The United States and India have their own distinct jurisprudence on freedom of speech and expression despite the similarities in constitutional provisions. Analyse. (Answer in 150 words) 10 marks

India provides for freedom of speech Article 19 (1)a provides for freedom of speech and expression reasonable restrictions. Article 19(2) provides for restriction on the exercise of these freedom eg: national security, public morality, relations with friendly nations, etc. There are other methods of restricting this freedom in India: a Section 124 A of Indian Penal Code provides for sedition on grounds of which a person can be arrested b Preventive detention (Article 32(3)) to prevent future crime c Disqualification in case of hate speech, etc under RPA 1951 However, the United States has diffused treatment of freedom of speech.

Greater freedom (as opposed to India) (section 124 A of Indian Penal Code provides for sedition on grounds of which a person can be arrested) b) Preventive detention (Article 32(3)) to prevent future crime. c) Disqualification in case of hate speech, etc under RPA 1951. However, the United States has diffused treatment of freedom of speech: d Greater freedom (as opposed to India) (sedition laws do not apply). e Religious discrimination occurs more expensive to western form of secularism. f State laws apply, not national law due to federal structure. US and India both encourage freedom of speech, but with different jurisprudence.