Speech is a form of expression; freedom of expression encompasses freedom of speech. To quote from the link you provided:

"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.

Neither the World Press Freedom Index nor the Freedom of Expression Index are particularly good measures of government restrictions on individual's speech.

The former includes things like how much editorial control journalists are subjected to, the right of journalists to unionize, the cost to print/distribute newspapers, whether journalists are subject to economic constraints (like being dependent on advertising money), etc.

The later is not only far more opaque in how it measures things, relying on a panel of country-specific experts, but it also more press/media related and includes things like media bias and print/media perspectives which is more about diversity of press opinion than freedom of expression (arguably, media bias shouldn't negative affect a freedom of expression index unless it is government imposed).

A more objective comparison of freedom of expression/speech would rate how the government would respond to specific instances of public and private speech - like say calling for the king/president/prime minister/etc. to be replaced, posting nudes (or going nude), blaspheme a particular religion, publishing embarrassing and reputation harming information about a celebrity/someone powerful/a judge/a religious figure, playing loud music outside, refusing to speak when ordered to by a police/judge/legislature/ruler, wearing the clothes various sexes, etc.

It might be difficult to create perfectly equivalent speech across countries, but I think one could get close enough.

I'm not sure I buy that we can entirely separate the freedoms of journalists from the freedoms of individuals; but I do like your idea of coming up with a list of criteria for measuring the freedom of speech for individuals. It seems a useful point of comparison. Where I think you'd need to be careful is in weighting the criteria.

These Indexes exist so that people (that may have an agenda) can point to it and say "well we aren't as bad as these other places" and can dismiss the actual issues that exist.

No freedom of expression is a nebulous term that was invented obfuscate the very discussion we are having. It consider it to be nothing more than weasel words.

Pointing at extreme examples like North Korea and pretending their isn't an issue because we are better them is classic whataboutism.

I also don't care about what some random index that people pull out of their backsides. I care about the legality. Freedom of Speech in the US is enshrined in the constitution. It is not enshrined anywhere in UK law.

As for the section you quoted, that is made effectively moot by the exceptions that I originally quoted.

Generally I am pretty tired of people engaging in apologia for the British state.

So your argument is that if we define freedom of speech according to US law, then only the US has freedom of speech?

I mean, I agree with you on that, but it's a circular argument.

My comparison to North Korea wasn't whataboutism; it was intended to illustrate that while there are obvious points for agreement (i.e. that the DPRK obviously has no freedom of speech), for many countries the comparison is less black and white. Which restrictions on free speech can you accept and still call it free speech?

I also respectfully disagree with you that only legality matters. If a government is actively punishing those who speak against it, even if it is strictly legal for them to do so, then I'd question whether that country is has freer speech in practice. Few developed countries have a government as hostile to the press as the current US administration!

I certainly don't align with the British government on many issues, encryption backdoors being one of them, but framing free speech as a binary is, I think, ultimately unhelpful. All countries have restrictions on speech, and drawing a line upon what is in reality a gradient over-simplifies the issue.

I personally agree that morality and territorial integrity aren't adequate reasons to restrict speech, and I'd say that a country without those restrictions has freer speech (from a legal perspective) than those with them. But again, it's a relative comparison; I wouldn't say that a country had no free speech if they did have those restrictions.

> So your argument is that if we define freedom of speech according to US law, then only the US has freedom of speech?

No. My point is that in the UK we do not have freedom of speech enshrined in constitution or law.

I believe Freedom of Expression is weasel words to obfuscate the conversation as now you have an additional legal concept in the mix, with some nebulous definition that reads like a Terms and Conditions from one of the big tech players.

That is it.

> My comparison to North Korea wasn't whataboutism; it was intended to illustrate that while there are obvious points for agreement (i.e. that the DPRK obviously has no freedom of speech), for many countries the comparison is less black and white. Which restrictions on free speech can you accept and still call it free speech?

It is the fact that it is brought up at all is engaging in whataboutism.

Why are you even mentioning NK? Why do you care what old Kim Jong does? Really think about why you are even mentioning North Korea. I don't expect or want an answer BTW.

> I also respectfully disagree with you that only legality matters. If a government is actively punishing those who speak against it, even if it is strictly legal for them to do so, then I'd question whether that country is has freer speech in practice. Few developed countries have a government as hostile to the press as the current US administration!

I don't care about the left/right slop politics. I don't care who the "villian of the week" is. Most politics is presented to you in the same way as Scooby Doo.

Why do you care about what Donald Trump is doing in the US? Please actually think about why you are even mentioning it. I don't expect (or want) an answer BTW.

> I certainly don't align with the British government on many issues, encryption backdoors being one of them, but framing free speech as a binary is, I think, ultimately unhelpful. All countries have restrictions on speech, and drawing a line upon what is in reality a gradient over-simplifies the issue

The very fact that you are making this argument about gradients of freedom, and everyone has restrictions etc. Is literally the issue. The conversation about it has been obfuscated deliberately.

I don't care what restrictions they have in France, NK, China or anywhere else. That is their business.

I care about the restrictions in the UK, why they exist and whether they are valid.

As for the encryption back-doors, why do you think they actually want to do it? GCHQ just happens to be looking for more developers BTW! I know this for a fact because I had one of their recruiters phone me. I told him what I thought about the British state and not to ever call me again.

> No. My point is that in the UK we do not have freedom of speech enshrined in constitution or law.

We do, in the Human Rights Act 1998.

Now, you've said you don't believe that the definition of freedom of expression in the HRA and ECHR lines up with your definition of free speech. That's fine. You are of course welcome to that opinion.

But you act as though your definition of free speech is authoritative, and yet you also have not defined it. When I've prompted you to narrow it down, you avoid the question.

So let me ask you extremely directly: what's your definition of "free speech"? Or to be more precise: which restrictions on speech are allowed, and which are forbidden, in order for a country to have "free speech" in your book?

> We do, in the Human Rights Act 1998.

No we don't. I've explained why. It even says in the text of the law the caveats it carves out.

But you can believe whatever fantasy you like. I am tired of trying to convince the fish that they are indeed swimming in water. The funniest thing is that until you've had it affect something/someone you like or respect, you won't change your mind.

BTW, I used to make all of the same arguments as you do btw about the Human Rights act and the ECHR etc. I realised after actually reading them, and seeing what actually happened and how the state operates, that what I believe was all bollox and I had been deceived.

> Now, you've said you don't believe that the definition of freedom of expression in the HRA and ECHR lines up with your definition of free speech. That's fine. You are of course welcome to that opinion.

It doesn't line up with any definition of free speech because it is a separate legal concept. I've already explained why they are different.

I happen to believe that legal concept is done deliberately so people like yourself will engage in this time wasting discussions about what is and isn't free expression. That is evidenced in this very discussion.

Ask yourself. If you happen to support Palestinian Action and do so publicly how long until police visit you or you are put on a watch list? Probably not long.

> But you act as though your definition of free speech is authoritative, and yet you also have not defined it. When I've prompted you to narrow it down, you avoid the question.

If I provide you with any sort of definition someone else will say "well that definition isn't correct", all of which ultimately deflects from the issue and is another waste of time.

The issue is that speech is restricted in the UK. It is done selectively. Some viewpoints are allowed by the British state and other aren't. Some of this is done directly, some of this is done indirectly.

e.g. There was a super injunction granted sometime last year to hide information about a large number of Afghan migrants / refugees / nationals being resettled after the Taliban took back control. Therefore the public, the press (little good they are) and presumably oppositional political parties couldn't scrutinise these plans. These types of super injunctions happen all the time.

What good is it that someone it is written on a piece of paper that you are legally able to have opposing view (as long as they fit inside the Overton window), when they literally hide information that is important for you to have any sort of informed view from you?

I asked you in my previous reply to go away and think about why certain narratives are presented to you. I never mentioned Trump, yet you seemed to want to talk about him without explicitly saying his name.

Someone somewhere wants you to worry about the press freedoms in the US. This is likely to distract you from more important things like the US have just landed some strategic nuclear bombers in the UK ahead of peace talks between Ukraine/Russia.

> So let me ask you extremely directly: what's your definition of "free speech"? Or to be more precise: which restrictions on speech are allowed, and which are forbidden, in order for a country to have "free speech" in your book?

It is irrelevant, I've explained why above. Any nation state will suppress your speech when it deems it to be necessary and will invent excuses as why it has to do it. That is the reality of it. How you choose to deal with that reality is your own choosing.

So allow me to summarize.

You believe that the HRA does not grant "free speech" due to some, or all, of the exceptions.

You refuse to define which specific exceptions you have a problem with, or define what you mean by "free speech", because if you did, people could argue against you.

That's all fine, but I wish you'd led with that. Next time write something like:

"I have my own definition of 'free speech' which I will not share, and according to this definition the UK has no freedom of speech."

To which the only response can be: "OK."