Limitations on Rights
Limitations on Specific Rights Only
  Protection from Attacks on Honor and Reputation Other Limitations on Freedom of Expression Other Specific Limitations
Constitutions
  South African Constitution (no provision) §16(2) (war propaganda; incitement of imminent violence or of harm based on racial, gender, or religious hatred) §15(3) (permitting limitation of freedoms of conscience under traditional systems of personal or family law)
French 1958 Constitution No explicit provision, but see 1798 Declaration Art. 11 (those who abuse the freedom of expression will be held responsible by law). (no provisions found) There are a number of specific limitations, noted in the relevant Chart entries.
Canadian Charter of Rights and Freedoms (no provision).  For analysis of treatment by the courts of issues related to racist incitement, protection of honor/reputation, see Schneiderman. See comment at left. (none)
Constitution of Argentina (no provision) (no provision) (no provision)
United States Constitution No explicit provision, but this sort of limitation on the Constitutional right of free speech has been explored in caselaw. E.g. New York Times Co. v. Sullivan, 376 U.S. 254 (1964). One of the key caselaw-derived limitations comes from Dennis v. United States, 341 U.S. 494 (1951) ("whether the gravity of the evil, discounted by its improbability, justifies such invasion of free speech as is necessary to avoid the danger").  Obscenity is not protected and caselaw has explored the meaning of this term. (no explicit provisions)
Constitution of India (no provision) Arts. 19(2), 31C As noted in the overview of the Indian Constitution, the definitions of most rights include specific limitations. Under Art. 33, Parliament may modify the rights of members of the armed forces.
Würzburg Key System (Key has not yet been developed) (Key has not yet been developed) (Key has not yet been developed)
International Instruments
  Universal Declaration of Human Rights Art. 12 (right to the protection of the law against attacks upon honor and reputation) Art. 7 (incitement to discrimination) (no provision)
Int’l Covenant on Civil and Political Rights ICCPR Art. 17 (right to protection of the law against unlawful attacks upon honor and reputation) ICCPR Art. 20 (propaganda for war and advocacy of national, racial, or religious hatred) There are specific limitations contained in various Articles, as noted in the relevant Chart entries.

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