| We do not. There are so many caveats in relevant part of the human rights act. > The exercise of these freedoms, since it carries with it duties and responsibilities, may be subject to such formalities, conditions, restrictions or penalties as are prescribed by law and are necessary in a democratic society, in the interests of national security, territorial integrity or public safety, for the prevention of disorder or crime, for the protection of health or morals, for the protection of the reputation or rights of others, for preventing the disclosure of information received in confidence, or for maintaining the authority and impartiality of the judiciary. https://www.legislation.gov.uk/ukpga/1998/42/schedule/1/part... While the US has restrictions on speech, there are far far fewer restrictions. The "uncodified constitution" that we have doesn't guarantee you "Freedom of Speech" either. I've read the relevant parts of the constitution in the UK. It gives Parliamentarians the right to unlimited speech. Finally "Freedom of Expression" and "Freedom of Speech" are not the same thing. |
"This right shall include freedom to hold opinions and to receive and impart information and ideas without interference by public authority and regardless of frontiers."
As you point out, all countries have some restrictions on speech. We can obviously agree that somewhere like North Korea has no freedom of speech, in the same way we can agree the Moon is clearly outside our atmosphere. But in the margins it comes down to where you draw the line.
There's also a difference when it comes to theory and practice. In theory the US is more permissive; it lacks the ECHR's caveats that permit restricting speech to protect health, morals and territorial integrity. But in practice the US is rated as coming below the UK in the World Press Freedom Index and the Freedom of Expression Index. The US government has a lot of power to lean on organisations and individuals to stifle speech, which of course it's currently doing.