How Linguistics Shapes Freedom of Speech
The US television programme 60 Minutes recently ran a piece on how freedom of speech works in Germany. Audiences were shocked. Americans take for granted that “freedom of speech” means what it says — in the United States, with extremely narrow, context-based exceptions, you really can say whatever you want.
By contrast, German law imposes important and severe restrictions. Not just denying the Holocaust, or raising one’s arm at a certain angle, but even posting false content about politicians can land you in jail. Anyone who has been on Twitter recently may feel a certain attraction to legally-enforced civility, but Americans would never really tolerate this. Of course, the difference is cleft largely by history and culture. But language itself also plays a role.
The German equivalent of “freedom of speech” is Meinungsfreiheit, literally “opinionsfreedom.” In today’s globalised world, especially within the West, people calling for freedom of speech, Meinungsfreiheit, libertad de expresión, et cetera, share similar ideals. But we should not discount how diction and semantics subtly influence the way we perceive something. You can have whatever opinion you like, without necessarily having full rights to express it.
To use a stark example, a few hundred years ago, “freedom” did not mean “freedom.” It was originally a term for belonging to a community, related to Old English words like frith (peace or protection) and friga (love). It was only in the 1630s that it began to develop its modern political sense, as being unrestricted by arbitrary laws became seen as inseparable from the freedom of being English. By 1644, John Milton’s Areopagitica helped define free speech as essential to it.
The word’s Latin analogue likewise developed from liberi, the free (i.e., non-slave) children of a Roman household. The old community-oriented sense of “liberty” still survives in the British custom of granting dignitaries “the liberties” of a city.
European cultures derive their current understanding of both words from the Enlightenment. Given this development was essentially arbitrary, it should not surprise us that other cultures feel differently.
Perhaps the starkest illustration of this can be seen in Hong Kong. The city-state was traditionally the most liberal (in the classical sense) place on earth, with both the economy and civil society governed by little other than the invisible hand. In 2019, this view of freedom clashed with another, inspired as much by Confucianism as much as any newer ideology. Chinese authorities insist that “freedom of speech” includes the right of citizens not to be offended by unruly demonstrations.
The Chinese word in controversy is 自由 (“zi-you”), which was originally a Taoist concept referring to flowing freely with nature. In the 19th Century, it became the translation for the Western notion of freedom. For Hong Kongers, the English and Chinese words mean the same thing. But on the Mainland, this mixed heritage and foreign taint mean ziyou does not pack the same punch as “freedom” or “liberty” do in the West.
Likewise, in Arabic, hurriyat at-ta’bir is a 19th Century term for an imported ideal. For cosmopolitans in Beirut or Cairo, it means what it says: freedom of expression, just like in Britain and France. But it coexists with older concepts like fitna (schism) and hisba (morals), that are deeply-rooted culturally and often enshrined in law.
Liberal Arabs sometimes point to the Islamic tradition of “enjoining good and forbidding evil,” which could be interpreted as licence to criticise unjust or backward regimes. But others interpret the same thing as a mandate to stop the sorts of people who want to do that. Even many liberals would not imagine that freedom of speech extends to blasphemy against Muhammad, just as libertine Thai people would not dare to insult their king.
Sometimes, the exact same word can mean different things, according to historical context. Singapore is more restrictive than other prosperous British spin-offs, but its rules are fairly similar to those in Great Britain two hundred years ago. There is even a “Speakers’ Corner,” the one place where people can truly say whatever they like, which is modelled off of a historic one in Hyde Park.
Likewise, Francophone countries in Africa may not live up to the metropolitan ideal of liberté. This is not to excuse the behaviour of those countries’ current leaders, but people who learned that word from colonial governments inevitably learned to imagine what it means in a different way.
In a variety of societies, everyone remembers a pithy phrase that sets guardrails on speech. Americans will point out that you cannot “shout fire in a movie-house,” even though that expressive rule comes from a World War I-era Supreme Court case and has not been good law for decades. China’s prohibition of “picking quarrels and provoking trouble” sounds reasonable, but practice is rather problematic.
The most prolific tag of our age is “hate speech.” Criminalising certain offensive rhetoric has become common in many countries that are otherwise very liberal, including the UK and Canada. In the US, right-wing commentator Michael Knowles topped 2021 bestseller lists with a book arguing that his countrymen should embrace speech restrictions, albeit with a different ideological bent. The term is so virulent that many Americans assume it is already a real legal concept, even though it exists nowhere in US law.
Clever rebranding can even make ancient concepts seem new. “Censorship” dates back to the imperial Roman censor’s side job of monitoring public morals, and it was traditionally held in opprobrium by enlightened people. But in recent years, “content moderation” online has become popular and respectable.
It is possible to overstate how much meaning is lost or warped in translation. Protesters complaining of restrictions on free speech in London, Tehran, Berlin, or Washington are generally after the same thing. But language does form the substance of our consciousness, and how we understand what others say. Even within a society, semantics really matter.
One cannot take for granted that everyone who hears the same word thinks of the same thing. If we fail consciously to consider how other people perceive what we say, it is easy for two sides to talk past each other. Especially for the foundational issue of civil society, it is imperative to take context and nuance into account. Good things happen when we speak each other’s language.
