Anti-Islam video clip spotlights difference in global free speech limits

The "Innocence of Muslims" video clip has fueled important debates: Should the principles of free speech apply when it comes to insulting Islam? And do differences of opinion in the United States and Middle East over the video represent an unbridgeable values gap?

In Egypt, the makers of such a video would almost certainly be charged with insulting Islam and could face years in prison. So the protesters, like many Egyptians, considered it perfectly reasonable to demand that the US government censor a film that offended Muslims – and assumed that Washington's failure to take action signaled endorsement.

"Yes, there is freedom. But there are limits," said protester Mohamed Ahmed Sayed.

But Hisham Hellyer, a Cairo-based fellow with the Brookings Institution in Washington, D.C., argues it is incorrect to portray Egyptian values regarding freedom of expression as being in total conflict with Western free speech values.

"The idea that this is a West-versus-Egypt-or-Muslim-world kind of issue isn't quite right," he says. "It's far more disputed and complex than that."

The US differs from European nations in the extent to which it protects free expression. In most European nations and Canada, expression is more limited. Hate speech, for example, which is legal in the US, is banned in many European countries and Canada. Denying the Holocaust is also a crime in some European countries.

Dr. Hellyer argues that Egypt is more like many European countries than has been acknowledged because both ban certain types of speech. Even in the US, certain speech is limited, such as slander, libel, and speech that intentionally incites violence.

"It's just that different things will be acceptable as limitable in Europe than in Egypt," he says. "Different societies will interpret some things to be sacred, and some not to be sacred."

But blasphemy laws in the Middle East are often used against minorities or those who hold unorthodox views. In Egypt, the law is vague enough to be easily abused, and the penalty is jail time, not fines.

Some Muslim societies have historically taken those limits too far, argues Nina Shea of the Hudson Institute's Center for Religious Freedom in Washington.

"By giving … power to extremists as to what can be discussed, explored, invented, written about," citizens become confined in a "suffocating chamber of dogmatism [so] that they cannot develop socially, economically, or politically," she says.

Tunisia, seen as more linked to Europe than many other Arab countries are, is an interesting case study. Tunisian police failed to stop a crowd led by Salafi activists from ransacking the US embassy and a nearby American school on Sept. 14, and later refrained from arresting a key suspect.

Tunisian authorities said they wanted to avoid violent confrontations. But they also may fear inflaming an ongoing debate over how to balance free speech with respect for Islam, says Henry Smith, a North Africa analyst at the British security firm Control Risks.

Proposals from Tunisia's moderate Islamist Al Nahda party, which heads a coalition government, to start punishing "offense to the sacred" with prison terms have sparked fierce polemic. Al Nahda has said the move is prompted by a desire to head off public anger such as that on display last week.

"Personally, I never cared about what people call 'blasphemy,' " says Tunisian Aymen Ben Abderrahmen, a university graduate who until recently taught at the American school that was attacked.

Still, Mr. Ben Abderrahmen says some limits on free speech are justified to preserve order – at least in the short term.

In Tunisia and other countries beset by unrest since their uprisings, the desire of many for stability trumps the desire for unfettered free speech.

"We can also take a longer path of making a better education for everyone and working more on cultural dialogue," Ben Abderrahmen says. "And that takes more time."