Freedom of opinion and expression also form a basis for the full enjoyment of a wide range of other human rights. For instance, freedom of expression is integral to the enjoyment and exercise of the right to take part in the conduct of public affairs, including the right to vote which is at the core of democratic governance based on the will of the people.76 Voters should be able to form opinions independently, free of violence or threat of violence, compulsion, inducement or manipulative interference of any kind. This implies that voters should be protected from any form of coercion or compulsion to disclose how they intend to vote or how they voted, and from any unlawful or arbitrary interference with the voting process. In order to ensure the full enjoyment of rights to take part in the conduct of public affairs including the right to vote, the free communication of information and ideas about public and political issues between citizens, candidates and elected representatives is essential. This implies a free press and other media able to comment on public issues without censorship or restraint and to inform public opinion.77 Concerns were raised during the 2021 elections with regard to the individual’s right to properly participate and express their right to vote. Some of these concerns include village council activities that were seen to be discriminatory or coercive of the individual in their effect; and political campaigns designed to influence voters’ preference by unacceptable electoral practices including bribery.78 There were also issues raised with alleged interference by officials.79 These concerns impact upon the right of voters to choose who they want to represent them in public office. Furthermore, citizens also take part in the conduct of public affairs by exerting influence through public debate and dialogue with their representatives.80 Concerns with regard to the lack of open debate between citizens and their representatives on important issues that affect them were also raised by some.81 In 2000, the Samoa Supreme Court decided on the case concerning the freedom of expression of the opposition leader and his ability to take part in the conduct of public affairs was denied by the Government of the day where his access to State-owned media to address the people of his constituency, and all the 76 UN HRC, CCPR General Comment No. 25: Article 25 (Participation in Public Affairs and the Right to Vote), The Right to Participate in Public Affairs, Voting Rights and the Right of Equal Access to Public Service, 12 July 1996, CCPR/C/21/Rev.1/Add.7, https://www.refworld.org/docid/453883fc22.html. 77 UN HRC, CCPR General Comment No. 25: Article 25, para. 19. 78 Office of the Ombudsman NHRI Samoa, “Citizens right to free and fair elections”, Press Release (1 March 2021), https://ombudsman.gov.ws/wp-content/uploads/2021/03/OMB-PR_-Free-and-Fair-Elections_FINAL.pdf. 79 See for example Matai'a Lanuola Tusani-Ah Tong, “Policeman removed after political interference complaint”, Samoa Observer (8 April 2021) https://www.samoaobserver.ws/category/samoa/82125. The article provided that a Police officer posted to the Utuali’i polling booth was removed on Wednesday after allegedly interfering with the political process by asking after and then criticizing a voter's choice of candidate. 80 UN HRC, CCPR General Comment No. 25: Article 25, para 8. 81 Focus groups consultations (Upolu and Savaii). See also Sapeer Mayron, “Samoa needs whistleblower protection: Fiame”, Samoa Observer (17 March 2021). State of Human Rights Report 2021 | 25