The Undergraduate Law Review at UC San Diego

This article delves into why the United States and Singapore, despite their shared colonial history, democratic institutions, wealth, and global influence, have drastically different free speech models. This paper will look at three points of comparison: historical context, political theory, and evolution of judicial interpretation. By comparing the current events and the prevalent political theories at the time of drafting the Singaporean and American constitutions, this paper seeks to understand why the nations ratified contrasting free speech clauses.  However, the Constitution is only as meaningful as the courts interpret it, so this paper also explores how the respective Supreme Courts of Singapore and America have evolved their interpretation of the Constitution to shape their contrasting free speech models. While this paper will not argue which model of free speech is more effective, it will outline the underlying reasons for Singapore and America's drastically different free speech models.