examination. It is still necessary to review it against the principle of proportionality expressly defined in Article 23 of the Constitution and the principle of legal certainty, as well as the current trends in human rights protection. Media Independence 123. Professional and independent news coverage serves as the foundation of a healthy democracy. All private and public groups, as well as government agencies, should do their best to establish and ensure that the news media play a critical role and act as a monitoring mechanism dedicated to preventing the government from abusing its powers and becoming corrupt. The Hualien County Government in 2017 and 2018, with the excuse of setting up the county government’s database of promotional materials for showcasing the county government’s resources, contracted individually with 15 local journalists from 14 press media at negotiated prices between NT$147,000 and NT$283,000 (US$4,900-9,450). As a result, the press media became loud sycophants of the county government agencies. Such a development can damage the public trust in the independence, impartiality and reliability of the news media, and it also impairs the news media’s independence and diligence in government monitoring. It was even worse than placement marketing, because it was tantamount to buying-off reporters. These contracts clearly distorted freedom of speech as protected under Article 11 of the Constitution, and the intent of Judicial Yuan’s Interpretation Nos. 509, 613, 678 and 689, that the public opinion formed by freedom of press is what sustains a healthy, democractic and diverse society. The Executive Yuan, in response, should deliberate on adding relevant requirements to the Budget Act, Radio and Television Act, Satellite Broadcasting Act, and Cable Radio and Television Act. Article 21 Freedom of Assembly Assembly and Parade 124. Article 14 of the Constitution protects the people’s fundamental rights to freedom of assembly and association. After all, active public participation in the formation of important national policies is also a basic requirement in a democratic country ruled by law. All the same, in practice, the police will often arrest and hand over the people participating in an assembly to legal authorities for persecution actually according to their protest demands and gestures, though ostensibly on the grounds of obstructing an officer in discharge of his duty, in accordance with Paragraph 1 of Article 135 of the Criminal Code. Prosecutors and judges habitually also expand the interpretation of elements constituting “violence” in an offense of obstructing an officer in discharge of their duty, and indict at their discretion. These observations should lead to 53