respect of the rights and reputation of others and the protection of national security or public order, public health or morals. Permit us to digress a bit into the genesis of the restrictions on freedom of expression. After the Norman conquest of England, William1 set up church court to try the canon law crime of false allegation. The guilty is made to publicly confess and beg the injured for forgiveness. By the 16th century the church courts were replaced by the king’s courts which started imposing monetary fines on defamers. The invention of the printing press led to easy production and circulation of political tracts and this heightened the fear of seditious libel and led to the establishment of the court of the Star Chamber to affirm and protect royal authority. The court of Star Chamber began punishing any criticism that appears to the court capable of bringing the government to disrepute and since such publications tended to undermine the legitimate government, its truth was immaterial. In fact, “the greater the truth the greater the libel” since the exposure of the truth was more likely to lead to government downfall or a breach of peace. Historically, criminalizing defamation therefore was born out of the need to prevent breaches of peace / public order and secondly to preserve state security. See the cases of R v Holbrock, (1878) 4 QBD 42 and R v Labouchare, (1884) 12 QBD 320 The public order issue arose out of the tendency of the defamed to draw his sword for a duel in order to defend his integrity and in so doing disrupt public peace. This 33