Law of Sedition in Other Countries: A Comparative Study

The word Sedition has been derived from the Latin word “seditio” meaning “going apart.” Sedition essentially means any person who by making use of words either spoken, written, or signs or by visible representations tries to incite violence in the society against the Government. Whoever tries to create discontent in the minds of people against the Government and provokes them to incite violence, have committed sedition and can be held under Section 124Aof the Indian Penal Code. Sedition law aims to punish those who incite disaffection, hatred, contempt towards the government established by law. The law of Sedition was based on the Treason Law of British, which made any act of hate and disloyalty towards the Crown or queen punishable. Even after Independence, many countries like India, Australia, USA, Malaysia, Hong Kong, New Zealand, Canada and African countries like Nigeria, Uganda, Malawi, Kenya and Swaziland are prosecuting people under this British era law. This paper studies and discusses the Sedition law in various countries and highlights how few have given away with this law while few countries apply the amended version of this law. The countries discussed below are mainly countries which were ruled on the principles of Monarchy but after the International conventions these countries have accepted the democratic principle. The main aim of discussing these countries is to highlight how though being party to the International conventions these countries are still carrying the colonial law in their statute books. This research paper discussed the recommendations given by Law Commissions in these countries for amendment of the law. This paper further attempts to discuss the right of free speech in each of these countries and how Sedition can be a valid restriction. The chapter ends with a comparative analysis of these countries with Indian Sedition law.