Vague "Notorious Publisher" Standard Enables Arbitrary License Revocation

Section 72(1)(c) allows the Division to recommend license revocation after a publisher becomes "notorious for publishing false or other information" with only one compliance warning—bypassing the three-warning requirement in 72(1)(a). This undefined standard creates legal uncertainty that prevents digital businesses from understanding what conduct triggers existential risk. Combined with 73's warning-free Cease and Desist orders, this provision enables rapid escalation to business closure without clear criteria, proportionality analysis, or consideration of good-faith compliance efforts. The vague triggering standard deters investment in Ghanaian digital media, discourages startup entry, and creates regulatory capture risk where enforcement could selectively target government critics while protecting aligned publishers.