ABSTRACT
Chapter 2 provides a comparative analysis of hate speech and hate speech laws in 12 countries: Nigeria, Kenya, South Africa, India, China, the US, Japan, the UK, Turkey, Germany, Hungary and Italy. The chapter argues that some of the most important differences between countries have to do not only with how the meaning and salience of the problems of hate speech influence the policy responses to these problems but also with how that very meaning and salience are shaped by particular historical, political, legal, economic, demographic, social and cultural circumstances. In the conclusion we provide an overview of what we believe are some of the key differences in the meaning and salience given to hate speech across the countries looked at. We also make some observations on standout differences in the real function, or point and purpose, of hate speech laws across the countries. Finally, we attempt to draw out similarities or recurring patterns of hate speech, including not least the problem of the use, or misuse, of hate speech by political figures.
