intrude on the professional practice of journalism. 87. Does compulsory accreditation in itself affect the enjoyment of freedom of expression? 88. Section 79(1) requires that before a journalist practices his/her profession within the Respondent State's territory, he/she must apply for and obtain a certificate of accreditation from the MIC. Section 83 of the AIPPA makes it clear that; ‘(1) No person other than an accredited journalist shall practice as a journalist nor be employed as such or in any manner hold himself out as a journalist'. 89. Official accreditation of a journalist is a mandatory precondition for operating within the Respondent State. Criminal sanctions are imposed for operating without accreditation. There are mandatory requirements for accreditation and the possession of the requisite qualifications does not guarantee provision of a certificate of accreditation. 90. The African Commission considers that registration procedures are not in themselves a violation of the right to freedom of expression, provided they are purely technical and administrative in nature and do not involve prohibitive fees, or do not impose onerous conditions. The requirements set out in AIPPA, in the opinion of the Commission, undoubtedly have a negative effect on the exercise of freedom of expression. There are no good grounds for official involvement in the registration of journalists. It creates considerable scope for politically motivated action by the authorities. The regulation of the media should be a matter for selfregulation by journalists themselves through their professional organizations, or associations. 91. A regulatory body such as the MIC whose regulations are drawn up by government cannot claim to be self-regulatory. Any act of establishing a regulatory body by law brings the body under the control of the State. This is exactly the case with the AIPPA. 92. The compulsory accreditation of journalists has been held at both national and international levels to be a hindrance to the effective enjoyment of the right to freedom of expression. 93. In its Advisory Opinion on Compulsory Membership in an Association Prescribed by Law for the Practice of Journalism,[FN10] the Inter-American Court of Human Rights emphasized the important role of the press in the development of a free and democratic society. , The Costa Rican government approached the Court for advisory opinion whether ‘…the compulsory membership of journalists and reporters in an association prescribed by law for the practice of journalism is permitted or included among the restrictions or limitations authorized by Articles 13 and 29 of the American Convention on Human Rights'. In responding to the Costa Rican government's question the Court stated that a law providing for compulsory association and, thus, barring non-members from the practice of journalism was incompatible with the American Convention, as it would deny access to the full use of the news media as a means of expressing opinions or imparting information. -------------------------------------------------------------------------------[FN10] Advisory Opinion OC-5/85, November 13, 1985, Inter-Am. Ct. H.R. (Ser. A) No. 5 (1985). -------------------------------------------------------------------------------94. The Inter-American Court noted further that compulsory licensing of journalists or the