48. The Complainants argue further that, compliance with formal but onerous and intrusive preregistration requirements stipulated in the statutory instrument does not guarantee registration of a journalist because the MIC has discretion to decide whether or not to register the journalist. 49. The Complainants urge the African Commission to draw inspiration from legal precedent developed in other regional human rights systems. They specifically draw the attention of the African Commission to Article 13 of the American Convention on Human Rights, which provides, inter alia, that: (1) “Everyone has the right to freedom of thought and expression. This includes freedom to seek, receive and impart information and ideas of all kinds regardless of frontier, either orally or in writing, in print, in the form of art or through any other medium of one’s choice.” (2) Article 13 paragraph 3, provides that: (3) “the right of expression may not be restricted by indirect methods or means such as the abuse of government or private controls over newsprint, radio broadcasting frequencies or equipment used in dissemination of information or by any other means tending to impede the communication and circulation of ideas and opinions.” 50. The Complainants also cite an Advisory Opinion of the Inter American Court of Human Rights on compulsory registration which dealt with the question of registration of journalists in Costa Rica. The Court stated in this Advisory Opinion that; “it is the mass media that make the exercise of freedom of expression a reality. This means that the conditions of its use must conform to the requirements of this freedom, with the result that there must be, inter alia, a plurality of means of communication, the barring of all monopolies thereof, in whatever form, and guarantees for the protection of freedom and independence of journalists. The compulsory licensing of journalists does not comply with the right to freedom of expression because the establishment of a law that protects the freedom and independence of anyone who practices journalism is perfectly conceivable without the necessity of restricting the practice only to a limited 6 group of the community…” 51. According to the Complainants, Article 13 of the American Convention on Human Rights defines freedom of expression in a way similar to that of Article 9 in the Charter; as “freedom to seek, receive, and impart information and ideas of all kinds.” 52. The Complainants note that the right protected by Article 13 of the American Convention (similar to the right protected under Article 9 of the Charter) has a special scope and character, evidenced by the dual aspect of freedom of expression. That, on the one hand, the prohibition of any restrictions or impediments by governments or privately against free expression, dissemination of information, communication or circulation of thoughts and ideas, and in that sense, it is a right that belongs to each individual. Its second aspect implies a collective right to receive any information whatsoever and to have access to the thoughts expressed by others. 53. The Complainants also submit that ‘if you control journalists you control expression; controls are an obstacle to the means of expression and therefore against freedom of expression itself’. According to them, the Respondent State’s attempts to distinguish between freedom of the press and freedom of expression are not sustainable. They add that, although freedom of expression encompasses a wider range of activities than freedoms of the press, in that sense the two are different. Freedom of the press is an element of freedom of expression. 54. The Complainants argue further that, freedom of expression goes further than the theoretical recognition of the right to speak or to write. They submit that it also includes and cannot be separated from the right to use whatever medium is deemed appropriate to impart ideas and to have them reach as wide an audience as possible. 55. The Complainants argue that the both the Inter-American Convention on Human Rights and the Universal Declaration of Human Rights proclaim that freedom of thought and expression includes the right to impart information and ideas through “any… medium”, and this means that the expression and dissemination of ideas and information are indivisible concepts. They submit that, the restrictions that are imposed on dissemination represent, in equal measure, a direct limitation on the right to express oneself freely. They argue further that the legal rules applicable to the press and to the status of those who dedicate themselves professionally to it derive from this concept. They state that in its social dimension, freedom of expression is a means of the interchange of ideas and information among