they contain vague concepts, such as the term “grossly offensive” that the law does not materialize, giving rise to arbitrary interpretation and application, making it a low quality Law, and on the other hand, the restrictions imposed by it to the right to freedom of expression are not established by law, are not reasonably justified, do not pursue legitimate objectives, are neither necessary nor proportionate. 90. Due to the vague character of the term, legitimate journalistic activity can be included in the scope of this provision and be subject to the threat of severe criminal sanctions, which is disproportionate and unnecessary. 91. Section 24 of the Cybercrime Act is not drafted with sufficient precision to allow an individual to predict whether his behavior would constitute an offense under the provision. That as a penal provision, it should be written in a strict and unambiguous way. 92. In addition, it does not provide for safeguards against law enforcement officers, who rely on this vague language to freely exercise the discretionary power to arrest, accuse, prosecute and or convict a person. 93. The sanctions provided for in Section 24 of the Law constitute restrictions on the right to freedom of expression and press not reasonably justified, which are not established by law, do not pursue a legitimate objective and are neither necessary nor proportionate. 94. The Applicant concluded that the provisions of Section 24 do not meet the three requirements regarding the validity of laws aimed at restricting freedom of expression, thus constituting a violation of the right to freedom of expression under the terms of Articles 19 of the ICCPR and 9 and 1 and 2 of the African Charter. 95. On its turn, the defendant State maintained that: 96. Article 1 of the African Charter empowers each Member State, including the Federal Republic of Nigeria, to adopt legislative or other measures to enforce the freedoms enshrined in the Charter. 23