,/~,,"J(,~ !d. ACH PR .. African Commission on Human and Peoples' Rights Human Rights our Collective Responsibility demonstrate in specific and individualized fashion the precise nature of the threat, and the I necessity and proportionality of the specific action token, in particular by establishing a direct and immediate connection and the threat." between the to support this submission. She therefore submits that was only prosecuted and convicted for doing her job as journalist and this could serve any legitimate interest under any circumstances. The Second Complainant submits not necessary in a democratic society. That the Johannesburg Security, Freedom 111. of Expression and Access to Information (J , tthe I restriction sought to be justified on grc>.UljlOSor-nauonai "",":!>".,~ ... ~ unless its genuine purpose and oe:m(rns:trcll11J!l10~.~tect or sanctions is also reley;an~.,'i~"'''''''''''''H that harsh criminal penalties referenced the KO~~!~;:~,~,~,~" imposed on Kgllate on '2harges a disproportionate interference Wit~~;hisright to freedom (jt<iex"t)re;SSll~r !:~~.:·;.h 'f' She also s-U:......ts that none of her ClJ"L,l\ ..J.<;'" have incited violence or can be in any 112. -~:t;. way.~nderstood . ty. Instead, her work contributes to a ~§ ""'._ );"~")' politi9~1~~~R~t~ that is ..i, ." . ',it~~Jl;~if{2~~' ry democranc society. Therefore, her prosecution . and cortviction,under Articles 4,7 and 9 of '" " " .~'~-.~., , " 0'- ,.. " \."-.,. Proclamation of 2009 and Article 684(1) " necessary to counter the threat of terrorism and to protect the State's national security and thus constitute a violation of her right to fr~~,9.omof expression. ;~ .. _' Alleged violation of Article 16 36 Principle 2 (a). See also principle 6. I ....·i 291 P age