iv. to make recordings with the use of audio-video equipment, photography and cinephotography; v. to refuse to prepare under his signature reports and materials inconsistent with his convictions; vi. to prohibit the publication of, remove his or her signature from or attach conditions to the manner of using a report or material whose content was distorted, in his or her opinion, in the process of editorial preparation." -------------------------------------------------------------------------------3. According to the Complainants, the Media and Information Commission (MIC) is managed by a Board appointed by the Minister of Information and Publicity, or other Ministers the President assign the administration of the AIPPA. Complainants allege that the Minister acts in consultation and in accordance with directions from the President of the Republic of Zimbabwe. 4. It is also alleged that no journalist may practice journalism unless he/she is accredited by the MIC and that Section 80 of the AIPPA provides that a journalist found guilty of abusing his or her journalistic privilege is liable to a fine or imprisonment for a period not exceeding two years. 5. It is further submitted by the Complainants that Sections 79 (1) and 80 (1) (b) of the AIPPA contravene Article 9 of the African Charter on Human and Peoples' Rights which provides that: "[e]very individual shall have the right to receive information. Every individual shall have the right to express and disseminate his opinions within the law." 6. According to the Complainants, compulsory accreditation of journalist, irrespective of the quality of the accrediting agency, interferes with freedom of expression. They state that accreditation fees provided for under the Law are an additional restriction on freedom of expression. They allege that compulsory accreditation of journalists by a Commission which lacks independence interferes with professional independence and the autonomy of the journalism profession. The Complainants submit further that, the MIC is not democratically constituted. Its constitution and control is not consistent with democratic values. 7. The Complainants submit further that self-regulation is a central feature of an independent profession and that the AIPPA is inherently inimical to freedom of expression and has no justification in a democratic society. 8. The Complainants claim further that they have a real and substantive interest in the matter as they were established to protect human rights and the freedom of expression. 9. They submit finally that they have exhausted local remedies and that they have litigated the issues in the highest court in Zimbabwe, whereby the Supreme Court of Zimbabwe declined to declare unconstitutional, the intentional publication of falsehoods and compulsory accreditation of journalists. COMPLAINT 10. The Complainants allege that Section 79 (1) and Section 80 of the Access to Information and Protection of Privacy Act of Zimbabwe contravene Article 9 of the African Charter on Human and Peoples' Rights. PROCEDURE

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