The State Requirement to Show that Each Restriction Serves a Legitimate, Enumerated Purpose 23. With respect to the second Article 19(3) requirement, each State must provide a legitimate purpose for restricting freedom of expression under one of the articulated aims: respect for the rights and reputations of others or protection of national security, public order, public health or morals.48 This criterion “may never be invoked as a justification for the muzzling of any advocacy of multi-party democracy, democratic tenets, and human rights.”49 Notably, all public institutions and figures, including heads of State and Government, “are legitimately subject to criticism and political opposition.”50 24. The former mandate holder stressed that the “use of an amorphous concept [such as] national security to justify invasive limitations on the enjoyment of human rights is of serious concern.”51 25. Governments often assert that the purpose of its restrictions are to protect national security and public order.52 Protecting national security and public order is a legitimate purpose under Article 19(3). Also, the Committee has found that “on the basis of maintenance of public order it may, for instance, be permissible in certain circumstances to regulate speech-making in a particular public place.”53 26. However, given the extremely political environment in which shutdowns typically occur, a State must demonstrate that its Internet shutdowns are in fact motivated by legitimate concerns regarding national security and public order and not by an attempt to “muzzle” dissent for the sake of political dominance. 54 The State Requirement to Show the Necessity and Proportionality of Each Restriction 27. Lastly, under Article 19(3), each State must ensure restrictions are not overbroad by meeting the strict tests of necessity and proportionality. Restrictions must be “implemented narrowly.”55 States must “demonstrate in specific and individualized fashion the precise nature of the threat, and the necessity and proportionality of the specific action taken, in particular by establishing a direct and immediate connection between the expression and the threat.”56 28. In the context of countering online extremism, the U.N. High Commissioner for Human Rights has explained that States obstructing communications networks must: 48 See ICCPR, art. 19. General Comment 34, para. 23. 50 Id., para. 37. 51 U.N. Doc. A/HRC/23/40/Add.1 (23 March 2013), https://undocs.org/A/HRC/23/40/Add.1. 52 See Statement in Defence: Republic of Togo (filed 19 February 2019) § I. 53 General Comment 34, para. 31. 54 See Response to Respondent’s Special Brief and Statement of Defence (filed 18 March 2019), paras. 16-17 (noting that Togo’s alleged evidence was not filed with the Court, nor provided to Applicants). 55 “Promotion and protection of human rights: human rights questions, including alternative approaches for improving the effective enjoyment of human rights and fundamental freedoms” U.N. Doc. A/71/373 (6 September 2016), para. 7, https://undocs.org/en/A/71/373%20. 56 General Comment 34, para. 35. 49 8