Elections of February 2016 by the respondent was a violation of the Constitution. With regard to the 1st issue, counsel for the petitioner submitted that Article 29 (1) (a) guarantees the right to freedom of speech and 5 expression which shall include freedom of the press and other media. Further that Article 22 (1) of the Constitution provides for the protection of life. That Article 45 of the Constitution provides that the rights, duties and freedoms specifically mentioned in Chapter Four shall not be regarded as excluding others not specifically mentioned, in which the 10 right to a livelihood falls. He further submitted that the right to speech and expression is guaranteed. That given it literal meaning, other media includes telephones, laptops, social media platforms which include WhatsApp, Twitter, Facebook and others. That through these media, Ugandans can 15 freely express their thoughts on different issues including political, social and economic. He referred to the different averments in the affidavits in support of the petition and the complaints of the various deponents about the shutting down of the various platforms. Counsel for the petitioner then submitted that democracy and the 20 freedom of expression are intertwined. He referred us to R v Zundel [1992] 2 S.C.R 731 and Edmonton Journal v Alberta (AG) (1989) SCR 1326, where it was held that it is difficult to imagine a guaranteed right more important in a democratic society than the freedom of expression. That indeed a democratic society cannot exist without the 25 freedom of expressing new ideas and putting opinions about the functioning of public institutions forward. Counsel then referred to Objective II of the National Objectives and Directive Principles of State Policy in the Constitution in which it is stated that the state shall be based on democratic principles which 6

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