When it comes to hate crime and defamation laws, there is no homogenous approach in Europe. Britain, for example, has long had a more tolerant approach to free speech than countries like Germany, France, and Austria, where Holocaust denial is a crime. "It's a mixed bag, a patchwork of practices and experiences in Europe," says Agnes Callamard, director of Article 19, a global freedom-of- expression campaign group. "It's very difficult to pretend there is a common position on hate speech."Australia and Canada also have similar limits on speech. And where have we recently heard free speech mentioned?
But Europe is generally warier of free speech than is the US, with its First Amendment. Laws against inciting hatred and violence have sprung up in countries such as France, the Netherlands, Germany, and Denmark, resulting in criminal cases, convictions, and, in the case of foreigners, expulsions.
While I personally don't have a problem with the publication of the controversial Danish cartoons, I am not a legislator in a European country. Somebody's double-standard is showing.