16 disruption to the extent legally feasible, increase transparency and communicate regularly with users, and finally join advocacy efforts against internet shutdowns. The movement and coalitions working on network shutdowns will be greatly strengthened if telecommunication providers were to join and provide an additional perspective. In Burundi, in 2015 internet service providers sought to resist government directives to shut off access to social media websites to quell protests against President Pierre Nkurunziza third term.® At the same time, they are also exposed to particularly hazardous and precarious positions as implementers of government directives.® In this case, the ISP’s resistance was unsuccessful. Shoring up arguments on admissibility: The (in) admissibility of petitions is often the states’ first line of argumentation. When the letter of the law is clearly stacked against the petitioner, it is unlikely that courts will deviate from it. The petition in Global Concern Cameroon sought to overturn clear bars on admissibility of the petition in Cameroon’s Constitutional Court using the overriding value of international law in Cameroon's monist system. In PTA, the Supreme Court observed that the petition in CM Pak was premature as the petitioners had failed to approach the Federal Government with their grievances. (Para 9)". If litigation is unsuccessful in courts, petitioners can consider alternative modes of putting pressure of advocacy in different fora. For example, in Aliansi Jurnalis Independen (AJI), advocacy efforts in the form of drawing domestic and international attention through online petitions and statements, and expansive news coverage are regarded as particularly helpful in achieving a favourable outcome. Illustrate the shutdown as proximate and actual causes of harm to highlight victim status of petitioner: This is critical in jurisdictions where public interest litigation does not relax the doctrine of locus standi. With the central role that the internet plays in the day-to-day functioning at both the individual and institutional levels, arguments articulating the harm caused by internet shutdowns are commonplace, relatively easy to make and often received favourably by courts. Several studies have brought out the same and relying on them would be helpful.*° For example, in Amnesty International Togo, a comment highlighting how the internet shutdown has hampered daily activities was sufficient to secure a favourable outcome for the petitioners. In CM Pak, alongside the appeal by CM Pak Limited, several connected petitions were filed by individuals who were using telecommunications services. The filing of multiple petitions could have been a key strategic choice, and may have played a crucial role in securing a favourable judgement. Importance of technical legal arguments: While larger constitutional questions are important both in terms of the prevailing political situations and precedent value, the most appealing arguments to the court have been rooted in procedural questions. Therefore, petitioners could stress on the appropriateness of the statutes being used, the powers of authorities implementing the shutdown and the mode used to communicate this direction. Favourable outcomes on these questions can serve as incremental gains paving the path for substantive rights-based victories relating to internet shutdowns in the future. In ZLHR and Misa Zimbabwe and CM Pak, the litigation victories were a result of strong procedural arguments illustrating the lack of powers vested in the authorities that had issued directives shutting the internet down. 54 Press Freedom Defender Team. (2020). Internet Shutdown in Indonesia. Presentations at DRLN meeting.https: //docs.google.com/ resentation /d /lgfaoDCNas8JIUs3PU3_ N3mMvFex727T8MfpC5qigf-c/edit#slide=id. 55 West, D. (2016, October). Internet shutdowns cost countries $2.4 billion last year. https: //www.brookings.edu/wp-content/ uploads /2016 /10 /intenet-shutdowns-v-3.pdf Kathruia, R & Kedia, M. et.al. (2018, April). The Anatomy of an Internet Blackout: Measuring df/Anatomy of an Internet Blackout.pdf, Collaboration on the Economic Impact of Internet Shutdowns in India. https: //icrier.or International ICT Policy in East and Southern Africa (CIPESA). A Framework for Calculating the Economic Impact of Internet Disruptions in SubSaharan Africa. https: //cipesa.org/2wpfb_dl=252 Woodhams, S. & Migliano, S. (2020, 7 January). The Global Cost of Internet Shutdowns in 2019. https: /www.top10vpn.com /cost-of-internet-shutdowns 56 Collaboration on International ICT Policy in East and Southern Africa (CIPESA). A Framework for Calculating the Economic Impact of Internet Disruptions in Sub-Saharan Africa. https: /cipesa.org /? fb_dl=252, Kathruia, R & Kedia, M. et.al. (2018, April). The Anatomy of df/Anatomy of an Internet an Internet Blackout: Measuring the Economic Impact of Internet Shutdowns in India. https: //icrier.or Blackout.pdf