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Comoros

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The Comoros currently has no specific legislation to counter disinformation. However, the Penal Code contains restrictions on false news, and has been used to prosecute individuals for this offence.

This law raises significant concerns from a human rights perspective. It is ill-defined in its scope, meaning that authorities could interpret it as giving them power to restrict a wide range of speech; and it pursue aims which may not be considered “legitimate” according to international human rights standards—for example, preventing the undermining of the population’s morale or protecting the reputation of the state or its institutions. It carries penalties which are potentially disproportionate in their severity, and may result in a chilling effect on freedom of expression.

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General Speech Legislation
Penal Code
Is there clarity over the precise scope of the law?

No. Article 182(1) prohibits the dissemination of “false news or false allegations to the public” which are likely to, directly or indirectly, “undermine confidence in the credit of the state, local authorities, public establishments, and all organisations where these communities and public establishments participate”. Article 231 prohibits the publication, dissemination, disclosure or reproduction of false, manufactured, misleading or falsely attributed information, whether in good or bad faith, if it has led to or is likely to lead to “disobedience to the country’s laws or undermining of the morale of the population or discreditation of public institutions or their operation”. It is not clear how one would determine whether news or allegations are “false” or “misleading”, nor what sorts of information would be likely to discredit the state or public institutions or to “undermine the morale of the population.”

Is speech or content restricted only where it is in pursuance of a legitimate aim?

No. Speech should only be restricted where some clear and objective public harm might be caused. Some of the aims pursued by Articles 182 and 231 might be considered legitimate; for example, in the name of public order or national security. Yet, they also include aims which are unlikely to be legitimate, such as preventing the undermining of the population’s morale and for protecting the reputation of the state and its affiliates as well as public institutions.

Do any restrictions in the law account for instances where the individual reasonably believed the information to be true?

Potentially. Article 182 specifically targets those who have “knowingly” spread false news or false allegations, indicating that instances where the individual reasonably believed the information to be true would not be in scope. However, Article 231 condemns the spread of false news when made “in bad faith or not”, indicating that intention to deceive is not a prerequisite for the prohibition to apply.

Are determinations of whether speech or content is disinformation made by an independent and impartial judicial authority?

Yes, these are criminal offences and will be decided in a court.

Are any responses or sanctions proportionate?

Potentially. Article 182 provides for imprisonment from three months to two years and a fine of 24,000 to 240,000 Comorian francs (USD 53 to 530). Article 231 provides for imprisonment from one year to three years and a fine of 75,000 to 750,000 Comorian francs (USD 167 to 1,670), and – if the offender is a foreigner – a ban on staying in the country for five years. If penalties are applied without consideration of the circumstance of the offence, the intention of the individual, or the actual harm caused, these penalties would be disproportionate. Furthermore, any penalty would be disproportionate if levied in pursuit of an illegitimate aim, as potentially permitted by both articles.

Are intermediaries liable for third party content?

N/A.

Law enforcement action
Journalist arrested for spreading false news online, December 2020

In December 2020, Comorian journalist Oubeidillah Mchangama of Facebook-based news outlet FCBK FM was arrested and held at a remand centre in Moroni, following his publication about a potential gas shortage, which allegedly disturbed “public order” according to the reports from authorities. He was released after one day, but held at the judge’s discretion while other allegations were investigated, for another publication he authored in September 2020 about alleged government mismanagement of public funds, which the court said constituted spreading false news.

Does the action have a legal basis?

Yes, the action referenced Article 254 of the September 1995 version of the Penal Code (Article 231 of the current version of the Penal Code), which punishes “spreading false news” with up to three years in prison and a fine of 750,000 Comorian francs (USD 1,853).

Is the action clearly directed to tackle an objectively legitimate aim?

No. The authorities stated that the action was directed towards the protection of “public order”. Yet no actual harm was caused by Mchangama’s post and it seems more likely that the journalist was detained in order to punish his criticism of the government and to quash political dissent. 

Is the action necessary and proportionate in all the circumstances?

No. Mchangama was detained and investigated but not charged on the basis of insufficient evidence. Whilst no charges were made or penalties levied, the action would be unnecessary and illegitimate as it appears directed at silencing political dissent.