marital status, passports numbers, expiring dates of passports, place of issue of passports, driver's license numbers, demands for residential addresses, and details related to any criminal record. Others include demand for details concerning specific assignments to be covered by the journalists, all of which impose prior self-censorship as a precondition to acquire accreditation. They argue that the accreditation form have to be examined and approved by both the Permanent Secretary and the Minister, thereby establishing control of journalists by central government. 44. According to the Complainants, the fact that one has to be accredited to a media house and obtain the support of a media house to successfully apply for accreditation amounts to restriction on the practice of journalism and the free flow of information. 45. They submit that a foreign journalist is required to pay as much as US$1, 050 for accreditation and registration to carry out a temporary assignment. 46. The Complainants submit further that even more restrictive and unreasonable is the fact that there is no provision for a permanent accreditation of foreign correspondents. That the US$12, 000,00 requirement per annum accreditation and registration fees for a foreign news agency representative is unduly burdensome, unaffordable for most people in Zimbabwe and an unreasonable restriction on freedom of expression. 47. They claim that the temporary nature of the accreditation is itself particularly ominous and different from the accreditation required to cover specific events. The Complainants argue that accreditation is not aimed at giving the journalist access, but that it is apparent from the legislation that the accreditation is aimed at controlling and even obstructing the work of a journalist. 48. The Complainants argue further that, compliance with formal but onerous and intrusive preregistration requirements stipulated in the statutory instrument does not guarantee registration of a journalist because the MIC has discretion to decide whether or not to register the journalist. 49. The Complainants urge the African Commission to draw inspiration from legal precedent developed in other regional human rights systems. They specifically draw the attention of the African Commission to Article 13 of the American Convention on Human Rights, which provides, inter alia, that: "Everyone has the right to freedom of thought and expression. This includes freedom to seek, receive and impart information and ideas of all kinds regardless of frontier, either orally or in writing, in print, in the form of art or through any other medium of one's choice." Article 13 paragraph 3, provides that: "the right of expression may not be restricted by indirect methods or means such as the abuse of government or private controls over newsprint, radio broadcasting frequencies or equipment used in dissemination of information or by any other means tending to impede the communication and circulation of ideas and opinions." 50. The Complainants also cite an Advisory Opinion of the Inter American Court of Human Rights on compulsory registration which dealt with the question of registration of journalists in Costa Rica. The Court stated in this Advisory Opinion that;

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