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Free speech in Europe: mixed rules

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The general response from European politicians has been to frown on those who reproduced images first aired last fall in Denmark's Jyllands-Posten newspaper, while insisting that editors were within their legal rights to do so. Governments have refrained from apologizing to the Islamic community because they say publication is a matter for editors, not politicians. Muslim opinion, however, has not been appeased by this response.

"Muslims are complaining that they are not protected by the law as the other faiths are supposed to be," says Mr. Roy.

But if there are hints of double standards in the European approach, there are also suggestions of that in some Middle Eastern nations, which have exploded in fury at the cartoons but which are also liable to tolerate anti-Jewish sentiments. An Iranian newspaper has announced a plan to solicit cartoons about the Holocaust in response to the European position.

Europe is warier than the US

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."

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.

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