2. International and Regional Courts Have Widely Condemned Internet Shutdowns and Website Blocking Measures amounting to internet service disruption, website blocking, and online ―kill switches‖ or ―shutdowns‖ have been widely condemned by international, regional and domestic courts and human rights bodies. Most recently, in November 2016, the African Commission adopted a Resolution in which it expressed its concern over ―the emerging practice of State Parties of interrupting or limiting access to telecommunication services such as the Internet, social media and messaging services, increasingly during elections‖.13 In doing so, the African Commission aligned itself with the Human Rights Council of the UN General Assembly, which adopted a Resolution in June 2016 that appealed for the promotion, protection, and enjoyment of human rights on the internet.14 The Human Rights Council stated that it was deeply concerned ―by measures aiming to or that intentionally prevent or disrupt access to or dissemination of information online, in violation of international human rights law‖.15 In the Resolution, the Council ―condemns unequivocally measures to intentionally prevent or disrupt access to or dissemination of information online in violation of international human rights law and calls on all States to refrain from and cease such measures.‖16 In December 2017, the UN General Assembly adopted by consensus the resolution, "The safety of journalists and the issue of impunity", which contains an operative paragraph on shutdowns: “Condemns unequivocally measures in violation of international human rights law aiming to or that intentionally prevent or disrupt access to or dissemination of information online and offline, aiming to undermine the work of journalists in informing the public, and calls upon all States to cease and refrain from these measures, which cause irreparable harm to efforts at building inclusive and peaceful knowledge societies and democracies.‖17 In 2011, the UN Special Rapporteur on freedom of opinion and expression, the African Commission Special Rapporteur on Freedom of Expression and Access to Information, the Organization for Security and Co-operation in Europe (OSCE) Representative on Freedom of the Media, and the Organization of American States (OAS) Special Rapporteur on Freedom of Expression jointly declared that the; 13 African Commission on Human and Peoples‟ Rights, Resolution on the Right to Freedom of Information and th Expression on the Internet in Africa, 59 Ordinary Session, held Banjul, Islamic Republic of The Gambia, from 21 October to 04 November 2016, ACHPR/Res. 362(LIX) 2016. 14 UN Human Rights Council, The promotion, protection and enjoyment of human rights on the Internet, UN Doc. A/HRC/32/L.20 (2016). 15 Id., p. 3. 16 Id., par. 10. 17 UN General Assembly, The safety of journalists and the issue of impunity, UN Doc. A/C.3/72/L.35/Rev.1 (2017).