istered and unregistered associations, can enjoy and exercise this fundamental right and should be equally protected by the state in doing so. The obligation of participating States to guarantee the right to freedom of peaceful assembly applies to the state as a whole. As such, central government authorities must ensure that municipal and other authorities also comply with this obligation, and in the case of federal states, that all federal authorities are bound by this obligation. 171. The UN Special Rapporteur on the rights to freedom of peaceful assembly and of association has stressed the important role of new information and communications technologies, including the Internet and mobile telephone services, in enabling and facilitating the enjoyment of freedom of assembly and association rights.242 Moreover, the UN Human Rights Council has underlined the obligation of States “to respect and fully protect the rights of all individuals to assemble peacefully and associate freely, online as well as offline […]”.243 In line with this, participating States should ensure that human rights defenders can freely use such technologies as tools for organizing assemblies, disseminating information about forthcoming events and performing other related activities. The authorities should cease practices and regulations that clamp down on the access to and the use of these tools by human rights defenders. Any restriction on such access or use should be reviewed by a competent court.244 172. Spontaneous, simultaneous and non-notified assemblies: Participating States should facilitate and ensure the protection of various types of peaceful assemblies, including spontaneous and simultaneous assemblies. Spontaneous assemblies are often triggered by an event, and therefore meeting the requirement of an advance notification, if there is one, may not be feasible. Furthermore, such events are often gatherings with no prior advertising or invitation and no identifiable organizers, which also make advance notification impracticable. Nevertheless, spontaneous assemblies of a peaceful nature should be fully protected, recognized in law and regarded “as an expectable (rather than exceptional) feature of a healthy democracy”.245 Likewise, simultaneous assemblies should also be allowed, protected and accommodated. “If this is not possible (due to, for example, lack of space), the parties should be encouraged to engage in dialogue to find a mutually satisfactory resolution.”246 Where counter-demonstrations occur, the authorities should take all necessary measures to ensure that the assemblies occur within the sight and sound of their target audiences. The emphasis, however, “should be placed on the state’s duty to prevent disruption of the main event where counter-demonstrations are organized”.247 242  A/HRC/20/27, 21 May 2012, paras. 32 and 84(k). 243  A/HRC/RES/24/5, 8 October 2013. 244  A/HRC/23/39, para. 83(e). 245  OSCE/ODIHR-Venice Commission Guidelines, para. 128. 246  Ibid. para. 122. 247  Ibid. Guidelines on the Protection of Human Rights Defenders 83