A/HRC/32/36/Add.3 or on traffic flow considerations are intrusive restrictions that exceed the criteria of necessity and proportionality. 537. The Special Rapporteur takes this opportunity to remind the Government to ensure that any system of prior notification gives effect to the presumption in favour of assemblies, places narrow limits on the discretion of authorities to restrict assemblies, and incorporates a proportionality assessment (A/HRC/31/66, para. 28(a)). Also, he emphasizes that the “time, place and manner” restrictions should never be used to undermine the message or expressive value of an assembly or to dissuade the exercise of the right to freedom of assembly (A/HRC/31/66, para. 34). 538. Regarding the Joint Allegation Letter sent on 10 December 2015 about the intimidation and violence of journalists and media outlets, including at protests, as well as measures of arrest and prosecution (MNE 2/2015). The Special Rapporteur notes the reply of the Government of 16 January 2016. However, he remains concerned about the details of the individual cases outlined that were not directly addressed in the State’s reply and would appreciate additional information in this regard. He takes this opportunity to remind the Government of Montenegro to protect the rights to freedom of peaceful assembly and association, and freedom of expression and opinion. 539. He reaffirms that the rights to freedom of peaceful assembly and of association are necessary elements for the possible emergence and sustainability of effective democratic systems. In this regard, States should therefore make every effort to facilitate those rights. Moreover, he stresses that it is the obligation of States to respect and fully protect the rights of all individuals to assemble peacefully and associate freely, online as well as offline (A/HRC/RES/24/5, operational para. 2). Norway 540. JAL 24/07/2015. Case no. NOR 1/2015. State reply: 22/09/2015. Alleged investigation of a human rights organization and its President for their peaceful and legitimate human rights activities. Observations Response to communication 541. The Special Rapporteur thanks the Government of Norway for responding to the communication sent during this reporting period. 542. In the case of the human rights organization, the Global Network for Rights and Development, and its President, Mr. Loai Deeb, the Special Rapporteur thanks the Government of Norway for its reply (NOR 1/2015), and looks forward to being kept informed of all developments about this case. Russian Federation 543. JAL 06/03/2015. Case no. RUS 1/2015. State reply: 20/05/2015. Alleged killing of a political opposition leader in Moscow for his peaceful and legitimate political activities. 544. JAL 07/08/2015. Case no. RUS 4/2015. State reply: 16/11/2015. Alleged targeting and criminalization of environmental human rights defender and the inclusion on the “foreign agent” list of a human rights organisation in Ozersk, Chelyabinsk region in an attempt to hinder the work the organisation’s work. 78