[davidnu]

You don't have a free speech clause in your constitutions that is above all else (neither does the UK). You ban or at least attempt to ban questionable comedy/satire. You have ridiculous liable laws (so does the UK). You're government mustn't be allowed within a mile (1.60934 km) of an Internet governing body.

[SEMW]

> You don't have a free speech clause in your constitutions that is above all else (neither does the UK)

http://en.wikipedia.org/wiki/Article_10_of_the_European_Conv...

[davidnu2]

First it's not "above all else" seeing that it's "Article 10".

Second, the second clause basically negates the first one in its entirety:

2. 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.

The USA's first amendment of the constitutions includes no such concession nor limitations.

[SEMW]

> The USA's first amendment of the constitutions includes no such concession nor limitations

As a Brit, my knowledge of US law is limited, but that seems pretty clearly false. The exceptions and limitations are set out in case law rather than in the text of the amendment (as they are in A.10), but that doesn't mean they don't exist. http://en.wikipedia.org/wiki/United_States_free_speech_excep... lists the main ones (Miller v. California, Chaplinsky v. New Hampshire, etc.). The areas covered seem at a glance to be broadly similar to those in A.10(2).

I think it's probably true that exceptions to the US 1st amendment are narrower than those to A.10 -- the US does indeed have fairly strong free speech protection -- but that's a long way from saying there aren't any!

(I don't think I'd want free speech to be an unqualified right, either. Many of the limitations in the US and EU seem broadly sensible - obvious example: there are good consequentialist reasons for restricting the distribution of child pornography).

[polymatter]

* They aren't like Asmiov laws. The order doesn't matter. In either the Articles or the order of the Constitution. They are numbered more for convenience than anything else.

* There are similar restrictions on the US 1st Amendment. Crying "fire" in a theater is the common example. I note that the 1st Amendment didn't protect Manning for very similar reasons. The EU law is just being more explicit.

[Dylan16807]

It.. the order doesn't do anything..

[riffraff]

you are aware that "amendment" means "correction"?

That means it's the first bugfix of the constitution. There are 7 articles and a preamble before that, each of which has many sections.

[arethuza]

I think you mean libel and England and Wales rather than the UK.

[robin_reala]

To be fair, the UK doesn’t have a right to free speech in its constitution because it doesn’t have a constitution at all.