ingabire Victoire Umuhoza v. Republic of Rwanda that “[...] the determination of necessity and proportionality in the context of freedom of expression should consider that some forms of expression such as political speech, in particular, when they are directed towards the government and government officials, or are spoken by persons of special status, such as public figures, deserve a higher degree of tolerance than others.” (para. 142) 154. In the same vein, the African Commission stated that “Any restriction on freedom of expression must be…. Necessary in a democratic society.”19 155. In law, the principle of proportionality or proportional justice is used to describe the idea that the punishment of a particular criminal offense must be proportional to the seriousness of the criminal offense itself. 156. The principle of proportionality seeks to determine whether, through the action of the State, a fair balance has been achieved between the protection of the rights and freedoms of the individual and the interests of society as a whole. 157. The African Court wrote in the aforementioned case Issa Kanote, “As concerns proportionality of punishment against the right to freedom of expression, in its decision of 3 April 2009 on Zimbabwe Lawyers for Human Rights & Associated Newspapers of Zimbabwe v. Zimbabwe, the Commission considered that even when a State is concerned 19 Communication No. 284/03, Zimbabwe Lawyers for Human Rights and other v. Zimbabwe, para. 176. 36