SPECIAL COLLECTION OF THE CASE LAW ON FREEDOM OF EXPRESSION in the words of another UN Special Rapporteur, “by depriving people of information sources, Internet shutdowns do not curb disinformation but, rather, hamper factfinding and are likely to encourage rumours.” 90 The COVID-19 pandemic has undeniably helped expand disinformation and also exacerbated the impact of shutdowns. As noted by the UN Special Rapporteur, the shutdowns became “an affront to the right of everyone, especially health-care workers, to access health information. There is no room for limitation of Internet access at the time of a health emergency that affects everyone from the most local to the global level.” 91 The UN Secretary-General, in his 2021 report “Our Common Agenda”, called upon governments “to find alternatives to disruptive blanket Internet shutdowns and generic blocking and filtering of services to address the spread of disinformation and harmful life-threatening content, in line with international human rights law.”92 In its turn, the Freedom Online Coalition called on all governments to “[r]efrain from discrediting criticism of their policies and stifling freedom of opinion and expression under the guise of countering disinformation, including blocking access to the Internet”. 93 War propaganda. Article 20 of the ICCPR calls upon the States to prohibit by their national law “propaganda for war” and “advocacy of national, racial or religious hatred that constitutes incitement to discrimination, hostility or violence”. 94 An applicable international agreement, although obsolete, remains relevant in this context. The International Convention concerning the Use of Broadcasting in the Cause of Peace, a 1936 League of Nations treaty recognized by the UN, binds states to “restrict expression which constituted a threat to international peace and security.”95 The Convention obligates governments to prohibit and stop any broadcast transmission within their frontiers that are “of such a character as to incite the population of any territory to acts incompatible with the internal order or the security of a territory.” It also contains a similar mandate in regard to “incitement to war against another high contracting party.” This provision makes no distinction between the speech of the state and the speech of private individuals. 96 More recently, the Special Rapporteur for Freedom of Expression of the Organization of American States declared that under the standards of the Inter-American System for the protection of human rights, 90 Disinformation and freedom of opinion and expression Report of the Special Rapporteur on the promotion and protection of the right to freedom of opinion and expression, Irene Khan, 13 April 2021, A/HRC/47/25, Para 51, https://www.ohchr.org/en/documents/thematic-reports/ ahrc4725-disinformation-and-freedom-opinion-and-expression-report. 91 Disease pandemics and the freedom of opinion and expression Report of the Special Rapporteur on the promotion and protection of the right to freedom of opinion and expression, 23 April 2020, A/HRC/44/49, Para 28, https://www.ohchr.org/en/documents/thematic-reports/ ahrc4449-disease-pandemics-and-freedom-opinion-and-expression-report. 92 Our Common Agenda, Report of the Secretary-General, 5 August 2021, A/75/982, Para 35, https://documents-dds-ny.un.org/doc/UNDOC/GEN/N21/217/01/PDF/N2121701.pdf?OpenElement. 93 “FOC Joint Statement on Spread of Disinformation Online”, November 2020, https://freedomonlinecoalition.com/wp-content/uploads/2022/03/FOC-Joint-Statement-on-Spread-of-Disinformation-Online.pdf. 94 See: https://www.ohchr.org/en/instruments-mechanisms/instruments/international-covenant-civil-and-political-rights. 95 https://treaties.un.org/pages/LONViewDetails.aspx?src=LON&id=509&chapter=30&lang=en. 96 See more in: Propaganda and Freedom of the Media. Non-paper of the Office of the OSCE Representative on Freedom of the Media, Vienna: OSCE Representative on Freedom of the Media, 2015. – 78 p., https://www.osce.org/fom/203926 22