#FreedomOfSpeech: What that means in the US, Britain and France

LONDON, UK The attacks against French newspaper Charlie Hebdo in Paris last week have sparked a worldwide conversation about free speech.

Now the satirical paper is going to print again with its first post-attack edition, and the freedom of expression debate is raging on.

Whats on the cover? You guessed it a new cartoon of Prophet Muhammad. That's forbidden in Islam, but Charlie Hebdo and its fast-growing fan base insist the paper has the right to print it.

Some are wondering what that right is all about. Americans know something about their First Amendment. International law also protects freedom of expression and opinion its in the second sentence of the Universal Declaration on Human Rights. In practice, it varies considerably by country, even within Europe.

Heres a brief explainer on the different legal interpretations of free speech in the United States, Britain and France.

The US has the First Amendment: Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press.What First Amendment protections exist in say France or Britain?

None. The Bill of Rights applies only in the US.

Thats irritating.

Sorry. But both France and Britain are signatories to the European Convention on Human Rights and theInternational Covenant on Civil and Political Rights, which spell out countries obligation to protect citizens rights to free expression, even of controversial or inflammatory opinions. (The US has signed on to the ICCPR as well.) They have national laws protecting free speech as well.

And citizens here are serious about that freedom. When marchers mobbed the streets across France this weekend, many raising pens toward the sky, they were showing solidarity with the slain staff of Charlie Hebdo. But demonstrators were also taking a stand for the newspapers right to express itself through controversial cartoons.

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#FreedomOfSpeech: What that means in the US, Britain and France