Defamation and the Right to Freedom of Speech: The UK in Comparative Perspective (Routledge Research in Human Rights Law)

In an effort to balance the protection of reputation and the right to free speech, the UK Parliament attempted to fundamentally transform English libel law through the Defamation Act 2013.This book evaluates the success of this attempt by means of a comparative analysis of relevant law in the United States of America (US), Germany, and the European Court of Human Rights.It examines the reasons that it was deemed necessary to reform the common law of defamation in England and Wales, the changes wrought by the act, and the case law it has engendered.As defamation often occurs internationally, the book also takes a broad comparative look at the way in which other relevant jurisdictions attempt to balance reputational protection and free speech.The natural starting point is the US where freedom of expression is strongly protected by the US Constitution.From there the focus shifts to Germany where both competing legal interests are likewise given constitutional protection.The European Court