petition heard. In some jurisdictions such as India and Zimbabwe, public interest is an exception to, and relaxation of, the requirement of locus standi (the right to bring an action in court). In this case, any citizen can litigate the alleged violation of fundamental rights on behalf of disenfranchised groups. In jurisdictions where the requirement of locus standi is not relaxed, the petitioners have shown (largely successfully) that they have been personally impacted by the shutdowns and therefore have the right to pursue the claim. In Murad Khazbiev, the petitioner stated that he was a part of the protests that led up to the internet shutdown and as a result, the disruption of services was impacting his freedom of expression online. Similarly, in Amnesty International Togo, concerning the internet shutdown in Togo, the petitioners argued that they were journalists and human rights organisations that needed the internet to carry out their operations and also express themselves online and were thus directly impacted by the shutdown. The exception was in Global Concern Cameroon, where the petition was rendered inadmissible due to a lack of locus standi, although the circumstances here were exceptional. While there were prima facie infringements of constitutional rights, Article 47 (2) of the Cameroon Constitution posed a challenge as it limits the right to approach the Constitutional Council to the “President of the Republic, the President of the National Assembly, the President of the Senate, one-third of the members of the National Assembly or onethird of the Senators, and Presidents of Regional Executives.” The petitioners creatively argued that this provision itself was unconstitutional and used the monist nature of Cameroon enshrined in Article 45 of the Cameroon Constitution which states that duly approved or ratified international treaties/ agreements has an overriding effect over national laws, including the Constitution. However, the Cameroon Constitutional Council stuck to the letter of the law and rendered the petition inadmissible. The petitioners tried to bring the same case to a lower court, to the Cameroon High Court, a year later but were similarly unsuccessful in having the petition admitted. Arguments on merits Arguments on merits advanced by petitioners can be classified into three buckets. The first bucket was a procedural question on whether the appropriate legal provision was used by the government to order the shutdown. For example, in Gaurav Sureshbhai Vyas, it was argued by the petitioners that Section 144 of the Criminal Procedure Code (CrPC)?’ could not be used to shut down the internet and any power to do so, if any, was available only under Section 69A of the Information Technology Act (2002) (IT Act). The parameters listed in Section 69A form a much higher threshold than Section 144 CrPC. Similarly, in Dhirendra Singh Rajpurohit, the primary contention of the petitioner was that the Divisional Commissioner of Jodhpur had no authority to suspend the internet services in this manner. In CM Pak, the petitioner argued that the suspension of internet services could not be directed by the federal government (through the Telecommunications Authority) on the basis of a mere apprehension. They argued that Section 54(3) of the Pakistan Telecommunication (Reorganization) Act 1996 only allowed suspension of operations under the licenses granted by the Telecommunications Authority of Pakistan only upon the President of Pakistan exercising their power relating to the proclamation of an emergency through Part X of the Constitution. In ZLHR and MISA Zimbabwe, the petitioners had argued that the procedure for issuance of the warrant shutting internet services failed to comply with the provisions of the Interception of Communications Act. The second bucket centred around the violations of fundamental rights. Most cases stressed the violations of two fundamental rights in particular—the freedom of speech and expression, and the right to equality. In a few cases, such as in Zimbabwe and Pakistan, the petitioners had also argued that right to peaceful association. In Pakistan, the petitioners argued that the suspension of the internet, in the manner that it was effected, resulted in violation of a range of fundamental rights enshrined in Pakistan’s Constitution including those of movement, assembly, trade, speech and life. 27 Section 144 of the CrPC empowers an executive magistrate to issue orders in urgent cases of nuisance or apprehended danger. It is often used to prohibit assembly of one or more persons when unrest is anticipated.