A/HRC/15/46 good protection for property owners. The Ministry of Land Management made the process of adopting the Circular participatory, allowing civil society organizations and development partners to make their input. 32. The Special Rapporteur was pleased with the proposal made by the President of the Human Rights Committee of Cambodia during their meeting in June 2010 to constitute an ad hoc, informal group to look at outstanding land disputes with a view to screening them and proposing recommendations for resolving them in a legal and fair manner. This group would comprise a representative from his office, a representative of the Office in Cambodia of the United Nations High Commissioner for Human Rights (OHCHR-Cambodia) and several representatives from civil society organizations working on land issues. Given the inability of existing institutional bodies to resolve some of these disputes, and the lack of redress for individuals, the Special Rapporteur welcomed the proposal as constructive, provided that this new informal mechanism did not replace or undermine existing mechanisms such as Cadastral Commissions, the Courts, or the National Authority for Land Dispute Resolution. The Special Rapporteur encourages cooperative discussions among stakeholders about the possible role that such a mechanism could play in contributing to the resolution of difficult land disputes or eviction cases. The objective should be a transparent cooperative dialogue between the Government, OHCHR-Cambodia and civil society (including voices from communities) to make this a worthwhile exercise. The Special Rapporteur hopes that such a working group can be established in the near future. B. Freedom of expression 33. Freedom of expression is the lifeblood of democracy but it continues to be one of the main areas of concern in Cambodia. There does not seem to be a proper interpretation of the UNTAC criminal provision on defamation allowing for a proper balance between safeguarding private reputation and making public information concerning matters of public interest. The law regarding defamation and disinformation has been used selectively and in a biased manner against journalists, human rights activists and political leaders, and the courts do not seem to interpret the law and the restrictions on freedom of expression according to domestic laws, much less international standards binding Cambodia. The parliamentary immunity of three members of parliament – Sam Rainsy, Mu Sochua, and Ho Vann – all three belonging to the main opposition party - was lifted in 2009 to allow for criminal charges against them for defamation and/or disinformation 34. In none of these proceedings were the members of parliament given an opportunity to put their case before the National Assembly or rebut the charges levelled against them. This practice went against the basic principle of natural justice which requires that those accused of wrongdoing or committing a crime must be given an opportunity to present their case before action is taken against them. However, the courts did not look into such matters when finding them guilty of defamation. Similarly, the prosecution and imprisonment of journalists such as Hang Chakra, editor of the opposition newspaper Khmer Machas Srok, and another journalist, Ros Sokhet, should not take place in a normal functioning democracy as their actions have not undermined law and order or posed any threat to Cambodia’s national security interests. 35. Mr. Hang Chakra’s case is particularly illustrative of the practice of the judiciary in Cambodia. In May 2009, he faced a disinformation lawsuit filed by a lawyer acting on behalf of Sok An, a Deputy Prime Minister and Minister of the Council of Ministers, after his newspaper published an article on 5-7 April 2009 entitled, “Hun Sen has cracked down on bad and corrupt officials who are working around Sok An”. The article stated that Mr. Sok An was not enjoying the same degree of trust from the Prime Minister as in the past. On 21 May 2009, he published another article entitled “Officials Loyal to Sok An face 9