22. The Applicants are claiming that, once enacted into law, journalists and the media profession would be susceptible to arrests, intimidations, harassments and detentions for making critical comments or remarks about government. 23. According to the Applicants, the Respondent equally has provisions in its criminal code and law criminalizing defamation of character and incitement which said laws by their purports are disproportionate to the right of freedom of expression as guaranteed. 24. They state that the existence of these laws in themselves run counter to the goals and objectives of the charter, as the restrictions created by the said laws are not within the limits contemplated by the charter as it attaches grave criminality as penalty for such speeches or communications that are defamatory or inciting. 25. The Applicants conclude that their right, and indeed that of the citizenry of the Respondent State to freedom of speech, even though not absolute, and subject to restrictions under the law, cannot be wholly criminalized and subjected to sanctions such as the death penalty or any other criminal penalty as proposed under the said Bill. b. Pleas in law 26. The Applicants rely on the following laws: i. Articles 1, 2, 3, 6, and 9 of the African Charter on Human and Peoples’ Rights (African Charter); ii. Articles 1, 2, 9 and 19 of the Universal Declaration of Human Rights (UDHR); iii. Articles 1, 2, 6 and 19 of the International Convention on Civil and Political Rights (ICCPR); and 7

Select target paragraph3