Constitutional restrictions on press freedom (a comparative study)

Freedom of the press is one of the most important aspects of freedom of expression that international human rights law affirms its protection in its two branches, convention and customary. And since freedom of the press is an essential expression of freedom of expression, it was the whole research. The research focused on the constitutional restrictions on press freedom, which were included in the objective provisions of the rules of international legitimacy for human rights. And the provision of protection mechanisms represented by international regulatory and judicial bodies to implement these provisions, so I tried to research through analyzing these provisions and understanding these international and regional mechanisms to determine the scope of these restrictions stipulated by the rules of international human rights law,  and what is the extent to which constitutional systems respond to the scope and limits of these restrictions in the sources of international human rights law. The researcher drew up his plan for this research, and dealt with it in two sections. In the first section, he presented some Western constitutional systems in his Latin and Anglo-Saxon schools, being the two previous ones in this field, both in text and in deduction. He presented the constitutional rules that guarantee freedom of expression and the press and the restrictions included, and the interpretation of jurisprudence and the judiciary in them for the limits and scope of these restrictions and the conditions for their implementation as they are an exception to freedom of expression and the press, and the researcher also tried to show this in the Arab constitutional systems, Among the most important of them are the Egyptian constitution, its jurisprudence, and its judiciary. The researcher tried to make a comparison between them all with what was mentioned in the modern Libyan constitutional system in front of these constitutional systems. As the constitutional restrictions in these systems are linked to the restrictions on freedom of expression and the press in the rules of international human rights law, The researcher tried to present the objective restrictions contained in this international legitimacy on freedom of expression and the  interpretations created by the mechanisms to protect their implementation to delineate the boundaries of their scope. From all this presentation, the researcher reached the results presented at the end of his research, and approved recommendations that he saw pushing towards finding an acceptable balance between the limitation of freedom that might support it and the release that might explain it.