exclusively or explicitly on mis- and disinformation; instead, they rely on legislative clauses aimed at mis- and disinformation contained in other types of legislation. These include cyber-security laws, laws against falsehoods, laws relating to information about Covid-19, sectoral laws, and/or a combination of these laws. Only Ethiopia has legislation that addresses information disorder, in the form of the Hate Speech and Disinformation Prevention and Suppression Proclamation No. 1185/2020. Data show that the majority of countries have instituted legislation addressing information disorder under their penal codes, with the second most common type of legislation being cybercrime legislation. The most common type of information disorder legislated is disinformation, with twenty-two laws passed against it. This is followed by laws against falsehoods5 and cybercrimes. The majority of laws passed are concentrated in southern Africa, with thirty laws in sixteen different countries. This is followed by West Africa, where sixteen laws have been passed in thirteen countries. The central African region has the least coverage, with only three out of seven countries having legislation against any type of information disorder. The following subsections provide an overview of the legal environment, based on different categories of legislation. CRIMINAL LAW Data from the study revealed that of the forty-six countries, only four—Gambia, Ghana, Mauritius, and Zimbabwe—made use of criminal law to combat information disorder. Of the four countries, Gambia and Ghana criminalize the spreading of disinformation, while Mauritius legislates against falsehoods and Zimbabwe against misinformation. Gambia makes use of the Criminal Code Act 25 of 1993 to criminalize the publication of false news. Section 59 of the Code prohibits the publication of any statement, rumor, or report “which is likely to cause fear and alarm to the public or disturb the public peace, knowing or having reason to believe that such statement, rumour or report is false.” Section 181A prohibits the willful, negligent, or reckless publication or broadcasting of any information or news which is false. On the other hand, in Ghana, Section 208 of the Criminal Code I N FO R M ATI O N D I SO R D ER IN THE GLOBA L SOUTH Act 29 of 1960 (as amended) prohibits “the publication or reproduction of any statement, rumor, or report which is likely to cause fear and alarm to the public, or to disturb the public peace when knowing or having reason to believe that the statement is false.” In Mauritius, Section 299 of the Criminal Code (Supplementary Act) Cap. 196 makes it an offense to publish, diffuse, or reproduce false news or news which, though true in substance, has been altered in one or more parts or falsely attributed to some other person if it stands to disturb public order or public peace. In Zimbabwe, the Criminal Law (Codification and Reform) Act (Chapter 9:23) criminalizes the publication or communication of false statements that are prejudicial to the state. It covers false statements that are “wholly or materially false.” According to Section 31, statements are considered prejudicial to the state when they either risk or cause public disorder, adversely affect the defense or economic interests of the country, or interfere with any essential service. It is worth noting that in the case of Gambia, Ghana, and Mauritius, the element of intention is present in the wording of the legislation, while in Zimbabwe, intention is not considered; rather, the focus is on the effect that the false information will have on public peace and the economic interests of the state. PENAL CODES The majority of sub-Saharan countries maintain and make use of penal codes to combat information disorder. It is worth noting that while some jurisdictions and scholars may consider penal law/ codes as being synonymous with criminal law, this study has opted to separate the two. This is primarily because this study subscribes to the school of thought that criminal law is the designation assigned to the body of law that defines what kind of conduct is prohibited by the state and sets the penalties for such conduct (Pirius n.d.). Penal law, on the other hand, refers to a particular written code of statutes defining what the elements of various crimes are (US Legal n.d.). In short, penal law deals with the punishment of one who has been proven guilty of a crime defined by criminal law. From the data, it was found that in the fortysix countries studied, a total of twenty Acts had been passed under the umbrella of penal codes. Two countries legislate against falsehoods; nine countries address disinformation, specifically focusing on the intent to mislead or deliberately spread false information; while eight countries penalize misinformation. The diction found in these Sub -Saharan Africa – 1 59