49 S.C. 128\02 In Ireland, as already indicated, members of the regulating authority are appointed by government through the responsible Minister. The government has power to remove a member of the regulating authority for state reasons. In Norway the King and the Minister have very wide powers including those of making appointment to the regulating authority. In the United States appointments to the regulating authority are made by the President with the advice and consent of the Senate. Similarly in Sweden, Malaysia, South Korea, Canada and New Zealand the government makes appointments to the regulating authority. In South Africa the government’s power to appoint members of the Independent Communications Authority of South Africa is seriously circumscribed by statutory provisions that seek to enhance the plurality of the regulating authority. In France and Italy more than one arm of government controls the appointments to the regulating authority. It is quite apparent from the foregoing that section 4 of the Act is modelled on provisions existing in countries that are generally considered as democratic. As I have already stated in impugning section 4 and section 6 the applicant relied on the Sri Lankan case of Athukorale and Ors v Attorney-General,