Freedom of expression and defamation of religion: a comparative perspective

The balance between freedom of expression and defamation of religion is analyzed in a comparative perspective, with reference to the Italian and French cases in the broader framework of European and international law. The comparative perspective offers a valuable observation point from which it is possible to analyze the relationship between the balance that the legal systems operate and the different fundamental constitutional values. In the analysis, the different approach of the diverse countries highlights some critical issues relating to the fragmentation of the system of legal sources and the unity of international law, of the problems of interpretation that characterize the multilevel protection of rights.