controlling journalists through the exercise of prior self censorship, and obstruction of the work of journalists. They submitted that there are civil and criminal sanctions within Zimbabwe, which provide remedies in the event journalists violate legal provisions during the exercise of their profession. They argue against the conditions for compulsory accreditation. 102. The African Commission agrees with these submissions and states that the presence of laws which provide for civil and other legal sanctions in the event of any injury caused, or infraction of the law by journalists during the practice of their profession, coupled with self regulation, would provide an adequate mechanism for the regulation and control of the journalism profession in a democratic society, without the necessity of the rigorous regime under AIPPA. 103. The right to freedom of expression is protected by national, regional as well as international human rights instruments. One common thread that runs through the freedom of expression guarantees at all levels is the fact that the right to freedom of expression is not absolute. 104. The European Convention on Human Rights regulates freedom of expression in Article 10(2) and spells out the legitimate aims that can justify the restriction of freedom of expression, states that: "[t]he exercise of these freedoms, since it carries with it duties and responsibilities, may be subject to such formalities, conditions, restrictions or penalties as are prescribed by law and are necessary in a democratic society, in the interests of national security, territorial integrity or public safety, for the prevention of disorder or crime, for the protection of health or morals, for the protection of the reputation or rights of others, for preventing the disclosure of information received in confidence, or for maintaining the authority and impartiality of the judiciary." 105. Article 13 of the American Convention on Human Rights guarantees the enjoyment of the right of freedom of expression. Article 13(2) provides that the exercise of freedom of expression; "shall not be subject to prior censorship but shall be subject to subsequent imposition of liability, which shall be established by law to the extent necessary to ensure respect for the rights and reputation of others as well as to protect national security, public order, public health, or morals. 106. Article 10 of the European Convention, 13 of the American Convention and 9 of the African Charter all emphasize that the exercise and enjoyment of freedom of expression can be restricted under lawful conditions. 107. The African Commission has adopted a Declaration of Principles on Freedom of Expression in Africa which upholds certain basic principles aimed at enhancing the enjoyment of freedom of expression. Principle II of the Declaration states that; "(1) No one shall be subject to arbitrary interference with his or her freedom of expression; and (2). Any restrictions on freedom of expression shall be provided by law, serve a legitimate interest and be necessary in a democratic society"(emphasis is added). The African Commission reads from the foregoing that the right to freedom of expression may be restricted by legislation which aims to protect the public or individuals, against practice of journalism which deviates from certain basic norms and legitimate interests in a democratic society. The restrictions imposed by AIPPA do not fall within those norms or interests.