36 S.C. 128\02 It is apparent from the above that the Malaysian Act confers on the Minister a lot more power than does the Zimbabwean Act. SOUTH KOREA In South Korea the Broadcasting Act No 6139 of January 12th 2000 regulates the private (public broadcasters are excluded) broadcast industry in South Korea. It creates a nine-member Korean Broadcasting Commission which is appointed by the President of the Republic of Korea, from among those persons with specialized expertise and who are representatives of different fields of society” (Article 21(1)). Article 21(2) enjoins the President to appoint three persons from the nine “who are recommended by the Speaker of the National Assembly after consulting with the assembly men representing each negotiating party of the National Assembly and three persons who are recommended by the Speaker of the National Assembly in consideration of their expertise with respect to broadcasting and ability to represent the viewers.” In making these recommendations, the Speaker is required to present the criteria and grounds for recommendation. Significantly, Article 24(1) considers all the members “public officials in political service.” To protect the independence of the Commission, Article 26 provides that a member shall not be subject to any external direction or interference with his duty, and shall not be dismissed from his office contrary to his consent except for stated offences. Article 9(1) makes the Minister of Information and Communication the licensing authority. It reads:- “… a person who intends to operate a terrestrial broadcasting business or satellite broadcasting business shall, upon receiving the recommendation of