More or Less: A Comparative Study on Freedom of Speech

In March 2020, Jolovan Wham stood outside a Singapore police station holding a cardboard sign with a smiley face. Officers inside were interrogating two teenage climate activists. Five months later, he was charged with unlawful public assembly. The sign had a smiley face. The cause was climate change. The effect on the public around him was almost non-existent.

What stands out is not that Wham was charged. Singapore's Public Order Act is well-documented. It is that most Singaporeans barely reacted. In many other democracies, that silence would have been the story.

That difference points to something more interesting than a straightforward comparison of speech laws. Singapore's Constitution guarantees freedom of speech. In practice, POFMA, the Sedition Act, and the Public Order Act make that guarantee considerably narrower. Singaporeans largely know this and, according to surveys, most are satisfied. 82% 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 legal protection, more self-censorship. That is a strange result, and it points to something the legal comparison on its own misses. 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. This is not a uniquely American problem, but the data suggests it runs deeper there.

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.