SPECIAL COLLECTION OF THE CASE LAW ON FREEDOM OF EXPRESSION be invoked if there is a Proclamation of Emergency by the President of Pakistan pursuant to powers vested under Part X of the Constitution. The High Court also warned that causing the suspension otherwise may expose the Federal Government or the Authority to claims of compensation or damages by the licensees or the users of the mobile cellular services. In a similar vein, in 2019 the Magas District Court in Russia held that the Federal Security Service (FSB) in Ingushetia acted lawfully when they restricted internet access on eight occasions, all of which coincided with peaceful protests. The FSB qualified its actions under Section 3 of Article 64 of the Federal Law on Communication, that obliged commercial and private entities to restrict access to the internet or other modes of communication upon receipt of a written request from law enforcement or security agencies. The District Court simply agreed with the arguments of the FSB and found that the shutdowns were legal. Once again in India, in the decision on the case of Vyas v. State of Gujarat, the High Court of Gujarat found that the state was justified in issuing an order blocking internet access on mobile phones for one week after widespread public protests, according to the already cited Section 144 of the Code of Criminal Procedure. The Court found the application of internet shutdown in the circumstances to be justified by giving deference to the decision of the authorities in finding the most appropriate mechanism for controlling the situation. It is also important to note a relevant case of total absence of deference. Governments in Sudan have been systematically and abundantly using shutdowns as a mechanism to curb dissent and criticism. Disruptions in 2019 and 2021 were challenged before the Courts by a local lawyer. In September 2019, a court ordered the telecom companies Sudani and MTN to apologize to customers for disrupting access to their networks at the behest of the military authorities. In 2021 the General Court of Khartoum ordered ISPs to restore internet services to all subscribers in response to a lawsuit raised by the Sudanese Consumer Protection Organisation. On the same day, the Telecommunication and Post Regulatory Authority (TPRA) insisted on maintaining the shutdown. The various restoration orders and arrest warrants subsequently adopted by courts held the regulator, ISPs, and the government to account115. Need to respect the distribution of competences Lastly, some judicial decisions appear to overturn or confirm decisions ordering the shutdown of access to online services solely based on whether the measure had been adopted by a body or agency that had or had not the legal authority to proceed in such way. In 2022, the High Court for Zambia at Lusaka issued a consent judgment, confirming that the Zambian Information and Communications Technology Authority (ZICTA) should not “do any act or make any omission outside of their legal regulatory powers and authority which may inhibit or interrupt the flow of and uninhibited access to information on all available telecommunication platforms under their control and/ 115 CIPESA, Litigating Internet Disruptions in Africa: Lessons from Sudan, 3 March 2022, https://cipesa.org/2022/03/litigating-internet-disruptions-in-africa-lessons-from-sudan/ 40