A look back to the 2006 Danish Cartoons crisis

Aren’t we all Charlie Hebdo? Or not?

Protesters in Paris condemn attack on Charlie Hebdo

The brutal attack against the French satirical magazine Charlie Hebdo has brought back the spectre of the “culture wars” that erupted in 2005–2006, when the publication of twelve cartoons depicting the Muslim prophet Mohamed by a Danish newspaper triggered a global wave of violence and an intense editorial debate. According to the site www.cartoonbodycount.com (no longer active), 139 people were killed in related incidents in February 2006 in countries such as Kenya, Lebanon, Pakistan, Somalia or Afghanistan.

After the murderous attack in Paris on January 7th 2014 , all newspaper sites were placed under Police protection in the French capital while authorities completed the atrocious body count: ten workers of Charlie Hebdo -including some of its most well-known cartoonists- and two policemen dead. At least three Spanish media, El País, 20 Minutos and El Huffington Post were evacuated that day under unsubstantiated alerts. And surveillance and the levels of protection were raised in the Copenhaguen headquarters of the Jyllands-Posten daily, the very same newspaper that published the Mohamed cartoons on September 30, 2005.

According to my own academic research back in 2006, while I was a graduate student at Columbia University’s Master of International Affairs, no British daily and only three out of more than 1.400 newspapers in the United States at the time -The Philadelphia Inquirer, The Austin American-Statesman and The New York Sun- published the so-called “Danish cartoons”. On this side of the Atlantic, at least 70 newspapers in some 30 European countries had published all or some of the cartoons by the spring of 2006, according to the Editors Blog published by the World Editors Forum (check the list here). Charlie Hebdo lead of course the trend in early 2006 to publish the Danish cartoons.

At the time I called it a “Transatlantic Free Speech Gap”, and it was a reversed, counter-intuitive one. Newsrooms in the land where burning the flag is legal and the First Amendment sacred -and also in the UK, Canada and Australia- restrained themselves from reprinting humorous depictions of a religious figure. “The New York Times and much of the rest of the nation’s news media have reported on the cartoons but refrained from showing them. That seems a reasonable choice for news organizations that usually refrain from gratuitous assaults on religious symbols, especially since the cartoons are so easy to describe in words,” said The New York Times in its February 7th, 2006 editorial.

In continental Europe, however -where defamation is still a crime in many penal books and the history of ethnic and religious prosecutions a living trauma-, most leading newspapers chose to reprint the controversial cartoons. Roger Koeppel, then editor of he German newspaper Die Welt, said, “We owed it to our readers. They have to understand what the fuss is about.”


Cover of Charlie Hebdo (Cabu was among the victims of the attack)

The fuss was about a fascinating debate that still haunts us: to print, or not to print. Publish and be damned… or tell, but don´t show? Can we journalists, cartoonists, editorialists make fun of the gods without fear of retribution? Should we? Back in 2006, I argued for a “strategic restraint” in the defense of free speech, against the backdrop of increasing religious fanaticism in open societies and the jihadi threat against them. I look back at the paper I wrote for professor Brigitte Naco’s class, Mass Mediated American and Global Politics, and I feel somewhat uncomfortable for not being more assertive in the defence of free speech. Period. Because we all are Charlie Hebdo.

But the debate -an informed, cool-headed one- is crucial. And the best answer, unclear. The Daily Telegraph’s decision to pixel one of the Charlie Hebdo’s covers depicting the Muslim Prophet Mohamed after the attack against the satirical magazine reheated the editorial dilema (see picture below).

The Daily Telegraph chose to pixel a Charlie Hebdo cover depicting the Muslim Prophet Mohamed

So I hope you don’t mind if I publish below the paper I wrote back then under the title: “Covering the Danish Cartoons: A Transatlantic Free Speech gap”. It includes a quantitative content analysis of the coverage of the controversy in four Anglo-Saxon newspapers -The New York Times (US), The Chicago Tribune (US), The Los Angeles Times (US) and The London Times (UK), and three continental European dailies -Le Monde (France), El País (Spain) and Le Soir (Belgium)- and most reactions of political and media leaders.

Reading them today is still interesting, and relevant, I think. I am not sure my point was right. I don’t really care. But the analysis, sources and materials I gathered could be useful to some of you. Let the debate continue. The Danish Cartoons/Charlie Hebdo topic is relevant to all of us, because the fuss -and the dead bodies in Rue Nicolas Appert- are about the very nature of freedom and democracy in this “performative” (see paper below) and militant global arena.


Note: The text below is an edited version of an academic paper written by Borja Bergareche in the spring of 2006 in Columbia University’s School of International and Public Affairs (SIPA).

Covering the Danish Cartoons: The Trans-Atlantic Free Speech Gap

I. Introduction

The chain of reactions and violence unleashed by the publication of 12 cartoons depicting the Muslim Prophet Muhammad in the Danish daily Jyllands-Posten, on September 30, 2005 has become a signature symbol of the alleged salience of cultural and religious cleavages in a globalized world. The global impact of an initially local story and the geographical spread of the protests and riots associated to the cartoons remains an intriguing, distressing development. The wide range of events associated to the publication of these cartoons taps on numerous problems and hence, many are the possible frames to describe the matter and analyze its underlying causes.

Many have argued that the cartoons themselves are not the issue, but only a galvanizer that spurred some of the defining tensions and dynamics of our time: the troubled relations between Muslim countries and the West; the Islamist challenge within Muslim societies; the survival strategies of Arab autocracies; the inability of European countries to cope with Muslim immigration; the intimidating climate surrounding the discussion of Islam etc. Thus, it is as if the cartoons acted as a mirror in which all of these questions -and many others- were reflected, turning the decision of the cultural editor of an unknown publication in a small European country into a multi-layered political and diplomatic conflict with global reach.

This paper will leave aside the intra-Muslim aspects of the controversy and the particular dynamics in the Middle East and in Muslim countries that might help understand the chain of events. It will address, on the contrary, the transatlantic differences around notions of free speech in the Anglo-Saxon and the continental European media spheres raised by the cartoons controversy. Traditional concepts of freedom of expression in the common law legal tradition tend to be much broader and unrestricted than in continental law, in which several laws are in place that limit and restrict the scope of free speech, notably in the cases of Holocaust denial, anti-Semitism and blasphemy.

The hypothesis put forward by this paper is based on the expectation that, if consistent with these different legal traditions, Anglo-Saxon media should have defended the right to publish the cartoons whereas European media should have signaled a greater willingness to self-restrict themselves.

And yet, as it will be further explained, the vast majority of American and British media refrained from republishing the cartoons, grounding their decision on sensitivity to Muslim beliefs and the editorial judgment that the issue could be explained without reprinting the caricatures. In continental Europe, the reaction was the opposite: dozens of newspapers in several European countries republished some or all of the Danish cartoons claiming the need to defend free speech and expressing solidarity with the Jyllands-Posten, in the light of the violent response against the paper.

These different reactions and editorial choices indicate a transatlantic free speech gap, but also a counterintuitive reversal of the traditional notions of free speech described. Such decisions will be portrayed as hypocritical to the extend that the accusation of bowing to fear and intimidation in the case of Anglo-Saxon media holds and, from the continental European side, to the extend that such closing ranks behind free speech and so-called “European values” hides increasing Islamophobic sentiments in the Old Continent.

From a policy perspective, this scenario reveals some fundamental challenges on each side of the Atlantic: the limits of the culture of tolerance in the face of the Islamist threat in the U.S. and the U.K., and the counterproductive impact of anti-immigration feelings in continental Europe on the struggle of moderate and liberal Muslims against Islamic fanatics. Reframing the issue from its original editorial dilemma –to publish or not to publish- into this broader policy context will lead us to the following conclusion: the most effective defense of freedom of expression requires, at this point in time, a strategic restraint in the exercise of free speech. The justification: not to feed the beast, i.e. avoid providing the only beneficiaries of the cartoon controversy -European extreme-right, Islamist groups and Arab/Muslim autocratic regimes- with new ammunition.

The materials used in this paper include stories about the Danish cartoons from September 30, 2005 until April 15, 2006 in four Anglo-Saxon newspapers -The New York Times (US), The Chicago Tribune (US), The Los Angeles Times (US) and The London Times (UK), and three continental European dailies -Le Monde (France), El País (Spain) and Le Soir (Belgium). The results were obtained by running searches for the terms “cartoons” and “Danish” on Lexis Nexis (for The New York Times, The London Times and The Los Angeles Times), ProQuest (for The Chicago Tribune) and the archives of Le Monde, Le Soir and El País yielding 624 stories, including news stories, commentaries and brief pieces.


II. A Quantitative Picture First

The main focus of this paper is qualitative. The stress will be on the content itself, using terms, phrases and ideas found on the different publications analyzed to provide evidence and describe in greater detail the free speech transatlantic gap just mentioned. However, some basic quantitative findings are necessary to obtain a better picture of the transatlantic coverage of the Danish cartoons controversy. It is interesting to note that, unlike the diverging editorial decisions, notions of free speech and justifications used, quantitative results show similar coverage patterns for the two regional groups described.

As indicated in Chart 1, the press started to pick the story only in January, with very scarce coverage in the preceding months. Important events such as the refusal of the Danish Prime Minister to receive a delegation of Muslim ambassadors (October 12th), early peaceful protests against the cartoons in Denmark (October 14th) or the Middle Eastern tour of Danish Imams in the fall, which internationalized the crisis, received very little or no attention.

Chart 1 — Monthly distribution of the coverage of the Danish cartoons (absolute terms)

The figures used on Chart 1 include news stories, commentaries/editorials and brief pieces. European outlets as El País (105 articles analyzed) and Le Monde (105 articles analyzed) printed more stories in absolute numbers about the cartoon controversy in the time frame studied than American newspapers such as The New York Times (95 stories), The LA Times (56 articles) and The Chicago Tribune (53 observations). However, a comparison of the percentage break-up of the number of stories run, including The London Times in the category “Europe,” indicates almost exactly the same pattern of coverage on both sides, as seen in Chart 2.

Chart 2 — US v. Europe: A Very Similar Pattern

With no exceptions, most of the coverage concentrates in February: 80% of the articles in European dailies and 82% in American newspapers were published in this month. Stories in October, November and December are close to 0%, and the issue died as a news story by April. This trend shows a very strong correlation between media coverage and violence. According to www.cartoonbodycount.com, violent riots and incidents directly related to the publishing of the cartoons caused 139 deaths and 823 injured. All 139 deaths occurred in February, clearly indicating that violent protests and deadly riots drove media attention.

A quantitative look at the type of stories published by a continental European newspaper (Le Monde) and an American one (The Los Angeles Times) again indicates a parallelism between Anglo-Saxon media (or American for the purposes of this particular comparison) and European dailies. Seven were the main story categories found: “Protests/Violence,” “Free speech/Media,” “Official Political Reactions in Western Countries,” “Official Political Reactions in Muslim Countries,” “Local Repercussions,” “Islam/Religion,” “Clash of Cultures” and “Denmark/Europe”. Only news stories were analyzed in this case, excluding commentaries and editorials.

Chart 3 — Type of Stories (Le Monde)

Chart 3 shows that protests and violence accounted for most of the coverage (32%), followed by the debate around free speech and the role of the media raised by the controversy (23%). Local repercussions in France were widely addressed (13%), as much as the implications in Denmark and in Europe in general (13%), referring most often to the issue of immigration and the rise of xenophobic and Islamophobic sentiments in the continent.

Chart 4 — Type of Stories (Los Angeles Times)

As Chart 4 indicates, violent riots and protests received an even wider coverage in The LA Times (37%), almost four out of ten stories. The debate about free speech deserved less attention in this case (11%) than in the case of Le Monde. The importance attached to official political reactions is greater in the case of The LA Times (20%, adding reactions from Western and Muslim countries, against 15% in Le Monde). The chart indicates a greater salience of the cultural or religious frame of the issue, with 9% of the stories dealing with Islam itself and religious aspects of the controversy, and 6% of stories addressing the so-called “Clash of Cultures” as central topic (against no articles on Le Monde about the clash of cultures as main story). Local repercussions deserved also significant attention (14%), usually referring to Los Angeles’ immigrant communities and Muslim populations.


III. A Counterintuitive Reaction: Reversal of Notions of Free Speech

Transatlantic parallelisms found on the quantitative aspects of the coverage of the cartoon story in the seven newspapers analyzed become a transatlantic gap when addressing the different notions of free speech claimed by Anglo-Saxon and continental European media. A study, if superficial, of traditional notions of freedom of expression indicate important differences between the more liberal Anglo-Saxon or Common Law sphere and the Napoleonic continental European tradition, or Civil Law system.

“In Britain and the United States we regard Free Speech as sacred,” wrote D. Guttenplan, the author of “The Holocaust on Trial: History, Justice and the David Irving Case.” Limits to free speech are rare and carefully defined under Common Law jurisprudence. The First Amendment is one of the most revered aspects of the American Constitution. As most famously described by Justice Oliver Wendell Holmes in Schenck v. United States, “The most stringent protection of free speech would not protect a man in falsely shouting fire in a theatre and causing a panic.” But besides shouting fire inside a theater, the scope of free speech is broad and almost unlimited.

According to the First Amendment Center, there are only nine categories of unprotected speech: obscenity, fighting words, defamation (including libel, slander), child pornography, perjury, blackmail, incitement to imminent lawless action, true threats and solicitations to commit crimes. Some scholars add treason, if committed verbally, to the list. This legal panorama leads the First Amendment Center to conclude that “unless restricted by a valid prior restraint (which is rare), the news media are free to publish any information or opinion they desire”, although the exercise of free speech is balanced against journalists’ liability for what they publish. “Because such liability can be staggering, most journalists strive to exercise their freedom to publish in a responsible and ethical manner.”

In Civil Law countries, the legal status of free speech is more constrained and usually regulated by laws defining the scope of legal rights related to freedom of expression. The most cited examples are laws prohibiting anti-Semitism and defining Holocaust denial as a criminal offence. Holocaust denial is illegal in ten European countries: five of them on the side of the perpetrators at the time of the Holocaust (Germany, Austria, the Czech Republic, Romania and Slovakia); three of them with a traumatic history of collaborating with the Nazis, France (Loi Gayssot of 1990), Belgium (Belgium Negationism Law, passed in 1995) and Switzerland; and Lithuania and Poland.

Laws banning hate speech, racial hatred, the denial of genocide (Spain) and blasphemy are not uncommon either. The Dutch Penal Code identifies “scornful blasphemy” as a criminal offence, restricted though to expressions regarding the Christian deity. Finland, Italy and Greece also consider blasphemy or offence of religion as a criminal offence. In Greece, the Austrian author Gerhard Haderer was convicted in absentia in 2005 for depicting Christ as a hippy in his comic book The Life of Jesus. He was given a six months suspended sentence.

The UK seems to be moving in the direction of its European neighbours since an offence of blasphemy was incorporated to English common law in 2004 and “encouragement of terrorism” became a criminal act under the controversial 2006 Terrorism Act, drafted in the aftermath of the June 7 2005 London bombings. The original wording of the legislation entailed a long, troublesome parliamentary debate for the British government when the House of Lords refused to accept “glorification” of terrorism as a criminal offence, arguing it was an unacceptable hindrance of free speech, potentially making illegal to speak in favor of Palestinian national rights.

The Terrorism Bill came into force in April, and considers the encouragement of terrorism and the glorification of terrorism as criminal offenses. However, Blair´s government has been defeated both by the House of Lords in October 2005 and the House of Commons last January in the case of the proposed Racial and Religious Hatred Bill.

In any case, these different free speech traditions would endorse the following hypothesis: in the face of the editorial dilemma raised by the Danish cartoons, it is fair to assume that Anglo-Saxon media should have been more outspoken in the defense of free speech, even by reprinting the cartoons, whereas continental European media should have demonstrated a greater willingness to give away or limit their editorial freedom. All things being equal, and assuming a consistent relation between the editorial choices of newspapers and these broader legal cultures, this would have been the expected reaction. And yet, a retrospective look indicates the opposite happened.

According to the Editors Weblog, published by the World Editors Forum (the editors branch within the World Association of Newspapers or WAN), at least 70 newspapers in some 30 European countries published all or some of the cartoons, whereas no British newspaper and only three American regional dailies (The Philadelphia Inquirer, The Austin American-Statesman, Texas, and The New York Sun) on more than 1,400 newspapers in the States published them.

These results show that the hypothesis above stated is not confirmed; on the contrary, these counterintuitive findings indicate a reversal of the traditional notions of free speech, and raise two important questions: How were the decisions to print or not to print justified on both regions? What are the real reasons behind such decisions? The answer to these two questions leads us to the qualitative media analysis of this paper and to the underlying policy and strategic considerations.


IV. To Print or Not to Print: Justifications and Transatlantic Accusations

Before newspapers, political leaders laid the ground for the intense debate surrounding the cartoon controversy. British and American politicians were unanimous in condemning their continental friends for supporting the republishing of the cartoons. Jack Straw, British Foreign Secretary, was quoted in The London Times saying: “the decision to republish the cartoons is insensitive, disrespectful and wrong”. According to Le Monde, Straw also said: “There is free speech, but there is not an obligation to insult or to be gratuitously incendiary.” A spokesman for the US State Department was quoted in The London Times arguing that, “We all respect freedom of the press but… inciting religious and ethnic hatreds in this manner is not acceptable.”

On February 8th, President Bush said: “We believe in a free press. But we also recognize that with freedom comes responsibilities. With freedom comes the responsibility to be thoughtful about others.”

The picture on the European side was more nuanced, or better, contradictory. Only the Danish Prime Minister Rasmussen consistently upheld the right to publish the cartoons of the Jyllands-Posten: “I will never accept that respect for a religious stance leads to the curtailment of criticism, humor and satire in the press”, he said according to The London Times. On the other side of the issue, his also conservative Austrian counterpart Wolfgang Schüssel, Austrian chancellor and President in office of the European Council of Ministers at the time, stated: “Neither cartoons of Mohammed not denying the Shoah have a place in a world were the cohabitation of cults should be based in respect.”

More generally, and in a typical European Union (EU) manner, messages from EU leaders were often unclear and contradictory as they tried to encompass all sides of the issue, usually compromising around the idea that “Free media are indispensable to a free and open society and to accountable systems of government. Freedoms, however, come with responsibilities. Freedom of expression should be exercised in a spirit of respect for religious and other beliefs and convictions,” as agreed by the Council of the European Union on February 27th.

The EU’s Chief Foreign Policy Representative, Javier Solana, said: “the European Union member states have a total respect for all religions and we do not want to offend anyone.” However, the President of the European Commission, Jose Manuel Durao Barroso, seemed to align himself with the supporters of free speech: “We have to stick very much to these [European] values. If not, we are accepting fear in this society.”

Even if European political leaders generally tried to assuage the consequences of the decision of European newspapers to reprint the cartoons, coming closer to their American and British counterparts, the political version of the transatlantic free speech gap was summarized by Le Monde´s Brussels correspondent:

“The reactions of Western governments and media have, in a first stage, revealed a profound cleavage between continental Europe and the United States that a later scouring has not erased. Moved by its neoconservative convictions, the Bush administration has spontaneously and clearly expressed its religious solidarity with Muslims offended by the cartoons, regretting their publication in Europe. Coming from the country of the First Amendment, in the name of which it is allowed to say and write pretty much anything one might want to say and write, much more than in Europe, it is a surprising reaction (…) On the contrary, in continental Europe, several newspapers from the Atlantic to Ukraine have published some or all the Danish cartoons and governments there have shown a much higher sensitivity to the argument of the defense of freedom of speech.”

Solidarity in France with Charlie Hebdo

On the media front, among American and British newspapers, the decision not to publish the cartoons was usually grounded on religious sensitivity, avoiding unnecessary provocations, pragmatism and the editorial consideration that the issue could be explained without printing the cartoons. In an editorial on February 7th, The New York Times argued:

“The New York Times and much of the rest of the nation’s news media have reported on the cartoons but refrained from showing them. That seems a reasonable choice for news organizations that usually refrain from gratuitous assaults on religious symbols, especially since the cartoons are so easy to describe in words.”

“We can communicate to our readers what this is about without running it,” said James O’Shea, managing editor of the Chicago Tribune, to The New York Times.The Tribune chose not to publish the cartoons “because editors decided the images inaccurately depicted Islam as a violent religion, and that it was not necessary to print the cartoons in order to explain them to readers.” In the UK, The London Times adopted a very high profile on the issue. In its editorial on February 3rd, the paper argued:

“To duplicate these cartoons several months after they were originally printed also has an element of exhibitionism to it. To present them in front of the public for debate is not a value-neutral exercise (…) On balance, we have chosen not to publish the cartoons but to provide weblinks to those who wish to see them. The crucial theme here is choice. The truth is that drawing the line in instances such as these is not a black-and-white question (…) The Times would, for example, have reservations about printing a cartoon of Christ in a Nazi uniform sketched because sympathizers of Hitler had conducted awful crimes in the name of Christianity.”

In Britain, only a few church and university publications chose to show the cartoons to their readers. In a controversial local repercussion of the issue, an Anglican archdeacon was forced to resign as editor of a Welsh church magazine, Y Llan (The Church), after publishing one of the Danish Cartoons. According to The London Times, “The Archbishop of Wales, Dr. Barry Morgan, made a public apology to Muslim leaders for any offence caused by the cartoon.”

Among the few American dailies that did publish the cartoons, the Philadelphia Inquirer’s editor, Amanda Bennett, sounded like a dissident voice when she expressed her strong disagreement with the decision of her colleagues:

“In 30 years as a journalist, I have come to believe strongly that it is better to make information available than to suppress it. Withholding information for fear of the wrath of one group nearly always means denying one group access to knowledge it needs.”

The decision of continental European newspapers to republish fully or partially the Danish cartoons was unanimously substantiated in the name of freedom of expression, European values and in solidarity with the Jyllands-Posten. This is how the man behind the whole controversy, Flemming Rose -editor of the cultural pages of the Jyllands-Posten- justified his decision:

“This is about standing for fundamental values that have been the (foundation) for the development of Western democracies over several hundred years, and we are now in a situation where those values are being challenged”.

Roger Koeppel, editor of he German newspaper Die Welt, which published the cartoons in December, said, “We owed it to our readers. They have to understand what the fuss is about.” Paolo Lepri, acting foreign editor of Corriere della Sera, said it was not a political decision: “We simply felt that you could not explain to readers why the cartoons had caused such a furore without showing them some examples by way of illustration”. Carlos Enrique Bayo, foreign editor of the Spanish daily, El Periódico, said: “We don´t normally shy away from things like this. Publish and be damned, as they say.”

Other European newspapers found other ways to express their solidarity without publishing the Danish cartoons. It is the case of Spain’s leading newspaper, El País. On its February 1st editorial, “Beware satire,” the paper said:

“Freedom of the press and freedom of expression shall not have any other restrictions than those determined by the law for all citizens, and whoever feels insulted or slandered has the right to go to Court, the only instance where these conflicts should be settled.”

El País did not publish the 12 Danish cartoons, but reproduced instead a cartoon by Plantu –the well-respected Le Monde cartoonist- on its February 3rd front page that included a drawing of the Prophet. As explained by the papers ombudsman, the editor of El País at the time, Jesús Ceberio, refused to publish the Danish cartoons, especially the one with the bomb on Muhammad’s turban, because “they can be understood as a criminalization of all Muhammad followers and more than one billion people might be offended”. However, he justified the publication of Plantu’s caricature as been “satiric” but “respectful,” arguing that he did not feel bound by the Islamic prohibition of iconic representations of the Prophet, “as long as the image is not ridiculized.”

Plantu himself was quoted in Le Monde saying:

“There is more and more a capstone over press cartoonists and humorists when it comes to religion. People do not realize the extend to which -excluding the Catholic church, on which one can tap- it has become impossible to criticize religion men”.

The transatlantic differences of editorial judgment found between Anglo-Saxon media and continental European newspapers quickly escalated into an exchange of accusation from both shores. In the US and the UK, several journalists and columnists criticized the decision to republish the cartoons as offending and insensitive. The Chicago Tribune, for example, said in its February 8th editorial:

“Angry Muslims demanded an apology. What they got was a simplistic defense of the right to free expression (…) All of this indignant posturing overlooks the fact that nobody´s stopping editors from publishing whatever they wish. Freedom of speech, after all, means freedom from government sanction not freedom from angry reactions by your readers.”

On The Los Angeles Times, Gregory Rodriguez wrote a commentary making the following provocative and insightful point:

“So far, only a handful of American newspapers have chosen to publish the offending cartoons of Muhammad. It´s not that we believe in freedom of speech any less than the Danes, but we are infinitely more attuned to the tensions between that freedom and the realities of a diverse society.”

The answer from the continent was also coined in expressive terms. Le Soir, for example, run the following headline in a story about another of the very few British papers that published the cartoons, Gair Rhydd, a Welsh free weekly published by the students union at the Cardiff University. “English newspapers are all afraid of Muhammad.” The editor of Gair Rhydd, Tom Wellingham, was suspended by the union under accusations of being an “enemy of Islam.”

Probably the most outspoken critic of those media that refused to show the cartoons was Ayaan Hirsi Ali, the Muslim, Somali-born member of the Dutch parliament, also known as “the Voltaire of Islam.” A speech she gave in Berlin on April 29th was widely echoed in European newspapers:

“Shame on all newspapers and TV channels who have not had the courage to show their audiences what was at stake with the “cartoon affair”! Intellectuals who make a living out of freedom of expression, but now accept censorship hide their mediocrity of mind behind grandiloquent terms such as “responsibility” or “sensitivity.”


V. Behind the Headlines: Culture Talk, The Price of Tolerance and the Battle of Europe

Two were the most appealing superficial frames to cover the controversy surrounding the Danish cartoons: free speech v. hate speech and, in its more dramatic version, the cultural chasm between secular Western societies and Islam. Indeed, the issue was clearly cast as a free speech problem by Muslim radicals protesting in London, in a placard shown in a demonstration that said: “Freedom of Expression Go to Hell.” In a more nuanced manner, The Los Angeles Times portrayed the story as follows on February 3rd:

“Debate over the drawings, which were first published in September by a Danish newspaper, is being seen as a collision between freedom of expression and religious sensitivities in European nations, where Muslim populations have struggled to fit in.”

But beyond the more specific frame of the conflict between free speech in a secular society and religious sensitivities, it seemed unavoidable to find several articles and phrases alluding or quoting directly the notion of clash of civilizations. Thus, Le Soir had the following headline on April 30: “Cartoon war or war of civilizations?” The London Times seemed especially keen on stressing the idea of a cultural war. “The trigger for the latest clash of cultures was the publication by the Danish newspaper Jyllands-Posten on September 30 of 12 cartoons of Muhammad.”In an editorial on February 3rd, the paper said: “The cultural chasm has, if anything, grown in the past 20 years.

The lead paragraph of a story on the Chicago Tribune on February 7th replicated this analysis, with an aggravating factor: the reporter, conscious or unconsciously, establishes a particularly discriminating differentiation using the plural on “Western cultures” and the singular on “Islam,” therefore portrayed (conscious or unconsciously) as a monolithic, immutable cultural block.

“The violent and now deadly protests rippling through Asia and the Middle East over the publication of caricatures o the Prophet Muhammad reflect a larger schism and lack of understanding between traditional Western cultures and Islam, experts said Monday.”

Resorting to the alleged cultural wars between the West and Islam is a tempting narrative for journalists when attempting to provide an explanatory frame for the certainly astonishing and distressing consequences of the Danish cartoons. But the Culture Talk, as defined by Columbia professor Mahmood Mamdani, is both intellectually lazy and journalistically inaccurate as an explanatory framework, and fails to capture important underlying challenges exposed by the cartoon controversy.

Instead of portraying the cartoon saga as the latest chapter on Huntington´s “clash of civilizations,” it is more revealing to see the caricatures as a mirror that reflected, among other things, very disturbing underlying dynamics both in continental Europe and in the US/UK. Is the Anglo-Saxon multicultural model paying the price of tolerance, silenced and bowing to the intimidation of Islamist radicals? Will Europe´s hypocritical defense of the right to make fun of (the Muslim) god and its inability to adapt itself to the presence of European Muslim communities make it an involuntary ally of Muslim fanatics?

These issues are at the heart of the ultimate dynamics mirrored by the Danish cartoons in Europe and in the United States. And even if they were often silenced by the preferred culture talk, they did not go unnoticed in the newspaper stories analyzed.

In the case of continental Europe, the cartoon controversy occurred against the background of an increasing anti-immigration climate, Denmark itself being one of the most salient examples. The imbalance between the legal protection of Judaism and the Holocaust compared to the clamor that reminded Muslims they ought to accept the price of free speech was the main argument behind accusations of hypocrisy against European media and political leaders. The argument was usually raised by European Muslims themselves as a way to synthesize their grievances and feelings of being discriminated.

The abuse of the cartoon issue by European religious conservatives and extreme-right parties, in this increasingly vocal anti-Muslim climate, raises important questions about the real motivations of some of those who so emphatically closed ranks behind free speech. The connection between the publishing of the Prophet’s caricatures and Europe´s inability to manage immigration and adapt itself to the presence of Muslim communities in European societies was, first of all, in the mind of the man behind the cartoons, Flemming Rose, who was quoted by The New York Times saying:

“People are no longer willing to pay taxes to help support someone called Ali who comes from a country with a different language and culture that is 5,000 miles away.”

250,000 Muslims or 5% of the population leave in Denmark, a highly secularized country of five million people in which only 3% of its citizens attend church once a week. Since the conservative government lead by Prime Minister Rasmussen came to power in 2001, immigration policies have been considerably toughened. The symbol of the Danish domestic debate about immigration is the controversial “24-years rule,” by which Danish citizens cannot obtain living permits in Denmark for their foreign spouses if either of the parties is under 24. The new laws include an “attachment criteria” to be fulfilled by Danish-foreign couples, showing that their common attachment to Denmark is greater than their attachment to any other country.

The Human Rights body of the Council of Europe has long criticized Denmark for its immigration policies, concluding in 2001 that “over-generalisations and misperceptions about Islam are promoted by public opinion leaders, including political elites from across the political spectrum, intellectuals and journalists.” The (former) High Commissioner for Human Rights of the Council of Europe, Alvaro Gil-Robles, criticized the Danish government’s proposal of replacing “Religious instruction” at school by “Christian studies”.

Even the arts in Denmark have become involved in this discussion after the Danish Minister for Culture, Brian Mikkelsen, announced in December 2004 a plan to compile a “cultural canon” of 2500 years of “Danish history” with the goal -among others- of strengthening “the sense of community by showing key parts of our common historical possessions.” The Minister has made his intentions very clear:

“We aren’t afraid to say that some things are better than others. I want to start a debate on values, about quality, about our cultural heritage and what it means to be Danish in a time when the national state is under pressure and globalization hovers above us,” said Mikkelsen.

In this scenario, it is not surprising that many European Muslims and several American and British commentators accused Europeans of saying free speech when in fact they meant Islamophobia. In a commentary in The London Times, David Aaronovitch said:

“I do know that an anti-immigrant strand has taken hold there in recent years, that Danish citizenship laws are some of the most discriminatory in Western Europe, and I would guess that this right-wing newspaper, Jyllands-Posten, has something invested in the idea that the cultures might be unassimilable. Certainly it was being mischievous. It was interesting to discover yesterday that in 2003 the same paper refused to print some cartoons featuring Jesus, on the basis that (according to the editor): “I don´t think Jyllands-Posten’s readers will enjoy the drawings. As a matter of fact, I think that they will provoke an outcry. Therefore, I will not use them.”

If a group of French writers stressed the right to blasphemy in a manifesto, saying, “It is not only about the freedom to be wrong. The truth is that we are free to blasphemy,” Gamal Ghitani, an Egyptian writer and editor of the culture magazine of Al-Akhbar, one of Egypt´s main newspapers, argued:

“European laws ban, with the threat of prison, all anti-Semitism, any denial of the Shoah and any racist action or intent. Why are irony and the offence against the prophet of a religion embraced by more than a billion people in the world allowed?”

Olivier Roy, a French Islam specialist, wrote in Le Monde:

“Freedom of expression is in every Western country already limited, by two things: the law and a certain social consensus (…) But there is equally a very variable tolerance threshold in public opinion (…) No big newspaper would publish cartoons that ridicule blind people, dwarfs, homosexuals or gypsies, more by fear of bad taste than judiciary prosecution. But bad taste is fine with Islam because public opinion is more permeable to islamophobia (which often hides in fact the rejection of immigrants)”

The accusation of hypocrisy was especially common among European Muslims themselves. In an interview in El País, Lahj Thami Breze, chairman of the Union of Islamic Organizations of France, the largest Muslim organization in France, said:

“We don´t understand why only Judaism is legally protected.[42] We think other religions deserve the same treatment. If we don´t get it, we will be forced to acknowledge, against common wisdom, that Muslims are treated as second class citizens, with lesser rights than others.”

The best indicator that Muslims and immigrants have increasing difficulties in integrating successfully in European countries is the rise of extreme-right parties. The case of the Nordic countries, traditionally perceived as a beacon of progressive and tolerant policies, is notoriously disturbing. In Denmark, the Danish People´s Party obtained 13.2% of the votes in the February 2005 elections, and is a key parliamentary ally of the Rasmussen government. In Norway, the Progress Party (extreme-right) became the main opposition force after the September 2005 elections, with 22.05% of the votes. An article in Le Monde said:

“The Danish People’s Party (DF), a fundamental ally for the liberal-conservative government in parliament, misses no opportunity to feed the fire. Louise Frevert, DF’s candidate for Major in Copenhagen, compared Muslims to a cancerous tumor and portrays Muslim males as potential rapists.”

The article gathered some priceless statements by extreme-right politicians in Europe. According to Le Monde, Roberto Calderoli, Lega Norte, Berlusconi´s Minister of Institutional Reform, declared to La Republicca:

“The Pope must intervene like Pius V and Innocent XI did. At the time of the battle of Vienne and the battle of Lepanto (against the Turks in 1683 and 1571), the popes took the place of governments and created broad coalitions to defeat the islamist danger.”

Belgium has been especially sensitive to the rise of European extreme-right for years, where the Vlaams Belang (a Flemish xenophobic party) is the most voted force in one of Belgium´s most important cities, Anvers. A commentary in the Belgium newspaper Le Soir summarized the issue, referring to a “nativist Europe”:

“There is another Europe that claims as well the ‘European values’ in order to declare itself superior to others and to lift the drawbridge. A nativist Europe that votes Vlaams Belang or Lega Nord [xenophobic, extreme-right parties], keeping watch behind the barbed wire at Ceuta and Melilla, ‘where the enemy will come from.’ A Europe of darkness.”

From a policy perspective, a clear link between editorial decisions about religious topics, immigration policies and the Islamist threat emerges. Therefore, the deeper issue mirrored in the debate around the publishing of the Danish cartoons in continental Europe is how will defenses of free speech perceived as hypocritical by Muslims (moderate and radicals) and the increasing Islamophobic trends among a nativist Europe that rattles the saber of “European values” against immigrants impact the struggle of liberal and moderate Muslims against fanatics highjacking their creed. Gilles Keppel, the French intellectual, speaks of The Battle of Europe:

“We are here at the heart of the battle of Europe: will European populations of Muslim descent be the driving-force for democratization in their countries of origin, via the example of their integration and success in liberal and pluralist societies, or will they, on the contrary, be held hostage by those –authoritarian regimes in the Muslim world or islamist movements- who try to use them as Trojan horse to destabilize the Old Continent by worsening religious antagonisms?”

In this context, European governments, especially in the case of France, have tried to foster the development of a “European Islam,” and not just an “Islam in Europe,” to advance the position of moderate European Muslim organizations working to make secularism and Islam compatible and protect them from the interference of more radical groups, usually supported and funded by Islamist groups and governments from the Middle East and the Persian Gulf.

More than ever, Middle Eastern politics have become a domestic issue in Europe. It is obvious that this Middle East-Europe dynamics have played a crucial role in the cartoon controversy. As Olivier Roy argued in Le Monde, “Arab regimes, in fact, have always tried to maintain immigration to Europe as a diaspora, to be mobilized for the national cause.” In the same article, noticing that mainstream European Muslim organizations tried to distance themselves from the cartoon controversy, he concluded:

“It is in the sense of this disconnection between European Islam and crises in the Middle East that we ought to seek the key to manage these inevitable tensions and to treat European Muslims as citizens, just as we do with Christians and Jews, even if we have to recall regularly the principles of freedom of speech and secularism.”

In the Anglo-Saxon context, policy considerations raised by the Danish cartoon debate relate to the presence of fear and intimidation in the discussion about Islam in the US and in the UK, stressing the limits of the traditional culture of tolerance in the face of the Islamist challenge. Many asked themselves: Has the mob won? Beyond the more violent reactions in Muslim countries, the climate of intimidation was palpable in some of the demonstrations that took place in London, where some protesters chanted, to mention a few examples: “UK go to hell, UN go to hell, Kill Denmark,” or “Bin Laden is coming back.”

But the ones that caused the greatest outrage among the British population were banners praising the “Fab four,” in a reference to the four British-born suicide bombers who killed 52 people in the London terrorist attacks of July 7th, 2005.

On the record, justifications for the almost unanimous decision not to publish the cartoons revolved around the ideas of respect, pragmatism and avoiding unnecessary provocation. But some of the articles analyzed leaked some deeper, underlying motives, less benign than originally intended. The London Times mentioned the need diplomatic to alleviate tensions with the Islamic world:

“No main US publication has published the images as politicians in Washington seek to repair their reputation in the Islamic world by criticizing Western governments that back the showing of the cartoons.”

But the idea that many editors meant fear when they claimed respect was also present to different degrees in Anglo-Saxon newspapers. “No British newspaper reprinted the cartoons, perhaps mindful of the Rushdie affair and the communal anguish that followed the London bombings last summer,” said The London Times. Andrew Sullivan, a columnist for the London paper, made the point crystal clear:

“The one argument you haven´t heard is the one off-camera. Many editors simply don´t want to put their staffs at risk of physical danger. They have “offended” Muslims in the past and learnt to regret it.”

In the US, Charles Krauthammer, a Washington Post columnist, was reproduced in The Chicago Tribune:

“What is at issue is fear. The unspoken reason many newspapers do not want to republish is not sensitivity but simple fear. They know what happened to Theo van Gogh, who made a film about the Islamic treatment of women and got a knife through the chest with an Islamist manifesto attached”

Ayaan Hirsi Ali, the liberal Dutch politician, knows what happened to Dutch filmmaker Theo van Gogh well. She was the author of the script of “Submission,” Van Gogh’s film about violence against women in Islamic societies that got him murdered. In her Berlin speech, she said:

“The publication [of the cartoons] allows us to confirm that there is a feeling of fear among writers, film makers, cartoonists and journalists who want to describe, analyze or criticize those intolerant aspects of Islam across Europe”

If this climate of fear and intimidation is the true reason for the surprisingly unanimous decision not to reprint the caricatures among American and British media, many are worried that this benevolent self-constraint in the name of religious respect and tolerance entails a naïve defeat against Islamist radicals who have launched a wild offensive against liberal values in the West and in Muslim countries. “Has the mob won?” read a letter to the editor by Ed Letchinger on The Chicago Tribune:

“It is surprising to me that these items [the cartoons], which supposedly were so incendiary and insulting, cannot even be seen by most Americans, and that out newspapers have chosen to censor them. Apparently press freedom does not extend to anything that arouses mob violence in the Islamic world. Has the mob won?”

Krauthammer made a similar point in his column about “the curse of the moderates”:

“The Mob has turned this into a test case for freedom of speech in the West. The German, the French and Italian newspapers that republished these cartoons did so not to inform but to defy –to declare that they will not be intimidated by the mob.”

From a broader perspective, just as continental Europe faces what Keppel has described as the Battle of Europe, the possibility that “the mob”, i.e. Islamist radicals, have defeated liberal values creating a suffocating climate of fear and intimidation among politicians, journalists, academics and intellectuals exposes the potentially self-defeating danger of the culture of political correctness in multicultural societies. In a commentary on The London Times, Minette Marrin argued:

“Until recently, the doctrine of multiculturalism reigned supreme here. For at least 15 years public services and the liberal media have been riddled with the idea that all cultures are equally deserving of respect, and that the values of the host culture are not supreme, but on the contrary rather racist and oppressive (…) The tragedy is that what they are now getting from the rest of us is not respect at all, but fear, posing as respect.”

Have the Danish cartoons unveiled the price of liberal tolerance? An article in The Times titled “An end to tolerance” mentioned this possibility:

“It is a hoary old cliché to say that British society is tolerant and forgiving, but by and large it happens to be true (…) Now, perhaps, we are paying the price of that unthinking tolerance. Amir Tahiri, the eminent Iranian writer, argues in this newspaper today that Britain has become a haven for Islamic political parties and movements that would be banned in much of the Arab world (…) The [British] public is deeply disillusioned with the way the Establishment appears to appease Islamic extremism. Two-thirds think senior policemen such as Sir Ian Blair, the Metropolitan commissioner, are too “politically correct” to deal toughly with extremists”

In a debate about “Idols and Insults: Writing, Religion, and Freedom of Expression” recently organized by the Pen Club in New York, Hirsi Ali warned the audience: “A society that does not protect the lives of people who are devoted to criticizing ideas (religious or other) is doomed to become a tyranny.”


VI. Conclusions on Free speech: The Case for Strategic Restraint

The analysis of the coverage of the Danish cartoon saga in seven newspapers confirms the existence of a transatlantic free speech gap. Miklos Haraszti, the Media Freedom Chief for the Organization for Security and Cooperation in Europe (OSCE), said about the cartoons debate:

“In fact, we could almost speak about a hate-speech definition gap. One of them is Trans-Atlantic, because Europe and the United States/Canada have quite a dissimilar philosophy of what is hate speech and how it should be regulated, curbed.”

Traditional debates about the nature of limitations to freedom of expression -whether it is the law only, the law and social consensus or whether limits extend to other considerations such as cultural/religious sensitivity- have become more acute and anxious in a time of salient cultural, religious and “civilizational” sensitivities. There are two traditional positions on the debate: the absolute defense of free speech as an inherent component of secular democracies (predominant in continental Europe) and the self-restraint on the use of free-speech in the name of multiculturalism and liberal tolerance in Anglo-Saxon countries.

Robert Menard, secretary general of Reporters without Borders, embodied the first position when he declared to The New York Times: “I understand that it may shock Muslims, but being shocked is part of the price of being informed.”

On the other side of the issue, Gregory Rodriguez argued in The Los Angeles Times that there is no such thing as free speech in multicultural societies:

“Every time we open our mouths, write an article or draw a cartoon, we weigh the costs and consequences. Because we live in an extraordinary heterogeneous society, Americans know this truth instinctively, if not consciously. Social etiquette dictates that we don´t discuss religions or politics at a dinner party for fear of giving offense or inciting argument. Even before the invention of political correctness, we tended to be conscious of offending those from different background.”

As the cartoon issue showed, the dilemma for newspaper editors is not only an intellectual choice but a decision that belongs to the day-to-day life in a press room: To print or not to print? To provoke or not to provoke? Publish and be damned or tell, don´t show? Andrew Sullivan in The London Times was very critical of the decision of British and American papers not to show, and posed a question about the role newspapers play in this context of exacerbated cultural and religious sensitivities waiting to be provoked to burst in anger:

“What are you to think? You´d think, wouldn´t you, it might be helpful to view the actual cartoons so you can see what on earth this entire fuss is about. But the British and American media have decided that it is not their job to help you understand this story. In fact, it is their job to prevent you from fully understanding this story. As of this writing no major newspaper in Britain has published the cartoons; the BBC has shown them only fleetingly and other networks have shied away.”

It is not an easy choice. A revision of the positions around the cartoon controversy indicates that the answer is not giving up a fundamental value such as free speech, bowing to the climate of fear and intimidation imposed by Islamist radicals, even if it is justified –as it was by American and British media- by allegedly benign and well-intentioned motives such as respect for diversity and religious sensitivity. However, the answer to the dilemma is not a hypocritical defense of the right to publish offensive materials if this stance, conscious or unconsciously, aggravates a climate of Islamophobia and anti-immigrants in Europe and benefits the enemies of liberal values, European extreme-right parties, radical Islamist groups and Arab/Muslim autocracies such as Libya, Syria, Egypt, Saudi Arabia Iran or Pakistan.

Any attempt to answer the question raised by the cartoon controversy -to publish or not to publish- should take into account that the controversy has clearly shown that we have moved from a “discoursive” political environment to a “performative” global arena, using the words of Nilüfer Göle (a Turkish-French sociologist), in which actions such as burning a consulate and images such as a caricature of Muhammad have become powerful political and ideological messages with global reach and geostrategic consequences.

Moreover, the unprecedented reactions to the publication of the cartoons –even if they often responded more to domestic political dynamics in Arab/Muslim countries- indicates, from a Western perspective, that our societies might not be as secular as we thought due to the increasing return to religious feelings among increasing Muslim communities –especially in Europe, but also because of the rising presence of religion among conservative politicians in the US and in Europe. The decision to publish 12 cartoons by a Danish newspaper in an environment that combines highly sensitive, discriminated Muslim minorities and openly Christian-based conservative politicians in power triggered a fantastic global uproar, and brings up the possibility that the principle -or myth- of secularism should be revised.

Does Islam deserve a special treatment? The principle of a cultural exception already exists in some legal and administrative frameworks in Britain and in continental Europe, allowing for exceptions to the general rule in the presence of unassailable religious norms. But the British journalist Melanie Philips, author of a controversial book, Londonistan, has warned against the creeping presence of sharia in Europe itself. In a recent interview in Foreign Policy, she said:

“[Sharia] is already creeping in. In Britain, it´s been tolerated. It´s part of the salami slicing that´s going on, so the bits –like Islamic banking- that don´t appear to cause a problem to the majority are being encouraged (…) There are people in Britain who think that within 10 years, we will have enclaves where there will be sharia, a kind of separate, parallel jurisdiction.”

The goal is the emergence of a Western Islam that neutralizes the alleged incompatibility between the Muslim faith and liberal democracies and beams a positive example to other Muslims with their successful integration in secular democracies. The answer is not to permit the development of Muslim ghettos in Western societies, event though such a risk is already in place.

All these issues considered, the answer to the Islamist threat against liberal values ought to be the defense of those values, notably free speech. But it should be a strategically-guided defense, acting not on the basis of matter-of-fact principles but aware of the consequences of editorial decisions. Such a strategically-guided defense of free speech entails a strategic constraint in the exercise of freedom of expression. Such conclusion is justified by the painful, but advisable, need to align editorial decisions with the most urgent geostrategic need the world faces: helping Muslim moderates and liberals in their struggle for a tolerant Islam, and the need to avoid feeding the beast with decisions such as the re-publication of the cartoons of the Muslim Prophet, immediately and skillfully used by radical Muslim activists and priests to serve their cause and win the hearts and minds of Muslims.

In Le Monde, Haddad, a Lebanese-born French cartoonist of Al-Hayat (an Arab paper published in London), made the same point:

“In the current situation, I wonder who benefits from all this. In the Arab countries, laics are in withdrawal everywhere. With this kind of scandal, I can assure you that fundamentalists are rubbing their hands together. I am not a religious person. But I do not draw about religion. Because I think that the real problem in our countries are injustice, poverty and violence. That is what nurtures terrorism.”

Rushy Rashid, a Muslim, Pakistani-born Danish expert on dialogue of religions said in El País:

“Millions of Muslims across the world have said: this is the evidence that the West oppresses us, offends us; this is the evidence of the failure of Western democracies, of the hate of Western democracies towards us; Western democracies allowed this, now we have the evidence, our Prophet was insulted, we have to do something.”

It is not the first time, and it will not be the last one, that the exercise of our dearest values is voluntarily constrained. But in the present situation, and in the aftermath of the cartoon controversy, the strategic restraint in the exercise of freedom of expression, notably in relation to Islam, is the best way to protect our values as they face the dangerous threat of Islamist fanatism. Craig S. Smith noted a useful comparison in The New York Times:

“In the current climate, some experts on mass communications suggest, the exercise was no more benign than commissioning caricatures of African-Americans would have been during the 1960s civil rights struggle.”

The specific features and implications of this strategically restrained defense and exercise of freedom of expression remain to be addressed and detailed, acknowledging that it is more about a temporary self-restraint than about legalizing the issue with new bills on freedom of expression and hate speech, a much more dangerous path. The issue will have to be dealt with further research and reflection, maybe in another paper.


[1] www.cartoonbodycount.com “The integrity of our information is based on news source credibility as well as wholistic reasoning by our editors (…) Incidents qualify under certain criteria, the most important being common sense. The easiest way to tell, of course, is when an incident is directly incited by anger over the cartoons. (…) It is also evident in what we don’t post. Incidents that have clearly unrelated primary stimuli are not considered, even though they may be happening on the fringes of the debate.”

[2] One deadly incident included by cartoonbodycount.com, occurred in “some boat”, is not shown on the table for its unclear location.

[3] D. Guttenplan, “How Many Jews Does It Take…?” Index of Censorship, issue 2/2005

[4] First Amendment: “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances.”

[5] http://www.firstamendmentcenter.org/Press/faqs.aspx?faq=freedom_of_press

[6] Article 147 of the Netherlands Penal Code

[7] In Greece, the Austrian author Gerhard Haderer was convicted in absentia in 2005 for depicting Christ as a hippy in his comic book The Life of Jesus. He was given a six months suspended sentence.

[8] Encouragement of Terrorism: “This section applies to a statement that is likely to be understood by some or all of the members of the public to whom it is published as a direct or indirect encouragement or other inducement to them to the commission, preparation or instigation of acts of terrorism or Convention offences.” Available from http://www.opsi.gov.uk/acts/acts2006/20060011.htm

[9] “For the purposes of this section, “indirect encouragement” comprises the making of a statement describing terrorism in such a way that the listener would infer that he should emulate it,” ibid.

[10] “Media Geopolitics of the Mohammed Cartoons,” The Editors Weblog, 15 February 2006, as available from: www.editorsweblog.org/analysis//2006/02/how_many_newspapers_published_mohammed_c.php#more

[11] “Gathering storm as protests hit Britain,” The Times, 4 February 2006 p. 1

[12] “La polémique sur les caricatures de Mahomet divise l’ Occident,” Le Monde, 05 February 2006

[13] “Gathering storm as protests hit Britain,” The Times, 4 February 2006 p. 1

[14] “Freedom v. Faith: The Firestorm,” The Times, 5 February 2006, p. 16

[15] The Council of the European Union officially declared: “Freedom of expression is a fundamental right and an essential element of a democratic discourse, with an independent judiciary as a safeguard mechanism. Free media are indispensable to a free and open society and to accountable systems of government. Freedoms, however, come with responsibilities. Freedom of expression should be exercised in a spirit of respect for religious and other beliefs and convictions. Mutual tolerance and respect are universal values we should all uphold.” Council of the European Union (Brussels), 27 February 2006, as available from http://ue.eu.int/uedocs/cms_Data/docs/pressdata/en/gena/88536.pdf

[16] “Les fractures de l’affaire Mahomet,” Le Monde, 21 February 2006

[17] “Those Danish Cartoons,” The New York Times, 7 February 2006, p. A 20

[18] “US Says It Also Finds Cartoons of Muhammad Offensive,” The New York Times, 4 February 2006, p. A. 3

[19] “Why cartoons sparked furor…,” The Chicago Tribune, 7 February 2006, p. 1

[20] “Drawing the line,” The Times, 3 February 2006, p. 23

[21] “Editor of church magazine quits over cartoon,” The Times, 22 March 2006, p. 31

[22] “This is not just about cartoons, but standing up for our values,” The Times, 1 February 2006, p. 37

[23] “This is not just about cartoons, but standing up for our values,” The Times, 1 February 2006, p. 37

[24] “Las imágenes de Mahoma,” El País, 5 February 2006, p. 18

[25] “Dieu, Mahomet et les dessinateurs,” Le Monde, 3 February 2006

[26] “No Such Thing as Free Speech,” The Los Angeles Times, 12 February 2006, p. M5

[27] “Les journaux anglais ont tous peur de Mahomet,” Le Soir, 30 April 2006

[28] “Je suis une dissidente de l’Islam,” Le Soir, 30 April 2006

[29] “Anger over Cartoons of Muhammad Escalates,” The Los Angeles Times, 3 February 2006, p. A1

[30] “Denmark faces internacional boycott over Muslim cartoons,” The Times, 31 January 2006, p. 29

[31] “Drawing the line,” The Times, 3 February 2006, p. 23

[32] “Why cartoons sparked furor…,” The Chicago Tribune, 7 February 2006, p. 1

[33] “Culture Talk assumes that every culture has a tangible essence that defines it, and it then explains politics as a consequence of that essence,” Mahmood Mamdani, Good Muslim, Bad Muslim (New York: Pantheon Books, 2004), p. 17

[34] “Cartoon Dispute Prompts Identity Crisis for Liberal Denmark,” The New York Times, 12 February 2006, p. A. 22

[35] In the Second Report on Denmark of the European Commission against Racism and Intolerance (Council of Europe), made public on April 3 2001, the Commission said: “Muslims are particularly vulnerable to racism and discrimination in Denmark. Negative stereotypes and prejudices about Muslims as well as over-generalisations and misperceptions about Islam are promoted by public opinion leaders, including political elites from across the political spectrum, intellectuals and journalists. This anti-Muslim climate leads to intolerance and discrimination directed towards members of this group in various spheres of life, especially as regards access to the labour market, housing and public places. Muslim women wearing veils reportedly experience hostility on streets and buses and particular discrimination in the labor market, such as being refused jobs in the service sector in roles involving interaction with customers.”

[36] Danish Minister of Culture, as available from http://www.kum.dk/sw37439.asp

[37] “What does it mean to be Danish?” The Copenhagen Post online, 12 December 2004.

[38] “Restraint, please…,” The Times, 7 February 2006, p. 18

[39] “Les écrivains faca à la caricature,” Le Monde, 14 February 2006

[40] “Un journal danois s’excuse pour avoir ‘offensé’ les musulmans,” Le Monde, 1 February 2006

[41] “Caricatures: géopolitique de l’indignation,” Le Monde, 9 February 2006

[42] Under the 1990 French law that bans anti-Semitism and xenophobia, Holocaust denial carries a penalty of 45,000 euros and one year of prison.

[43] “No entendemos por qué…,” El País, 19 February 2006

[44] “Des dessinateurs danois menacés pour leurs caricatures de Mahomet,” Le Monde, 18 October 2005

[45] “Des dessinateurs danois menacés pour leurs caricatures de Mahomet,” Le Monde, 18 October 2005

[46] “Le choc des Europes,” Le Soir, 30 April 2006.

[47] “Europe en nouveau ‘grand Satan,” Le Monde, 11 February 2006

[48] “Caricatures: géopolitique de l’indignation,” Le Monde, 9 February 2006

[49] “Caricatures: géopolitique de l’indignation,” Le Monde, 9 February 2006

[50] “Gathering storm as protests hit Britain,” The Times, 4 February 2006 p. 1

[51] “Freedom v. Faith: The Firestorm,” The Times, 5 February 2006, p. 16

[52] “Islamo-bullies get a free ride from the West,” The Times, February 12 2006, p.4

[53] “Curse of the Moderates: How to endorse the goals of the mob without endorsing its means,” The Chicago Tribune, February 13 2006, p. 21

[54] “Je suis une dissidente de l’Islam,” Le Soir, 30 April 2006

[55] “Cartoon Controversy,” The Chicago Tribune, 19 February 2006, p. 8

[56] “Curse of the Moderates: How to endorse the goals of the mob without endorsing its means,” The Chicago Tribune, February 13 2006, p. 21

[57] “Muslims are trading respect for fear,” The Times, 12 February 2006, p. 16

[58] “An end to tolerance,” The Times¸ 12 February 2006, p. 16

[59] The New School Tishman Auditoriumm, New York City, April 29th 2006.

[60] “OSCE Media Freedom Chief Discusses Hate Speech,” Radio Free Europe, 30 March 2006

[61] “More European Papers Print Cartoons…,” The New York Times, 2 February 2006, p. A. 12

[62] “No Such Thing as Free Speech,” The Los Angeles Times, 12 February 2006, p. M5

[63] “Islamo-bullies get a free ride from the West,” The Times, February 12 2006, p.4

[64] A famous example being the exemption from the obligation to wear a helmet for British policemen and postmen of Sikh religion.

[65] “Minority Report,” Foreign Policy, May/June 2006, p.19

[66] “Dieu, Mahomet et les dessinateurs,” Le Monde, 3 February 2006

[67] “El primer frente del choque de civilizaciones,” El País, 6 February 2006

[68] “Adding Newsprint to the Fire,” The New York Times, 5February 2006, p. A.5