was unconstitutional because it represented an unwarranted interference with editorial matters. 56. The Applicant also relied on a statement in the Report of the Mission to Hungary (29th January 1999) where the UN Special Rapporteur on Freedom of Expression took a skeptical view of the right to reply and stated that it should be allowed, if at all, only as part of the media industry’s self-regulation and applied to correction of facts and not opinions. 57. Further, the Applicant pointed this Court to Resolution No. (74)2b where the Council of Europe’s Committee of Ministers suggested the limited exceptions that should be made to the rule that the right to reply should only be applicable to facts and not opinions. The Press Law, it argued, provides on the other hand, an unduly broad set of circumstances and allows a near- continuous interference with the work of the media. g) That Articles 56-64 and 66-69 of the Press Law create penalties that are unduly severe and restrictive of press freedom and fail to comply with generally accepted standards of criminal law and procedure. That the penalties also depart from the principle of proportionality and it was the Applicant’s argument that under International Human Rights’ Law, where a sanction is also placed when restricting the right to freedom of expression, such a sanction should not be disproportionally harsh. In that regard, the ECHR decision in Tolstry Miloslavsky vs. UK, Appl. No.18139/92 (1993) was cited in support thereof. 58. The Applicants also contended that the National Communications Council is not the appropriate authority to enforce the above Articles of the Press Law because it lacks the necessary independence to do so, as Reference No. 5 of 2013 Page 19