principle.195 Consequently, as the UN Human Rights Committee has stressed, any such limitations must be understood in light of the universality of human rights and the principle of non-discrimination.196 139. In a number of OSCE participating States, defamation laws are reportedly used to silence, and sometimes even imprison, human rights defenders. There have been reports of the abuse of laws on defamation and of laws that aim to protect the honour and reputation of the political leadership to stifle legitimate expression, including online. The UN Human Rights Committee has observed in its jurisprudence that in circumstances of public debate in a democratic society, especially in the media, concerning figures in the political domain, the value placed by the ICCPR upon uninhibited expression is particularly high.197 Furthermore, the Committee has stated that “States parties should consider the decriminalization of defamation and, in any case, the application of the criminal law should only be countenanced in the most serious of cases and imprisonment is never an appropriate penalty.”198 Indeed, as the opinions of the OSCE Representative on Freedom of the Media regularly highlight, there is full agreement among international organizations and institutions that defend freedom of expression that criminal defamation is unnecessary for the protection of reputation and must be abolished in view of its chilling effect on free expression.199 Together with the UN Special Rapporteur on the promotion and protection of the right to freedom of opinion and expression and the OAS Special Rapporteur on Freedom of Expression, the OSCE Representative on Freedom 195  UN Human Rights Committee, General Comment No. 34 on Article 19, para. 26. 196  Ibid. para. 32. 197  See for example, the views of the Human rights Committee in the case of Bodrozic v. Serbia and ­Montenegro, Communication No. 1180/2003, October 2005, para. 8, referred to above in the section General Principles. 198  UN Human Rights Committee, General Comment No. 34 on Article 19, para. 47. In its Concluding ­Observations, the Committee also regularly recommends that States Parties decriminalize defamation. See, for example, UN Human Rights Committee, “Concluding Observations on Czech Republic”, UN Doc. CCPR/C/ CZE/CO/3, 22 August 2013, para. 21; “Concluding Observations on Turkey”, UN Doc. CCPR/C/TUR/CO/1, 13 November 2012, para. 24; “Concluding Observations on Serbia”, UN Doc. CCPR/C/SRB/CO/2, 20 May 2011, para. 21; “Concluding Observations on Uzbekistan”, UN Doc. CCPR/C/UZB/CO/3, 7 April 2010, para. 24; “Concluding Observations on Russia”, UN Doc. CCPR/C/RUS/CO/6, 24 November 2009, para. 23. See also, for ­example, the report of the Commissioner for Human Rights of the Council of Europe on his visit to Azerbaijan, ­CommDH(2013)14, pages 8-10. 199  See, for example, OSCE Representative on Freedom of the Media legal analysis of draft laws in ­L ithuania, January 2014, available at: <http://www.osce.org/fom/111060>; and in Italy, November 2013, available at: <http://www.osce.org/fom/108108>. 70 Guidelines on the Protection of Human Rights Defenders