12. The rights of journalists and freedom of the press receive particular attention by human rights bodies.875 This includes, for example, the ability of journalists to access and observe meetings of Parliament,876 and protection against harassment.877 The need to protect journalists' sources to ensure freedom of expression, and therefore a democratic society, is a key principle of freedom of expression.878 Where freedom of the press infringes on the authority of the judiciary, 879 or to protect the rights or reputation of others,880 restrictions may be permitted. It is unlikely that a custodial sentence could ever be justified for a prosecution relating to political speech, particularly where the State could have used means other than a criminal penalty to achieve the same objective. 881 13. Concerns have also been expressed about the restrictions on the freedom of expression of human rights defenders,882 with the UN General Assembly noting in particular the right of individuals ‘freely to publish, impart or disseminate to others views, information and knowledge on all human rights and fundamental freedoms’.883 Right of access to information 14. Freedom of expression in some human rights treaties has been interpreted as providing a right of access to information.884 As the Inter-American Court of Human Rights has held in respect of Article 13 of the ACHR: ‘in guaranteeing expressly the rights to “seek” and “receive” “information”, protects the right of every person to request access to the information under the control of the State, with the exceptions recognised under the regime of restrictions in the Convention. Consequently, the said article encompasses the right of individuals to receive the said information and the positive obligation of the State to provide it, in such form that the person can have access in order to know the information or receive a motivated answer when for a reason recognised by the Convention, the State may limit the access to it in the particular case. The information should be provided without the need to prove 875 See e.g. African Commission, Communication 224/98, Media Rights Agenda (on behalf of Mr N Malaolu) v Nigeria, 6 November 2000; Communication 102/93, Constitutional Rights Project and Civil Liberties Organisation v Nigeria, 31 October 1998. UN Special Rapporteur, A/HRC/20/22. 876 Human Rights Committee, Communication 633/1995, R. Gauthier v Canada, 5 May 1999. 877 Concluding observations on Report of Gabon, Human Rights Committee, UN Doc.A/56/40, vol.I, p.44. Concluding observations on report of Peru, Human Rights Committee, UN Doc.A/56/40, vol.I, p.48. 878 European Court, Goodwin v UK, 27 March 1996. 879 E.g. see reasoning by European Court, Sunday Times v UK, 26 April 1979. 880 European Court, Lingens v Austria, 8 July 1986. 881 European Court, Lehideux and Isorni v France, 23 September 1998. 882 Human Rights Committee, concluding observations on report of Syria, UN Doc.A/56/40, vol.I, p.75. African Commission, Communication 225/98, Huri-Laws (on behalf of Civil Liberties Organisation) v Nigeria, 6 November 2000. 883 UN Declaration on the Right and Responsibility of Individuals, Groups and Organs of Society to Promote and Protect Universally Recognized Human Rights and Fundamental Freedoms, GA Res.53/144, 9 December 1998, Art.6. 884 However, contrast the ECHR, see Leander v Sweden, 26th March 1987; but more recently, Kenedi v Hungary, 28th August 2009. 141