The state actor or entity imposing a limitation on free expression bears the burden of satisfying
each of the three requirements. To satisfy the first requirement, the law or regulation, which
should be formally adopted by law-making authorities, must be sufficiently clear and precise;
vague or unclear provisions will not suffice.11 To meet the second requirement, only two
narrowly specified “aims” will be considered, namely those — and only those — outlined in
Article 19(3): “national security or public order,” or “public health or morals.” This limited list of
aims is designed to ensure that laws or regulations interfering with the freedom of expression
be kept to a minimum, and passed for only certain narrowly tailored, justifiable reasons.
12 Even
when justified by one of the two permissible ‘aims’ stated above, such laws/regulations must be
accompanied by adequate safeguards to ensure against interpretive abuse or disproportionate