of falsehoods. Constitution. However, this has seen a number of journalists falling foul of the legislation. The COVID-19 pandemic further muddied the waters in terms of freedom of expression and of the media in Southern Africa, with a number of countries coming up with legislation that criminalised the publication of falsehoods. Alpha Media Holdings editorin-chief Wisdom Mdzungairi and senior reporter Desmond Chingarande were on 3 August 2022 charged for allegedly publishing falsehoods. Hopewell Chizuzu, a freelance journalist, faces similar charges. The Cyber and Data Protection criminalises the publication of falsehoods despite a Constitutional Court ruling in 2013 that ruled the criminalisation of the publication of falsehoods had a chilling effect on freedom of expression. The Constitutional Court ruled that Section 31(a)(iii) of the Criminal Law (Codification and Reform) Act contravened the South Africa was the first to promulgate fake news regulations, with the rest of the region following suit. This is regardless of the fact that the regulations were in most instances in contravention of national constitutions. While governments have enacted cybercrime legislation that effectively impacts on freedom of expression and in some instances criminalises journalism, there is generally a dearth in legislation that focuses on online gender-based violence in Southern Africa. Moreso, there are lack of laws that focus on protecting female journalists online. Cyber security laws are often vague and do not adequately cover the issue of online genderbased violence. However, during the course of this study a seminal resolution was passed by the African Commission on Human and People’s Rights (ACHPR) on online gender-based violence. While most legal and policy frameworks are broad in terms of wording and what protections they offer, Resolution 522 is notable as it specifically mentions female journalists. Amidst numerous points, the resolution calls on states to: “Undertake measures to safeguard women journalists from digital violence, including gender-sensitive media literacy and digital security training; Repeal vague and overly wide laws on surveillance, as they contribute to the existing vulnerability of female journalists.” The United Nations Plan of Action on the Safety of Journalists and the Issue of Impunity also provides for the protection of journalists both offline and online. While these frameworks are not legally binding, there is scope for these instruments to be adopted into national laws and be the benchmarks by which journalists, in particular female journalists are protected. All the Southern African countries have ratified the United Nations Convention on the Elimination of all Forms of Discrimination Against Women. DESMOND Chingarande 10 While the convention is broad, its provisions can be used in an effort to combat online genderbased violence.