Analytical note on Comparative Law Regarding the Criminalisation of Defamation in Germany, France, the United Kingdom, Italy, Canada, Japan, the United States and Poland

Abstract. This analytical note presents the results of a study of the issue of establishing criminal liability for defamation. It identifies the types of criminal liability for defamation, the conditions under which such liability arises, and the aggravating factors. Trends towards the decriminalisation of defamation are also explored. The analysis is based on a study of the relevant legislation of the Group of Seven (G7) countries (Germany, France, the United Kingdom, Italy, Canada, Japan, the USA), as well as Poland.

Keywords: criminalisation, decriminalisation, slander, defamation, criminal liability, criminal code.

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03/2026