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  > Why did it successfully pass in UK
Among many other legal differences, the UK has no free speech guarantee.


That's hardly the full story. The UK prescribes a limited right to free expression just like other similar countries, although it is weirdly limited in several ways. Notably it's relatively easy to use the courts to prevent the dissemination of information harmful to a person or business, or even more vaguely harmful, like "incitement to hatred".

For example, take Article 10 here, https://www.legislation.gov.uk/ukpga/1998/42/schedule/1


Libel laws in the UK are way more problematic / idiosyncratic than law about "incitement to hatred", which are common (at least in Europe) and made to repress dog whistles.

edit: SLAPP suits are basically legal there, and often used to suppress speech or journalism which would be legitimate and even encouraged elsewhere.

see e.g. https://en.wikipedia.org/wiki/English_defamation_law


If you can be put in jail for hurting somebodies feelings, there is no functional right free expression.


In general? If you're looking for a jurisdiction where you'll be able to get away with saying things that upset others without limit then maybe a libertarian paradise like Somalia will suffice.


Bad take. There’s a huge difference between government and individual “upset”. One has a monopoly on force, the other has cancel culture.




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