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High Severity

Executive Body Adjudicates Speech Disputes

This provision grants an executive-appointed Division initial adjudicatory power over most speech-related complaints, requiring individuals to exhaust administrative remedies before accessing courts (60). The Division determines whether speech constitutes misinformation, disinformation, hate speech, or private facts disclosure—all vague categories requiring constitutional analysis—yet operates under the National Communications Authority with a President-appointed Director (14). While certain matters are excluded (government allegations, criminal cases, monetary damages), the "public traction" standard for court referral is undefined, allowing the Division to retain jurisdiction over controversial speech most in need of judicial protection. This structure violates separation of powers by placing speech adjudication in executive hands, creating chilling effects as speakers face a non-independent tribunal before reaching courts.