More or Less: A Comparative Study on Freedom of Speech
In March 2020, Jolovan Wham stood outside a Singapore police station holding a smiley-face sign in support of two teenage climate activists being questioned inside. He was charged under the Public Order Act, which requires a permit for public assemblies, even those involving a single individual. Supporters of the prosecution argued that consistent application of the law matters regardless of cause or scale; critics maintained that the charge was disproportionate to any plausible harm.
What stands out is not that Wham was charged. It is that most Singaporeans barely reacted, and the absence of reaction tells you something about how differently the relationship between speech, law, and public life is understood here.
Singapore's Constitution guarantees freedom of speech. In practice, POFMA, the Sedition Act, and the Public Order Act define its boundaries. POFMA allows the government to issue correction notices or remove content it deems false. Supporters argue it protects public discourse from disinformation in a socially complex society; critics question how much discretion the government should have in deciding what counts as false. Yet according to the 2023 Asian Barometer Survey, over 80% of Singaporeans report satisfaction with how democracy is functioning. Meanwhile, 45% of American college students, according to a 2023 survey by the Foundation for Individual Rights and Expression, report self-censoring in classrooms. More formal legal protection for speech, more reported self-censorship.
The social environment in which speech occurs matters as much as the legal one. In the US, public backlash and online shaming have created their own unwritten rules around speech. Those can be harder to navigate than an actual law because there is no clear line to know when you have crossed it.
But neither country has figured this out. The comparison shows the disconnect between what the law says and how speech actually works in practice. That disconnect is where most of the real tension sits. In the US, growing up where speech rights carry significant formal weight tends to make people more alert to anything that feels like a restriction. Singaporeans have largely internalised a different calculus: that free expression sits alongside other obligations, including keeping the peace in a multiracial society. Both countries have just located the tension differently.
