In Online Citizen, the Court of Appeal’s first judgment on appeal under Section 17 of the Protection from Online Falsehoods and Manipulation Act, the Court addressed the constitutionality of POFMA’s provisions empowering the Minister to issue Correction Directions under Article 14 of the Constitution. The decision is the first application of the three-step framework set out in Jolovan Wham for Article 14 challenges, but the Court’s reasoning therein appears to differ quite considerably from that earlier decision, both on how courts should identify restrictions on free speech under Article 14(1) and how courts should assess justifications given for those restrictions under Article 14(2). This note unpacks the Court’s reasoning on the Article 14 challenge in Online Citizen, drawing out the implications that it may have for future challenges and constitutional adjudication more broadly.