Limits on the right to freedom of speech: Discourse in various jurisdictions

Abstract

Freedom of speech is recognized as a universal human right. However, review of
different jurisdictions reveals that the right to free speech is nuanced by cultural,
historical, social and political compulsions of a particular society. Very often this
variance finds expression not in legislations but through court interpretations of these
laws leading to difference in practice and implementation. The tension between free
speech and hate speech is a constant phenomenon necessitating perpetual evaluation
and redrawing of norms that are acceptable or unacceptable. Each legal jurisdiction is
compelled to balance speech from its particular perspective and this becomes evident
from legal interpretations offered mainly in US and EU.