a) Accreditation Regime: Like the Applicant, the Amici Curiae faulted Articles 5-7 of the Press Law and have relied on both the Compulsory Membership Case [supra] as well as Scanlon & Holderness [supra] to buttress their submissions. b) Content-Based Restrictions: Regarding Articles 17 – 19 of the Press Law, it was the Amici Curiae’s submission that the restrictions contained therein limit the ability of the media to be critical of the Government or government officials. That such restrictions are detrimental to democracy and human rights and Courts in several jurisdictions have recognized this type of restriction as unacceptable. The Amici Curiae, on the above submissions, relied on the decisions in Mills vs. Alabama 384 U.S. 214 (1996), New York Times Co. vs. Sullivan 376 U.S. 254 (1964), Case of Herera – Ulva vs. Costa Rica[2004] 1ACCHR 3 and Lingers vs. Austria [supra]. It was their further submission that content-based restrictions that are unreasonable, for example on grounds of “morality and common decency” or “public order and security” should not be included in any progressive Statute on the Press. c) Right of Reply and right of correction under Articles 48-54 of the Press Law: On this point, the Amici Curiae submitted that while the right of reply has been recognized in some jurisdictions, others have concluded that it is inconsistent with freedom of expression and freedom of the press. Reference No. 5 of 2013 Page 23