using this law. Out of the 96 cases, seven were filed under the previous government and 89 were filed under the current National League for Democracy (NLD) government. The ratio of cases according to the party that filed the complaints during the NLD government is illustrated in Figure 1. From the ratios, we can see that more than half of the cases are motivated by political reasons, which include cases filed by the government, military, political parties and supporters of a certain political party. In Article 66(d) of the Telecommunications Law, there are seven actions for which a person could be charged: “Extorting, coercing, restraining wrongfully, defaming, disturbing, causing undue influence or threatening to any person by using any Telecommunications Network.” But in reality, almost all of the known cases have been filed under the category of defamation. All of the complaints have also been filed on the basis of content posted on Facebook and not on other online platforms such as websites or blogs. The following are some of the prominent cases under Article 66(d). figure 1. Ratio of cases according to the party that filed the complaint under the Telecommunications Law Supporter of political party Private entity Political party Military Government Media Case study 1: Chaw Sandi Htun16 Chaw Sandi Htun, also known as Chit Thamee on Facebook, was arrested in October 2015 for her post on her Facebook profile that compared the colour of Military General Min Aung Hlaing’s uniform to the colour of one of Aung San Suu Kyi’s longgyis (skirts). This was considered inappropriate according to the widely accepted culture in Myanmar, as comparing a man’s shirt with a woman’s underskirt is considered to lower the dignity of the man. The complaint against Chaw Sandi Htun was filed by an army official, for the reason that her Facebook post allegedly undermined the dignity of the Tatmadaw (army). Chaw Sandi Htun was held in custody for four days without proper judicial procedure. She was first charged under Section 34(d) of the Electronic Transactions Law, Article 66(d) of the Telecommunications Law and Section 500 of the Penal Code. In the final court judgment, which was available in December 2015, she was sentenced to six months imprisonment, under Article 66(d) of the Telecommunications Law. 16 The case of Chaw Sandi Htun, Global Freedom of Expression. https://globalfreedomofexpression.columbia.edu/cases/ case-chaw-sandi-htun-myanmar Case study 2: Hla Phone17 Kyat Pha Gyi (The Big Rooster) is the name of the Facebook account that mocks the government and military by posting “photoshopped” images. Hla Phone was accused of being the person behind Kyat Pha Gyi, and was arrested in February 2016 on the basis of a complaint filed by a military officer. He was sentenced to imprisonment for two years under Article 66(d) of the Telecommunications Law, the National Flag Act, and Section 505(b) of the Penal Code, which establishes penalties for: Whoever makes, publishes or circulates any statement, rumour or report– […] (b) with intent to cause, or which is likely to cause, fear or alarm to the public or to any section of the public whereby any person may be induced to commit an offence against the State or against the public tranquillity… 17 Khine Khine. (2017, 27 May). Free, but not free. The Voice. thevoicemyanmar.com/perspective/8866-fre 100 / Unshackling Expression