SPECIAL COLLECTION OF THE CASE LAW ON FREEDOM OF EXPRESSION alia, “facilitating wider access to the global market and international distribution networks for their cultural activities, goods and services”. 72 In 2020, the four international rapporteurs deplored “restrictions on the ability of the public to access the Internet, including complete or partial shutdowns, which seriously limit… the ability of members of the public to access information”. 73 They went so far as to call internet shutdowns to be a form of prior censorship of the media. 74 Regarding regional intergovernmental organizations, it is important to note the African Commission on Human and Peoples’ Rights, which called on States to “recognise that universal, equitable, affordable and meaningful access to the internet is necessary for the realisation of freedom of expression, access to information and the exercise of other human rights.” 75 The Committee of Ministers of the Council of Europe, for its part, considers that freedom of information entails the right of access to documents of State bodies, which today is typically provided online. Thus freedom of information is dependent upon widely available and affordable access to the internet. “The latter is a prerequisite for content disseminated through the media and platforms to be available and accessible to all groups without discrimination.”76 It acknowledges that “Internet access improves public administration and services by making them more accessible (inter alia through access to official documents), responsive, user-oriented, transparent, efficient and cost-effective, thus contributing to the economic and cultural vitality of society.” 77 In the eyes of the Council of Europe, this freedom of information “applies not only to the content of information, but also to the means of dissemination or hosting, since any restriction imposed on the means of dissemination necessarily interferes with the right to receive and impart information.”78 1.4. Shutdowns as an instrument to protect national security and public order Intergovernmental organizations have observed that States most often invoke public safety or national security concerns as justifications for restrictions on distribution of information deemed illegal or likely to cause harm. In the words of the report of the Office of the UNHCHR, “[W]hen shutdowns are based on legal 72 Convention for the Protection and Promotion of the Diversity of Cultural Expressions (2005), https://en.unesco.org/creativity/convention/ texts. See also: https://unesdoc.unesco.org/ark:/48223/pf0000379015. 73 International Mechanisms for Promoting Freedom of Expression, “Joint Declaration on Freedom of Expression and Elections in the Digital Age”, 2020, https://www.osce.org/files/f/documents/9/8/451150_0.pdf 74 Ibid. 75 African Commission on Human and Peoples’ Rights, Declaration of Principles on Freedom of Expression and Access to Information in Africa, principle 37 (2). 2019. https://www.achpr.org/public/Document/file/English/Declaration%20of%20Principles%20on%20Freedom%20 of%20Expression_ENG_2019.pdf. 76 Council of Europe, Principles for media and communication governance - Recommendation CM/Rec(2022)11 and explanatory report (2022), Strasbourg, 2022, para 6.5, https://edoc.coe.int/en/media/11117-principles-for-media-and-communication-governance-recommendation-cmrec202211-and-explanatory-report.html 77 Recommendation CM/Rec(2007)16 of the Committee of Ministers to member states on measures to promote the public service value of the Internet (Adopted by the Committee of Ministers on 7 November 2007 at the 1010th meeting of the Ministers’ Deputies), https://search.coe. int/cm/Pages/result_details.aspx?ObjectId=09000016805d4a39 78 Recommendation CM/Rec(2015)6 of the Committee of Ministers to member States on the free, transboundary flow of information on the Internet (Adopted by the Committee of Ministers on 1 April 2015, at the 1224th meeting of the Ministers’ Deputies) Para 1, https://search.coe.int/ cm/Pages/result_details.aspx?ObjectID=09000016805c3f20 19