14 information access. For example, in a landmark order to further the interest of sovereignty and integrity, security of state, public order or any of the other grounds mentioned in the text of Article 19(2). They rejected the argument of the petitioner that restrictions can never equal complete prohibition and stated that the same is allowed in All courts recognised “reasonable restrictions” to fundamental rights and also on internet access. The crucial pivot was on understanding the extent of what constitutes “reasonable” and the government's powers to determine the same. Ina couple of instances, the court attempted to draw up a framework to assess reasonableness. requirements to impose a complete prohibition are: first that there must not be an excessive burden on free speech and the government must justify why complete prohibition was the least conditions were laid down to examine the throttling and termination of internet access in West Papua: first, the fulfilment of a legitimate aim of human rights limitation which is to recognize and respect the rights and honour of others, or to protect moral, religious values, national security, decency, public order or public of different interests at stake. In this case, the decision, the High Court in the Indian state of Kerala read the right to have access to the internet as being a part of the fundamental rights to education and privacy accorded by the Constitution of India.** In Aliansi Jurnalis Independen (AJJ), three health in a democratic society; second, the restriction must be based on law; and third, it must be proven that such restriction was necessary and proportionate.*? Applying this framework, it was held that the throttling and termination of internet access in West Papua fulfilled the first requirement, which is carried out to protect national security and public order.*4 The Court held that the shutdown did not meet the second and third requirements because they were not carried out according to the law nor were they proportional. Similarly, in Anuradha Bhasin, the Supreme Court of India held that the right to freedom of speech and expression under Article 19 includes the right to choose the medium of expression, in this case, the internet. Therefore, the freedom of speech on the internet is an essential part of Article 19(1)(a) and consequently any restriction thereon must fulfil the requirements under Article 19(2). These requirements are: first that there must be a law providing for the action;second that the restriction must be reasonable; and third, it must be in certain appropriate cases. As per the Court, the restrictive measure and; second that the existence of a complete prohibition is a question of fact. Further, they held that the test for proportionality would necessarily involve the prioritization court held that the government was required to evaluate whether the measure was in line with the reasonable restrictions on free speech allowed under Article 19(2). In various other instances, no overarching framework was deployed to assess the restrictions on fundamental rights arising from internet shutdowns. Instead, the starting point of the analysis was the threat to national security that the internet shutdown was imposed as a response to. For instance, the Gujarat High Court which upheld the constitutionality of the shutdown made references to the protests as riots and a law and order situation. Bearing this in mind, it held that “hence, it could not be stated that the objective materials were not at all considered [by the state]”.45 As per the court, this meant that the court did not need to go the material. Deference the court’s fundamental did make a reference to into the sufficiency of to the state played out in rights analysis as well. It freedom of expression in Article 19 of the Constitution of India but stressed on reasonable restrictions and complete deference to decisions by the state. It did refer to other cases that spoke to fundamental rights including those cited by the petitioner, including Shreya Singhal v UOI which struck down Section 66A but held that it revolved around a different context. 43 Aziezi, T. (2020, 19 June). The Implementation of Human Rights Principles i in J akarta Administrative Court Judgement on Internet Access in Papua and West Papua. https: . on-internet-access-in-papua-and- -west-papua/ 44 Ibid. 45 Gaurav Sureshbhai Vyas v State of Gujarat, Para 10 46 Ibid., Para 10 47 Amicus Curiae Submission of Access Now on Aliansi Jurnalis Independen (AJI) and Pembela Kebebasan Berekspresi Asia Tenggara (SAFEnet) v The Ministry of Communication and Information (Kominfo) and The President of the Republic of Indonesia. https: //www.accessnow.org/ cms /assets /uploads/2020/05/Indonesia-Shutdowns-Amicus-ENG.pdf Amicus Curiae Submission of Access Now on Amnesty International cms /assets /uploads/2020/06/KIO ECOWAS Togo-Intervention.pdf Togo. https: //www.accessnow.or