Countries across the world have defamation laws in accordance with their social setup and legal system. Here’s a look at defamation laws in various countries:

India

Definition: Defamation may be by words, either spoken or intended to be read, or by signs or visible representation. Any person who makes or publishes any imputation concerning any person, knowing or having reason to believe that such imputation will harm, the reputation of such person, is said, to defame that person.

Some defences: Truth published for public interest is the best defence.

•Any expression in good faith on the conduct or character of a public servant on a public question.

•Publication of a substantially true report.

•It is not defamation to prefer in good faith an accusation against any person to any of those who have lawful authority over that person with respect to the subject matter of accusation.

•It is not defamation to make an imputation on the character of another person, provided it is made in good faith by person for protection of his or other’s interests.

Punishment: Section 500 of IPC prescribes imprisonment for a term that may extend to two years, or fine, or both.

The US

•The Government introduced the Defamation Bill, 1988. Truth was not a defence under the Bill. This Bill never became a law.

•Defamation law in the United States is much less plaintiff-friendly than its counterparts in European and Commonwealth countries.

•A defamation on the Internet could be contested in any country in which it was read. American law only allows one claim for the primary publication.

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