The Right of Criticism and Defamation Crime in Media: Iraq and U.S. as a Case Study
Omed Aziz Ismail*
College of Engineering, Sulaimani
Polytechnic University, Sulaimani, Iraqi
Kurdistan Region, Iraq
- *Corresponding Author:
- Omed Aziz Ismail
College of Engineering
Kurdistan Region, Iraq
Tel: (+964)-771 234 5678
Received Date: June 03, 2017; Accepted Date: January 29, 2018; Published Date: February 08, 2018
Citation: Ismail OA. The Right of Criticism
and Defamation Crime in Media: Iraq and
U.S. as a Case Study. Global Media Journal
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This paper is an attempt to find out the role of mass media in criticizing public officials in the government by referring to its constitutional framework. This role, however, can be restricted through the libel suit which might be filed by the public officials against media. Under the right of freedom of expression, media has been enabled to criticize public officials in favor of public interest. The right of criticism often empowers media to participate in public life and protect people from the tyranny system. While practicing its constitutional functions, media might be charged to defame the privacy of others. Consequently, the defamation claims may run against the right of freedom of criticism, and restrict the role of media in some legal cases. A balance between the right of privacy protection and free speech of media should be taken into consideration. Hence, the current paper shed lights on how defamation law should be set in a way that does not suppress media in performing its function. For that, defamation law in the United States and Iraq will be compared in regards to the above mentioned point.
Free speech; Right of criticism; Criminal defamation rules; Mass media;
Following the collapse of the Iraqi regime in 2003, freedom of
expression and criticism have become common issues in the
field of media. Though the Iraqi constitutions and various laws
guarantee these rights, they were never respected until the
April of 2003 when a dictatorship regime was taken over. After
that date, a great development of free speech and criticizing the
government has achieved since it has become something real
in public life and media as well. Media, then, is considered as
an important method and technique for the citizens to publicly
criticize the government and its officials without fear.
The new situation, however, paved a way for media to perform
its functions, but media still has faced many challenges under
Iraqi laws. Meanwhile the case is totally different in the US laws.
The reason behind this could be attributed to the fact that the
Iraqi law enacted in light of philosophy of dictatorship regimes.
Moreover, it might restrict the fundamental rights in different
ways and without compelling justifications. Iraqi defamation
law can be considered as an example which always leads to
suppress free speech and the right of criticism; especially, when
the defamation case arises between public officials and media or
journalists. Therefore, it is the duty of legal scholars to inspect
and review law articles in Iraq. Furthermore, some certain articles
might be changed by the competent authorities in way that does
not suppress human rights as it is seen in the US.
Clarification and Provisions of the Right
The right of criticism as a form of freedom of expression is
guaranteed for media to become a platform for people to explicit
public problems and criticize the government so as to improve its
performance. Hence, one may ask a number of related questions
to the concept of criticism rights, for example: What is it? Where
is it? Is it a statutory right? What are the conditions of exercising
this right? The previous questions are explained below:
The concept of criticism in legal system
Criticism can be considered as a wide concept, it enters into all
areas because it constitutes opinion and/or reaction towards
a particular positive/negative work. So, criticism points out
different aspects of something after inspection and consideration
. In the field of law, criticism is the expression of opinion and
free speech on an issue without prejudice to the issue’s owner, i.e., without prejudice toward the owners’ reputation and their
position in society . The Iraqi judiciary defines the right of
criticism through the decision of Federal Court of Cassation
number 206/public body/on 31st of August, 2009 that criticism
is referred to “any opinion or correction with regard to the
performance of public officials seeking to protect the national
interest” without determining the concept of the national interest
. Similarly, in the American legal system, one can find this right
in the concept of free speech. Additionally, the First Amendment
protects the right of the people to “petition the government for a
redress of grievances” . Thus, in both legal systems, American
and Iraqi, the value of this right is the people’s ability to criticize
the government and public officials for the purpose of redress
and protect the government from corruption.
Legal basis of the right of criticismLegal basis of the right of criticism
In common and civil law system, human rights should have basis
and this could be a statutory right or derived from case law. The
right of criticism as a form of the expression rights is considered
as one of the statutory rights in both American and Iraqi law.
Legal basis in Iraqi legal system: There are many implied
indications for the right of criticism in the Iraqi constitution,
treaties, international charters and secondary laws under the title
of Freedom of Expression, Freedom of Opinion, and Freedom of
Belief. Here are some provisions:
• Article 29, in the Constitution of the Republic of Iraq in
1963, provides that “freedom of opinion and scientific
research are guaranteed, everyone has the right to express
his/her opinion and publish by saying, writing, pictures, or
other within the law” .
• Tripartite Unity Agreement (of Egypt, Iraq, and Syria in
1963) states that “public freedom is guaranteed within
the law, and the United Arab Republic ensures for all
citizens without discrimination, freedom of opinion
and expression, freedom of criticism, freedom of press,
freedom of assembly and to create associations, freedom
of belief and exercise of religious rites, and other of public
• In the Temporary Iraqi Constitution in 1968, Article 32
provides that “freedom of press, printing, and publication
are protected according to Interest of the people and
within of the law” .
• In Article 38, the recent Iraqi Constitution (2005) confirms
that “the state guarantees in a way that does not violate
public order and morality:
a) Freedom of expression, through all means.
b) Freedom of press, printing, advertisement, media, and
c) Freedom of assembly and peaceful demonstration. This shall
be regulated by law .
• Section 6 in the article 3 of the Iraqi Journalists Syndicate Law
number (4) of 1998, claims that “the defense of the freedom
of press and the right of journalists to provide necessary
immunity for press in order to be able to express its message
for growth and prosperity”.
Legal basis in American legal system: Freedom of expression
in all its forms, including the right of criticism and free press, is
one of the fundamental rights in the American legal system. As
it is mentioned in the First Amendment in the U.S. Constitution,
“Congress shall make no law respecting an establishment of
religion, or prohibiting the free exercise thereof; or abridging
the freedom of speech or of the press; or the right of the people
peaceably to assemble, and to petition the government for
a redress of grievances.” . The doctrine of the U.S Supreme
Court is also obvious regarding protecting this right and finds it as
an essential tool for a fair life.
Conditions of the right of criticism
As it has been explained, the right of criticism refers to a form of
the right of expression which is practiced by media. This right is
guaranteed in the Iraqi constitution with having some restrictions
imposed on the right in the current Iraqi Constitution. Due to that,
it is not absolute right. This means that it has to be organized by
the law and should not violate the "public order and morality" of
article (38) in the Iraqi Constitution. For this reason, it must meet
some conditions. However, the jurisprudence and the judiciary in
Iraq have deduced some conditions from the previous article for
practicing the right of criticism in the media as follows:
Criticism and evaluating public officials performance: Media is
not the place to criticize private conduct or abuse the reputation
of a person since media is regarded as bridges between people
and government. For that reason, public officials must be subject
to oversight by the media in order to protect them from corruption
that leads to the corruption in the whole body of government
. This is pointed out in the decision of the Federal Court of
Cassation in Iraq, number 206/public body/in 31/8/2009, which
restricts the right of criticism to direct only against public officials
by defining this right as “any opinion or correction in regards to
the performance of public officials seeking to protect the national
interest”. In addition, in article 2, Civil Service Law No. 64 in
1939, the public officials are defined as “any person entrusted
to do a job in the government with a salary received from the
general budget or special budget and follows the provisions of
the pension law .”
Criticism and public interests: The combination of the right of
criticism with the public interest or national interest comes
in the same decision of the Federal Court of Cassation that is
mentioned above. It is observed that the court mentions national
interest without determining the concept and giving details, i.e.,
both national interest and public interest are mentioned. This
attitude may give an interpretation that the purpose of the Iraqi
judiciary in the national interest is to activate criticism in subjects
of political and social importance, i.e., in subjects of common
interest of the people. It is not permissible for media to interfere
the private conduct and private interests. “Society does not
benefit anything if a critic faces the private life of others, but that
this may constitute an assault on the private life of individuals as
a human right .”
Good faith: Good faith is an essential condition in exercising any
right guaranteed by law. The basis of good faith in this right is that
the critic should believe in the validity of the incident which is
cited to a public official who faces the criticism; the criticism itself
aims at achieving public interest, not only defaming others. If the
criticism is to the private interests based on the personal reasons,
it will be out of the right of criticism limitation and constitute
the defamation crime. With regard to this point, the public
body in the Iraqi Court of Cassation issues the decision, number
306/public body/2009which states that “the act of defamation
and libel go out for being the opinions or assessment to the
performance. It is impermissible exercise and exceeds to exercise
the right of criticism, which aims to achieve the national interest.”
The relationships between criticisms and achieving the national
interest have a positive great impact on the validity of criticism
rendered to any individual. For instance, it is not allowed to any
critic to exercise this right since there is no good intention with
this, rather injuring the others. Moreover, Article 7 in the Iraqi Civil
Law No. 40 of 1951 focuses on impermissibility of practicing the
right and states that “if he/she does not has intention to benefit
public order, and intent to cause injury to others.” . When
a critic does not have intention to benefit public order, rather
has intention to injure others, he or she exceeds exercising the
criticism right. The issue of good faith estimate is subject to the
judge discretion, and “it does not required for the judge to extract
bad faith only from the words of article, it can be extracted from
other situations, like having threat from journalist and researcher
against the complainant before the publication of the article and
demanding an amount of money for non-publication.” Finally,
the good faith is presumptive element for critic because the basis
of human intention is good faith; otherwise the burden of proof is
responsibility for the person who claims bad faith .
Using appropriate phrases: Generally speaking, the main goal
of criticism is to obtain benefits to the public interests in public
domain, e.g., political and social area; it is not to defame the
reputation of others. Therefore, the right of criticism should
be linked with appropriate words which are consistent with
the purpose of criticism . So, critics are not permitted to
use defamatory phrases. With this in mind, most of the jurists,
finds that the boundary line between the right of criticism and
defamation can be derived from the wording of article. An
appropriate word will be directed to address an official behavior
of a person who has been criticized, while harsh phrases tend
to harm the honor and person's reputation. The first represents
the permissible criticism, whereas the second is considered as
defamation against the reputation of others. For this reason, the
issue of the appropriate words is subjected to the discretion of
the judge .
The decision of Cairo Criminal Court No. 2453 of 2008, in case
of Mohammed Bekri, Member of Egyptian Parliament, against
the journalist Yasser Barakat, editor of the Mojaz newspaper
can be regarded as a good example of judicial opinion. The court
convicts the defendant, and concludes that “the defendant has
exceeded his right to criticize performance of the plaintiff inside
Parliament. The defendant has not used appropriate statements in the article even in its cruelty. Hence, he cannot protect himself
from the punishment for abusing the reputation of plaintiff,
under the pretext of the right to permissible criticism even with
alleging good faith or claiming to obtain public interest” . The
court notes that using inappropriate statement is presumption to
devise bad faith in criticism which aims to defame the defendant.
“The court has found that the defendant, Yassir Barakat, has
exceeded the permitted criticism to challenge reputation and
personality of Mohammed Bekri, Parliament Member because of
using outrageous phrase; this indicates the intention of libel and
contempt to plaintiff that considered as abuses and arbitrary to
use the freedom of press”.
Right of Criticism vs. Defamation
After reviewing the legal basis and conditions of the right of
criticism practiced by media, one can see the fact that this right
in the American and the Iraqi legal system is a constitutional right
with some differences in philosophical and legal conditioning.
When this right is constitutionally protected, it sometimes
clashes with interests served by the defamation law. While talking
about freedom of media, one should claim that responsibility
is prerequisite to refrain from defaming others. On one hand,
the media has a great freedom to evaluate public officials’
performance. On the other hand, the public officials who believe
that they have been defamed by the media have the right to
challenge the media by bringing libel suit . Though libel suit is
recognized legally and it is a protection for the public officials to
stop media from unfair use of the right of criticism. Despite the
previous mentioned fact, libel suits must not impede the media
from performing its function within its constitutional rights. So,
the questions might be asked about the distinction between
criticism and defamation. Furthermore, the guarantees to
protect the right of criticism beside a libel suit against the media
in a way that does not lead to suppress the media might be raised
as another question. Constitutions typically do not contain detail
about these standards, so it is a responsibility of the jurisprudence
and judiciary to create a distinguished standard between them by
taking into account what is superior constitutionally and aims to
the best interest.
In Iraq, the media faces many challenges because of having
many libel suits which are filed by the public officials against
the media. Libel suits have become lethal weapons to restrict
the media and limit the freedom of criticism. Recently, filing
large number of libel suits against the media and journalists
has led to the withdrawal of many journalists in the press and
contracted the role of media fact-finding in political issues due
to fears of prosecution. In addition, the large number of judicial
decisions fines journalists and the effects of these decisions on
the freedom of the press results in the issuance of Order No. 7 of
2003. This order prevents the courts from accepting complaints
about publishing crimes without the consent of the Coalition
Provisional Authority (dissolved) in accordance with item (2) of
section (2) thereof. This means that any complaint or prosecution
for any media or a journalist, as well as any newspaper or other
media, could not be begun without the approval of the Coalition
Provisional Authority in Iraq. But, after dissolving and replacing the Coalition Provisional Authority by Iraqi Prime Minister, the
mentioned article is canceled and this weakens the legal status of
the media and journalists again.
To illustrate the defamation law and how it limits the right of
criticism, one may focus on the provisions of defamation with
regard to public officials with judicial guarantees to be sure that
it does not impede right of the media to criticize in both the
American and the Iraqi legal system. Consider the following:
Defamation in Iraqi legal system
Defamation, in article 433, section 1 of the Penal-Code, is defined
by Iraqi legislator as:
(1) The imputation to another in public of a particular matter
which if true, would expose such person to punishment or cause
him to be scorned by society. Any person who defames another is
punishable by detention plus a fine or by one of those penalties.
If such defamation is published in a newspaper or publication or
other press medium it is considered as aggravation circumstance
(2) Such person is not permitted to establish the proof of his
imputation unless that imputation is directed at a public official
or agent or public deputy or he is carrying out an act in the public
interest or if such imputation is connected with the office or
employment of aggrieved person but if he establishes the proof
of all imputations made, then there is no offence.”
Elements of defamation: Building on the above mentioned article,
Iraqi judiciary and jurisprudence have deduced two elements of
defamation through the definition: material and mental. In order
to make a certain crime happens, these elements should be
A- The material element in the libel crime consists of imputation
and publicity. Imputation is the statement or accusation that
causes a particular person to be falsely convicted of a crime or
to suffer the contempt by the people. Meanwhile, publicity is a
condition in the material element of the libel crime. According
to law, imputation should be in public because the protected
interest is referred to reputation, honor, and dignity of persons.
Furthermore, publicity is achieved when imputation takes place
in public or is published in media that is distributed among the
B- The mental element consists of science and will. The libel
crime is one of the intentional crimes requires criminal intent
which is represented by the knowledge of the facts and the will
with respect to all aspects of the crime. Knowledge of the fact, in
this crime, refers to having knowledge of the truth with regard
to the defamed person, and the will is the purposeful attempt to
harm a person’s reputation and causes him/her the contempt in
Distinction between criticism right and defamation: As a matter
of fact, the Iraqi legislature defines the term of defamation in
criminal law, but does not set a standard to distinguish between
defamation and the exercise of freedom of expression and
criticism. The legislature leaves this point to the interpretation of
legal scholars and courts. When the defendant alleges during the
hearing of a libel suit, he or she practices freedom of expression
guaranteed by the Constitution, and he does not intend to offend
anyone, so the judge is obligated by law to adjudicate in this
allegation. In Iraq, most jurists note that the boundary between
the practice of the right of criticism and defamation is reflected
in the distinction between directed blame and cruel phrases
aimed at the honor and reputation of the person who has been
criticized, or directed at his/her official acts without prejudice to
his/her honor and reputation.
Generally speaking, the material element of the libel crime is similar
with the material elements of the exercise the right of criticism,
whereas the crucial difference between them is in the nature of
the activity and the intention. The committer's intention in the
defamation crime is deliberate abuse of the plaintiff and defames
his/her reputation for purely personal reasons. Meanwhile, the
intent of the practice of expression freedom and the criticism
right is to achieve the public interest including the development
of the overall performance, avoiding financial loss, and exposing
the crimes of a financial or administrative corruption. Thus, the
mental element is the most important standard for distinguishing
between the defamation and exercise the right of criticism.
Defects of the Iraqi defamation law: The article of defamation
and its judicial applications may have some defects. Consider the
• In Iraq, defamation against public officials is considered
as criminal offences. The resort for the criminal law to
protect reputation constitutes imminent danger regarding
the expression right and press freedom. It is a threat
which indicates that the media is a place to commit
crimes without respecting its role in the society. In most
democratic countries in which the reputation and privacy
are protected by civil law, most jurists believe that criminal
law provisions are not the correct response to redress libel
directed to public officials.
• When the defamation is published in the media, it is
considered an aggravating offence. Sometimes, there is
an attempt by the Iraqi authorities to make media silent
and this happens when media criticize the government or
public officials, meanwhile the recent trend is to reduce
liability upon the media to develop its role in progress.
• The most dangerous point in the article (433) is observed
in section (2) which imposes the burden of proof on the
defendant for the purpose of absence of offence, if it is
directed to the public officials .
Hence, the journalists or media have to prove the truth of
statements when they become defendant in the libel suit. This
is often leaded to weaken the legal status of the defendant,
and convict the media and journalists in case that the courts do
not convince the validity of their statements towards the public
officials. This can be considered as a main reason beyond the
large number of libel suits against the media in Iraq where the
public officials are sure of winning the libel suit because they do
not have responsibility to prove falsehood and actual malice at
the media in front of the court, as it is in the United States . Furthermore, this shows a big restriction upon Iraqi media; a
number of journalists have been prosecuted and convicted under
article 433 of the Penal Code, while performing their role via
evaluating government policies and the poor performance of
public officials. Below are some courts decisions about media
convicting and journalists who have written critically towards
a) Kamal Sayid Qadir, an Iraqi Kurd was arrested in October 2005
in Erbil because of publishing online articles on Kurdistan
Post, a political website, criticizing the Kurdistan Democratic
Party and its leader, Massoud Barzani, whom he accused of
corruption and abuse of power. Mr. Qadir was convicted and
sentenced to thirty years’ imprisonment on 19 December
2005 for “endangering national security”. On 26 February
2006, the Supreme Court of the Kurdish Region overturned
the conviction and ordered a retrial on the charge of
defamation the Kurdish regional leadership. Finally, in March
2006, Mr. Qadir was convicted for publishing “defamatory”
articles about the authorities in Kurdistan and was sentenced
to one and a half years’ imprisonment.
b) Wasit Court issued an arrest warrant for Sada Newspaper
editor in chief for publishing an article criticizing the
performance Wasit Provincial Council. The court considered
the article as defamation towards the members of Wasit
Provincial Council, and the court later released the editor in
chief on guarantor bail of five million dinars.
c) Erbil Court imposed a fine of three million dinars to Shwan
Mohammed, Awena Newspaper editor in chief, for publishing
an article in his newspaper criticizing the Kurdistan Region
Government performance 
Defamation in American legal system
It might be not necessary to provide an accurate definition and
elements of defamation in American legal system, but how the
criticism right and press freedom limit the government awarding
libel damages brought by a public official against their critics
should be taken into consideration. Chemerinsky (2005: 1284)
states that “the challenge for the court in this area is to balance
the need to protect reputation, the obvious central concern of
defamation law, with the desire to safeguard expression, which
can be chilled and limited by tort liability.” The constitutional
protection of the right of expression and the historic value of
it make the Supreme Court protecting the right substantially.
Concerning the constitutional right, the Supreme Court doctrine
is clear and protects it from any attacks or attempt to convict it,
or turning it to criminal conduct. Moreover, in most countries of
Middle East such as Iraq, defamation law takes a way to strict the
right of expression and criticism, but in American legal system,
defamation law has been regulated in a way that does not
contradict with this constitutional right.
Public officials in the libel suits: The first approach of the Supreme
Court regarding defamation law in a way that does not contradict
with the right of free speech and criticism is distinguishing
between two conditions in the libel suit: the plaintiff is a public
official and the plaintiff is a private figure.
The consequence of this distinction is to make defamation proof
more difficult if the plaintiff in the libel suit is public official. The
burden of proof is the public officials' responsibility claiming for
damages of defamatory falsehood regarding his official conduct;
they must prove that the statements are false and make it suits
with actual malice .
Actual malice test: Though a burden of proof on public officials is
imposed and this makes the legal status of the defendant which
represents in the media or journalists strong, it is public officials'
responsibility to pass a severe test in order to win the libel suit.
This test is called Actual Malice which is established by the U.S.
Supreme Court. The proof of falsity is not sufficient to convict the
media by defamation without proof of actual malice in the media.
The Supreme Court establishes the actual malice test in New
York Times Co. v. Sullivan, which rules “the constitutional
guarantees require a federal rule that prohibits a public official
from recovering damages for a defamatory falsehood relating
to his officials conduct unless he proves that the statement was
made with actual malice – that is, with knowledge that it was
false or with reckless disregard of whether it was false or not.”, as
Chemerinsky (2005: 1287) claims.
Since the court imposed on public officials the requirement to
prove actual malice, they have rarely won libel suits because
actual malice deals with intent which is hard to be proved. It may
be sufficient to the court to decide that an act is not malicious
when media publish a story in good faith that aims at serving the
public interest. Generally, the actual malice test provides a wide
scope of freedom of criticism so as to protect the media from a
variety of libel suits.
On the whole, the media in both the United States and Iraq
practice a constitutional right when they criticize public officials’
performance and government policies. The U.S. Constitution
protects this right in absolute language and allows the judiciary
to protect it by imposing the severe scrutiny on the government,
if the government’s actions restrict the right of criticism.
In comparison with the American legal system, it is observed
that this right is restricted constitutionally in Iraq. This defect
of the Iraqi Constitution paves the way for the government to
limit the right of criticism without any high level of scrutiny from
the judiciary. In addition, an article of law passed by the Iraqi
legislature makes defamation a criminal matter rather than a
civil one as it is seen in the US Constitution. The Iraqi law also
puts the burden of proof on the media in these libel suits. For this
reason, the media is reluctant to perform its function in Iraq in
fear of being liable for every defamatory suit in an environment
where public officials are most likely to win a libel suit. Unlike the
Iraqi legal system, freedom of media is guaranteed by the U.S.
Constitution, i.e., U.S. media express every statement toward
public officials, even false statement. Imposing burden of proof
on the plaintiff and the difficulty of proving actual malice in the
media causes losing most libel suits by public officials.
Since the media perform a crucial role in monitoring the government performance and the right of criticism is necessary
for the government betterment, the fear of incrimination must
be eliminated as a method of silencing the media. To accomplish
this end, the current study suggests the following:
• Abolition of penal sanctions resulting from the crime of
defaming public officials in their official conduct and limit
the compensation for damages from libel in order to be
determined by civil lawsuit with the publication of public
apology by the defendant.
• Enacting provisions which clearly define the boundary
between the practice of expression freedom with the right
of criticism and defamation crimes. Thus, it is necessary to
make the constitutional provisions related to the freedom
of expression and the right of criticism.
• Re-drafting the provisions of defamation in a way that
makes the burden of proof the responsibility of the public
officials in the libel suit. This strengthens the legal status
of the media and journalists.
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