ABSTRACT
In Chapter 5, possible alternatives to criminal laws against hate speech were examined. The approach to hate speech in the US was analysed and compared to the approach of the European Court of Human Rights and it was concluded that a similar test appears to be used by the Court as the one used in the US: a clear and present danger test, which means that hate speech can be restricted without violating the right to freedom of expression of the speaker or author if there is a clear and present danger of violence occurring.
