protection of children online, fighting hate speech and extremism online, and promoting user responsibility and digital security practices. The applicants are greatly perturbed by this exercise of ministerial power, and in particular, are aggrieved by a number of provisions contained in the said Regulations, hence this application. According to the statement of facts of the applicants, the grounds upon which the said relief is sought are stated to be the following. One, Ultra vires: According to the applicants, the 1st respondent has acted in excess of his jurisdiction in that Section 103 (1) of the Electronic and Postal Communication Act gives the Minister for Information, Culture, Arts and Sports power to make regulations on content related matters. The complaint against the 1st respondent, according to them, is that by making regulations 4, 5 (d), (e), (f) and (g), 6, 7, 8,9,10 and 14 which provisions deal purely with compliance and regulatory matters, the 1st respondent has acted ultra vires. Two, unreasonable, arbitrary and ambiguous: it is contended by the applicants that the regulations 16 and 17 which are on complaints handling are unreasonable and prone to arbitrary use as they do not provide for the right to be heard and that regulation 16 has been drafted in a vague and ambiguous manner, thus impairing the right to be heard Three, interference with privacy, hence illegal and unreasonable. On this ground, the attack has been made against regulations 5 (1) (e) and 9 (d) which require on line content providers to have in place