The United States and India have their own distinctive jurisprudence of freedom of speech and expression despite the similarities in constitutional provisions. Analyse.

US, world's oldest democracy and India, world's largest democracy have areas of convergence and divergence in implementing freedom of speech and expression. Similarities in constitutional provisions (1) Freedom of speech and expression ensured (2) Independent Judiciary to deliver those laws (3) Court history as source of privilege (4) Rule of law upheld (5) due process of law established (6) ensure courts deliver complete justice Despite the similarities, there are forms of Divergence

INDIA / US (1) Conservative - ex burning of flag not allowed / (1) Liberal - burning of flag allowed (2) Sedition (Art 124A) still there / (2) No Sedition law (3) Contempt of any court against judges / (3) allowed to criticise judges on individual level (4) jury system absent / (4) jury decides cases (5) single law to deliver justice / (5) different class and central law (6) Advisory jurisdiction / (6) Not have