We have all seen, and the spate of attacks in France and Austria tells us, that the threat of terrorism hasn't gone away.

French teacher Samuel Paty's head was cut off by an 18-year-old Chechen teenager. He had shown his classroom students, when they were discussing freedom of speech, cartoons that were put out by Charlie Hebdo, a satirical magazine.

French President Emmanuel Macron issued a statement paying tribute to Mr Paty and defending the right in France to publish such cartoons. He made a very strong speech, covering many different aspects.

That speech then got a very strong counter-reaction from Muslims around the world, and some described the actions of France as Islamophobic. Jihadists have jumped on it. They've called on followers to attack French interests, and to attack anyone who insults Islam and the way they define as insulting Islam.

As a result, there were follow-up attacks. There were attacks in Nice, Lyon and in Vienna, Austria. It shows that when jihadists make such calls, there are people who will follow, and a few others, and more terror.

We all have said, we all know, jihadists don't represent Islam. You have people like that in every religion who will resort to violence. It is not a problem with any particular religion, but you will always have people like this. The question is how we deal with them.

What has happened in France has restarted the debate on what freedom of expression means, how much you can say, and what is the boundary between free expression and your obligation not to offend someone's religion.

In France, secularism, the French call it laicite, means that the government will not intervene in religious matters or stop publications that attack religions.

Freedom of speech is quite absolute to the extent that it even includes the right to blaspheme, which means you can publish anything that is offensive to any religion.

This didn't happen overnight. If you go back some centuries... to the Middle Ages, the Church was extremely powerful. If a clergyman was walking on the streets and if you didn't kneel and pay homage, you could be whipped, you could be arrested.

But over the centuries, with the Renaissance, with the assertion of nationhood... the balance shifted. Along the way, but not before there were several religious wars between the Protestants and Catholics, and between the kings and the churches, and of course the French Revolution... the principles of separation of state and religion, and the secularity of the state, developed.

Post-World War, that became a stronger principle. At the same time, France, along with some other countries, faced greater immigration post-World War II.

There are two principles worth noting about the French experience. One, the French state, the establishment, assumed that new immigrants will accept the French way of looking at freedom of speech and that they will also accept the French approach to secularity, meaning you could say what you like about any religion and the state will not intervene. They expected that all the new immigrants will accept that.

The government and the state did not engage in any active efforts to integrate the new immigrants, to see how their values can be integrated with the French approach, nor did they look at whether the French approach needed to be reconsidered and recalibrated in the light of the changing population. The French simply assumed that everyone will accept their traditional values.

And laicite meant that the state couldn't actually intervene, or seriously interact with different religions. They left the religions to themselves and they couldn't help bring people together, mould a common viewpoint, while protecting freedom of religion. Something like MHA (Ministry of Home Affairs) interacting with RRG (Religious Rehabilitation Group) to promote... unity, to promote a better understanding of religion, would not be acceptable in France, because that means the state is getting involved. But it's very difficult without the state getting involved. The state doesn't tell people what to believe in - that must be for religious leaders - but the state has resources that can be brought in to help, to assist.

What is the result when the state takes a hands-off approach and if we took a hands-off approach? You have publications like Charlie Hebdo, which publish repulsive, highly offensive cartoons and articles on religion, in the name of free speech. And the French expect all religions to accept this.

The French are shaped by their own tradition, their own history. For them, this is new, they don't realise it.

But looking at it as an outsider, some will say that if you insult my religion, I am not going to stand by and say this is your right to free speech. I'm not going to accept that free speech means that you can give offence to my religion.

So France will have to find a way to bridge this gulf between its principles of laicite and freedom, and the expectations and beliefs of its people who don't accept that their religion should be offensively caricatured.

Every now and then, we get debates in Singapore - why is the Government not allowing free speech, why is the Government so protective or so defensive when it comes to race and religion? This is why we are defensive when it comes to race and religion. Because if we take a hands-off approach, then people will say since the Government won't do something, I will do something, and people are going to be upset with one another.

National harmony will be affected and the majority of people will be affected. Some groups will be saying yes, free speech, it's okay, I don't get offended, you can say what you like about the Prophet, the Pope or God. But many other people would feel offended. So that is why we take a different approach.

We take a secular approach, so when the Government looks at policies, we are secular. We don't favour any particular religion and we guarantee freedom of religion. We are secular, France is secular; we guarantee freedom of religion, France guarantees freedom of religion. But how we achieve it is different. France says that it prefers to achieve it by taking a hands-off approach; we are interventionist, we intervene.

Because we take the position, that the right to speak freely goes with the duty to act responsibly, the two must go together.

And, as a secular government, we are neutral in the treatment of all religions. We also do not allow any religion to be attacked or insulted by anybody else, whether majority or minority. Same rules.

We guarantee freedom of religion, the right of every person to practise his or her religious beliefs, and we protect everyone, majority or minority, from any threats, hate speech or violence.

That is the assurance one gets in Singapore. It is also what we need to do to make sure that we preserve racial and religious harmony in Singapore.

Therefore, the Charlie Hebdo types of cartoons will not be allowed in Singapore, whether they are about Catholicism or Protestants or Islam or Hindus. Free speech for us stops at the boundary of giving offence to religion. There is a fence, and that fence protects religious sensitivities.

The Charlie Hebdo cartoonists, if they were here, they would have been told to stop. If they didn't stop, ISD (Internal Security Department) would visit them, and they would have been arrested.

We believe that we can build a multi-religious, multiracial society based on trust, and only by taking a firm stance against hate speech, and dealing with all communities equally and fairly.

We have laws designed to ensure racial and religious harmony in Singapore. We update them regularly to make sure that they are relevant and effective as times change.

Many of you might know that we amended the Maintenance of Religious Harmony Act (MRHA) last year. One key amendment is that the minister can issue restraining orders to take effect immediately, removing the requirement for a 14-day notice period, because when it was introduced several decades ago, you had to give 14 days' notice. But today, if you give 14 days' notice, it goes around the world several times before 14 minutes are up. With social media and the Internet, a 14-day notice period doesn't work any more.

We've been noticing foreign groups intervening, using religion, not just in Singapore, but in many other countries. We didn't want to wait until that happened here, so we made amendments to the MRHA to say that foreign actors should not be exploiting our religious groups, imposing their values here.

Let Singapore Muslims, Singapore Christians, Singapore Hindus decide for themselves.

You can adapt the religiousbeliefs, but foreigners shouldn't intervene actively in the way wedo it.

Religious groups are now required to report all donations they receive from overseas, and we have rules. It doesn't prevent foreign leadership of our organisations, but we have rules restricting the number of foreigners who can be in committees in charge of religious institutions.

The Government can also issue a restraining order against religious groups to prohibit donations, or change the leadership, if we assess that foreigners are heavily influencing those groups.

In contrast to France, we maintain secularity, we guarantee freedom of religion by putting a limit to free speech. We'll say it cannot be used to attack religion, and actively intervene to put in policies which promote religious harmony.

I'm sharing this because France has been in the news, the French approach has been in the news, and in Singapore, the constant debate is about freedom of speech and the limits. So, we understand why 40 to 50 years ago, our first generation of leaders decided on these principles which are still valid.

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Free speech stops at the boundary of giving offence to religion: Shanmugam - The Straits Times