Press Freedom and Globalisation - International Press Institute

Press Freedom 

and 

Globalisation: 

Press Freedom and Globalisation 

Scandinavia and East Africa 

Compared 

By 

Jens Barland 

A thesis submitted to fulfill the degree of 

Masters of Arts in International Relations 

United States International University – Africa 

Nairobi, Kenya 

May 2005 

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Declaration 


I hereby declare that this thesis is my own original work. It has not been published or 

presented in any other institution. All material obtained from other sources is cited. 

…………………………………………………………….. … ……………………… 

Jens Barland Date 

Supervisor 

I hereby declare that this thesis has been presented for examination with my approval as 

the appointed supervisor. 

…………………………………………………………….. … ……………………… 

Professor Macharia Munene Date 

The Dean, School of Arts and Science 

I hereby endorse this thesis document subject to all the University requirements. 

…………………………………………………………….. … ……………………… 

Professor Ruthie C. Rono Date 

Vice-Chancellor, United States International University – Africa 

…………………………………………………………….. … ……………………… 

Professor Freida A. Brown Date 

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Content 


Abstract ............................................................................................................ 1 

Chapter 1: Introduction ................................................................................. 2 

Background and Problem Statement..........................................................................2 

Hypothesis..................................................................................................................4 

Objectives...................................................................................................................4 

Literature Review.......................................................................................................4 

Theoretical Frameworks ..........................................................................................14 

Definition and Examination of the Concept ‘Press Freedom’ .................................15 

Methodology ............................................................................................................20 

Chapter 2: Globalisation of the Mass Media.............................................. 21 

The Economic Globalisation....................................................................................21 

Milestones in the History of Globalisation ..................................................21 

The Forces Behind the Globalisation Processes ..........................................24 

Mass Media Involvement in Globalisation ..............................................................26 

How Mass Media Came to be a Globalised Industry...................................27 

Press Freedom and Spread of Democracy ...................................................31 

Press Freedom as a Universal Concept....................................................................38 

International Regimes on Global Press Freedom.........................................38 

Debates on Global Press Freedom ...............................................................45 

Chapter 3: Press Freedom in Scandinavia ................................................. 58 

The Scandinavian Context .......................................................................................58 

Growth of Press Freedom.............................................................................58 

Reasons for Press Freedom ..........................................................................62 

Mass Media in the Societies.........................................................................64 

Four Aspects of Press Freedom in Scandinavia.......................................................65 

Role of the Press...........................................................................................66 

Gathering Information..................................................................................69 

Publishing.....................................................................................................73 

Protection of Journalistic Activities .............................................................76 

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Chapter 4: Press Freedom in East Africa................................................... 80 

The East African Context.........................................................................................80 

Growth of Press Freedom.............................................................................80 

Forces Around Press Freedom .....................................................................90 

Mass Media in the Societies.........................................................................96 

Four Aspects of Press Freedom in East Africa ........................................................98 

Role of the Press...........................................................................................98 

Gathering Information................................................................................100 

Publishing...................................................................................................103 

Protection of Journalistic Activities ...........................................................107 

Chapter 5: Scandinavia and East Africa Compared............................... 111 

Contexts and Aspects of Press Freedom................................................................111 

Growth of Press Freedom...........................................................................111 

Reasons for and Forces Around Press Freedom ........................................112 

Mass Media in the Societies.......................................................................112 

The Aspect of the Press’ Role....................................................................114 

The Aspect of Gathering Information ........................................................115 

The Aspect of Publishing ...........................................................................115 

The Aspect of Protection of Journalistic Activities ...................................116 

Press Freedom Interactions Between Scandinavia and East Africa.......................117 

Direct Links Between Scandinavia and East Africa ..................................117 

Relations to Global Regimes of Press Freedom.........................................119 

Chapter 6: Conclusion ................................................................................ 122 

Press Freedom and Globalisation in Scandinavia and East Africa ........................122 

Bibliography and Sources........................................................................... 129 

© Copyright: USIU, Kenya and Jens Barland, Norway (jens@start.no) 

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Abstract 


Press freedom is what enables democracies to work. A free press is supposed to maximise 

political, social and cultural outcomes for citizens in a society. Democracy is commonly 

accepted as the global standard of good governance. Hence, globalisation spreads 

democracy including press freedom. 

This thesis examines what effects such a spread has on press freedom. Further, 

forces involved with globalisation has interests in how press freedom is formulated, 

interpreted and practised. The thesis elaborates on how these forces promote, spread and 

even manipulate press freedom. 

In global communication there is a great gap between North and South. Global 

media in the North also perform a dominance over South. An effect is how global media 

are spreading Western values. Such perspectives are major issues in this thesis which gives 

attention to the two regions of Scandinavia and East Africa. Scandinavia is in the main- 

stream of Western democracies and ranks at the top level of press freedom globally. East 

Africa attempts to join democratisation processes conducted by globalisation. Press free- 

dom in East Africa is in a period of change between authoritarian systems and democracy. 

A globalisation perspective on press freedom calls attention to how different forces 

use or misuse press freedom in a global struggle for power. 

Constructivism theory is employed. That one focus on roles of regimes, agents and 

circumstances. Then the following questions arise: Who or what rule global press 

freedom? Who or what spread press freedom globally? Which underlying forces support 

good conditions for global press freedom? 

Press freedom is only one among many concepts used in globalisation. However, 

the study of how these forces interact with press freedom illustrates the great game of 

globalisation. 

1

Chapter 1: Introduction 


This thesis examines the spread of press freedom in the context of globalisation. The first 

chapter gives introduction to the issue, the core literature is reviewed, and theoretical 

framework, the concept of press freedom and methodology are clarified. Chapter two will 

analyse globalisation and how mass media and press freedom are involved in this process. 

Then, chapters three and four will be on press freedom in Scandinavian countries and East 

Africa. Chapter five will compare practices in the two regions. Chapter six will be the 

conclusion. 

Background and Problem Statement 

The globalisation process brings the whole world’s population into the same house, and 

everyone is more or less influenced by and linked to each other. The globalisation process 

covers a huge agenda from environment, trade, peace and war as well as human rights, 

health, communication, culture, and football. 

For poor countries, democratisation has emerged as a governance issue, and with 

democratisation is the question of press freedom. Press freedom is considered to be a 

vehicle and agent which contributes to the spread of democracy. 

In a democracy the government is supposed to serve its people and is expected to 

carry out what is the common good for citizens. 1 To ensure authorities do what is expected, 

an educated and well-informed population is necessary to demand transparency in 

1 Jackson, Robert H., “The evolution of international society” in Baylis, John and Smith, Steve (eds.), The 

Globalization of World Politics : An introduction to international relations (Oxford: Oxford University 

Press, 2001), pp. 38-44; and Philip’s, Philip’s Encyclopedia : comprehensive edition (London: Philip’s, 

2002), pp. 105-106 and 601. 

2


powerful institutions. In this regard, the mass media play the role of providing the needed 

flow of information. 2 

In Western democracies, the mass media have developed to enable the flow of 

information necessary for popular rule. These democracies and their mass media are 

intertwined. 3 However, the mass media need freedom to play such a role. From this point 

of view, the mass media’s mandate is derived from the people, not from authorities. The 

ideal is that the mass media would then ensure that the authorities always serve people and 

not any other goals. 4 

The focus of attention is on two regions and two countries; Scandinavia as 

represented by Norway, and East Africa as represented by Kenya. These are quite different 

from each other, yet, the regions are connected to each other. Norway and Scandinavia are 

considered to rank at the top of press freedom and are among those that spearhead further 

development of democratic instruments. 5 The East African countries are not at the bottom 

level of press freedom. However, these are still among poor countries where press freedom 

needs to be improved. 6 Additionally, press freedoms in those regions are interconnected 

because the Scandinavian countries link their aid politics to press freedom. 7 Due to the 

attention to Scandinavia and East Africa, a North-South perspective will be emphasised in 

this study. 

2 

Stiglitz, Joseph, “Transparency in Government” in World Bank, The Right To Tell : The Role of Mass 

Media in Economic Development (Washington: The World Bank/WBI Development Studies, 2002), pp. 

27-29 and 32-34. 

3 

Gunther, Richard and Mughan, Anthony, “The Media in Democratic and Nondemocratic Regimes: A 

Multilevel Perspective” in Gunther, Richard and Mughan, Anthony (eds.), Democracy and the Media : A 

Comparative Perspective (Cambridge: Cambridge University Press, 2000), pp. 1-3, Altschull, J. Herbert, 

From Milton to McLuhan : The Ideas Behind American Journalism (New York: Longman, 1990), pp. 1-6. 

4 

Stiglitz, “Transparency in Government”, pp. 27-43. 

5 

Herbert, John, Practising Global Journalism : exploring reporting issues worldwide (Oxford: Focal Press, 

2001), pp. 69 and 88. 

6 

Merrill, John C., Global Journalism : Survey of International Communication : third edition (New York: 

Longman Publishers, 1994), p. 71; and International Press Institute, IPI Report 2003 : World Press 

Freedom Review (Vienna: The International Press Institute, 2003), pp. 27, 48 and 50. 

7 

Statens Forvaltningstjeneste, St.prp. nr. 1 : (2003-2004) : for budsjetterminen 2004 : Utenriksdepartementet 

(Oslo: Statens Forvaltningstjeneste, 2003), pp. 91-92 and 137; and Bourgault, Louise M., Mass Media in 

Sub-Saharan Africa (Indianapolis: Indiana University Press, 1995), p. 128. 

3


Democracy as an instrument for good governance is not only based on constitut- 

ions, but also on law and order. Culture is another crucial element in the development of 

such a rule. Furthermore, if a democratic institution is copied from one country to another, 

it would probably work differently due to odd cultural conditions. 8 The spread of press 

freedom as an element in democratisation processes raises the question of what press 

freedom means and in what context. The problem that arises is whether the concept of 

press freedom can be transplanted from one country to another when the political and 

cultural circumstances are different. 

Hypothesis 

While press freedom can be a universal concept, there are differences in the practice of 

press freedom. 

Objectives 

To provide understanding of press freedom as a global concept. 

To establish understanding of the globalisation context as well as the concept of press 

freedom. 

To describe the practice of press freedom in two different regions, and then to compare 

these. 

To give a balanced description of press freedom in the context of globalisation. 

Literature Review 

A number of books deal with globalisation. Among them is The Globalization of World 

Politics : An introduction to international relations, edited by John Baylis and Steve Smith. 

8 Getecha, Ciru, “Audit Public Leadership as a Way of Combating Graft”, paper presented at the ‘Eastern 

Africa International Conference on Media Fighting Corruption’, at United States International University 

(USIU), Nairobi, 30 th -31 st March, 2004, pp. 4-7. 

4


It gives a fundamental understanding of global history, development of International 

Relations theories, and several global issues. While the book is relatively broad range, it 

lacks critical approaches to globalisation processes and offers little on mass media as a 

global force. 

Andrew Williams’ book Failed imagination? : New world orders of the twentieth 

century presents different political actors’ agenda that were behind globalisation in the 20 th 

century. Its strength is in the understanding of how American interests have used global 

politics to develop a new world order that supports their own interests. American concepts 

such as open doors, free trade and democracy are introduced as good global concepts. 

Williams describes global politics as competing interests and not as fair play. He writes 

almost nothing about mass media’s role. 

Even more critical in approach to the globalisation processes is Richard Falk in his 

Predatory Globalization : A Critique. He paints a picture, from the bottom, of how 

globalisation’s adverse side strikes those who already were poor and weak. He predicts 

global instability and urges for global governance through a reformed United Nations. 

A much referred to philosopher for a critical and alternative approach towards 

globalisation is Immanuel Wallerstein. He gives a brief introduction to his thought in the 

chapter “The inter-state structure of the modern world-system” in the book International 

theory: positivism and beyond edited by Steve Smith, Ken Booth and Marysia Zalewski. 

Derived from Marxism and Leninism, he describes the world as core, semi-periphery and 

periphery. Accodring to Wallerstein’s theory, the actual world order is constructed to 

collect values for the capitalists in the core areas. 

Opposite to the critical approaches above, the World Bank’s report Globalization, 

Growth, and Poverty : Building an Inclusive World Economy presents globalisation from 

the dominant actors’ point of view. It gives a lot of facts and attention to poverty and 

development as well as to global trade. 

5


Some books specifically deal with globalisation and the mass media. Edward S. 

Herman and Robert W. McChesney’s book The Global Media : The New Missionaries of 

Corporate Capitalism has two contributions. They describe the history of globalisation of 

mass media from simple newspapers to a global and extensive industry. An interesting 

aspect is how global radio has been used in ideological warfare, especially during the Cold 

War. Further, the book describes how media business and all other global businesses are 

intertwined. The book hardly covers media’s social responsibility, and has the view that all 

mass media are purely capitalistic actors. 

Lynne Joyrich’s Re-Viewing Reception : Television, Gender, and Postmodern 

Culture is on post-modern theories. In her opinion, TV introduces its audience to a world 

of dreams where they become perfect consumers. The mass media are both agents for and 

advertising channels for commodities. TV is supposed to “drug” its audience into losing 

critical capacity and being made passive. Her perspective is that of powerful companies 

and interests using the media as agents for business. 

John C. Merrill has edited Global Journalism : Survey of International 

Communication that considers journalism as a global phenomenon. He describes how 

media are different around the world, and challenges journalists who operate in a 

globalised profession. One of his chapters is about press freedom around the world. His 

survey describes all the world’s regions in details and the book contains a lot of facts. 

However, globalisation process is taken for granted and the book does not challenge what 

the media’s role as global actors is supposed to be. 

John Herbert’s book Practising Global Journalism : exploring reporting issues 

worldwide provides discussions on different aspect of press freedom. These include the 

government perspective as well as freedom according to media’s own market-driven 

approach. The book points out how competition within the media business creates new 

threats to press freedom, not from governments but from commercial forces. 

6


The book News Culture by Stuart Allan deals with how a culture which determines 

news came up. He describes how a professional culture developed to become crucial to 

determine what is included or excluded from media’s coverage. Allan’s book is useful for 

journalists to think critically about their own professionalism. 

The book, The Globalization of News, edited by Oliver Boyd-Barrett and Terhi 

Rantanen, presents different views on global journalism and global culture. Most of all, the 

book gives attention to the dominant news agencies’ role in the globalisation process. The 

book has a broad perspective, where the news media are considered as agents for transfor- 

mation. Among the case studies, is the chapter on “From State Socialism to Deregulation” 

from Tanzania. 

The aspect of global patterns of dominance and subordination, is the major concern 

in George Gerbner, Hamid Mowlana and Kaarle Nordenstreng’s The Global Media Debate 

: Its Rise, Fall, and Renewal. During the 1970s UNESCO became the arena for the debate 

on a New World Information and Communication Order (NWICO), where poor countries 

confronted the rich world. Media’s role as a supporter of the world order, where the rich 

countries are superior, was the core of the debate, which the book describes. This is an 

important aspect about mass media and globalisation. 

The report Globalization of the Mass Media, published by the U.S. Department of 

Commerce, demonstrates most of all how global spreading of American media is a 

declared policy. The aim is stated to be to spread American businesses and American 

values. The important thing is that this report unveils pure American interests in 

globalisation, and the use of mass media. 

Concerning mass media ideology, J. Herbert Altschull’s From Milton to McLuhan : 

The Ideas Behind American Journalism gives the philosophical history of mass media 

growth in the West. The place of origin for the mass media was Europe. In the Anglo- 

American world in the 17 th and 18 th century philosophers such as John Milton, Thomas 

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Hobbes, John Locke, and David Hume were among those who influenced thinking about 

newspapers’ functions and effects in the society. In contemporary France, the great 

philosophers Montesquieu, Voltaire and Rousseau gave significant contributions. Those 

English and French philosophies merged in the founding of the new American constitution 

in 1787 and influenced development of the American concept of democracy, self-image 

and perception of the world. Understanding of present American mind of media and 

democracy is provided by Democracy and the Media edited by Richard Gunther and 

Anthony Mughan. Due to the American hegemon status in forming a global culture 

through mass media, Exploring Media Culture by Michael R. Real completes this aspect. 

An African perspective is given by Johan Retief in Media Ethics : An Introduction 

to Responsible Journalism. The book focuses on concrete ethical cases, and is written by a 

South African scholar for African journalism students. Although press freedom is not 

discussed in particular, it emerges frequently as an underlying principle. 

A number of books discuss global mass media’s role as Africa’s image builder. 

Among these is Africa’s Media Image, edited by Beverly G. Hawk. The interaction 

between global media and African domestic policy as well as foreign policy are discussed. 

The case studies cover a wide time frame from “The Media and the Mau Mau” during 

Kenya’s struggle for independence, the Cold War, and even to current covering of 

emergencies. Another case study is the book Imaging the Congo : the international 

relations of identity, written by Kevin C. Dunn. The book is not only about media, but how 

the concept of identity is of growing concern within the field of International Relations. He 

labels Congo as ‘symbol of contemporary Africa’. He argues how Western stereotypes and 

images of Congo and Congolese through their mass media have been demeaning to the 

country. Within the same perspective is Graham Mytton’s book Mass Communication in 

Africa. In particular his fourth chapter “Communication and Political Power” describes this 

thinking from political circles. He elaborates how strategies on mass media are included in 

8


the power politics, both by the colonial masters as well as the African rulers after 

independence. 

The World Bank is, among others, the chief agent for the globalisation process. 

During recent years press freedom has been included in the World Bank’s policy for 

development, democratisation and globalisation. An extensive political background for its 

policy is described in the book The Right To Tell : The Role of Mass Media in Economic 

Development, edited and published by The World Bank Institute. Most of all, the book 

discusses how to include the Third World and new democracies after the Cold War into the 

political systems built in the Western world. However, this book is more about politics 

than about journalism but it is useful in the way it looks at the media through both political 

and commercial lenses. 

However, the idea of press freedom crashes into other interests. William Miller has 

edited the book Alternatives to Freedom : arguments and opinions where such perspectives 

are described. The essays examine press freedom as opposed to parliamentary sovereignty, 

national interests, responsibility, accountability, equality, and the moral community. The 

book shows that there are many things to consider other than press freedom, takes 

democracy as a given, and the basic value of press freedom is not challenged. Some aspect 

around how the press and its role has changed through the history are given by Mitchell 

Stephens in his A History of News. The book is about news as a genre, but his chapter 

about newspapers and revolutions is enlightening. 

There are several international bodies promoting press freedom even if the 

understanding of the concept may be variable. From the beginning UNESCO has been an 

important actor. Another is International Press Institute (IPI) which was founded partly as a 

result of processes within UNESCO, and connected to the World Press Freedom 

Committee. IPI has published its own history of promoting press freedom which gives the 

aspect seen from the inside of an international organisation. Three books, a pamphlet and a 

9


report cover the years from late 1940s to 2003: IPI – The First Ten Years, IPI: The 

Undivided Word : A History of The International Press Institute : Part I: 1951-1976; IPI: 

The Defence of Press Freedom : A History of The International Press Institute : Part II: 

1976-1988; 10 Years IPI Headquarters in Vienna (covers 1993-2002); and IPI Report 2003 

: World Press Freedom Review. 

Further, books about Scandinavian or Norwegian concept of press freedom can be 

represented by Den redigerende makt : Redaktørrollens norske historie (in English: The 

editing power : History of the Editor’s Role in Norway) written by Martin Eide. This is a 

history book on how the editor’s role as an institution developed in Norway. The book 

looks at the editor as a defender of press freedom, and discusses various threats to such a 

free and powerful role. Numerous references to Sweden and Denmark make the book ade- 

quate as a source for press freedom in Scandinavia. A weakness of this book is the impres- 

sion that the editor’s freedom is limited to freedom from government control, the owners’ 

interference in editorial affairs, and some other forces which want to control the news. It 

does not discuss the possibility of being puppet of global cultural or ideological interests. 

Another Scandinavian contribution is Kyrre Eggen’s Ytringsfrihet (in English: 

Freedom of Expression). The book covers almost every question about the right of free 

speech included debates where freedom of expression is in conflict with other interests. 

This book too, has many references to Scandinavia as well as practices of free speech in a 

European legal context. However, the philosophical basis for such a democratic freedom in 

itself is not discussed very much. The author’s reason for that choice is that it is a book 

based on law, not the history of ideas. 

A global aspect from Scandinavia is given by the book Utviklingshjelp, utenriks- 

politikk og makt (in English: Development Aid, Foreign Politics, and Power) written by 

Terje Tvedt. The book is a result of a subproject in a Norwegian study of power and demo- 

cracy. One of his descriptions is how mass media as an actor is included in the Norwegian 

10


development aid policy. The book does not get into the core of press freedom, yet, media’s 

role in the interaction between Scandinavia and Africa is exposed. 

Then, books presenting the African or Kenyan concept of press freedom is repre- 

sented by Louise M. Bourgault in her Mass Media in Sub-Saharan Africa. This book gives 

a broad and extensive understanding of mass media in Africa. The historical and cultural 

background are described and Kenya is covered through different cases. A valuable 

chapter is the one which discusses press freedom according to the African oral tradition 

and discourse style. Due to changes in African countries, democracies and mass media, her 

writing is not up to date. Towards Press Freedom collects contributions from a round-table 

conference in Zimbabwe in 1996 about press freedom in Africa. Several of the participants 

give papers at the core of North-South matters of press freedom. 

A relatively simple textbook is Law and Ethics of the Media : Media Training in 

Africa written by André Linard. The book is meant generally for the whole of Africa. The 

concept of press freedom is discussed according to ethics as well as legal limits. The book 

is a basic introduction, a good one indeed, yet without any deep background. 

Another book which has a practical approach is the Handbook for African Journa- 

lists : With Leaders in African Journalism, edited by Malcolm F. Mallette. It is a simple 

and practical book. The book’s starting point is a consideration of the role of a free press 

which is a given condition for all the journalistic practice. 

A short, although important text, is Tom Mboya’s address to the IPI’s global confe- 

rence in Paris, 1962, on “Relations Between Press and Governments in Africa”, included in 

his book The Challenge of Nationhood : A collection of speeches and writings. At that 

time of liberation, he pointed out the importance of an ‘Africanised’ press. His opinions 

were similar to those which arose during the NWICO debate. His views were influential on 

thoughts on and within the Kenyan press. 

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Philip Ochieng in I Accuse the Press : An Insider’s View of the Media and Politics 

in Africa, accuses his colleagues within the Kenyan press, of joining the Western press’ 

subjugating approach to Africa. In his opinion, Western commercial interests are a more 

serious threat to the freedom of the African press than bad governments. He contributes to 

this debate with radical and anti-mainstream reasoning. The book covers Kenya, Tanzania 

and Uganda. Still in East Africa, there are three similar books which are oriented towards 

facts about media and press freedom in these countries. These are The State of the Media 

in Uganda edited by Rose Mary Kemigisha, A handbook on the State of the Media in 

Tanzania edited by Lawrence Kilimwiko and Joseph Mapunda as well as the more 

extensive Media culture and performance in Kenya edited by Mitch Odero and Esther 

Kamweru. These three books are all sponsored by Friedrich Ebert Stiftung. 

Reporting Politics and Public Affairs, edited by Charles Okigbo, portrays ideals of 

African social journalism. Distinctions of ‘African’ emerge compared with a traditional 

Western approach, for instance concerning the declared ideal of objectivity. The editor 

argues that in Africa journalism practice and political decisions are not completely 

divorced. The book is a broad and practical textbook about political journalism. Many 

books on journalism are written in the West. Therefore, this book’s major contribution is 

its African based content. 

Another core text is Ethics in Journalism : A Reader on Their Perception in the 

Third World, edited by Michael Kunczik. His question to the whole debate on media ethics 

is: Freedom of the press – where to draw the line? Further, he discusses tensions around 

Western developed values in an African context. In particular the chapter “Anglophone 

Africa: Journalists – puppets of the proprietors?”, written by Joe Kadhi, elaborates on the 

space of press freedom within the reality of an African society and ethics in journalism. 

The History of the Press in Kenya by John Baptist Abuoga and Absalom Aggrey 

Mutere gives the picture of the development of the Kenyan press, since its origin among 

12


white settlers and missionaires in 1895. The book covers emerging and foundations of the 

media organs as well as political forces, which constituted the environment. The book, 

which was issued in 1988, includes broader perspectives too, as press freedom, press 

organisations and matters on communication structure. 

Another history book is Britain’s Gulag : The Brutal End of Empire in Kenya 

recently written by Caroline Elkins. Of interest for this thesis is her descriptions on how 

the British colonial rule in Kenya manipulated media to be propaganda tools. Instruments 

established by the British have even had impact on Kenyan press freedom after 

independence. 

Mass Media and the African Society is edited by Jerry Domatob, Abubakar Jika 

and Ikechukwu Nwosu. Their testimonials to leaders of the liberated African countries are 

harsh. Media were not liberalised when these leaders continued as the colonial rulers. In 

addition, strong Western media’s influence on political dynamics in Africa, related to the 

NWICO debate, is well covered as well. Media and Democracy in Africa is edited by 

Göran Hydén, Michael Leslie and Folu F. Ogundimu. This is a relatively up to date book 

about the role of media in democratisation in Sub-Saharan Africa. The book’s perspectives 

are multi-diciplinary. It provides examinations of democratisation in Africa within 

different contexts as History, Political, Technological, Economic and Cultural. 

A new book on Kenya is Media Law and Practice : The Kenyan Jurisprudence 

edited by David Makali and published on behalf of The Media Institute. The detailed book 

has most of all a juridical approach to press freedom. From this point of view the texts 

contributes both in historical and political perspectives with a description of press freedom 

and the freedom of expression in Kenya. Several key judgements are surveyed. 

13

Theoretical Frameworks 


There are two theoretical frameworks used in this thesis; one within the realm of Inter- 

national Relations, and another theory which is specific to the press’ role in societies. 

Within International Relations theories, the field of international institutionalisation 

seems to be able to explain the phenomenon of press freedom in the perspective of globali- 

sation. Robert O. Keohane and Joseph S. Nye Jr. edited Transnational and World Politics 

in 1970, whose major concern was to describe a complex pattern of world politics. 

Keohane and Nye took a liberal stand where they emphasise all non-state actors. They 

gave a theoretical framework which is labelled liberal institutionalism, a branch within 

neo-liberalism. They presented a variety of possible international actors, both connected to 

governments and nongovernmental, as well as actors who are superior to states. Their 

framework provides understanding of global forces independent of the states’ role. 

John Gerard Ruggie, in his book Constructing the World Polity : Essays on inter- 

national institutionalization, first published in 1998, claims neo-liberals such as Keohane 

and Nye, and neo-realists such as Kenneth Waltz, have merged into the mainstream which 

he labels ‘neo-utilitarianism’, whose weaknesses are the limits of positivism. He describes 

how he, as a constructivist, is able to use something from the mainstream, but mix it with 

elements from the classical tradition of Emily Durkheim and Max Weber. He puts himself 

into a category called neo-classical constructivism. 

What makes sense between Ruggie’s constructivism and press freedom, is the 

complexity of global actors and forces, and especially the notion of agents. Those are not 

limited to the organisations even if organisations can be agents. ‘Regime’, ‘agency’, and 

‘circumstances’ are among the key concepts in constructivism. The common approach to 

press freedom in literature is functional as, for instance, such as absence of governmental 

interventions in the press’ affairs. Press freedom can be considered to be such an agent 

14


because of its capability to establish circumstances for democracy. This democratisation is 

a part of the globalisation process. 

Within theories about the media, the book Four Theories of the Press by Fred S. 

Siebert, Theodore Peterson, and Wilbur Schramm published in 1956 is a classic. They 

categorised media’s role in four different political systems: First, in authoritarian systems 

the media have to serve the central authority. Second, in libertarian systems the individual 

rights are the most important interest for the media to serve. Third, in social responsibility 

systems media need to serve both individual and society. Fourth, in communist or totalitar- 

ian systems, the media have to serve the needs of society as interpreted by the Communist 

party. Several other views have emerged out of debates on these classical models. Ray 

Eldon Hiebert and Sheila Jean Gibbons’ book Exploring Mass Media for a Changing 

World added a fifth model: the the capitalistic system where media purely exist to make 

profit for their owners. 

These five different media systems constitute a theoretical framework which this 

thesis will use on media’s role in the sosiety. Below, it is pointed out how the three 

systems of libertarian, social responsibility and capitalism influence the dominant global 

media. 

Definition and Examination of the Concept ‘Press Freedom’ 

A typical definition of ‘press freedom’ in text books has a functional approach, for instance 

such as: “the mass media’s unquestionable right to discuss whatever is not explicitly 

forbidden by law, including the wisdom of any restrictive statute”. 9 The emphasised aspect 

is the press’ independence of intereference from any external interests. The attention is 

most of all given to how political authorities give the press space and freedom to play its 

9 

Among many examples, this one is quoted from: Ahuja, B. N., Theory and Practice of Journalism (Delhi: 

Surjeet Publications, 2004), p. 4. 

15


autonomous role. An alternative approach is to emphasise press freedom as a regime, for 

instance as: “[…] This regime presupposes that information resources are significantly 

independent of political or economic powers…” 10 

The English pilosopher of the Enlightenment, John Locke, is among the most 

influental contributors to freedom thinking in Western democracies. In his contract theory, 

government need support from the governed. In addition, people have the right of 

revolution, even a duty to rise up against tyrants. These two assumptions have been the 

basis for civil rights such as freedom to say, print and publish opinions and beliefs. 11 

Search for truth was at the core in early philosophy about the press. The German 

printer John Peter Zenger, an immigrant to the United States, was in 1735 found not guilty 

in a case on seditious libel. The defense was that what he had written, was the truth. This 

was the start of the ideology where truth is given as reason for press freedom. The event is 

also celebrated as the origin of the watchdog principle. 12 

Despite honourable phrases, definitions and practices of press freedom have been 

flexible. The legal origin and the best conditions for a free press is often credited to be in 

the First Amendment of the Constitution of the United States in 1791 which states: 

“Congress shall make no law … abridging the freedom of speech, or of the press”. 13 This 

doctrine which ‘no law is the best law’ is in accordance with American liberalism where 

the ideal is a minimised state beyond serving individual freedom, order and security. The 

historical contrast was the Constitution of the Soviet Union which also guaranteed freedom 

10 

Linard, André, Law and Ethics of the Media : Media Training in Africa (Nairobi: Paulines Publications, 

2002), p. 132. 

11 

Altschull, From Milton to McLuhan, pp. 49-52. 

12 

Ibid., pp. 109-110. 

13 

Patterson, Thomas E., “The United States: News in a Free-Market Society” in Gunther, Richard and 

Mughan, Anthony (eds.), Democracy and the Media : A Comparative Perspective (Cambridge: Cambridge 

University Press, 2000), p. 242. 

16


of the press. However, what the Soviets meant was freedom from capital, careerism, and 

bourgeois archaic individualism. 14 

Another early influential thinker on press freedom is John Stuart Mill. His “Essay 

on Liberty” in 1859 has been credited as one of the founding documents of the liberalism. 

Mill was concerned with plurality, including the right to be wrong and make mistakes. The 

many sides of truth was among his reasons for need of free expression. He described that 

right as one of the most sacred. 15 Mill is much referred in Western as well as in African 

writings which indicate his global impact on the notion of press freedom. 16 

A twin concept of press freedom is ‘freedom of expression’ which is a cornerstone 

in democracy. The concepts press freedom and freedom of expression seem to overlap 

almost completely. Many text books mix these without clear distinctions but press freedom 

is among the means or conditions for a satisfactory working freedom of expression. Hence, 

these concepts are two sides of the same issue. 17 

In terms of democracy, a major point is that press freedom belongs to the public, 

not to the media corporates. If information is a public good, a necessity for democratic 

processes, the purpose for press freedom is that the press should get conditions to serve the 

public. 18 

A legal description of press freedom gives attention to four aspects of press free- 

dom. The case studies from Scandinavia and East Africa will be organised in accordance to 

this classification. One aspect is content-neutral regulations arrangements. These influence 

the media indirectly, for instance, subsidies, customs, taxation, as well as anticompetition 

14 

Siebert, Peterson and Schramm, Four Theories of the Press, pp. 125-126. 

15 

Altschull, From Milton to McLuhan, pp. 161-172. 

16 

Ogbondah, Chris W., “Media Laws in Political Transition” in Hydén, Göran, Leslie, Michael and 

Ogundimu, Folu F., Media and Democracy in Africa (New Jersey: Transaction Publishers, 2002), p. 58; 

and Makali, David (ed.), Media Law and Practice : The Kenyan Jurisprudence (Nairobi: Phoenix 

Publishers, 2003), p. 25. 

17 

Krug, Peter and Price, Monroe E., “The Legal Environment for News Media” in World Bank, The Right 

To Tell : The Role of Mass Media in Economic Development (Washington: The World Bank/WBI 

Development Studies, 2002), p. 195. 

18 

Ibid., p. 194. 

17


laws. Those instruments may incite or obstruct a country’s mass media due to political 

preferences, and decide the scope of media’s role in that society. Another aspect is 

news gathering. That is about the media’s right to access information, and exceptions, the 

media’s criminal and administrative liability, relations with and protection of confidential 

sources as well as selection systems in licensing of journalists. The next aspect is about 

content-based regulations which cover the media’s right to publish and to decide over its 

own content. That right is not absolute. Different kinds of protections are established to 

protect other interests such as the state’s collective concerns as well as other private and 

individual interests. Many competing freedoms in this area have to be regulated even in a 

liberal society. Finally, an aspect is about protection of journalistic activity. It may include 

‘internal press freedom’ which means arrangements that control the relations between 

media owners and their editorial staff. Towards authorities it is whether journalistic 

activities are offered privileges which function as protection, or opposite; harassment of 

journalists. 19 

More than 100 international non-governmental (NGO) or inter-governmental org- 

anisations (IGO) are involved in evaluating or promoting press freedom. Considered as 

agents, those organisations constitute a press freedom movement. Altogether, those 

provide numerous definitions and angles to understand, consider or evaluate press 

freedom. Among those with great impact is International Press Institute where members 

are among the senior executives in the world’s leading news media. IPI, based in Vienna, 

constitute an influential network well involved with the United Nations and UNESCO. 

IPI’s annually report World Press Freedom Review monitors press freedom worldwide by 

qualitative methods. Another important press freedom NGO is Freedom House, based in 

Washington, which through detailed legal, political and economic criteria measures press 

freedom in each country on a scale from 0 (best) to 100 (worst). A similar ranking is made 

19 Ibid., pp. 187-205. 

18


from Reporters Sans Frontieres, based in Paris, through 53 questions. Further, World Press 

Freedom Committee coordinates the majority international organisations concerned with 

press freedom. 20 WPFC’s criteria for press freedom are formulated in twenty questions, for 

instance such as: “Are there restrictive press laws, are journalists in jail, is libel a civil or 

criminal offense?” and “Is government advertising allocated fairly?” 21 

Debates on press freedom and hence, the press’ responsibility, are often a hot 

issue. 22 The question is, how can responsibility be developed when the press claims 

independence? In many countries the media have introduced their own system of codes of 

ethics. The purpose has been to create a sense of professional responsibility, as well as to 

provide the industry with a system of conflict resolution. The idea is that in such a system, 

the government will not interfere with the details of the media’s behaviour and would not 

be a part of the conflict resolutions – except in the most serious cases which appear in the 

court. Such a system, made and introduced by the press itself, would be considered as the 

practice of press freedom. A similar system, made and introduced by the government, may 

be considered as an attack on press freedom. As a part of the global spread of press 

freedom, a corresponding system of self-governing codes of ethics for the mass media 

emerge in more and more countries. 23 These are typically administered by media councils 

initiated by the press itself. 

20 Becker, Lee B., Vlad, Tudor and Nusser, Nancy, Measuring Press Freedom: A Technical Report (Athens, USA: 

Grady College of Journalism & Mass Communication, University of Georgia, 2004), pp. 1-8, 14-15 and 34-39. 

21 World Press Freedom Committee: “Criteria for Press Freedom”, 

http://www.wpfc.org/index.jsp?page=Criteria%20For%20Press%20Freedom, downloaded 28 th March, 

2005. WPFC’s homepage: http://www.wpfc.org/ 

22 Oloo, J. B., “Why media freedom is so vital” in Daily Nation (Nairobi: Nation Media Group), reader’s 

letter, 21 st December, 2003; and Ngari, Johnson L., “Freedom of the Press and its responsibility” in East 

African Standard (Nairobi: The Standard Ltd.), commentary, 27 th April, 2004. 

23 Herbert, Practising Global Journalism, pp. 69-75. 

19

Methodology 


To examine the hypothesis, the thesis’ order starts with globalisation in general, and how it 

is intertwined with the mass media. The examination of press freedom will be based on 

already published data and information. Different aspects of press in Scandinavia and East 

Africa will include some case studies. The two regions will be described by similar models 

to fit into a comparative study. Development and the status of press freedom in these two 

regions illustrate the practice of international regimes of press freedom. 

Sources will be books and academic journals in libraries such as the Lillian K. 

Beam Library at USIU as well as at UNESCO in Nairobi. There will also be personal 

contacts with key-players involved in press freedom both in East Africa and Scandinavia 

through oral interviews or e-mail. Further, some international organisations engaged in 

press freedom will provide information. Articles from magazines and newspapers as well 

as web-sites and unpublished documents will be used. 

20

Chapter 2: Globalisation of the Mass Media 


Globalised mass media supports other globalisation processes and are vehicles for the 

economic globalisation process. This chapter has three parts. First, the history of modern 

economic globalisation and its triggering forces. Second, is the mass media’s role in this 

process and media’s role in global spread of democracy as the standard of good 

governance. Third, is press freedom as a universal concept with attention to global press 

freedom regimes and critical debates. 

The Economic Globalisation 

Although there are numerous definitions of ‘globalisation’, the one employed by the 

editors of The Globalization of World Politics, John Baylis and Steve Smith, is 

appropriate. They define globalisation as: “the process of increasing interconnectedness 

between societies such that events in one part of the world more and more have effects on 

peoples and societies far away.” 1 

Milestones in the History of Globalisation 

The modern economic globalisation process can be divided into four phases. 2 First is the 

five decades before First World War dominated by the British and the French empires. 

These empires thought that an open international trade would benefit them because they 

had modern technology, steamships, railways, falling transport costs, and access to 

productive land which contributed to growth in global trade. They led colonisation in 

Africa that was part of globalisation. Some countries without colonies in Africa which 

benefitted most from the open global trade included the United States, Argentina, 

1 

Baylis, John and Smith, Steve (eds.), The Globalization of World Politics : An introduction to international 

relations, second ed. (Oxford: Oxford University Press, 2001), p. 7. 

2 

World Bank, Globalization, Growth, and Poverty : Building an Inclusive World Economy (Oxford: Oxford 

University Press, 2002), pp. 23-24. 

21


Australia, and New Zealand. These became some of the world’s richest countries due to 

land resources, the possibility to import labour force, slaves and immigrants, and export 

commodities. 3 

Second was the period between the First World War and the Second World War 4 

in which there was a decline in international trade due to growing trade barriers, 

nationalism, and international conflicts. Nationalism resulted in protectionism. 5 Increased 

trade barriers removed the benefits of technical progress. The United States, which had 

gained huge surpluses from the free trade, wanted to take advantage of the peace process 

after the First World War and advocated further liberalisation of the global economy. 

Among the ideals in the American President Woodrow Wilson’s ‘Fourteen Points’ in 1918 

was how collective security could be ensured by cooperation and free global trade. If 

countries became dependent on each other, he believed, the price of war would rise. 6 

However, the British and the French had other interests and “won” the peace settlement 

including economic punishment of the Germans who failed to pay the imposed penalties. 

Trade barriers increased, trade policy supported cartels which excluded foreign 

competitors. 7 The Great Depression after 1929 worsened the economic situation around the 

world. These forces paved the way for Adolf Hitler and for another World War. 

Third was the period after the Second World War in which Britain and the other 

European empires were bankrupt and broke into pieces. When British Prime Minister, 

Winston Churchill, pleaded with the United States for help during the war, the Americans 

3 

Ibid., pp. 23-26; and Herman, Edward S. and McChesney, Robert W., The Global Media : The New 

Missionaries of Corporate Capitalism (London: Continuum, 1997), pp. 16-17. 

4 

The era from the First World War to after Second World War is based on: Williams, Andrew, Failed 

imagination? : New world orders of the twentieth century (Manchester: Manchester University Press, 

1998), pp. 50-78; and World Bank, Globalization, Growth, and Poverty, pp. 26-28. Other sources are 

indicated. 

5 

Halliday, Fred, “Nationalism” in Baylis and Smith (eds.), The Globalization of World Politics, pp. 441-448. 

6 

Carruthers, Susan L., “International history 1900-1945” in Baylis and Smith (eds.), The Globalization of 

World Politics, pp. 56-57. 

7 

Porter, Michael E., “Competition in Global Industries: A Conceptual Framework” in Porter, Michael E. 

(ed.), Competition in Global Industries (Boston: Harvard Business School Press, 1986), pp. 42-43. 

22


took the opportunity to dictate the objectives of the war according to suit American 

interests. Global cooperation and free trade should be the order, under the United States’ 

hegemony and institutions such as the United Nations, the International Monetary Fund 

(IMF), the World Bank, and the General Agreements on Tariffs and Trade (GATT) were 

designed as agents for this new world order. 8 

Global trade in this period meant increase in trade between developed countries, but 

trade barriers towards developing countries. Most of the developing countries did not 

participate in the growth of global manufacturing and trade during this period. 9 Some 

statistics may prove this unfair in global trade. From 1948 to 1988 British export per capita 

increased 305%, compared to the figure for Sub-Saharan countries which was 11%. 

Concerning import, corresponding figures are similar. In 1948, the British exported 12 

times more per capita than the Sub-Saharan countries, a proportion that grew to 44:1 in 

1988. For import, corresponding figures are 15:1 in 1948 and 56:1 in 1988. 10 Yet, Japan is 

considered to be the winner of this period of globalisation. Japan rose from war ruins to be 

an economic superpower. 11 

Fourth is the period after the 1980s that changed the globalisation process. 12 Firstly, 

a group of developing countries broke into the global markets. Among them are China, 

India, Malaysia, the Philippines, and Thailand as well as Argentina, Mexico and Turkey. 

Altogether, the population of these countries is more than three billion. Secondly, other 

developing countries became increasingly marginalised, especially in Africa. Thirdly, the 

Cold War ended. Russia and her former allies were absorbed into a United States 

8 

Williams, Failed imagination?, pp. 79-141; and Woods, Ngaire, “International political economy in an age 

of globalization” in Baylis and Smith (eds.), The Globalization of World Politics, pp. 278-282. 

9 

World Bank, Globalization, Growth, and Poverty, pp. 28-31. 

10 

Rothgeb, John M. Jr., “The Changing International Context for Foreign Policy” in Neack, Laura, Hey, 

Jeanne A. K. and Haney, Patrick J. (eds.), Foreign Policy Analysis : Continuity and Change in its Second 

Generation (Englewood Cliffs, N.J.: Prentice Hall, 1995), pp. 39-46. 

11 

Porter, Michael E., “Competition in Global Industries”, p. 44. 

12 

The era after 1980s is based on: World Bank, Globalization, Growth, and Poverty, pp. 31-51; and 

Williams, Failed imagination?, pp. 236-239. 

23


dominated globalised economy. Fourthly, the globalised corporates and non-governmental 

actors increased in number and strength so much that they overshadowed states and raised 

questions of who was in charge; whether it was the big CEOs or the American politicians. 

Fifthly, is the renewed flow of migration and capital. During the first period of modern 

globalisation, about 10% of the world’s population was relocated. At the same time, there 

were few hindrances to international capital flow. These two phenomena have re-emerged 

with the reduction of control of capital flow and relocation of people. Approximately 120 

million people live in foreign countries. In that way, globalisation makes a web of personal 

strings around the world. These kind of connections and kinships stimulate international 

trade. 

The Forces Behind the Globalisation Processes 

Economic forces drive economic globalisation. According to the World Bank, the 

newcomer countries in the globalised economy, made their success almost by themselves. 

They helped their firms to break into industrial markets by improving infrastructure, skills 

and institutions, which modern production and marketing needed. 13 The marginalised 

countries have, according to the World Bank, bad infrastructure, poor education, rampant 

corruption, high trade barriers, and lack of adequate institutions. 14 Among African 

countries, the World Bank and IMF’s policy have had positive results in Uganda in terms 

of economic growth, 15 and more or less collapsed in Zambia. 16 

13 

World Bank, Globalization, Growth, and Poverty, pp. 32-38. 

14 

Ibid., pp. 38-41. 

15 

Leggett, Ian, Uganda : the background : the issues : the people : An Oxfam Country Profile (London: 

Oxfam/ Kampala: Fountain Publishers, 2001), pp. 5 and 60-62; and Datta-Mitra, Jayati (ed.), Uganda : 

Policy, Participation, People (Washington: The World Bank, 2001), pp. 3-7 and 13. 

16 

The report Zambia: Condemned to Debt, made by the London-based NGO World Development 

Movement, is referred to in: Suri, Sanjay, “How IMF, World Bank Brought Down Zambian Economy” in 

The East African (Nairobi: Nation Media Group), news article, 7 th June, 2004. 

24


Globalisation subordinates liberal ideals and the state has to serve the economic 

interests even if these are against its own citizens. 17 As described by Richard Falk, Profes- 

sor Emeritus of International Law at Princeton University, and a well known critic to 

mainstream liberal global politics: 

“[globalization has] broken the social contract that was forged between state 

and society … global apartheid … adverse effects … insensitivity to human 

suffering … insufficient attention to ecological sustainability … polarization 

… marginalization … give government little political space. States are coopted 

or subordinated, weakening impulses to regulate on behalf of the 

common good.” 18 

This opinion is shared by those who claim that the globalisation process can be good if the 

starting point could be the needs of people and not of companies. 19 Similar is the theory on 

‘world-system’ attributed to Immanuel Wallerstein who described the world as core, peri- 

phery, and semi-periphery. 20 The core is the centre for capitalists, where they collect the 

surplus of their business. The raw materials are produced in the periphery where the labour 

is unsecured and underpaid. In the middle, is the semi-periphery where the welfare is low, 

however, states and people in this group benefit from the capitalists so that they contribute 

to stabilise the system. From Wallerstein’s point of view the globalised international 

system is developed to serve capitalist interests. 21 This picture of the world is adopted by 

several writers on mass media’s role in globalisation. 

The present stage of economic globalisation is made by the architects of American 

foreign policy. They have made a world order where the forces that resulted in world wars 

are removed. At the same time, the interests which benefit from that order are most of all 

17 

Petras, James and Veltmeyer, Henry, Globalization Unmasked : Imperialism in the 21st Century (London: 

Fernwood Publishing, 2001), p. 12. 

18 

Falk, Richard, Predatory Globalization : A Critique, (Cambridge: Polity Press, 1999), cut from pp. 3, 15 and 71. 

19 

Mkapa, Benjamin and Halonen, Tarja, “Globalisation Can Work, the Question is: How?” in The East 

African (Nairobi: Nation Media Group), commentary,15 th March, 2004. 

20 

Smith, “Reflectivist and constructivist approaches to international theory”, p. 237; and Dunne, Tim: 

“Liberalism” in Baylis and Smith (eds.), The Globalization of World Politics, p. 179. 

21 

Wallerstein, Immanuel, “The inter-state structure of the modern world-system” in Smith, Steve, Booth, 

Ken; and Zalewski, Marysia (eds.), International theory: positivism & beyond (Cambridge: Cambridge 

University Press, 1996), pp. 87-107. 

25


located in the United States. 22 The system is wrapped up with concepts of American 

ideology. In that way, globalisation has led to a global American empire. 23 

That empire, according to Noam Chomsky, is full of contradictions between what 

the United States professes and what it practices at the global level. Noam Chomsky is a 

Professor of Linguistics at the Massachusetts Institute of Technology. The ‘war on terror’, 

he argues, is an excuse for forcing regimes to adapt an American friendly policy while the 

United States itself ‘is a leading practioner of international terrorism’. 24 On ‘human rights’, 

he notes that the United States gave aid to regimes in Latin America who tortured their 

citizens, 25 and that the media in the United States serve the American elite interests and in 

fact undermine democracy. 26 

Mass Media Involvement in Globalisation 

Mass media in general are involved in globalisation in two ways. First are the mass media 

as global industry. Second are mass media as the core spreading democracy, shaping 

liberal world order and creating globally shared culture. 

The concept of ‘media globalisation’ or ‘global media’ means large cross-border 

flows of mass media content, growth of transnational media corporations, centralisation of 

media control, and a strong emphasis on the commercial side of media activities. 27 There is 

a distinction between the ‘medium’ and the process of ‘mass communication’. Media are 

instruments of that process. Any instrument that makes ‘mass’ communication can be 

22 Williams, Failed imagination?, pp. 284-286. 

23 Petras and Veltmeyer, Globalization Unmasked, pp. 61-73. 

24 Chomsky, Noam, “Commentary: moral truism, empirical evidence; and foreign policy” in Review of 

International Studies (Cambridge: Cambridge University Press, 2003), p. 610. 

25 Chomsky, Noam, “United States and the challenge of relativity” in Evans, Tony (ed.), Human Rights Fifty 

Years On : A reappraisal (Manchester: Manchester University Press, 1998), p. 27. 

26 Herring, Eric and Robinson, Piers, “Too polemical or too critical? Chomsky on the study of the news 

media and US foreign policy” in Review of International Studies (Cambridge: Cambridge University 

Press, 2003), pp. 554-556. 

27 Herman and McChesney, The Global Media, p. 8. 

26


defined as a ‘mass medium’. 28 Even if mass media may have a broad meaning which 

includes even films, computer games and recorded music, the focus is on mass media with 

declared social purposes; such as newspapers, parts of radio and TV, and some magazines 

and books. Sometimes, these are also categorised as ‘news media’. 

How Mass Media Came to be a Globalised Industry 

A historical description of how mass media became a global business starts with the news 

agencies. During 1850s the Reuters (Britain), Havas 29 (France), and Wolff (in areas which 

became Germany) created a cartel. They divided functions for providing news from 

European colonies to the networks of newspapers in their countries. After some years, the 

American Associated Press (AP) and the rival United Press, joined the cartel. This is the 

origin of global production of content and the foundation of transnational media 

corporations. 30 

Then, the film industry took its global steps. Hollywood became quickly the 

world’s film capital. As early as 1914, 85% of the world’s film audience watched 

American films. That rose to 90% before “talkies” created language barriers, which 

resulted in a decline of the American film’s global share. However, links between Wall 

Street’s investments, Hollywood’s film projects, and a global market were established. 

British film industry, the sole global challenger to the American, was bought by 

Hollywood in the 1960s. 31 

Public radio dominated Europe from the earliest years and spread to other parts of 

the world. The new technology of short wave was introduced at the end of 1920s, and 

removed the borders as limits of radio broadcasting. Radio became global, the whole world 

28 Hiebert, Ray Eldon and Gibbons, Sheila Jean, Exploring Mass Media for a Changing World (London: 

Lawrence Erlbaum Associates, 1999), p. 23. 

29 Now renamed to Agence France Presse, AFP. 

30 Herman and McChesney, The Global Media, pp. 12-13 and 18-19. 

31 Ibid., pp. 13-15 and 19. 

27


could be served from only one sender, and became a tool of ideological warfare. Soviet 

Union started, followed by the Nazi Germany, fascists in Italy, BBC, and Voice of 

America in spreading their propaganda worldwide. After 1945, shortwave radio became 

the Cold War’s arena for radio warfare. At its peak, 55 countries entered the shortwave 

arena with the BBC broadcasting in 46 languages. The Americans used the radio actively 

to support their operations in Latin America too. 32 

Recorded music grew close to radio as provider of content. The music industry was 

similar to the film industry, and music was included in large cross-media companies. Five 

firms have dominated this business and have the main share of global sale; the American 

CBS, Warner Brothers, and RCA, besides the British EMI and the Dutch PolyGram. 33 

Televison emerged as the most important new media technology in the postwar 

period. Very quickly, televisions were spread in the United States. As an industry, the large 

television companies faced strong regulations when those should grow globally. Even if 

those had bought shares in television companies abroad, regulations both at home and in 

countries which wanted to protect their own culture – or by other agendas – locked out the 

global TV industry. The door to globalisation of the television therefore became the pro- 

gramming, which met regulations too. The American television companies and the BBC 

took the dominance in two areas where they were permitted to operate, that was on news 

and sports. Hollywood’s film studios were allowed to take ‘the rest’. 34 

Among the different mass media, television is considered to be the one where 

interaction between content and commerce is developed to the higest level. Some examples 

which support this view are: Priority to programs which give commercials an attractive 

context and public; product placement in programs as ‘hidden promotion’; and finally how 

consumer ideology is introduced to the public, that creates like-minded consumer needs. 

32 Ibid., pp. 14-16. 

33 Ibid., pp. 18-20. 

34 Ibid., pp. 20-22. 

28


Television gives them the perfect role as the connection between the commodity producer 

and its market. 35 

Newspapers were the earliest widespread mass media, but remain as the part of the 

media industry which is least integrated into the global system. 36 Foreign ownership in 

major newspapers is still relatively low. 37 The globalisation process has even, as a reaction, 

contributed to a wave of ‘localism’ that local media benefit from. 38 That trend is an 

advantage for newspapers. However, newspapers are completely included in the mass 

media’s transferring of news and influence around the world. Further, newspapers have 

often an élitist public and traditions that make this medium especially influential. 39 

Books grew as a mass medium where concentration of the publishing business was 

consolidated, but to a lesser degree than the film industry. In the early 1970s, the number 

of annual new titles in some countries were: the United States 80,000; United Kingdom 

40,000; France 30,000; Nigeria 1,316; and Kenya 224. India developed a significant book 

industry, yet a little export trade came from this industry. Later, the book industry came to 

be concentrated and linked to large global media corporations. 40 

The internet is the youngest widespread mass media which has achieved global 

penetration faster than any other media. However, the bias in access and use between the 

rich and the poor world is extreme. The internet is more complex than any other broad or 

narrow media. Internet represents the convergence between content, technology, and 

communication. In that way the internet is the ultimate global roundabout of media from 

many points of view; content, users, owners, technology, politicians and sellers, with all its 

35 

Joyrich, Lynne: Re-Viewing Reception : Television, Gender, and Postmodern Culture (Indianapolis: 

Indiana University Press, 1996), pp. 9-14 and 169-175. 

36 

Herman and McChesney, The Global Media, p. 12. 

37 

Islam, Roumeen, “Into the Looking Glass” in World Bank, The Right To Tell : The Role of Mass Media in 

Economic Development (Washington: The World Bank/WBI Development Studies, 2002), p. 21. 

38 

United States’ Department of Commerce, Globalization of the Mass Media (Washington: U.S. Department 

of Commerce, 1993), pp. 215-217. 

39 

Islam, “Into the Looking Glass”, pp. 16-18; and Hiebert and Gibbons, Exploring Mass Media for a 

Changing World, p. 141-142. 

40 

Ibid., pp. 19-20. 

29


threats and possibilities. The internet will, as other media, produce new winners and losers. 

How the internet will change political patterns is still too early to determine. 41 

From a functional point of view, globalisation of mass media has resulted in some 

key features. First, global media channels reach all the places on the globe. Second, even 

local media are influenced by globalism in its content, or ownership as well as through 

market forces. Third, a global audience has emerged and share a great part of common 

content and experiences, including commercials and the content’s underlying ideology. 

Fourth, the increased number of media have penetrated almost all everyday situations. The 

mass media’s variety has been developed to pluralism in all its dimensions. Fifth, the 

owners have grown in size, declined in numbers, and have constructed connections 

between different media which constitute great conglomerates with a large number of 

media. The result is a concentration of media control into few hands. These are in the 

cores, in terms of the world-system theory. Sixth, crossconnections within media, conver- 

gence, and media connections to commodities have intertwined mass media together with 

each other, with communication technology and with other kinds of industry. Seventh, the 

bias between the rich and poor parts of the world in access and use of media is extensive. 

And finally, media have always played a political role. Emergence of global media 

increase the strengths to play a role in global politics, culture, and promotion. 

The forces which triggered the globalisation of mass media are the logic of econo- 

mic growth, similar to other globalised business. In media, growth in audience is the key to 

success. 42 Growth can emerge as ‘segment growth’ where target groups or the assortment 

of products are increased in specific market niches. Another is ‘vertical growth’ where, for 

instance, a film producer enter into cinemas and TV stations. The ‘geographical growth’ is 

41 Aronson, Jonathan D., “The communications and Internet recolution” in Baylis and Smith (eds.), The Globalization 

of World Politics, pp. 541-551; and Strömberg, David, “Distributing News and Political Influence” 

in World Bank, The Right To Tell : The Role of Mass Media in Economic Development (Washington: The 

World Bank/WBI Development Studies, 2002), p. 104. 

42 Strömberg, “Distributing News and Political Influence”, p. 96. 

30


to spread already established business geographically. 43 Even if the geographical direction 

is the globalisation issue, these kinds of growths support each other. 44 The advertisement 

industry’s need of global markets have also supported globalisation of mass media. Other 

forces behind globalisation of media have been migration, propaganda for political 

ideology, new technology and a more connected world in any ways. 

Press Freedom and Spread of Democracy 

Globalisation spreads democracy as the standard of good governance. Democracy is 

associated with free press which is considered as a cornerstone of democratisation. 45 

Western democracies are influenced both by the libertarian system of the role of media as 

well as a sense of social responsibility and the capitalistic system. First, liberal ideals, 

which grew together with the development of the democracy in Western countries, ruled 

the press. 46 Then, after the Second World War, two trends resulted in the rise of a social 

responsibility view within the Western press. On one hand, the press was included in the 

optimistic democratic wave in the Western world immediately after the Second World 

War. The press took a key role in the building of these new democracies, and in the 

consolidation of existing democracies, 47 and at the same time became aware of its own 

increasing potential. A growth of scandalous popular newspapers and purely entertaining 

mass media, such as radio and films, had squeezed the established press which became 

more concerned about its own role. 48 

43 Porter, Michael E., “Competition in Global Industries”, p. 22. 

44 Herman and McChesney, The Global Media, pp. 40-45 and 54. 

45 Gunther, Richard and Mughan, Anthony, “The Media in Democratic and Nondemocratic Regimes: A 

Multilevel Perspective” in Gunther, Richard and Mughan, Anthony (eds.), Democracy and the Media : A 

Comparative Perspective (Cambridge: Cambridge University Press, 2000), pp. 5 and 9. 

46 Altschull, From Milton to McLuhan, pp. 167-172. 

47 Righter, Rosemary, IPI: The Undivided Word : A History of The International Press Institute : Part I: 

1951-1976 (London/Zurich: The International Press Institute, 1988 [1976]), pp. 10-11 and 21. 


31


In the United States some of these aspects were picked up by the Hutchins 

Commission in 1947. It criticised sensational trends, examined the role of the press, and 

came up with the concept of ‘social responsibility’. 49 Ideally, media’s social responsibility 

in a democracy is to influence economic, political and social outcomes to be the best for 

the citizens. 50 The debate on New World Information and Communication Order (NWICO) 

can be considered to be a global consequence of this trend of social responsibility. The last 

system, capitalism, increased its influence during the last decades. That system influenced 

the majority of media to make profit for the owners as the primary purpose, before the 

media can fulfill its social purposes. 51 

The idea of a democracy is the rule of the people. 52 A condition of such a broad 

involvement of people is the need for information. Since the government is supposed to act 

in the interests of its citizens, information is a public good that people need in order to 

participate in the democratic processes. The free media’s role is to gather and distribute 

information to ensure that the elected government works for its people. Open access to 

information ensures quality in debates and decision making processes resulting in the best 

politics for the public. Such openness and flow of information are essential parts of good 

governance. 53 While press freedom ensures independent information, a plurality of media 

actors will enhances the possibilities that each voice would have access to the public 

sphere even if each single channel is influenced by particular interests as they compete in 

the ‘marketplace of ideas’. This concept is based on John Stuart Mill’s philosophy. 54 

The information process in a democracy includes many actors beyond a free press. 

These may be opposition parties, a myriad of public interest organisations, as well as 

49 

Ibid., pp. 283-287. 

50 

Islam, “Into the Looking Glass”, p. 21. 

51 

Hiebert and Gibbons, Exploring Mass Media for a Changing World, pp. 45-49. 

52 

Philip’s, Philip’s Encyclopedia, p. 271. 

53 

Stiglitz, “Transparency in Government”, p. 27-43. 

54 

Altschull, From Milton to McLuhan, p. 40. 

32


persistent individuals. These forces supposedly check the authorities, whether 

governments, private institutions, organisations and powerful individuals. Forces within 

the private corporate sector and the civil society have to be subjected to the same critical 

attention by media as government. 55 

Even within liberal philosophy, press freedom will come into conflict with other 

freedoms and values. These may, for instance, be need for secrecy; individual, institutional 

and national interests; and different ways to consider responsibility. 56 Therefore, press 

freedom has to be balanced with other freedoms or concerns. Such a ranking of press 

freedom against other concerns is what the whole process about implementing of press 

freedom is about. 

Freedom of expression, including freedom of the press, grew up together with ideas 

of the Enlightenment. 57 As a universal principle it found its way into the Human Rights 

Declaration by the United Nations at 1948. 58 Article 19 states that: “Everyone has the right 

to freedom of opinion and expression; this right includes freedom to hold opinions without 

interference and to seek, receive and import information and ideas through any media and 

regardless of frontiers.” 59 However, due to the great degree of differences in traditions and 

politics around the world, the power of the Human Rights article 19 is limited. Hence, the 

European Convention on Human Rights article 10 – with similar content – makes a 

55 

Stiglitz, “Transparency in Government”, p. 40; and Dyck, Alexander and Zingales, Luigi, “The Corporate 

Governance Role of the Media” in World Bank, The Right To Tell : The Role of Mass Media in Economic 

Development (Washington: The World Bank/WBI Development Studies, 2002), 107-111; and 

Transparency International – Kenya, Lesson From the Fight Against Corruption (Nairobi: Transparency 

International – Kenya, 2001), pp. 12-13. 

56 

Miller, William L. “Introduction: Alternative values” in Miller, William L. (ed.), Alternatives to Freedom : 

arguments and opinions (New York: Longman, 1995), pp. 1-17. 

57 

Altschull, From Milton to McLuhan, pp. 101-102; and Eide, Martin, Den redigerende makt : 

Redaktørrollens norske historie (Kristiansand, Norway: IJ-forlaget, 2000), p. 115. 

58 

United Nations, Basic Facts About the United Nations (New York: United Nations, 2000), pp. 216-217. 

59 

World Press Freedom Committee: “Fundamentals”, http://www.wpfc.org/index.jsp?page=Fundamentals , 

downloaded 28 th March, 2005. WPFC’s homepage: http://www.wpfc.org/ 

33


stronger protection of these freedoms than the universal declaration. The reason is that the 

European countries have a more homogeneous history than other parts in the world. 60 

The United States dominates how concepts such as democracy and press freedom 

are interpreted around the world. Characteristic values of the American society are 

optimism, action, belief in progress, growth and science, as well as education as the key to 

the future. In such a value system, the press have a prominent role and is a strong 

instrument of power with a great potential for good. 61 In the United States political and 

commercial interests benefit from global spreading of American values, supported by the 

mass media. 

Mass media produce or influence a society’s shared experience and understanding. 

Even if a medium can have objectivity as a declared goal, this is difficult. The whole 

process of deciding policy, selecting focus, selecting information, presentation, and 

distribution are all influenced by someone’s subjective opinion. That ‘someone’ is the 

force that rules the actual medium. In that way, media are a main source for a community’s 

ideology. Despite the media’s plurality, the interests of a few are the determining factor. If 

all the dominating mass media are streamlined according to their interests, then, the public 

opinion is not a result of plural impulses by the media, but a result of many media impulses 

similarly lopsided by the same interests. Such kind of systematically lopsided information 

will sway the ideology in the same direction. 62 

Theories about mass media in terms of ideological hegemony were made by 

Marxist critics such as T. W. Adorno, Max Horkheimer, and Herbert Marcuse. They claim 

that mass media have risen under capitalism and mass media have been instruments of 

commodification. Mass media have created a mass culture that successfully channels 

desire into a commodity structure, manipulates the audience’s sense of needs, and 

60 

Eggen, Kyrre, Ytringsfrihet : Vernet om ytringsfriheten i norsk rett (Oslo: Cappelen, 2002) , pp. 136-138. 

61 

Altschull, From Milton to McLuhan, p. 238. 

62 

Briggs, Adam and Cobley, Paul (eds.), The Media: An Introduction (Essex: Longman, 1998), pp. 277-282. 

34


homogenises pleasure. In that way commercial interests have determined the logic of mass 

media because they provide the mass media’s income. That process includes more than 

commercials and advertisements. The whole underlying ideology imparted through the 

editorial content, the programs, films, and music, will together influence the public’s 

feelings of needs as consumers. Simultaneously, these media have offered a perfect 

occasion for its advertisers’ messages. In that way, the mass media create a consumer 

ideology that creates markets and supports the advertisers commercial interests far beyond 

the actual advertisement, claim these critics. 63 

Economic globalisation include spreading of democracy including press freedom. 

The economic interests behind globalisation expect the democracy to not only be good for 

its citizens, but also to give commercial business the best conditions possible. Regarding 

the public, the idea is that economic growth will provide everyone with improved welfare. 

That is the theory, the practical experience gives another record where the gap between 

rich and poor is widening. However, due to such a philosophy, spreading democracy 

means advancing the interests of those behind economic globalisation. 64 It is here where 

press freedom comes in. The dilemma is that spreading of press freedom conducted by the 

interests behind globalisation is similar to spreading of business freedom. That is not 

identical with press freedom in terms of social responsibility. 

Jürgen Habermas is concerned with media and global aspects of democracy. He is 

Professor Eremitus at the University of Frankfurt, and Professor of Philosophy at 

Northwestern University in the United States. He emphasises the contradiction between 

democracy limited to state borders, when the economic and cultural forces work globally. 

His theory on ‘radical democracy’ says that state borders are obstacles for democratic 

63 Joyrich, Re-Viewing Reception, pp. 22-26 and 33. 

64 Islam, “Into the Looking Glass”, pp. 21-22. 

35


rights. He recognises media’s role in global democracy, but has a critical approach to 

whose interests media actually are serving. 65 

Press freedom as means of democracy or human rights has been criticised. One 

problem can be a narrow understanding of press freedom, for instance freedom to publish 

without free access to information. Despite declared press freedom, such a practice is a 

sabotage of public’s right to know, a condition for freedom of expression. 66 Or as stated by 

the Malaysian foreign minister Abdullah Badawi at the summit of the Association of 

South-East Asian Nations (ASEAN) in 1998: “Too much freedom could destroy 

democracy.” 67 Several regimes have developed press freedom instruments such as ‘code of 

ethics’ and a ‘national press council’ in democratisation processes. However, the purpose 

for using these terms has been to get recognition by the dominant countries in the 

international community, but not necessarily to increase the practice of press freedom. 68 

Another problem can be that the press has freedom, but do not use it to fulfil demo- 

cratic goals. The media are described as gatekeepers for the public debate. 69 The issue is 

about what guiding principles determine media’s performance, is it social responsibility or 

profit? In this case, Noam Chomsky stated that “in relatively free societies without state 

controls, the sinister fact is that censorship is largely voluntary.” 70 That means that press 

freedom is established, but is not utilised to all its limits to achieve democratic goals. 

65 Habermas, Jürgen, “Toward a Cosmopolitian Europe” in Journal of Democracy (Baltimore: The Johns 

Hopkins University Press, 2003), volume 14, number 4, pp. 86-100; and Hobden, Stephen and Jones, 

Richard Wyn, “Marxist theories of International Relations” in Baylis and Smith (eds.), The Globalization 

of World Politics, pp. 214-216. 

66 Linard, Law and Ethics of the Media, pp. 15-17. 

67 Kunczik, Michael, “Closing remarks: Is there an international ethics of journalism?” in Kunczik, Michael 

(ed.), Ethics in Journalism : A Reader on Their Perception in the Third World (Bonn: Friedrich-Ebert- 

Stiftung, 1999), p. 256. 

68 Moisy, Claude, ”Imposing Code of Ethics for Journalists : Less Innocent Than They Might Seem” in The 

World Press Freedom Committee, New Code Words For Censorship : Modern Labels for Curbs on the 

Press (Reston, USA: The World Press Freedom Committee, 2002), pp. 5-6. 

69 Richardson, Brian, “The Public’s Right to Know: A Dangerous Notion” in Journal of Mass Media Ethics 

(New Jersey: Lawrence Erlbaum Associates, 2004) volume 19, number 1-2004, pp. 52. 

70 Chomsky, “United States and the challenge of relativity”, p. 25. 

36


Concerning human rights, a purpose of press freedom is to protect all the other 

human rights. 71 However, many countries even reject that human rights are universal. 72 

More than 120 new states have come into being since the Universal Declaration of Human 

Rights of 1948. From Asia and Africa it is argued that the emphasis on individual rights is 

inappropriate. 73 Some of these poor countries have even refused to approve some of the 

United Nations’ conventions concerning free media. They consider these to be 

arrangements which further consolidate Western media as means for dominance over poor 

countries. 74 

An effect of globalisation is a separation between principles of human rights and its 

realisation. That means that the principles of these freedoms and rights have spread but 

adverse effects of globalisation have hindered realisation. 75 Regarding global governance, 

press freedom concerns democracy, social responsibility and human rights. In 

globalisation, economic forces have moved from state to global level. The political power, 

however, remains mainly at state level. The United Nations or any other has not achieved 

position to conduct a strong global governance. 76 In states, it is expected that press freedom 

is cornerstone of good governance in public as well as in private sector. 77 When it comes to 

global governance, global media seem not to use press freedom to carry out social 

responsibility to fulfil universal human rights. This is because the global ruling elites are 

71 

An-na’im, Abdulla, “The Freedom of Expression as a Universal Human Right” in Willie Musarurwa 

Memorial Trust, Towards Press Freedom (Harare, Zimbabwe: Willie Musarurwa Memorial Trust and 

Konrad Adenauer Stiftung, 1996), p. 24. 

72 

Kunczik, Michael, “Introduction: Freedom of the press – where to draw the line?”, in Kunczik, Michael 

(ed.), Ethics in Journalism : A Reader on Their Perception in the Third World (Bonn: Friedrich-Ebert- 

Stiftung, 1999), p. 7. 

73 

Kunczik, “Closing remarks: Is there an international ethics of journalism?”, pp. 255-256. 

74 

Ahuja, Theory and Practice of Journalism, p. 185. 

75 

McGrew, Anthomy, “Human rights in a global age: coming to terms with globalisation” in Evans, Tony (ed.), 

Human Rights Fifty Years On : A reappraisal (Manchester: Manchester University Press, 1998), pp. 188-189. 

76 

Falk, Predatory Globalization, p. 61. 

77 

Dyck and Zingales, “The Corporate Governance Role of the Media”, p. 135. 

37


powerful enough to manipulate press freedom and universal human rights to serve their 

interests. 78 

Press Freedom as a Universal Concept 

Concepts such as ‘democracy’ and ‘press freedom’ do not come up or spread by 

themselves, they are formualted and promoted by competing forces pushing their particular 

interests. When globalisation spreads press freedom, questions arise as to who defines, 

pursues and practises press freedom as a universal concept. According to constructivism 

theory, these questions are discussed with attention to global regimes, agents for press 

freedom, and how circumstances constitute good conditions for press freedom. 

International Regimes on Global Press Freedom 

Regimes on press freedom are for instance legal conventions, institutions or NGOs which 

have gained authority to decide or influence in such matters. A clear regime on press 

freedom is maintained by the United Nations. The Secretary-General Kofi A. Annan 

formulated the present universal notion of press freedom as: “A free press is one of the 

most essential components of a democratic society, which in turn is a prerequisite for 

sustainable social and economic development.” The United Nations has also declared 3 rd 

May every year to be observed as the Press Freedom Day. 79 

Article 19 in the Universal Declaration of Human Rights of 1948 deals with 

freedom of information. Its roots are in the 17 th century Enlightenment and ideals 

associated with the development of Western democracies. After 1948, the United Nations 

developed more details on conditions for press freedom. These include the Convention on 

Freedom of Information as well as The Convention on the International Transmission of 

78 An-na’im, “The Freedom of Expression as a Universal Human Right”, p. 25. 

79 United Nations, “Joint Message for World Press Freedom Day 3 May 2001”. A leaflet published by United 

Nations, UNESCO, and UN High Commissioner for Human Rights. 

38


News and the Convention on the International Right of Correction. 80 In this way the United 

Nations played a leading role in formulating and implementing an international regime on 

press freedom. On this basis even strong regional regimes, such as the European Con- 

vention on Human Rights, are constituted. 81 

The United Nations is influenced heavily by the United States. The philosophy of 

the Enlightenment had a great impact on American thinking about journalism and press 

freedom. 82 In the era of globalisation under the United States’ hegemony, the American 

version of these freedom ideals has been spread. Article 19 in the Universal Declaration of 

Human Rights upholds similar ideals as those for press freedom in the United States. 

In several ways the United States is a chief actor in forming and spreading press 

freedom globally. American actors have been substantial donors to campaigns and NGOs 

concerning global spread of press freedom. 83 American media practice has influenced 

similar development in other countries, for instance regarding the Fourth Estate role and 

commercialisation. Notions of the press as the Fourth Estate in its role as watchdog 

emerged first in the United States. The mainstream American view has regarded an 

independent press to be in an adversarial role to government, 84 that is widely accepted as 

the model which serves democracies best. 85 

Americans have also spearheaded commercialisation of media. In the United States 

the view has been that only a market-based press can be independent and play a 

democratically legitimate role. 86 Recent debates on American media claim that ideals such 

80 Ahuja, Theory and Practice of Journalism, pp. 179-184. 

81 Herbert, Practising Global Journalism, pp. 68-71; and Carver, Richard, Coliver, Sandra, Lauriciano, Gil, 

Lush, David and Maja-Pearce, Adewale, Who Rules the Airwaves : Broadcasting in Africa (London: 

Article 19 and Index on Censorship, 1995), pp. 23-27. 


83 Righter, IPI: The Undivided Word, pp. 29, 107, 111, 147 and 162 points out Ford Foundation, Rockefeller 

Foundation, Carnegie Endowment for International Peace and 20 American newspapers, as examples. 

84 Patterson, “The United States: News in a Free-Market Society”, pp. 248-251. 

85 Islam, “Into the Looking Glass”, pp. 2-5. 

86 Herman and McChesney, The Global Media, p. 24. 

39


as social responsibility and a free marketplace of ideas have lost value since the chief goal 

has been to create and attract a large audience for advertisers, to gain profit. 87 Acceptance 

of claims that media have to be successful businesses in order to play a political and 

cultural role, and to support economic development, 88 illustrate how the Americans define 

and globally influence notions of press freedom being markets as bases for independence. 

Despite the United States’ high democratic profile, there are times when press 

freedom is in conflict with interests of the political elites. 89 An example is the treatment of 

journalists in the war in Iraq in which journalists were embedded or had to be licensed to 

be in the Iraqi war zone. A study on the practice from March to May, 2003, concluded that 

there were a vast number of press freedom violations by the United States led coalition that 

targeted non-embedded journalists for harassment and confiscation of equipment. These 

journalists were fired upon and even deported. An American general pointed out that only 

embedded journalists would receive protection which contradicts the 1949 Geneva 

Convention as well as human rights. 90 

Agents are individuals, insitutions or forces which promote regimes. Among agents 

promoting regimes on press freedom, attention is given to the World Bank, NGOs, media 

ethics and education. First, the World Bank and IMF spread the United Nations’ and the 

United States’ global regimes on press freedom. The World Bank’s contribution, in 

particular, is spreading of the neo-liberal notion of press freedom in countries the bank is 

involved with and claims that press freedom supports development. ‘Development 

87 

Patterson, “The United States: News in a Free-Market Society”, p. 253; and Real, Michael R., Exploring 

Media Culture : A Guide (New Delhi: Sage Publications, 1996), p. 148. 

88 

Owen, Bruce M., “Media as Industry: Economic Foundations of Mass Communications” in World Bank, 

The Right To Tell : The Role of Mass Media in Economic Development (Washington: The World 

Bank/WBI Development Studies, 2002), pp. 167-168. 

89 

Herring and Robinson, “Too polemical or too critical? Chomsky on the study of the news media and US 

foreign policy”, pp. 554-555. 

90 

Leaper, Glenn W., Löwstedt, Anthony and Madhoun, Husam, Caught in the Crossfire: The Iraq War and the 

Media – A Diary of Claims and Counterclaims (Vienna: The International Press Institute, 2003), pp. 75-77. 

40


journalism’ was promoted by poor countries, a notion where media were supposed to 

support development efforts and its authorities. 

The World Bank’s ‘development journalism’ is quite the opposite and is based on 

the philosophy of liberalism. From this view the mass media provide a voice to people, 

improve transparency and reduce authorities’ scope to act on other interests than its 

citizens’. 91 Beyond these democratic and development arguments emphasis is on how 

media need to be based on market economy to ensure independence. 92 The World Bank 

presumes that press freedom compensates lack of good governance even in private 

sector. 93 Hence, press freedom supports liberal democratisation globally, partly 

independence of states. 

Second, a web of international NGOs act as press freedom agents. Some of them 

have even developed own regimes in accordance with the United Nation’s press freedom 

regime. 94 These NGOs constitute a global press freedom movement. They are advocating, 

monitoring and influencing practices on press freedom around the world. Further, as a 

network these NGOs connect institutions and professionals concerned with press 

freedom. 95 The efforts are to some extent coordinated by the World Press Freedom 

Committee based in Virginia in the United States. 96 WPFC acts as international umbrella 

organisation for 45 NGOs “united in the defense and promotion of press freedom”. 97 Most 

of the NGOs concerned with press freedom are based in the United States or Europe. Some 

of them have status as partners or observers with the United Nations and UNESCO. Hence, 

NGOs also establish relations between the media industry and governments. 

91 

Islam, “Into the Looking Glass”, p. 1; and Stiglitz, “Transparency in Government”, p. 27. 

92 

Owen, “Media as Industry: Economic Foundations of Mass Communications”, pp. 167-168. 

93 

Dyck and Zingales, “The Corporate Governance Role of the Media”, pp. 109 and 135. 

94 

Becker, Vlad and Nusser, Measuring Press Freedom: A Technical Report, pp. 1-15. 

95 


96 

World Press Freedom Committee, “Contact us”, http://www.wpfc.org/index.jsp?page=Contact, 

downloaded 28 th March, 2005. 

97 

World Press Freedom Committee, “Welcome to the World Press Freedom Committee” 

http://www.wpfc.org/, downloaded 28 th March, 2005. 

41


An example of interaction between media industry, NGOs and the United Nations 

is how UNESCO in 1947 proposed an ‘international institute of press and information’. 

That one should fulfil a policy where the press worked responsibly and supported 

democratisation. The press adapted the idea but refused that it should be subordinated to 

any body connected to governments. To ensure this request for independence, UNESCO 

left it to the press itself. Then the International Press Institute was established as an NGO. 

Today, IPI is an authority on global press freedom. 98 

Third, harmonising of media ethics reduces press freedom to a narrow but powerful 

concept. Beyond laws, codes of conduct make up the framework for practices. Common 

points on media ethics include responsibility, independence, human rights, tolerance, truth, 

professional confidence and privacy. 99 There is also proposed a move from codes of ethics 

over to universal ethical principles. The message is how social responsibility should be 

interpreted by media in a globalised world. 100 In the same spirit ‘democracy’ is emphasised 

as such a universal value which should be the basis of all journalism. These calls for ethics 

of ‘democratic journalism’ invoke universal validity. 101 

Fourth, journalism education and professionalisation of the industry is also 

supposed to narrow and strengthen press freedom. It has been common to argue for better 

qualified journalists as well as professional norms which harmonise behaviour. 102 

Education institutions make up an international web. When press freedom is established as 

a cornerstone of the press’ role, these schools implement press freedom as a shared notion 

among journalists globally. For that reason Western actors have supported development of 

98 

Righter, IPI: The Undivided Word, pp 24-26; and International Press Institute, IPI – The First Ten Years : 

The Story of the International Press Institute (Zurich: The International Press Institute, 1962), p. 11; and The 

International Press Institute, 1950-2000 : International Press Institute (Vienna: The International Press 

Institute, 2000), p. 3. 

99 

Kunczik, “Introduction: Freedom of the press – where to draw the line?”, p. 20. 

100 

Christians, Clifford and Nordenstreng, Kaarle, “Social Responsibility Worldvide” in Journal of Mass 

Media Ethics (New Jersey: Lawrence Erlbaum Associates, 2004), volume 19, number 1, pp. 13-15. 

101 


102 Righter, IPI: The Undivided Word, 140 and 145-149; and Eide, Den redigerende makt, pp. 91-93. 

42


journalism schools in poor countries. 103 Journalism schools focus on reporting and writing. 

The World Bank has pointed out the need of education in business and management of 

media to support implementation of press freedom in poor countries. That will strengthen 

media to operate as independent actors in a free market environment. 104 

Professionalisation and harmonised education can be in contradiction with 

liberalism and the ‘marketplace of ideas’. More like-minded journalists narrows media’s 

ability to expose plurality. From the South, a viewpoint is that Western ideas remain 

dominant in such a harmonised practice of journalism. 105 

Circumstances are created to support the development and spread of international 

regimes on press freedom in four ways. These are market economy, global culture, civil 

society and legitimacy. First, liberal market economy is the policy behind globalisation. 

The major points are how globalisation of mass media and the economic globalisation are 

intertwined, and how global media support other globalised business. For media itself, 

liberal market economy means deregulation, privatisation and a commercial purpose. 

These are considered to be bases for independence and freedom. 106 Then, to gain freedom 

media have to be run just like any other business. Outputs that give media income are 

content and audience. The goal will be growth in audience and circulation which are 

media’s key to business success. Common interests between media and advertisers 

constitute a partnership with other industries. 107 If local markets are capable, media can 

103 

Eikje, Ove, “God journalistikk er en vaktbikkje” in Dagen (Bergen, Norway: Dagbladet Dagen), news 

article, 18 th February, 2004. 

104 

Carrington, Tim and Nelson, Mark, “Media in Transition: The Hegemony of Economics” in World Bank, 

The Right To Tell : The Role of Mass Media in Economic Development (Washington: The World 


105 

Omwanda, Lewis Odhiambo, “Values, standards and ethics in journalism: The way forward for subsaharan 

Africa” in Odero, Mitch and Kamweru, Esther (eds.), Media culture and performance in Kenya 

(Nairobi: Eastern Africa Media Institute and Friedrich Ebert Stiftung, 2000), p. 187. 

106 

Herman and McChesney, The Global Media, pp. 38-40; and Carrington and Nelson, “Media in Transition: 

The Hegemony of Economics”, p. 226. 

107 

Owen, “Media as Industry: Economic Foundations of Mass Communications”, pp. 167-172. 

43


achieve economic independence from governments and achieve press freedom. However, 

at the same time these media are subordinated to impact from market logics. 

Second, global culture works supportively for global press freedom. There are 

interactions among cultures, media and identity. Culture can be understood as how the life 

is formulated in symbols, and how these symbols structure context. Then, media is the 

technology that carries this culture. Identity is how self-images are made in this context of 

media culture. 108 Hegemony is how one group can maintain power or dominance over 

other groups. Global media maintain such a hegemony, and these are based in the West. 

Hence, development of a global culture supports a global hegemony. In the framework of 

commercialisation, culture is big business for global media. Culture as sport, films, 

entertainment and music constitute a major part of content in mass media. Men and women 

in this culture are important actors in news. When this culture is shared globally, the 

markets for media are global. Global mass media make culture to be global culture, and 

make global culture to be business. 109 The industry of global culture gets the biggest profit 

if media are free and based on liberal market economy. Hence, global culture is a force 

which supports such a notion of global press freedom. 

Third, empowerment of civil society supports press freedom. Due to the watchdog 

role, it is not expected that governments will be a front runner for press freedom. Media 

and civil society made up a counterweight to power of state and politicians. According to 

Jürgen Habermas, communities have to recognise how journalism has a function as public 

good, that democracy lives in civil society, and that media make a culture of dialogue 

possible. 110 The neoliberal policy spread by globalisation emphasises importance of civil 

society and a reduced role to state and government. If power is decentralised, an 

108 Real, Exploring Media Culture, p. 35. 

109 Ibid., pp. 148-150, 168 and 249-253. 

110 Kunczik, “Closing remarks: Is there an international ethics of journalism?”, p. 255. 

44


empowered civil society ensures accountability and transparency. 111 Mass media free from 

government control enable the civil society to take this enlarged position. 112 

Fourth, legitimacy is necessary for rulers and media are legitimising tools. 

Government achieve legitimacy among citizens by having a free and vibrant press which 

people know the press to be free and transparent. Hence, a democratic government and 

democratic decision processes achieve public support and confidence. 113 In authoritarian 

regimes media are turned to cement the existing power and legitimise the rulers both 

domestic and abroad. As in ‘development journalism’, institutions as education and media 

were used to legitimise the hegemony of the ruling class. 114 In a democracy, media build 

support for the state system itself even if the actual government is critisised and maybe 

lose next election. 

Debates on Global Press Freedom 

The global spread of press freedom has became controversial from three perspectives. 

First, is the question of global media’s dominant position. Second, is on how the 

development agenda connects media with economic globalisation. Third are some African 

perspectives on press freedom. 

First, global media have grown to take a dominant position in the present world 

order. Due to concentration of ownership, even a few media companies dominate global 

media. The table below presents the annual turnover for the biggest global media 

111 

Litvack, Jennie and Seddon, Jessica, Decentralization Briefing Notes (Washington: The World Bank 

Institute, 2000), pp. 97-99. 

112 

Besley, Timothy, Burgess, Robin and Prat, Andrea, “Mass Media and Political Accountability” in World 

Bank, The Right To Tell : The Role of Mass Media in Economic Development (Washington: The World 

Bank/WBI Development Studies, 2002), pp. 45-46, 49-50 and 58-59. 

113 

Eggen, Ytringsfrihet, p. 63. 

114 

Abubakar, Dauda, “The Mass Media and Ideological Apparatuses in Post-Colonial Africa” in Domatob, 

Jerry, Jika, Abubakar and Nwosu, Ikechukwu (eds.), Mass Media and the African Society (Nairobi: The 

African Council on Communication Education, 1987), pp. 53-59. 

45


conglomerates. The comparison with some countries’ gross domestic product is meant to 

illustrate the largeness of such global media companies. 

Size: Media business compared with some states 

Media company Annual sales 115 Country Gross domestic 

product (2003) 116 

Time Warner US$ 38 billion (2003) Vietnam US$ 39 billion 

Disney US$ 31 billion (2004) Slovakia US$ 32 billion 

Bertelsmann US$ 21 billion (2003) Kenya + Uganda + 

Tanzania altogether 

US$ 30 billion 

News Corporation US$ 20 billion (2004) Syria US$ 21 billion 

In accordance with Wallerstein’s world-system theory, concentration of the mass 

media located to so-called cores, is similar to the economic globalisation process. These 

patterns of growth, dominance and concentration have also emerged at regional and 

national levels as well as in market niches independent of geography. Smaller and regional 

media conglomerates are intertwined with, influenced by, dependent on, or copies of the 

greatest global companies. 117 For these companies spread of press freedom act as spread of 

a harmonised practice which is friendly to media business. 

When media business as well as media practice are controlled by a few, it can be 

claimed that press freedom is used to maintain a hegemony of ruling classes. This critique 

is not directed at press freedom itself, but at how manipulative forces influence and 

formulate press freedom to benefit themselves. That is illustrated here through examining 

of how elites control the role of media in societies, how market economy influence mass 

media to operate and think similarly, how mass media support economic globalisation and 

115 Hoover’s Inc.: http://www.hoovers.com/. This is homepage for search in Hoover’s database of 12 million 

companies. Search of the actual companies were downloaded 12 th January, 2005. 

116 The World Bank, World Development Indicators database: http://devdata.worldbank.org/data-query/ 

Further comparison: GDP in 2003 in US$ billion: Uganda 6, Tanzania 10, Kenya 14, Denmark 212, 

Norway 222, and Sweden 301. 

117 Herman and McChesney, The Global Media, p. 70; and Herman, Edward S., “The Media and Markets in 

the United States” in World Bank, The Right To Tell : The Role of Mass Media in Economic Development 

(Washington: The World Bank/WBI Development Studies, 2002), p. 61. 

46


create a global culture, the United States’ role, how mass media legitimate and stabilise 

existing political systems, the NWICO debates and effects of new technology. 

The role media play in societies can be controlled by the few dominant owners to 

protect their interests. In this sense free press is more a myth than reality. 118 When the 

mighty and powerful appear as strong defenders of press freedom, 119 they defend their 

interests given that ruling ideas have always been ideas of the ruling class. 120 An effect is 

that despite growth in media channels, sources have been concentrated and the range of 

views and ideas has narrowed. 121 Hence, the growth in the number of media and channels 

has not resulted in democratic or ideological plurality. 122 In accordance with the owners 

interests, an informal filter system for media content ensures that the interests of the cores’ 

elites prevail. 123 The concept of marketplace of ideas as a basis for press freedom has been 

turned to a marketplace for content to attract audiences for advertising purposes. 124 The 

‘broadcasting’ has been ‘narrowcasting’, expressed in terms of television. 125 

To maintain the present liberal world order, mass media and press freedom are 

intertwined with free trade and democratisation. Thus, the purpose for a free press is to 

support markets because social matters have to be solved by markets. 126 In this context a 

market based mass media system is regarded as the best protection for freedom of expres- 

118 

Parenti, Michael, Inventing Reality : The Politics of the Mass Media (New York: St. Martin’s Press, 

1986), pp. 27, 50 and 236-238. 

119 

For instance Ted Turner, Vice-Chairman of Time Warner in: van der Heijden, Barend and Tahzib-Lie, 

Bahia, Reflections in the Universal Declaration of Human Rights : A fiftieth Anniversary Anthology (The 

Hague: Martinius Nijhoff Publishers, 1998), p. 299. 

120 

Abubakar, “The Mass Media and Ideological Apparatuses in Post-Colonial Africa”, p. 55. 

121 

Boyd-Barrett, Oliver, “ ‘Global’ News Agencies” in Boyd-Barrett, Oliver and Rantanen, Terhi (eds.), The 

Globalization of News (New Delhi/London: Sage Publications, 1998), p. 33; and Paterson, Chris, “Global 

Battlefields” in Boyd-Barrett, Oliver and Rantanen, Terhi (eds.), The Globalization of News (New 

Delhi/London: Sage Publications, 1998), p. 79. 

122 

Boyd-Barrett, Oliver, “ ‘Global’ News Agencies”, pp. 19-33. 

123 Herring and Robinson, “Too polemical or too critical? Chomsky on the study of the news media and US 

foreign policy”, pp. 554-556; and Chomsky, “Commentary: moral truism, empirical evidence, and foreign 

policy”, pp. 605-620; and Allan, Stuart, News Culture (Philadelphia: Open University Press, 2000), pp. 

57-60. 

124 Patterson, “The United States: News in a Free-Market Society”, pp. 253-254. 

125 Joyrich: Re-Viewing Reception, pp. 10 and 17. 

126 Herman, “The Media and Markets in the United States”, pp. 61, 70-73 and 78. 

47


sion 127 where media are not accountable to other powers except markets. 128 Extensive 

deregulation of media is part of this broader liberal globalisation agenda. 129 A function of 

global media is also to integrate new states into the global commerce system. 130 In this way 

press freedom has been used as agent for economic globalisation. 

Global culture spread by global media is another way of maintaining hegemony. On 

one hand, globally shared images create a global culture. Among the effects is a shared 

notion of what kind of society peoples want in terms of values and material needs. On the 

other hand, like-minded consumers are created, which benefits global markets. 131 Despite 

press freedom, more than 99.999% of the world’s population have no access to audiences 

because they are receivers and not senders in the mass media communication model. 132 

Hence, a shared culture, the technology and the exclusive access to influence media’s 

content, all of these support the existing hegemony. An effect of global culture is also how 

mass media’s streamlining of a mass culture results in reduced diversity in the cultural 

‘ecology’. Stronger impulses erode the weaker cultures, and global mass media are accused 

of reducing cultural plurality. 133 

Cultural and ideological narrowing as an effect of global media is not by accident. 

That is, in fact, declared American policy, according to the United States’ Department of 

Commerce, which writes: 

“Since the founding of the republic, the mass media industry has held a 

special place in American society. The products of this industry – films, 

video and radio programming, and recorded music, as well as books, 

magazines, and newspapers – provide the vehicles through which ideas, 

127 

Allan, News Culture, p. 49. 

128 

Okonkwo, Ifeanyi Edward, “Journalists in a Developing Economy” in Okigbo, Charles (ed.), Reporting 

Politics and Public Affairs (Nairobi: The African Council for Communication Education, 1994), p. 10. 

129 

Gunther and Mughan, “The Media in Democratic and Nondemocratic Regimes”, p. 14. 

130 

Boyd-Barrett and Rantanen, “The Globalization of News”, pp. 3, 8, 10 and 15. 

131 

Real, Exploring Media Culture, pp. 3, 18-20 and 148. 

132 

Boyd-Barrett and Rantanen, “The Globalization of News”, p. 11. 

133 

Oluoch, Fred, “Is Globalisation Eroding Our Culture?” in The East African (Nairobi: Nation Media Group), 

news article, 29 th December, 2003; and World Bank, Globalization, Growth, and Poverty, pp. 129-130. 

48


images, and information are dispersed across the United States and 

throughout the world.” 134 

This policy serves both political and economic ends in the United States. Due to American 

media’s influence on the whole world, all business elites with shared interests benefit from 

this policy. 

To legitimise and stabilise existing political order can be another purpose of press 

freedom. A problem that arises is whether these media are true in their criticism or if the 

criticism is modest not to jeopardise an existing order that media benefit from. 135 When an 

issue is covered and opponents and experts on all sides are interviewed, the given image is 

a critical coverage. In reality, however, arguments which do not fit into the case, or 

opponents who are critical are left out of the debate. In that way, the press cultivate debates 

within a mainstream framework. Such debates sound critical and legitimate decision 

processes. In this way an effect of “critical journalism” can be to hide important views. 

Hence, the press contributes to support an existing system. Globally, international news 

media create similar legitimising conditions for the current world order. 136 

When the purpose for press freedom is to maintain the existing system, press 

freedom can be subordinated to other considerations. An example of this logic is how press 

freedom has been subordinated to regulations to support war on terrorism. It has been 

justified by the purpose which is to protect democracy. In that way press freedom has been 

subordinated to protection of democracy as a superior purpose. 137 

The NWICO debates in the 1970s and 80s, illustrate an early resistance to how 

global media support rich countries. 138 Among poor countries a sense of being excluded 

134 

United States’ Department of Commerce, Globalization of the Mass Media, p. 1. 

135 

Patterson, “The United States: News in a Free-Market Society”, p. 252. 

136 

Shiller, Robert J., “Irrational Exuberance in the Media” in World Bank, The Right To Tell : The Role of 

Mass Media in Economic Development (Washington: The World Bank/WBI Development Studies, 

2002), pp. 83-86. 

137 

Elliott, Deni, “Terrorism, Global Journalism and the Myth of the Nation State” in Journal of Mass Media 

Ethics (New Jersey: Lawrence Erlbaum Associates, 2004), volume 19, number 1, pp. 42-43. 

138 

Abubakar, “The Mass Media and Ideological Apparatuses in Post-Colonial Africa”, p. 56. 

49


from the so-called ‘information age’ emerged. They were worried about how mass media 

were lopsided in coverage favouring the rich countries, and in accessibility to technical 

equipment. UNESCO became the major forum for this debate. UNESCO appointed, in 

1976, a commission chaired by Seán MacBride to study ‘the totality of communication 

problems in modern societies’. The 1980 UNESCO summit agreed upon proposals from 

the commission where some of the poor countries’ concerns were adapted. The result was 

a great debate where leading media, especially those in the United States and the British, 

blamed UNESCO for trying to implement a media policy, where governments should 

correct these biases in media. That would be an intervention into the press freedom and 

impossible regarding democratic considerations. In 1983/84 the United States withdrew 

from UNESCO, partly due to this conflict. 139 

The major proposals of the NWICO debates are not implemented. The process also 

illustrate how global media is a stronger political player than poor countries. 140 The ruling 

elites both in North and South have common interests in media maintaining their 

hegemony which makes the dividing line not geography but economic classes in a global 

informal network. 141 These are supposed to act as capitalists whether they are from North, 

South, are domestic or foreigners. 142 

The United States contributed to reduce UNESCO’s role through increasing the 

mandate of another UN agency, the International Telecommunication Union (ITU), for 

shaping the ‘global mass media policy’. 143 With technological development, in particular 

how internet put traditional media and communication technology together, ITU emerged 

as an important actor in media policy. The way the internet is used by terrorists, extremists, 

139 Gerbner, George, Mowlana, Hamid and Nordenstreng, Kaarle, The Global Media Debate : Its Rise, Fall, 

and Renewal (New Jersey: Ablex Publishing, 1993), pp. 1-33. 

140 Ibid., pp. 25-26. 

141 

An-na’im, “The Freedom of Expression as a Universal Human Right”, p. 25. 

142 

Ochieng, Philip, I Accuse the Press : An Insider’s View of the Media and Politics in Africa (Nairobi: 

Initiatives Publishers, 1992), p. 115. 

143 

Savio, Roberto, “New Information Order Leading Towards ‘Unthink’ ” in The East African (Nairobi: 

Nation Media Group), 19 th April, 2004. 

50


organised crime, and pornography have been reasons for implementing stronger 

international control mechanisms towards that new medium. 144 However, these attempts to 

restrict press freedom have not sparked off great debates. 

Second is how the development agenda connects media with globalisation. These 

debates concern mass media’s support to development in accordance with Western donors’ 

interests, and alliances between media and other development actors. Recent changes in 

development theories has also changed thinking about relations between media and 

development. Authorities used to decide issues and development journalism was supposed 

to support the authorities’ efforts. The change is that emphasis is on solutions and priorities 

emanating from people, and media were key to this change of attitude regarding 

development. 145 

On behalf of Western donors, the World Bank ties political conditions to aid. 146 The 

purpose is to develop democracies. However, the World Bank’s definiton of ‘democracy’, 

including ‘free market’, ‘privatisation’, and ‘civil society’ is a model that benefits global 

economic interests dominated by Western companies. ‘Free media’ is expected to 

contribute to better democracy. The bank says that a new mind-set will emerge where 

governments will understand that it is an agent for its own citizens. India is pointed out as 

evidence from the World Bank, because that country has not had any famine since 

independence even if there has been poverty and drought. The explanation is given to be 

the media’s freedom and role in good governance in India. 147 Uganda is mentioned as a 

successful example of the World Bank’s policy of development. As a force to build the 

144 

Loader, Brian D., The Governance of Cyberspace : Politics, Technology and Global Restructuring 

(London: Routledge, 1997), pp. 209-212. 

145 

Hydén, Göran and Leslie, Michael, “Communications and Democratization in Africa” in Hydén, Göran, 

Leslie, Michael and Ogundimu, Folu F., Media and Democracy in Africa (New Jersey: Transaction 

Publishers, 2002), pp. 4-5. 

146 

Browne, Stephen, Beyond Aid : From Patronage to Partnership (Aldershot: Ashgate, 1999), pp. 5, 19-27 

and 169. 

147 

Stiglitz, “Transparency in Government”, p. 39 (mind-set); and Besley, Burgess and Prat, “Mass Media and 

Political Accountability”, p. 53 (India); and Godbole, Madhav, “Good Governance: A Distant Dream” in 

Economic and Political Weekly (Mumbai: Sameeksha Trust, 2004), 13 th March, 2004, pp. 1106. 

51


country, the bank emphasised the media’s role as a part of the Ugandan civil society. 148 

However, the actual politics on openness into public information, is not an easy process to 

establish in the country. 149 

An alliance evolved among media, development politicians, NGOs engaged with 

development aid, and scientists within the field, all who benefit from interactions in 

development. Critics claim that the mass media are too much intertwined with the 

development sphere to have a critical approach where some distance is necessary. The 

development agenda (or ‘development regime’) benefits from the extensive attention from 

the mass media to achieve public support. 150 In this way the mass media enter development 

politics as an actor, and the World Bank emphasises how it is a goal for the development 

politics to strengthen this alliance. The goal is to re-establish the role of mass media to 

become a partner in the development politics, connected to the agenda of globalisation. 151 

Introduction of mass media into development aid policy is controversial. Despite 

media’s supports to global democratisation processes there are considered to be a part of 

the process where states are weakened and the underlying interests are to promote 

American values and economics. 152 Democratisation is in accordance with the mass 

media’s declared social responsibility. Thus, in that concept interests behind the liberal 

economic globalisation have found a key to create an alliance with the most honourable 

interests within mass media. Whether liberalism is the system which benefit mass media’s 

social responsibilty is another debate. 

Third are three types of criticism about press freedom that arose from Africa. One 

is warning against copying of Western concepts. Second is the attempt to define African 

148 

Datta-Mitra (ed.), Uganda : Policy, Participation, People, pp. 133 and 138-141. 

149 

Musoke, David, “Uganda Publishers Right to Information Bill” in The East African (Nairobi: Nation 

Media Group), news article, 19 th April, 2004. 

150 

Tvedt, Terje, Utviklingshjelp, utenrikspolitikk og makt : Makt- og demokratiutredningen (Oslo: 

Gyldendal, 2003), pp. 232-236. 

151 

Islam, “Into the Looking Glass”, pp. 1-23. 

152 

Munene, Macharia, “Hazards of Postmodern Colonialism in Kenya”, Draft Paper prepared for Conference on 

‘The Political Economy of Kenya’, Oxford University, 27 th – 28 th May, 2004, Oxford, United Kingdom, p. 14. 

52


versions of press freedom. Finally are claims that concepts of press freedom are among 

tools of neo-colonialism. 

In claiming that press freedom is a Western concept, critics point out that in the 

North, liberal authorities tend to protect citizens at the expense of the community, while in 

the South, people tend to be victims of activities that the authorities in the North protect. 

Hence, this Northern liberalism, including mass media, is not an appropriate model for the 

South. 153 UNESCO, in a worldwide comparative study of media councils and codes of 

conduct, concluded that Western ideas are not necessarily the basis for press freedom: 

“Because the pattern and philosophy of mass communication in Third 

World countries are not the same as that in many of the developed countries, 

the media councils in those countries cannot and should not be just carbon 

copies of those in the developed world.” 154 

This perception was reinforced in a 2002 study by Jennifer Ostini and Anthony Y. 

H. Fung that concluded that Western concepts and values such as a free press were not 

transferable. Ostini and Fung stated that these values do not work the same way in other 

cultures. 155 Western press systems implemented in Africa are even accused of damaging 

traditional community societies. Because mass media and information systems were used 

for control, power imbalances emerged. 156 

The Canadian philosopher Marshall McLuhan argued that communication 

technology tied the world together in globalisation and that technology was not neutral to 

values. Changes in communication changed values and that there were underlying forces 

of media dominance than the content in the media. 157 It was the underlying forces that 

African leaders, in newly independent states, felt used the media to control them. That 

153 Ochilo, Polycarp Omolo, “Africa : Perspectives for Editorial Independence” in UNESCO, Public Service 

Broadcasting and Editorial Independence: Strengthening Democratic Voices (Helsinki, Finland: The 

Finnish National Commission for UNESCO, 1998), p. 47. 

154 Jones, J. Clement, Mass Media Codes of Ethics and Councils : A comparative international study on 

professional standards (Paris: UNESCO Press, 1980), p. 56. 

155 Brislin, Tom, “Empowerment as a Universal Ethic in Global Journalism” in Journal of Mass Media Ethics 

(New Jersey: Lawrence Erlbaum Associates, 2004) volume 19, number 2-2004, p. 132. 

156 Makali (ed.), Media Law and Practice, pp. 41-45 and 60-64; and Merrill, Global Journalism, p. 213. 


53


included use of mass media as agents of cultural imperialism. McLuhan’s theories gave 

these leaders a framework to justify control of media to counter what they interpreted as 

Western propaganda. 158 

‘Media is the message’, McLuhan formulated. Some studies have pointed out how 

the African oral traditions made up societies different from those in the West based on 

written traditions. 159 Many differences between Western and traditional African societies 

can be traced back to these respectively written and oral traditions. 160 When African elites 

got education they adopted Western written traditions including use of written media. That 

is one of the reasons for growing elite alienation in Africa. 161 Radio and TV are more 

connected to the oral tradition. 162 

Some have attempted to identify a specific African press freedom. In 1962 Tom 

Mboya asked: “What is freedom of the press?” His answer was that African press can not 

behave like those in London, Paris or New York. After Kenya’s independence in 1963, he 

became a member of the cabinet. Mboya emphasised that the local press had a duty to 

Africa, and that they had to make their own contributions towards Africa. 163 His conclu- 

sion on press freedom sounded close to development journalism. 

One proposal of African press freedom is called the ‘unfinished agenda’. Emphasis 

is on democratisation processes where African actors pursue increased press freedom with 

support from the people. The ‘unfinished agenda’ calls for the repeal of anachronistic laws, 

many from the colonial days, and for free access to information in public administration. 

There is call for the creation of independent media councils that would handle disputes 

affecting the media, and for independent media commissions to ensure balanced coverage 

158 

Hydén and Leslie, “Communications and Democratization in Africa”, pp. 20-22. 

159 

Ibid., p. 20. 

160 

Bourgault, Mass Media in Sub-Saharan Africa, pp. 7-13. 

161 

Ibid., pp. 21-32. 

162 

Makali (ed.), Media Law and Practice, p. 44. 

163 

Mboya, Tom, “Relations Between Press and Governments in Africa” in The Challenge of Nationhood : A 

collection of speeches and writings (Nairobi: East African Educational Publishers Ltd., 1993 [1970]), p. 137. 

54


in public owned media. Finally, the most powerful step is pointed out to be politicians 

behaviour in practice of press freedom. 164 

Another proposal has an underlying premise that African democracies have not yet 

been well established. The ideal is yet similar to Western as described in the Universal 

Declaration of Human Rights. According to this ideal, the proposal recommends constitut- 

ions which guarantee press freedom as well as free access to information. Further, areas of 

official secrets have to be reduced and journalists should be allowed to keep confidential 

sources. To abolish regulations on contempt of parliament, government or the president 

and leave criminal defamations to civil cases, are pointed out as crucial. 165 

Press freedom is also accused of being a neo-colonialist instrument to suppress 

Africa. Press freedom ensures spread of like-minded media and a global culture. Hence, 

the media are among the means for the hegemon to control consciousness. This is 

supported by how the West controls almost all news to and from the South. 166 Even news 

events within Africa are, in African media, covered by Western news agencies due to lack 

of resources to cover “their own” events. 167 The point is that if the oppressed ones can 

view themselves as they are viewed by the ruling elites, then they can become their own 

policemen. That means that there is no need for a colonial master because Africans are 

ruled by the global culture and news flows. 168 In this argument global press freedom is 

regarded as a necessity to create a web of control. 

From the very beginning of Western civilisation, the Greeks portrayed Africa as an 

otherness – as ‘barbarians’ and ‘savages’. Western science continued to acquire knowledge 

about Africa within European philosophical frameworks. Present knowledge about Africa 

164 

Ogbondah, “Media Laws in Political Transition”, pp. 73-77. 

165 

Mbome, Peter H., “Aspects of Human Rights in an African Context” in Towards Press Freedom (Harare, 

Zimbabwe: Willie Musarurwa Memorial Trust and Konrad Adenauer Stiftung, 1996), pp. 42-44. 

166 

Thiong’o, Ngũgĩ wa, Moving the Centre : The Struggle for Cultural Freedoms (Nairobi: East African 

Educational Publishers, 1993), pp. 47-52. 

167 

Lehihi, Masego, “Broadcast Headaches” in Business in Africa (Rivonia, South Africa: Business in Africa 

Group, 2004), June 2004, pp. 24-25. 

168 

Ngũgĩ wa, Moving the Centre, pp. 47-52. 

55


is therefore mostly European interpretations. 169 This Western creation of Africa dominates 

stories about Africa in global media. Images from the colonial era are still alive. These are 

stereotypes such as adventures, crocodiles, Tarzan, disasters and military coups. Thus, 

Africa is transformed to adventures which can be commodities in the global market for 

media content. 170 Press freedom with social responsibility has not been any hindrance to 

exploit and stigmatise Africa like this in global markets. 

Even Africans themselves are inhibited by this Western philosophy. Attempts to 

make an African notion of press freedom, take a critical view to Western values but come 

up with similarities to Western practice. In the neo-colonialism debate, it is pointed out 

how Africans use Western philosophy to describe Africa and how that continue to support 

the Western notion of Africa. Within the framework of Western philosophy, it is 

impossible to produce unique African concepts. To be liberated from Western political and 

economic dominance, it is necessary to develop specific African thought systems. 171 Thus, 

it is a long way to any specific press freedom based on African values. 

Another neo-colonial force is ownership. A lot of African media industry is owned 

by Western corporates. In addition, almost all content beyond local events are produced by 

news agencies, other media providers as well as advertising agencies owned by Western 

companies. 172 It is in their interests to maintain the existing media order based on Western 

concepts of free markets and press freedom. 

The West preaches democracy and press freedom to Africa, but the democratisation 

processes are different. In the West, democracies emerged as a compromise to manage 

169 

Mudimbe, V. Y., The Idea of Africa (Bloomington: Indiana University Press, 1994), pp. 40-41, 71-72 and 

211-212. 

170 

Hawk, Beverly G. (ed.), Africa’s Media Image (Westport, USA: Praeger Publishers, 1992), pp. 4-16. 

171 

p’Bitek, Okot, African Religions in Western Scholarship (Nairobi: Kenya Literature Bureau, 1970), pp. 

90-91 and 102-119. 

172 

Brislin, Tom, “Empowerment as a Universal Ethic in Global Journalism”, p. 131; and Paterson, “Global 

Battlefields”, p. 80. 

56


conflicts between opposite camps. In Africa, the crucial point is to be liberated from an 

authoritarian system imposed by European colonial masters. 173 

173 Makali (ed.), Media Law and Practice, pp. 60-63. 

57

Chapter 3: Press Freedom in Scandinavia 


Scandinavian mass media are among the freest in the world. The notion of press freedom 

in Scandinavia evolved from common democratic philosophies. This chapter has two parts. 

First, the Scandinavian context is described. History of press freedom as well as reasons 

for it are examined, and the position of mass media in the societies is presented. Second, 

four aspects of press freedom are examined including use of case studies. These are how 

media’s role is settled, freedom to gather information, freedom to publish, and protection 

of journalistic activities. 

The Scandinavian Context 

The democratic, legal and cultural traditions in the Scandinavian countries of Norway, 

Sweden and Denmark are similar. They have similar notions about press freedoms, have 

similar history on press freedom and it is similar information about mass media in these 

societies. 1 Norway is representative of these Scandinavian countries. 

Growth of Press Freedom 

The first newspapers appeared in Scandinavia in the 17 th and 18 th centuries. The need for 

trade communication triggered the emergence of the press whose content was mostly 

advertisements and business information. Stories about issues in the society were still not 

properly developed. A basic principle at that time was that printing and publishing were 

subject to royal authorisation. The common condition was that the kings’ men ruled over 

the content. Otherwise, the printers – the editors of those days – censored themselves 

according to the kings’ requests. Laws on sencorship included even the death penalty. 2 

1 Statens Forvaltningstjeneste, Norges offentlige utredninger : NOU 1996:12 : Medieombud (Oslo: Statens 

Forvaltningstjeneste, 1996), section 3.1. Chapter 3 and 4 in this study include a comparative study on media 

ethics in the Scandinavian countries. 

2 Eide, Den redigerende makt, pp. 16-23, 27 and 45-50. 

58


The spirit and ideals of the Enlightenment, the French Revolution as well as con- 

temporary English philosophy, influenced the development of democratic trends in Scandi- 

navia. 3 Sweden got a kind of print freedom as early as 1766 4 which is considered as the 

world’s oldest constitutional provision for freedom of expression. 5 By 1814, a new Nor- 

wegian constitution guaranteed freedom of printing and publishing as well as freedom to 

do business. From the 1830s, a trend appeared where discourses on matters in society 

were moved from the king’s closed rooms to the public sphere. A strong growth of 

associations as well as an increasing number of newspapers and political pamphlets, 

contributed to an institutionalising of public discourse. 6 

Press freedom became a hot issue as some newspapers in Norway by 1837 

committed themselves to protecting their sources of information. Since authorities wanted 

to maintain their monopoly of information, the Norwegian government imposed a rule of 

confidentiality on its officials in 1845. That step surprised Denmark and Sweden because it 

was considered as a serious setback for democratisation. There followed debates on ethical 

matters with such questions as ‘what is the difference between law and morality?’, and 

‘what is privacy?’, or ‘what is of public interests?’ being raised 7 The debate started a 

continuing process that shapes the press’ code of conduct. 

The next phase was the establishment of press associations which institutionalised 

instruments that promoted the interests of the press. The numerous organisations indicates 

that ‘interests of the press’ were not one coherent subject. These organisations had 

different aims, such as editorial interests (in contradiction to business), education and terms 

of employment as well as political and regional purposes. The variety of media 

3 Ibid., pp. 26, 38-39 and 66. 

4 Statens Forvaltningstjeneste, Norges offentlige utredninger : NOU 2003:30 : Ny offentlighetslov (Oslo: 

Statens Forvaltningstjeneste, 2003), section 4.2.2. 

5 Ogundimu, Folu Folarin, “Media and Democracy in Twenty-First-Century Africa” in Hydén, Göran, Leslie, 

Michael and Ogundimu, Folu F., Media and Democracy in Africa (New Jersey: Transaction Publishers, 

2002), p. 218. 

6 Eide, Den redigerende makt, pp. 18 and 31-37. 

7 Ibid., pp. 45-50. 

59


organisations are today streamlined in a cooperating system. They include unions of 

journalists, association of editors, owner’s associations, and other interest organisations. 

They all emphasise different aspects of press freedom. 8 

Education has been considered crucial for press freedom. An educated journalist or 

editor is supposed to behave more professionally and resist external influence better than 

an uneducated one. In Norway, the first demand for editorial education was proposed in 

1875, and the first school of journalism was established in 1919. However, the first public 

school of journalism was not a reality until 1965. 9 

The European Convention on Human Rights, in paricular article 10, is important for 

the legal framework for press freedom in Scandinavia. This Convention has harmonised 

the legal practice in Scandinavia with Europe. 10 

Beyond progress in legal environment, two other movements promoted press 

freedom in Scandinavia. First was the independence and movement for editorial 

independence to resist pressure from the influence of external interests, the King or 

government officials. From around 1900 independence from government became the ideal 

to be pursued by editors. Several attempts to ensure the principle came to an end in 1953 

when a formal declaration of the editor’s independence was made between The Associ- 

ation of Norwegian Editors and The Norwegian Newspaper’s Owners Association. In 

Denmark a similar declaration was adopted at about the same time. Sweden passed laws to 

ensure freedom of expression. 11 

After 1970 Scandinavian newspapers liberated themselves from political parties, 12 

but not from the owners whose influence continued to determine media content. One way 

out was to have many owners so that if one newspaper is biased in favour of one camp, 

8 

Ibid., pp. 60, 74-77, 84-88 and 115-118. 

9 

Eide, Den redigerende makt, pp. 91-93. 

10 

Eggen, Ytringsfrihet, pp. 136-140 and 1002-1008. 

11 

Eide, Den redigerende makt, pp. 83 and 96. 

12 Ibid., p. 118. 

60


another view would emerge in another newspaper. That fits in with the Associate Justice of 

the United States’ Supreme Court, Oliver Wendell Holmes Jr.’s, concept of ‘marketplace 

of ideas’ where competing ideas would result in a public discourse where the best idea 

would receive support. 13 Such an approach has strong support in Scandinavia and is an 

important reason for politics which stimulate a wide range of different media. 14 

Second are formalised codes of conduct that support a self-regulating regime where 

“media rule media”. These are based on the assumption that if the media behave 

responsibly, and in accordance with the ideals of social responsibility, government would 

not need to interfere with media operations. Sweden, in 1874, was the first country in the 

world to forge a system of formalised codes of conduct within the press, 15 and founded a 

media council in 1916. 16 Norway followed by 1929. 17 In Denmark, this Scandinavian style 

of self-regulation is organised within a legal framework for a responsible press including 

provisions for judicial action. However, Sweden and Norway do not have such laws. 18 

Media’s role in societies, and hence the purpose of press freedom, has got its 

Scandinavian notion. A feature of Scandinavian democracies has been extensive welfare 

systems. In Sweden this philosophy is termed ‘the people’s home’. Such a system has been 

based on high level of union memberships and myriads of other organisations taking care 

of people’s interests in a highly organised civil society. A culture of collective interests has 

been dominant. In this way citizens have had a power base towards economic elites. 

Scandinavian media reflect these power structures. Patterns in civil society and collective 

interests have given the pattern in media which then have given the prevailing opinion of 

13 

Eggen, Ytringsfrihet, pp. 58-60. 

14 

Eide, Den redigerende makt, pp. 116-118. 

15 

Herbert, John, Practising Global Journalism, pp. 68-69. 

16 


17 

Eide, Den redigerende makt, p. 78. 

18 

Statens Forvaltningstjeneste, Norges offentlige utredninger : NOU 1996:12 : Medieombud, sections 3.1 

and 3.3.1. 

61


media’s role in societies as supporter of ‘the people’s home’ notion of democracy. 19 

Present forces in economic globalisation are a serious challenge to this kind of media 

supported welfare system. 20 

Commercialisation of Scandinavian media has followed patterns common to other 

Western countries. Popularisation of contents and restructuring of ownerships are among 

the results. An effect of popularisation is how content has to follow commercial logic and 

achieve market objectives rather than political objectives. An effect of altered ownerships 

is liberation from political owners only to develop new ties to owners with commercial 

purposes. Despite media’s strong bonds to traditional Scandinavian democratic values, a 

shift of power has taken place in newsrooms. Owners and managers adapt tough economic 

criteria that reduce the power of journalists to represent citizens. 21 In this way commercial 

interests have grown in importance as framework for press freedom in Scandinavia. 

Reasons for Press Freedom 

There are three given reasons for the growth of press freedom in Scandinavia. First is the 

search for truth. Second is democracy. Third is love of individual liberty. 

Firstly, truth is a good in itself, or truth is a means to achieve other goods. The 

search for the truth, including discourse among competing truths, is emphasised as a pur- 

pose for freedom of expression in Scandinavia. The belief that the truth will win is 

widespread in the Scandinavian countries. Therefore, even wrong expressions and opinions 

are protected in public discourses. 22 

Secondly, democratic reasons for press freedom have been argued in two ways in 

Scandinavia. On one hand, people need free information to be empowered to play their 

19 Dahlgren, Peter, “Media and power transitions in a small country: Sweden” in Curran, James and Park, 

Myung-Jin, De-Westernizing Media Studies (London: Routledge, 2000), pp. 252-253. 

20 Ibid., pp. 262-263. 

21 Ibid., pp. 251 and 257-258. 

22 Eggen, Ytringsfrihet, pp. 37-55. 

62


individual role in a democracy. If people decide leadership by ballots, they need free 

information to select and vote for candidates. Such a system trusts in the enlightened and 

rational man. On the other hand, a free press will be the channel of information to the 

leaders. Media’s critical attention to a wide range of issues ensure that the leaders are well 

informed about society’s needs. Since freedom of expression is meant to move conflicts 

from use of force and violence to debates, the youth in Scandinavia are raised and 

socialised to be democratic and to consider the interests of the minority. A free and open 

press may be means to ensure the interests of the minorities, to ensure plurality. In these 

circumstances a free press is supposed to legitimatise democratic decision-making 

processes. 23 

Thirdly, individual liberty is a basic value in a liberal society. Such an equal right to 

freedom of expression was the major concern when constitutions were written, influenced 

by French and English philosophy. Later, the Scandinavian societies changed. Practice in 

the countries’ Supreme Courts as well as in the European Commission and Court of 

Human Rigths indicates that democratic arguments are superior to individual liberal rights. 

Therefore, political expressions are supposed to be protected more than, for instance, 

information about privacy. In Scandinavia there is debate about balancing public interests 

with privacy. 24 

Press freedom is protected from at least three forces. These are interference from 

government, external private forces, and the owner’s commercial interests. In searching for 

freedom from such forces, a paradox has arisen. Editors sought alliance with legislators to 

increase the legal protection of editorial independence from their own owners. Another 

effort to reduce owners’ influence is to ensure spreading of media ownerships. 25 

23 Ibid., pp. 55-80. 

24 Ibid., pp. 80-87. 

25 Ibid., pp. 604-611; and Eide, Den redigerende makt, pp. 115-118. 

63

Mass Media in the Societies 


The Scandinavian countries are worldwide ranked at the top in many ways. Indicators 

which put these countries at the global top level include use of media, circulation, spread 

of media equipment and technological infrastructure. 26 Broadcasting in Scandinavia 

includes private commercial channels as well as public radio and TV stations both at local 

and national levels. The public broadcasters have long-established traditions and maintain 

a strong position in all these countries. The spread or use of radio and TV may be 

illustrated by the following table: 

Number of radio and TV receivers per 1000 inhabitants (1996) 27 

Country TV Radio 

Denmark 594 1145 

Norway 462 917 

Sweden 519 932 

There is extensive spread of print media in Scandinavia. Concerning newspapers, 

the Scandinavian countries are ranked with the top in the world. It is common to read more 

than one newspaper a day. 

Spread of daily newspapers (1996) 28 

Country Number of Total Circulation per 

titles circulation 1000 inhabitants 

Denmark 37 1,628,000 311 

Norway 83 2,578,000 590 

Sweden 94 4,499,000 445 

distinguished. 

Another print media, books, is an area where the Scandinavian countries are 

26 

UNESCO, World Communication and Information Report : 1999-2000 (Paris: UNESCO, 1999), pp. 262- 

271. 

27 

United Nations, Statistical Yearbook : Forty-fourth issue : 1997 (New York: United Nations, 2000), table 

18, pp. 130-137. 

28 

Ibid., table 16, pp. 117-123. More recent data are available, these are used to be comparable with East 

Africa below. However, these figures have been stable over time. 

64

Number of new published book titles (1996) 29 

Country New book titles Titles per 

1000 inhabitants 

Denmark 12,352 2.3 

Norway 6,900 1.6 

Sweden 13,496 1.6 


Internet and telecommunications have been widespread in all kinds of daily life in 

Scandinavia. Figures indicate that only neighbouring Finland and the United States have a 

more extensive use of internet in the world than Norway, Sweden and Denmark. 30 

Journalistic capacity indicates the media’s potential power in society. The numbers 

of practicing journalists and editors in Scandinavia are in Denmark 11,000, 31 in Norway 

8,000, 32 and in Sweden 15,000. 33 Hence, in statistical terms, each journalist has in average 

to watch about 550 citizens. 34 

Four Aspects of Press Freedom in Scandinavia 

The growth of press freedom can be examined in four ways. First is the role of the press 

itself. Second is the process of news gathering. Third is publishing. And fourth is the 

protection of journalistic activities. 

29 

Ibid., table 15, pp. 111-116. 

30 

UNESCO, World Communication and Information Report : 1999-2000, p. 271. 

31 

The Danish Union of Journalists, “Om DJ” (København: The Danish Union of Journalists, 2005), at: 

http://www.journalistforbundet.dk/sw101.asp, downloaded 11 th March, 2005. The figures here are 

calculated similar to the figures for Norway and Sweden. Denmark’s definition of ‘journalist’ is wider than 

in Norway and Sweden. 

32 

Estimate made by Jahn-Arne Olsen, Secretary-General of The Norwegian Union of Journalists, in 

correspondance by e-mail received 3 rd March, 2005. 

33 

Estimate made by Hans Kilsved, Secretary-General of The Swedish Union of Journalists, in 

correspondance by e-mail received 3 rd March, 2005. 

34 

Number of inhabitants from: Microsoft, Encarta Interactive World Atlas 2000 (Redmond, Washington: 

Microsoft, 1999), CD-rom. 

65

Role of the Press 


The Scandinavian countries have long-established democracies that support the develop- 

ment of media’s free and extensive role in society. Both the governments and the media 

have contributed to the development. 

At a constitutional level the principle is that anyone is free to publish without any 

permission in advance. That was formulated in Article 100 in the Norwegian Constitution 

of 1814. 35 Sweden has similar constitution but a more extensive legal system around these 

instruments. 36 Another constitutional regulation which supports free media within the 

private sector is the freedom for anyone to run a business. 37 

There are many regulations of publishing activities. These include the system of 

licence for radio or TV broadcasting because of limited access to frequences. Due to this 

scantiness of frequence numbers, politics and commercial interests entered in the 

distribution of licences. The politics have been to ensure that the airwaves bring cultural 

diversity, local content, and many voices in the democratic processes. The economic value 

of a frequency has sometimes been an object of charges or taxes as well. In this way, the 

licence system for broadcast media has been an instrument where the authorities decide a 

framework for content and economic conditions. Due to the democratic reasons behind 

these politics, such regulations are considered to be in accordance with the freedom of 

expression. 38 All the Scandinavian countries have strong public broadcasters which have 

dominant positions in TV as well as radio. These operate within a framework decided by 

cultural politics. The public broadcasters are mainly funded by public resources. 

35 

Eggen, Ytringsfrihet, pp. 35 and 95-96. 

36 


37 

Ibid., p. 35. 

38 


66


Scandinavian countries have been among the latest in the West to liberalise broadcasting 

and allow private actors in radio and TV. 39 

Taxes and subsidies have been instruments to support media activities in Scandi- 

navia. In Norway, about US$ 40 million are granted annually as subsidies to economically 

weak newspapers. 40 Further, newspapers are exempted from value added tax. The same is 

the case in Sweden where newspapers have value added tax at a reduced level. The media 

as an industry benefit from several economic arrangements which support media to grow 

stronger. The reason behind such politics is to ensure plurality and independence for the 

media as vehicles for democratic processes. 41 Similar reasons are given for regulations of 

media which are intended to maintain plaurality and prevent concentration of ownership. 42 

The press itself is a major actor in the society. The Scandinavian media, by 

performance, gain public support which in turn increases press freedom. At the moment 

there are two main means for strengthening the independence. First, is continuous pursuit 

of binding declarations and legal instruments that protect the independence. The 

Norwegian declaration “Rights and Duties of the Editor” from 1953 about the editor’s 

independence, has achieved a legal precedent. 43 Sweden has similar regulations by law. 44 

Second, the Scandinavian media live up to the self-regulation doctrine of ‘let the 

press correct the press’. 45 Therefore, media prefer to solve conflicts through media councils 

rather than in court. The courts are considered as government instruments, and media 

prefer that such an act from authorities should be reserved for cases they cannot solve by 

39 

Dahlgren, “Media and power transitions in a small country: Sweden”, p. 258. 

40 

Journalisten, “Pressestøtten kuttes fem prosent” in Journalisten (Oslo: Norsk Journalistlag), news article, 

11 th May, 2004. The article is also published at: 

http://www.journalisten.no/artikkel.asp?GUID={67CC731C-BD7D-442F-9573- 

4E4F1CFF8C58}&kategoriID=3&temaID=245, downloaded 8 th March, 2005. 

41 

Correspondance with Nils Øy, Secretary-General in the Norwegian Association of Editors, e-mail received 

9 th March, 2005. 

42 


43 

Eide, Den redigerende makt, pp. 80 and 83. 

44 Ibid., p. 96. 

45 Ibid., pp. 38-39 and 116-118. 

67


themselves. 46 The “law” for these media councils are codes of conduct usually made by the 

media themselves. Among many detailed descriptions, the superior value of independence 

is emphasised in Scandinavia. For instance, as quoted from article 1.1 in the Code of Ethics 

of the Norwegian Press: “A free, independent press is among the most important 

institutions in a democratic society.” 47 Of course, competing interests emerge between the 

press, authorities as well as other actors. These are typically actors mentioned in a bad light 

by the media. Such conflicts are usually left to the press’ own organs or as civil lawsuits. 48 

Scandinavian countries have called attention to the institution of ombudsman in 

media. The idea is to have the ombudsman as an independent mediator to channel conflicts 

between the public or single persons on one side and media actors on the other. It is 

supposed to be an institution which strengthens media ethics in an era where other forces 

place media’s conduct under pressure. 49 

The first media ombudsman emerged in Sweden in 1969 as a result of sharp debates 

on media ethics. Swedish media’s response was to create an ombudsman to ensure 

confidence in the established self-regulation system. His task was to assist complainants in 

their cases against media, mediate, or take cases to the media council. However, the 

Swedish ombudsman is appointed in a way that the Swedish government’s justice 

ombudsman is involved. So, the government has a stake into the press’ self-regulation 

system in Sweden. 50 

Good experiences from Sweden’s media ombudsman resulted in a call for a similar 

one in Norway. The Norwegian government initiated a study in 1996 that came up with a 

proposal. An ombudsman was supposed to work within the media’s self-regulation system, 

46 Ibid., pp. 76-79, 96-97 and 112. 

47 The Norwegian Press Association, Vær varsom : Etiske normer for pressen (Oslo: The Norwegian Press 

Association, 1999). This is published in English version at the web-site: Databank for European Codes of 

Journalism Ethics: http://www.uta.fi/ethicnet/ under the link “Norway”, downloaded 22 nd July, 2004. 

48 Correspondance with Øy, e-mail received 28 th January, 2005. 

49 Statens Forvaltningstjeneste, Norges offentlige utredninger : NOU 1996:12 : Medieombud, chapter 2. 

50 Ibid., section 3.2. 

68


and yet within a new legal framework and with some strings to authorities. 51 Even though 

the idea itself was welcomed, voices both inside and outside the press rose against such a 

government interference. The Norwegian government then decided not to initiate a media 

ombudsman and emphasised media self-regulation. 52 However, even if such a media 

ombudsman was considered not to be in accordance with press freedom, this government 

initiated process resulted in other reforms where the media itself improved the self- 

regulation system. 53 

Gathering Information 

The right to have information belongs to people, not to media. Due to the press’ social 

responsibility it is supposed to serve public with information. This democratic right is the 

reason why the right to information is included in Scandinavian constitutions. 54 Access to 

information concerns both ethics and law as well as practical circumstances. 

The Code of Ethics of the Norwegian Press guides the process acquiring 

information. In Norway, it is emphasised as a principle that the press have to protect the 

access to official documents. Sources should be identifiable as long as identification does 

not come into conflict with the need to protect the sources. Journalists have to be critical in 

the choice of sources. Use of anonymous sources implies a special need for critical 

evaluation. The press should protect its sources. Such a protection is a basic principle in a 

free society and ensures the access to essential information. As a main rule, unpublished 

material should not be divulged to third parties. The press may show consideration for 

people who cannot be expected to be aware of the effect that their statements may have. 

51 Ibid., chapter 5. 

52 Statens Forvaltningstjeneste, Ot prp nr 77 (1996-97) : Om lov om endringer i kringkastingsloven 

(Medieetikk mv) (Oslo: Statens Forvaltningstjeneste, 1997), sections 4.2-4.4. 

53 Correspondance with Øy, e-mail received 16 th February, 2005. 

54 Eggen, Ytringsfrihet, pp. 55 and 78; and Krug and Price, “The Legal Environment for News Media”, p. 191. 

69


Journalist may only use hidden cameras or microphones or false identity under special 

circumstances. 55 

The essence in this ethics is the principle of openness and open access to gather 

information, respect for the sources as well as protection of anonymous sources. Gradually, 

parts of this conduct of the press has been implemented into law. The principle of openness 

come up in philosophy of the Enlightenment, and was a matter in the struggle for press 

freedom in Scandinavia already in the 18 th and 19 th century. In Norway, several processes, 

setbacks and progresses resulted in a law in 1970 where openness in civil service became 

the main rule. 56 

The need to protect the press’ confidential sources started as an ethical issue, and 

then became the law in Norway, however, not as absolute as in the codes of conduct. 57 In 

Sweden legislators have gone farther and made the protection of sources complete. 

Regardless of the national laws, the European Court of Human Rights has in accordance 

with the European Convention on Human Rights article 10 established a strong legal 

protection of such sources. 58 

A question in the NWICO debate was ‘who is permitted to operate as journalist?’ 

Many countries make formal requirements and government authorities issue press cards as 

license to be a journalist. 59 In Scandinavia, authorities do not present requirements to 

media practitioners and the press’ own organs issue press cards. 60 It is not mandatory to 

have press card in order to operate as journalists. It is supposed that about 10% of 

journalists in Norway are not organised in the Union of Journalists and operate without 

55 The Norwegian Press Association, Vær varsom, cut from articles 1.3 and 3.1-3.10. 

56 


57 

Ibid., pp. 98-99. 

58 


59 

Krug and Price, “The Legal Environment for News Media”, pp. 192-193. 

60 Eide, Den redigerende makt, pp. 92-94. 

70


press card. 61 The selection and control of staff and other inputs is solely left to the editors 

who operate within a framework of their own editorial policy and collective agreements. 

Education and professionalising of journalism is another way to improve quality of 

fact finding. Most Scandinavian journalists have academic degrees. 62 Journalists in 

Scandinavia have had to raise professional standards due to a highly educated public, 

competition, a complex society, and the growth in information flows from professional 

information officials feeding the journalists. 

In principle, the public administration’s documents in Norway, with some 

exceptions, are open to anyone. That has been law since 1970. In practice, the press and 

officials of public authorities have many disputes about limitations and single cases. The 

purpose for openness is to create transparency. The law’s basic principle is that public 

administration’s documents are public as long as no exception in law has been made. 

Neither releasing of information is restricted to specific officials. 63 A government 

appointed committee which has carried out a study and new proposals, emphasises four 

reasons for the principle of openness: It is a way to ensure and maintain democracy, 

transparency to check public administration, public’s legal safeguards as well as admini- 

stration as a source of information. The first two, democracy and transparency, are pointed 

out as most important. 64 Documents exempted from publicity are mostly internal 

documents, information of a sensitive private nature, competition’s sensitive information 

(for instance during tender processes) as well as information concerning national interests 

or security. 65 

61 rd 

Correspondance with Olsen, e-mail received 3 March, 2005. 

62 

Ibid., pp. 92-94. 

63 

Statens Forvaltningstjeneste, Norges offentlige utredninger : NOU 2003:30 : Ny offentlighetslov, section 

3.2.3. 

64 

Ibid., sections 4.2.1-4.2.4. 

65 Ibid., section 3.2.5. 

71


The problem is the law’s ambit which is supposed to be all public authorities at all 

levels where very few organs are exempted. Earlier, sectors of limited openness have been 

social authorities such as offices for child welfare, social security benefits, and health care 

as well as authorities of foreign affairs and the military. 66 

Public sectors in Scandinavian countries are in a process of privatisation. Typically, 

public functions are reorganised into publicly owned limited companies or similarly run 

along the principles of private sector, sometimes even in competition with other private 

actors. Outsourcing of public services that can be provided by private actors is encouraged. 

The purposes are to increase the efficiency of public service and to reduce size of public 

sector. But the law’s principle of openness is not valid towards private sector. Therefore, 

privatisation results in reduced access to public information concerning crucial processes 

in a democratic society. 67 

The press complains over how privatisation has reduced openness in public 

authorities’ activities. In many single disputes, the decision is that publicly owned 

companies have to accept public involvement even if these are organised as limited 

companies, similar to private companies. 68 The actual proposal is to enlarge the scope of 

openness to include private actors which are performing authority on behalf of the public 

administration. The purpose is to maintain the principle of openness despite privatisation. 69 

Compared to Norway, the scope of openness is larger in Swedish administration, and 

smaller in Denmark. 70 

66 Ibid., section 3.3.7. 

67 Ibid., sections 6.2-6.4. 

68 Ibid., section 6.2, in particular footnote 4. 

69 Ibid., sections 6.8 and 6.9.2.2. 

70 Ibid., sections 6.5.1 and 6.5.3. 

72

Publishing 


This aspect about about freedom to select information and decide publishing has 

traditionally been at the core of press freedom. 71 This is the moment where information 

moves from few individuals to the public. So, information is transformed to be a force in 

society. In essence, it is media’s freedom to operate independently on publishing without 

external interference and only to be limited by democratic laws and ethics. 72 

Matters in conflict with freedom of expression can be categorised into national and 

collective interests as well as private and individual interests. The clearest national interest 

is national security. Despite extensive press freedom in Scandinavia, information that is 

injurious to national security is protected by law against publishing. In Norway, despite 

print freedom, police may confiscate all the copies immediately if they consider the content 

to be injurious to national security. Then, a court will have to confirm if the decision was 

right or not. 73 

The Scandinavian notion of ‘democratic society’ includes some collective values. 

Due to tolerance towards minorities, some discriminatory expressions are prohibited. 

These are such as expressions toward particular groups as religious, ethnic, or sexual 

minorities as well as racial expressions. However, expressions have to be made public and 

be quite harsh before these can be an offence. Further, the legal systems have restrictions 

against blasphemy, pornography and regulations of commercial messages. 74 

Private interests in conflict with publicity may be institutional as well as individual. 

A typical private institutional interest may be to protect a business from publicity that 

damages its reputation causing negative economic consequences. For individuals, bad 

71 Eggen, Ytringsfrihet, p. 345. 

72 Krug and Price, “The Legal Environment for News Media”, pp. 193-195. 


74 Ibid., pp. 486-583. 

73


publicity may typically insult their privacy, reputation or injure their future possibilities. 75 

The Scandinavian laws make a balance between the interests of transparency in the society 

and such private interests. 76 Typically, the press is allowed to give more details in matters 

of public interests compared with matters of private nature. 77 All these restrictions have 

resulted in the concept of ‘relative protection of freedom of expression’. The point is that 

the laws make a distinction between expressions which deserve to be protected according 

to democratic values, and those expressions which do not need such a protection. 78 

The codes of conduct are more detailed than laws. Typical Scandinavian rules of 

publishing can be found in the Code of Ethics of the Norwegian Press. The press is suppo- 

sed to be fair and thoughtful, and make plain what is factual information and what is com- 

ment. It has to respect a person’s character and identity, privacy, race, nationality or belief 

and not draw attention to personal or private aspects if they are irrelevant. Headlines, intro- 

ductions and leads have to be in accordance with the text. Presumption of guilt in crime 

and court reporting should be avoided. It has to be clear that the question of guilt has not 

been decided until the sentecne is legally pronounced. It is good press conduct to report the 

final result of court proceedings which have been reported earlier. The press should consid- 

er how reports on accidents and crime may affect the victims and next-of-kin. Victims or 

missing persons should not be identified before next-to-kin have been informed. In court 

and crime reporting names and pictures and other items of definite identification have to be 

used with caution, and only when this is necessary to meet just and fair demands for 

information. As a general rule, the identity of children should not be disclosed in sensitive 

cases. The press should in general never give any mention to suicide and attempted suicide. 

The credibility of the journalistic photograph as documentation has to be protected. If 

75 


76 


77 

Ibid., p. 771. 

78 

Ibid., p. 84. 

74


incorrect information is published, it must be corrected and, if necessary, an apology made 

as soon as possible. Those subjected to attacks should, as soon as possible, have the 

opportunity to reply. Those subjected to strong accusations shall, if possible, have the 

opportunity to simultaneous reply. Debates, criticism and dissemination of news must not 

be hampered by parties being unwilling to make comments. 79 

All Scandinavian countries have media councils to deal with such conflicts. The 

system insists that if a medium loses a case, it has to publish the media council’s 

statement. 80 In addition it is possible to prosecute media, and this leads to the problem of 

self-censorship as the editor seeks to avoid cases in court. 81 In Scandinavia plurality within 

media reduces such an effect. 82 

There is also concern over the balance between published details and the media’s 

social responsibility in crime reporting. The Norwegian code of conduct article 4.7 points 

out the rule that names and pictures and other details of identification in court and crime 

reporting have to be used with caution, and only when this is necessary to meet just and 

fair demands for information. Judgements by the Media Council indicate where the bar is 

set in Norwegian practice. In one case the newspaper Nordlys reported a case of domestic 

violence including details of the incident and about the couple. Beyond the described 

course of events the complaints were concerned about publishing of personal information. 

Even if they were anonymous, almost everyone in their home district would identify them. 

In Scandinavia the right of individuals to be protected from public reporting is highly 

regarded. Despite the attempt to conceal the identity of the couple, the Media Council’s 

79 

The Norwegian Press Association, Vær varsom, cut from articles 4.1-4.15. 

80 

Statens Forvaltningstjeneste, Norges offentlige utredninger : NOU 1996:12 : Medieombud, section 3.1. 

81 

UNESCO, World Communication and Information Report : 1999-2000, pp. 74-75. 

82 

Eggen, Ytringsfrihet, pp. 604-611; and Statens Forvaltningstjeneste, Norges offentlige utredninger : NOU 

1996:12 : Medieombud, section 2.1.2. 

75


conclusion was that the article “contains too many identifying details”. The right to be 

anonymous despite the press’ right to expose such a problem was emphasised. 83 

Another case was where the newspapers Agderposten and Verdens Gang published 

a picture of a gang of boys exercising vandalism. The boys were pictured from the back. 

However, when the parents recognised their own boys who were 12-13 years old, they 

went to the police and solved the matter. Despite the newspapers’ noble purposes, and the 

published picture’s contribution to solve the issue, the Media Council stated that the 

picture gave one of the boys an unnecessary additional burden due to his tender age. 84 

The point formulated by the Media Council is, however, that crime is a public mat- 

ter. Yet, as a main rule the culprit has a right of anonymity. The purpose is to subject crime 

to public debate without infringement of privacy. The identity tends to be published in the 

most serious cases, at a late phase in the process such as after judgement in a court, or if 

the person is already known to the public. The nuances between practices in the 

Scandinavian countries are that Sweden is most modest in publishing names, while 

Denmark exercises least protection of privacy. 85 

Protection of Journalistic Activities 

In Scandinavia, there are some arrangements to protect the press to freely perform its 

activities. It concerns how authorities treat the press’ activities, protection from private 

actors threats, and the editorial department’s independence from owners’ interference. 

Scandinavian media’s approach emphasises the editor’s independence. This quote 

from the Norwegian declaration “Rights and Duties of the Editor” points out this position: 

83 Pressens Faglige Utvalg (Norwegian Media Council), judgement in case 107/2004. Parts: NN and XX 

against Nordlys (newspaper). Concluding date: 24th August, 2004. Available at: http://81.0.149.237/pfu/ 

84 Pressens Faglige Utvalg (Norwegian Media Council), judgements in: Case 117/2003. Parts: NN against 

Agderposten (newspaper). And case 118/2004. Parts: NN against Verdens Gang (newspaper). Both cases 

at concluding date: 16 th December, 2003. Available at: http://81.0.149.237/pfu/ 

85 Omdal, Sven Egil, “Menn som slår, kommer i avisen” in Stavanger Aftenblad (Stavanger, Norway: 

Stavanger Aftenblad ASA), 15 th January, 2005. 

76


“[…] An editor is expected to share the fundamental views and aims of 

his/her publication. But within this framework the editor is entitled to a free 

and independent leadership of the editorial department and editorial work 

and full freedom to shape the opinions of the paper even if they in single 

matters are not shared by the publisher or the board. […] The editor carries 

the judicial responsibility for the paper, and has the full and personal 

responsibility for the contents of the newspaper. The editor directs and is 

responsible for the activities of the members of the editorial department and 

is the link between them and the publisher/board.” 86 

This agreement between the Association of Norwegian Editors and the Norwegian Media 

Business Association, makes a distinction between the editorial work and other businesses. 

Hence, the media have made an arrangement where editorial considerations, and not other 

purposes, will guide journalism. If the owner, the board or others should be concerned with 

the content, the culprit is the editor, solely. Denmark has adopted a similar declaration. 87 In 

Sweden, this arrangement is included in the constitution. 88 Further, several aspects of 

integrity are emphasised in the codes of conduct to ensure ethical adherence for press 

freedom in practice. 89 The maintaining of integrity will also include elements such as 

journalism without licensing, free entrance into the profession, and increased education. 

Despite these arrangements to ensure independence and intregrity, criticism about 

how commercial forces influence media content is still relevant. The commercialisation 

has found its ways into Scandinavian media, as in other countries, even if the owner and 

board respect the principle that they should not interfere with editorial matters. 

From the angle of the authorities, the question is how these behave when conflicts 

with journalists arise. Compared to other countries, very few cases of harassment are 

reported from Scandinavian media. 90 However, a typical conflict between authorities and 

the press can be search for journalists’ sources. A particular purpose in such conflicts may 

86 The Association of Norwegian Editors, “Redaktørplakaten”. The English version is provided by 

correspondance with Øy, e-mail received 10 th February, 2005. 

87 Eide, Den redigerende makt, p. 83. 

88 Correspondance with Øy, e-mail received 10 th February, 2005. 

89 The Norwegian Press Association, Vær varsom, articles 2.1-2.9. 

90 International Press Institute, IPI Report 2003, pp. 194, 217 and 238. 

77


be the police’s need to know sources for solving a crime case. In Norway, the law gives 

courts authority to claim knowledge about sources. However, the code of conduct does not 

allow journalists to reveal any confidential source. In these cases journalists usually refuse 

to give any information despite penalties. 91 Another issue is how editorial departments are 

protected against a police search, similar to offices of lawyers and doctors. If the police 

need a search they have to follow an arrangement together with the editor and then bring 

the items to court. 92 

Private actors have the possibility to harass media through use of courts or other 

means. Civil proceedings against media are of course common in Scandinavia but these are 

not considered serious problems. 93 Possibilities of compensations in civil libel cases are 

relatively limited in Scandinavian laws. 94 

The case study in this section digs deep into a matter where a private individual 

tried to interfere with a newspaper’s coverage. Tensions among two gangs in Oslo resulted 

in January 2001 in assassination of one person followed by great attention in the media. 

Verdens Gang, the largest newspaper in Norway, published name and picture of the 

suspected culprit. His brother then showed up at the newspaper office and demanded an 

end to the coverage of his brother. A conversation with one of the journalists and a deputy 

editor included threats, understood as serious threats of murder. Knowledge about the 

gang’s capacity and weapons supported such an impression. 

These serious threats ended up in court which decided that the purpose of the 

threats was to stop the press’ negative reporting about his brother. Further, it stated: “In a 

democratic society it is of fundamental importance to ensure a free and independent press – 

not only towards the authorities, but towards individuals who are subject to close and 


92 The Norwegian Government, “Straffeprosessloven”, Article 197, 198 and 200. This law is available in 

Norwegian on: http://www.lovdata.no/all/nl-19810522-025.html, downloaded 28 th March, 2005. 

93 International Press Institute, IPI Report 2003, pp. 194, 217 and 238. 


78


critical reporting too.” The conclusion was that the harshness of sentence in such a context 

should be distinctly higher than that in an ordinary case of threats. It was the prosecuting 

authority who brought the case to court. 95 

The case illustrates how journalistic activities in Scandinavia enjoy extraordinary 

protection. This is similar to, for instance, protection of public officials or police on duty 

because of the media’s important function in society. This case shows the level that press 

freedom has reached in Scandinavia and explains why these countries rank at the top of 

press freedom in the world. 96 

95 Den norske Advokatforening, Norsk Retstidende : 2002 (Oslo: Den norske Advokatforening, 2002), p. 1206. 

96 Herbert, Practising Global Journalism, p. 88. 

79

Chapter 4: Press Freedom in East Africa 


The press in colonial East Africa had to serve the purposes of the colonial rulers. Therefore 

the press brought the information they needed, and was turned into propaganda to promote 

their interests. The new African elite who succeeded as rulers after independence contin- 

ued to use mass media to consolidate their positions. However, democratisation in East 

Africa have resulted in increased press freedom. 

The notion of press freedom in East Africa is to a large extent fashioned on 

Western concepts and can be examined in two main parts. First, is the East African context 

on how press freedom developed, forces influencing the growth of press freedom, and the 

of position mass media in societies. Second, are the four aspects of press freedom that 

include media’s role, freedom to gather information, freedom to publish, and protection of 

journalistic activities. 

The East African Context 

The East African countries Kenya, Uganda and Tanzania have a similar history as 

colonies. Despite differences after independence, there are many similarities in democratic, 

legal and cultural traditions as well as notions of press freedom and mass media’s position 

in these countries. Kenya is to some degree representative of these East African countries. 


The missionaries started, and then white settlers and the colonial administration introduced 

printed press to Africa. 1 Patterns and trends of media and press freedom history in East 

Africa are similar. 2 The first printed periodical in East Africa was probably Taveta 

1 Abuoga, John Baptist and Mutere, Absalom Aggrey, The History of the Press in Kenya (Nairobi: The 

African Council on Communication Education, 1988), pp. 4-5 and 109. 

2 Makali (ed.), Media Law and Practice, p. 57. 

80


Chronicle, published quarterly by missionaires from 1895. During a few years, several 

newsletters, journals and even the newspaper The African Standard, in 1902, were laun- 

ched. Activities by European settlers and missionaires initiated most of these publications 

which used European as well as Indian, Arabic, Swahili and Kikuyu languages. The first 

indigenous papers, made by Africans for their own purposes, did not appear before the 

1920s. The first was the Swahili Tangazo. A few years later was Muigwithania founded by 

the Kikuyu Central Association with Jomo Kenyatta as its first editor. 3 

The British ruled Kenya from around 1890 and declared it a colony in 1920. 4 

Uganda fell under British control from 1900. 5 Tanganyika was transferred from Germany 

to Britain after First World War. 6 In early days of colonial rule relations between 

authorities and the press were harmonious. As controversies between authorities and 

indigenous people rose, such conflicts became issues in the press. Colonial authorities 

started to turn to the press to further their interests. An attempt in Kenya was to publish 

Habari by the Native Affairs Department. The aim was to give literate Africans a moderate 

paper supporting official policies to avoid growth of papers that rejected the government, 

Europeans and Christianity. 7 Another step in this initially moderate policy was when the 

British in 1927 introduced the first radio in black Africa in Kenya. 8 

The British press freedom and information policy in colonial East Africa came to 

be a dual history. On one hand, the British were influenced by philosophy which gave rise 

to such ideas as liberty, democracy, public participation and hence need for free informa- 

tion. On the other hand, to achieve control in East Africa became more important than 

3 

Abuoga and Mutere, The History of the Press in Kenya, pp. 4-10. 

4 

Sayer, Geoff, Kenya : the background : the issues : the people : An Oxfam Country Profile (Oxford: Oxfam, 

2004 [1998]), pp. 16-17; and Abuoga and Mutere, The History of the Press in Kenya, p. 11. 

5 

Leggett, Uganda, pp. 16-17. 

6 

Philip’s, Philip’s Encyclopedia, p. 724. 

7 

Ibid., pp. 8 and 13-17. 

8 

Nwosu, Ikechukwu, “An Overview of the Mass Media and the African Society” in Domatob, Jerry, Jika, 

Abubakar and Nwosu, Ikechukwu (eds.), Mass Media and the African Society (Nairobi: The African 

Council on Communication Education, 1987), p. 6. 

81


introducing democratic ideals. The press became a useful tool to introduce and support the 

colonial policies. The emerging hostile indigenous press had to be bridled and suppressed, 

and the British made colonial legislation to do so. 9 

Kenya’s colonial government’s State of Emergency from 1952 to 1960 is important 

for the history of press freedom in East Africa. The struggle between Kenyans and colonial 

masters increased from the 1920s to its peak during the Mau Mau war in the 1950s. During 

the State of Emergency, 1.5 million Kenyans were detained in camps or in villages of 

similar purpose. The press was treated as in war, including a propaganda war, targeting 

Kenyan, British and other foreign media. Yet, articles such as “Gestapo way in Kenya” and 

other similar ones emerged in England. Despite this, the colonial government did 

everything to silence sources, prohibit any contact between its staff and soldiers with 

journalists, denying facts and cover information which was not in favour of the British in 

Kenya. The means there were regulations as well as prosecuting, scaring and defaming 

sources to control the press. 10 

As a reaction to how mainstream media reflected the colonial rulers, a number of 

underground newspapers come into existence in Kenya. Out of this grew an alternative 

press as opposition to the mainstream press. 11 Despite nicknames as gutter press or similar, 

these newspapers have been included in the mainstream political process. 12 

Around 1960, most African colonies got their independence. The East African 

countries gained freedom between 1961-63. The transforming to African rule ensured an 

almost status quo in structures of power and economics. A new African elite emerged with 

similar interests to European colonial masters and settlers. Africans got the political 


10 Elkins, Caroline, Britain’s Gulag : The Brutal End of Empire in Kenya (London: Jonathan Cape, 2005), pp. 

46-47, 54-55, 84, 274, 284-292, 307 and 344-349; and Makali (ed.), Media Law and Practice, pp. 66-67. 

11 Karanja, Mugambi, “Growth of print media in Kenya” in Odero, Mitch and Kamweru, Esther (eds.), Media 

culture and performance in Kenya (Nairobi: Eastern Africa Media Institute and Friedrich Ebert Stiftung, 

2000), pp. 27-28, 31 and 33. 

12 Ogundimu, “Media and Democracy in Twenty-First-Century Africa”, p. 219. 

82


authority, but Europeans continued to own a lot of land and business. The socio-economic 

hierarchy was not challenged much. The printed press became a part of this pattern and an 

arena for the ruling elite’s issues, values, matters and interests. 13 At that time the press was 

supposed to promote development and nation building, in reality a manipulation where the 

press had to serve the elite and not democratisation. 14 

Media laws from the colonial era survived independence in Kenya, 15 Uganda 16 and 

Tanzania. 17 Colonial administration’s media laws to control and manipulate the colonies 

became useful instruments of the new ruling elite. 18 For instance, laws on ‘false news 

offence’ were introduced and are still valid in East Africa even though England abolished 

them in 1887. 19 

Independent East Africa has many examples of harassing of editors and journalists 

with or without lawsuits as well as banning of publications. 20 Another way was to national- 

ise media, such as the Tanzanian President Julius K. Nyerere did in accordance with his 

policy of Africanisation. 21 In Kenya, the colonial administration had established TV as a 

private company just before independence. President Jomo Kenyatta became suspicious of 

13 

Ibid., pp. 70-72; and Abuoga and Mutere, The History of the Press in Kenya, pp. 26-27, 77-81 and 98-100. 

14 

Hydén and Leslie, “Communications and Democratization in Africa”, pp. 1-5. 

15 

Makali (ed.), Media Law and Practice, pp. 58-60 and 67. 

16 

Kemigisha, Rose Mary (ed.), The State of the Media in Uganda (Nairobi: Eastern Africa Media Institute 

and Friedrich Ebert Foundation, 1998), p. 1. 

17 

Kilimwiko, Lawrence and Mapunda, Joseph (eds.), A handbook on the State of the Media in Tanzania (Dar 

es Salaam/Nairobi: Eastern Africa Media Institute, Friedrich Ebert Foundation; and Association of 

Journalists and Media Workers, 1998), p. 2. 

18 


19 

The East African, “Media and Freedom: Uganda Supreme Court Kicks Out Colonial Law” in The East 

African (Nairobi: Nation Media Group), 1 st March, 2004, pp. 8 and 10. 

20 

Ibid., pp. 72-79, Kemigisha (ed.), The State of the Media in Uganda, pp. v and 7-10, Kilimwiko and 

Mapunda (eds.), A handbook on the State of the Media in Tanzania, pp. 3 and 6. 

21 

Nyerere, Julius K., ”The Arusha Declaration: Socialism and Self-Reliance” in Freedom and Socialism : A 

Selection From Writings and Speeches 1965-1967 (Dar es Salaam/London: Oxford University Press, 

1968), pp. 231-234, Kilimwiko and Mapunda (eds.), A handbook on the State of the Media in Tanzania, 

pp. vii-viii; and Abuoga and Mutere, The History of the Press in Kenya, p. 34. 

83


the motives. So, despite Kenya’s privatisation policy, the broadcasting company became 

nationalised and subordinate to the Information Ministry. 22 

Nairobi has grown up to be a center of journalist education in Africa. IPI, one of the 

NGOs concerned with global spread of press freedom, considered around 1960 that it was 

crucial to educate African journalists and editors to be able to take over and run a democra- 

tic press. At independence, media were mostly run by Europeans. During the 1960s, 318 

journalists from 18 countries participated in half year courses in Nairobi or Lagos under 

the auspices of the IPI. 23 These journalism courses at Nairobi College were a predecessor 

for the establishment of Kenya’s first permanent journalism education, at the Nairobi 

Univeristy in the 1970s. 24 In Uganda and Tanzania limitations of adequate journalistic 

education institutions is pointed out as a hindrance to development of mass media. 25 

The rich variety of media associations in East Africa indicates that ‘interests of the 

press’ are not one coherent subject or are not yet carved out. 26 These are as wide-spread as 

labor unions, owner associations, The Association of Media Women in Kenya as well as 

community based fellowships. Despite the spread of interests, such organisations together 

play a role within the civil society where these are agents for media’s interests including 

press freedom. 27 Moreover, such organisations often participate in international unions 

with fellows from other countries, or as members of international NGOs. In this way these 

associations make up strings from East Africa to a global network concerned with mass 

media issues. These organisations can act as powerful lobbyists and are important players 

from an international relations perspective. The presence of a significant branch of 

22 

Makali (ed.), Media Law and Practice, pp. 82-93. 

23 

Righter, IPI: The Undivided Word, pp. 109-169; and International Press Institute, IPI – The First Ten Years, 

pp. 80-87. 

24 

Bourgault, Mass Media in Sub-Saharan Africa, p. 128. 

25 

Kemigisha (ed.), The State of the Media in Uganda, p. 3; and Kilimwiko and Mapunda (eds.), A handbook 

on the State of the Media in Tanzania, pp. viii, xi and 50-60. 

26 

Kadhi, Joe S. M., “Anglophone Africa: Puppets of the proprietors?” in Kunczik, Michael (ed.), Ethics in 

Journalism : A Reader on Their Perception in the Third World (Bonn: Friedrich-Ebert-Stiftung, 1999), p. 110. 

27 

Abuoga and Mutere, The History of the Press in Kenya, pp. 85-89; and Kilimwiko and Mapunda (eds.), A 

handbook on the State of the Media in Tanzania, pp. 61-73. 

84


UNESCO in Nairobi, concerned with press freedom, does strengthen the global connect- 

ions to East Africa in these matters. 

Kenya has enjoyed a higher level of press freedom compared to other developing 

countries. 28 One reason may be the education of journalists in the country. 29 The level and 

variety of journalism education in Kenya is among the highest in Africa. 30 Nairobi has 

emerged as the media centre in East and Central Africa. 31 In independent Kenya, press 

freedom has had its ups and downs. Due to weak legal protection, press freedom in Kenya 

has been dependent on politicians’ interpretation and goodwill. 32 While press freedom has 

been improved 33 there are occasions when journalists and editors are questionned and 

imprisoned. 34 

A chronological survey of some changes in Kenyan press freedom shows that the 

colonial rulers just before independence still maintained a strong regime towards the press. 

Even new restrictions were still introduced. 35 Emergence of the Nation newspapers in 1960 

marked a milestone. Despite foreign ownership, these newspapers were staffed with 

Africans and added Kenyan opinions within mainstream media. 36 

Optimism on press freedom was quickly reduced after independence when new 

rulers started to manipulate media and news for their propaganda purposes. 37 Criticism of 

government and the president resulted in silencing of editors. 38 Even worse became the 


29 Coppard, Kit, IPI: The Defence of Press Freedom : A History of The International Press Institute : Part II: 

1976-1988 (London/Zurich: The International Press Institute, 1988), p. 43. 

30 Merrill, Global Journalism, p. 253. 

31 


32 

Abuoga and Mutere, The History of the Press in Kenya, pp. 79-80. 

33 

Bindra, Sunny, “The real achievement of 2003 is an open society” in Sunday Nation (Nairobi: Nation 

Media Group), commentary, 21 st December, 2003. 

34 

International Press Institute, IPI Report 2003, p. 27-28. 

35 


36 

Ibid., pp. 71-72; and Odero, Mitch, “Press in Kenya: an overview” in Odero, Mitch and Kamweru, Esther 

(eds.), Media culture and performance in Kenya (Nairobi: Eastern Africa Media Institute and Friedrich 

Ebert Stiftung, 2000), pp. 11-13. 

37 

Kadhi, “Anglophone Africa: Puppets of the proprietors?”, p. 122. 

38 Odero, “Press in Kenya: an overview”, p. 15. 

85


suppressing of critical voices within the press after the assassination of the Planning and 

Economic Affairs Minister Tom Mboya in 1969. President Kenyatta used the political 

crises to force on performance of media that ensured the victory in the election the same 

year. 39 Banning of media became common. Newspapers and magazines had to support 

government to survive. During the presidencies of both Kenyatta and Daniel arap Moi 

there were periods where the press had no space to perform any democratic role. 40 Yet, the 

1970s and up to 1982, the end of Kenyatta’s and beginning of Moi’s eras, was a period 

where the press had some breathing space. Several newspapers were established, but poor 

markets made it difficult to keep on. 41 

The attempt of coup d’état in 1982 marked a change in press freedom. President 

Moi emphasised his ‘nyayo’ philosophy. That means that anyone, media included, had to 

subordinate themselves to the Head of State who acted as the nation’s father figure. Kenya 

entered an era of dictatorship. 42 The underground alternative press recurred as the 

opposition’s channel of information. Further, some critical magazines set standards of 

courage in this hostile era where media often were banned. Nairobi Law Monthly, Finance, 

Financial Review, Society, Beyond and Development Agenda were capable to express 

opinions towards the dictatorship, and became pioneers for renewed democratisation 

including an independent press. 43 Due to human rights offences, Kenya was under 

international pressure. Foreign correspondents in Nairobi were carefully watched. 44 

Foreign funding of critical magazines indicated how international actors were concerned 

39 Kamau, John, “How Kenyatte gagged the press to manage the Mboya crisis” in Sunday Standard (Nairobi: 

The Standard Ltd.), news article, 25 th April, 2004. 

40 Kamau, John, “When You Had to Shut up or Languish in Prison for Years” in Media Review, a pull-out in 

eXpression today (Nairobi: The Media Institute), May 1999, p. 38-41. 

41 Odero, “Press in Kenya: an overview”, pp. 15-17; and Makali (ed.), Media Law and Practice, pp. 74-75. 

42 

Ochieng, I Accuse the Press, pp. 58 and 118; and Makali (ed.), Media Law and Practice, p. 75. 

43 

Karanja, “Growth of print media in Kenya”, pp. 38-39; and Makali (ed.), Media Law and Practice, pp. 75- 

79 and 302-303. 

44 

Odero, “Press in Kenya: an overview”, pp. 19-22. 

86


with press freedom in Kenya. 45 From 1990 restoration of freedom of expression became a 

condition for the United States’ aid to Kenya. 46 

In 1991 multi party system was introduced and a corresponding growth of plurality 

in media followed. 47 The alternative press mushroomed, which also proved Kenya as an 

ethnically fractured society. In this way the alternative press became means of partisanism 

and ethnic journalism. 48 Critical journalism started to recur in mainstream media. 49 One 

issue that illustrated the press’ new role was how the state was no longer the only actor in 

making laws. Civil society participated in a public debate in media and started to influence 

law making. 50 

However, three examples illustrate that these still operated under difficult 

circumstances. First, in 1993 the police dismantled vital parts of Fotoform Ltd.’s printing 

machine and seized what they considered as seditious publications. Fotoform printed 

Society, Economic Review, Finance and Nairobi Law Monthly. The latter was banned at 

that time. Several people were arrested in related cases. 51 Second, a new Defamation Act 

was passed in 1992 that was seemingly designed to protect politicians. In the wake of the 

murder of Foreign Minister Robert Ouko in 1990, several media reports ended up in court. 

Nairobi lawyer George Oraro was in 1993 awarded about US$ 19,000, fifteen times more 

than in any other libel case. In 1999 Justice Evans Gichuru of Court of Appeal was 

awarded US$ 28,000 and Minister Nicholas Biwott was awarded US$ 390,000. The 

45 

Munene, Macharia, “Africans and Intellectual Adventurism: East African Intellectual Warriors”, paper 

presented in the University of Illinois NEH Seminar, African Studies in Africa, 11 th – 15 th November, 

2002, p. 8. 

46 


47 

Karanja, “Growth of print media in Kenya”, p. 39 

48 

Kadhi, “Anglophone Africa: Puppets of the proprietors?”, p. 103; and Omwanda, Lewis Odhiambo, “The 

mass media and democracy: Understanding the problem of objectivity in multicultural settings” in Odero, 

Mitch and Kamweru, Esther (eds.), Media culture and performance in Kenya (Nairobi: Eastern Africa 

Media Institute and Friedrich Ebert Stiftung, 2000), pp. 203 and 219. 

49 

Ochieng, I Accuse the Press, p. 189. 

50 

Mute, Lawrence Murugu, “Media policy in Kenya” in Odero, Mitch and Kamweru, Esther (eds.), Media 


2000), p. 148. 

51 

Ibid., p. 145; and Makali (ed.), Media Law and Practice, pp. 301-304. 

87


practice of these huge compensations made media careful and enforced self-censorship. 52 

Third, in 1997 President Moi wanted to avoid extensive attention to ethnic clashes. He 

used the Public Security Act and curfew to deny journalists entrance into actual areas of 

conflict and reduced media’s ability to cover those events. 53 

However, the level of press freedom increased through the 1990s. A milestone was 

liberalisation of the airwaves even if the first private actors entered broadcasting as result 

of political fraternity or struggles in court. 54 An attempt to reduce laws about media has not 

been successful. Still, there are about 14 Acts which have implications for media. 55 The 

greatest threat to press freedom in Kenya at present under Presiden Mwai Kibaki is 

probably self-censorship due to strong laws on defamation and sedition as well as 

contempt of court and freedom of speech. 56 Despite self-censorship, media’s activities in 

Kenya have shown that a free and vibrant press can be useful in effecting transparency, 

democracy and good governance. 57 The alternative press has still an ethnic feature. Yet, 

several of the most controversial cases latter years have come up through the alternative 

press and then been picked up by the mainstream media. 58 The Kenyan press seems to 

perform its role without direct intereference from government 59 although the broadcast 

media are still subjected to attempts of control 60 and although President Kibaki’s position 

52 

Makali (ed.), Media Law and Practice, pp. 181-183 and 192-201. 

53 

Okello, Rosemary, “Media law past, present and future” in Odero, Mitch and Kamweru, Esther (eds.), Media 


2000), p. 160. 

54 

Carver, Coliver, Lauriciano, Lush and Maja-Pearce, Who Rules the Airwaves, pp. 33-39. 

55 

Okello, “Media law past, present and future”, p. 158. 

56 

Makali (ed.), Media Law and Practice, pp. 181-190, 256, 272-277, 312-313 and 326. One example: Ogutu, 

Judy, “Mwau seeks orders to bar ‘The Standard’ ” in The Standard (Nairobi: The Standard Ltd.), news 

article, 2 nd March, 2005. 

57 

Munene, G. Macharia, “Historical Perspectives on Politics and Journalism” in Okigbo, Charles (ed.), Reporting 

Politics and Public Affairs (Nairobi: The African Council for Communication Education, 1994), p. 50. 

58 st 

Oral interview with Kodi Barth, Lecturer of Journalism at USIU, Nairobi, in his office at USIU, 1 

September, 2004. E-mail: kbarth@usiu.ac.ke. 

59 

Kadhi, Joe, in his address at The Media Council of Kenya’s public conferense on “Is There a Place for 

Unethical Journalism in Kenya?” at The Stanley Hotel, Nairobi, 1 st March, 2005. Kadhi is member of The 

Media Council of Kenya; and Head of Extended Studies and Journalist in Residence at USIU, Nairobi. 

60 

Daily Nation, “Tuju’s order to censor broadcasts ‘is illegal’ ” in Daily Nation (Nairobi: Nation Media 

Group), news article, 2 nd March, 2005. 

88


is that Kenyans shall enjoy unlimited press freedom because it entrenches development 

structures. 61 The government has stated that it supports a system of self-regulation. 62 

Uganda encourages private actors in the media and the print media operate like 

other businesses. Nevertheless, in Uganda the government is frequently hostile to media. 63 

Common methods of control are questioning, charging, imprisoning as well as demonising 

or scandalising journalists. For instance, the Ugandan journalist and editor Charles 

Onyango-Obbo was, between 1997 and 2003, arrested three times and brought before court 

120 times. Ugandan journalists, however, have not been targets of assassinations as was 

the case during the regimes of Obote and Amin. 64 

Broadcast media have to pay fees. For non-commercial actors these fees are a 

heavy burden. A radio station in Kampala has to pay US$ 1,500 annually. Many 

broadcasters are struggling to avoid bankruptcy. 65 The Penal Code still bans publishing on 

a wide range of information. 66 Unexpectedly, in 2004 Uganda’s Supreme Court ruled that 

Uganda’s laws, from the colonial era, on ‘false news offence’ were unconstitutional. 67 

Tanzanian press freedom is far behind Kenya and Uganda. There is freedom of 

expression in the Constitution, but about 40 laws make up a web of hindrances against free 

press. After pressure, the government started a process to review media laws and prepare 

61 

The Kenyan Government, “Why Mwai Kibaki does not speak out on everything” in Daily Nation (Nairobi: 

Nation Media Group), advertisement, 2 nd March, 2005. 

62 

Daily Nation, “Government set to review press laws, says Kiraitu” in Daily Nation (Nairobi: Nation Media 

Group), news article, 5th April, 2004. 

63 

Wakabi, Wairagala, “Kenya and Uganda Still Have Though Press Laws” in The East African (Nairobi: 

Nation Media Group), news article, 19th April, 2004. 

64 

Oral interview with Charles Onyango-Obbo, Managing Editor of Convergence and Syndication, Nation 

Media Group Ltd. in Kenya, e-mail: cobbo@nation.co.ke. Former editor of the newspaper The Monitor in 

Uganda. Interview with him in his office in Nairobi 21 st February, 2005, about press freedom in Uganda. 

65 

Nakkazi, Esther, “Uganda Cracks Down on Radio, TV Stations” in The East African (Nairobi: Nation 

Media Group), news article, 12th January, 2004. 

66 

Kemigisha (ed.), The State of the Media in Uganda, pp. 7-8. 

67 th 

Supreme Court of Uganda, judgement dated 11 February, 2004, on an appeal in Monitor v. Constitutional 

Court, judgement published 21 st July, 2000. The judgement is published in full by The East African 

(Nairobi: Nation Media Group), 1 st March, 2004, pp. 8-10 and 16-17. 

89


for open information policy. The review is expected to conclude in 2006. 68 The most 

important laws are The Penal Code (on sedition), The National Security Act, The 

Newspapers Act, The Broadcasting Service Act, Prisons Act 69 and a new Terrorism Act. 70 

Tanzania was a socialistic one-party state under President Julius K. Nyerere. In 1992 a 

liberalisation process including the media started and media’s role in development was 

emphasised. An experience from the time before 1992 was how political dependency 

reduced trust in media resulting in declined circulation. 71 Still, after liberalisation, the 

media experienced harassment, searching, questioning, imprisonment and even stripping of 

citizenship. At the same time, journalists friendly to government received favours such as 

transport and access to information. 72 

Tanzania is, except South Africa, the African country south of Sahara with the 

largest diversified media industry. 73 Regarding quality, Tanzanian media do not have such 

a prominent position in Africa. It is noteworthy that Tanzania in 2004 waived some taxes 

on the media industry. In addition, The Media Council established in 1999 contributed 

significantly to conflict mediation. The number of media cases in courts declined 

considerably. 74 

Forces Around Press Freedom 

Three forces have surrounded the growth of press freedom in East Africa. First, is 

ownership in general as well as global media and foreign owners’ impact on press 

68 

Oral interview with Theophil Makunga, Consulting Editor of Taifa Leo, Nation Media Group Ltd. in 

Kenya, e-mail: tmakunga@nation.co.ke. Former Editor-in-Chief of Majira and Managing Editor of 

Mwananchi, both Tanzanian newspapers. Interview with him at Nation Centre in Nairobi 1 st March, 2005, 

about press freedom in Tanzania. 

69 

Kilimwiko and Mapunda (eds.), A handbook on the State of the Media in Tanzania, pp. 1-9. 

70 

Oral interview with Makunga. 

71 


72 

International Press Institute, IPI Report 2003, pp. 48; and oral interview with Makunga. 

73 

Kivikuru, Ullamaija, “From State Socialism to Deregulation” in Boyd-Barrett, Oliver and Rantanen, Terhi 

(eds.), The Globalization of News (New Delhi/London: Sage Publications, 1998), pp. 140-141; and 

Kilimwiko and Mapunda (eds.), A handbook on the State of the Media in Tanzania, pp. vii. 

74 


90


freedom. Second, African elite classes hamper press freedom. Third, is the press freedom’s 

role in national development. 

First, despite the mushrooming of media in Kenya, there is concentration on the 

owners’ side. These owners are involved with the political and business elites. Politics 

have been determinant in allocating of broadcasting licenses. There are no legal regulation 

of how extensive ownership single actors can buy in media. Five units control mainstream 

media in Kenya. These are Nation Media Group, Standard Group, Royal Media, The 

People Daily and Kenya Times. The last two started late and remained marginalised. Due 

to this situation, press freedom in Kenya operates within a framework made up by a few. In 

addition, the state owned Kenya Broadcasting Service (KBC) has a national TV and 

several radio channels. 75 

Nation Media Group is known for its newspapers, radio and TV which all are 

named ‘Nation’. In addition, the group has engagements in several newspapers, magazines 

and broadcasting stations in all of the East African countries. The Aga Khan, leader of the 

Ismaili Muslim sect, is the founder and major owner with 45% of the shares. 76 The Aga 

Khan has a lot of business in Kenya. These are media, schools, hospitals and hotels. 

Nation’s media are considered as business friendly. The Aga Khan is known to influence 

politics in Kenya by media and networking, to ensure good conditions for his business. 77 

Indirect support is achieved by how his media advocate a multicultural nation governed on 

opportunities for all. 78 Nation’s media supported the new NARC government and President 

Kibaki during last election in 2002. 79 

75 Oral interview with Barth. 

76 Nation Media Group Limited, Annual Report & Accounts / Ripoti Na Hesabu 2003 (Nairobi: Nation 

Media Group, 2004), pp. 10-11 and 42. 

77 Oral interview with W. Kwendo Opanga, Executive Editor of The Standard/Sunday Standard, in his office 

in Standard, 10 th April, 2005. E-mail: opashw@eastandard.net. 

78 Karanja, “Growth of print media in Kenya”, p. 35. 

79 Oral interview with Barth. 

91


The Standard Group’s most prominent media are the newspapers The Standard and 

Sunday Standard and the TV station KTN. 80 The Standard had for the most part good 

relations with the presidents Kenyatta and Moi. The given reason was that Standard’s 

business benefitted from these relations. 81 Powerful individuals during Moi’s and KANU’s 

regime were major shareholders before the election in 2002, and used their power to 

influence Standard’s media. Now, these shares are sold to foreign companies probably 

controlled by the same individuals. However, after the loss in the 2002 election and 

transforming to ‘invisible foreign owners’, they have not interfered with journalism in 

Standard’s media. Their declared objective is that Standard shall make a good profit. 

Standard’s media are also considered as business friendly. Kibaki’s government consider 

The Standard as an enemy due the the newspaper’s mainly adversarial position. 82 

Royal Media is owned by Samuel K. Macharia. Citizen FM and Citizen TV are the 

most known media of this group which has several other radio stations as well. It is 

estimated that Royal Media’s potential listenership is 70% of all Kenyans. 83 In 1990 the 

first private actors entered broadcasting in Kenya. Macharia considered it as a business 

opportunity, and applied for licence which was rejected. 84 After a battle in court, President 

Moi in 1997 promised broadcast license in exhange for political support. The honeymoon 

with Moi became short. For a year, Macharia’s radio and TV stations were banned. In the 

2002 election, Citizen’s radio and TV were major supporters for President Kibaki. During 

the two last years, Macharia has got licences and been able to launch five new FM stations. 

He is regarded as close to Kibaki’s government. 85 

80 

Ibid. 

81 

Odero, “Press in Kenya: an overview”, p. 19. 

82 

Oral interview with Opanga. 

83 

Wachira, Nick, “The unlikely media mogul : Will Citizen rule the airwaves?” in The Standard (Nairobi: 

The Standard Ltd.), news article, 22 nd March, 2005. 

84 

Makali, David, “Progress and Problems in Freeing Kenya’s Airwaves” in Media Review, a pull-out in 

eXpression today (Nairobi: The Media Institute), May 1999, p. 13-14 and 18. 

85 

Wachira, “The unlikely media mogul : Will Citizen rule the airwaves?” 

92


Foreign owners have had major shares in East African media. Further, East African 

media have to operate within the regime of global media. Both factors limit their freedom. 

Put to an extreme, Tom Mboya stated that Kenya achieved independence despite the world 

press. 86 East African mass media do not work in a vacuum. Their content depends on 

foreign sources and news agencies. 87 Advertisement income depends on foreign global 

business and its preferences. 88 Media ideology is a result of Western capitalistic concepts. 89 

Hence, East African media are wrapped up in a web made by global media. One view is 

that this is how global forces secure universal spread of press freedom. A competing view 

is that East African media are slaves of a global media regime and have lost freedom to 

play their own unique role. According to the latter, one allegation is that such a Western 

ideological press would never liberate the third world. 90 

Foreign owned media were initially nationalised in Tanzania and Uganda. Kenya 

allowed the presence of foreign owners and precipitated recurring debates about their role 

and purposes. One claim is that foreigners were the only ones strong enough to resist 

pressure from Kenyan authorities. Foreign ownership was thus a security for press 

freedom. Another claim was that foreign owners through Kenyan media can interfere with 

domestic affairs. This made foreign ownership an agent for foreign interests. A third view 

was that owners were owners, and both locals and foreigners were pursuing their media 

business according to commercial interests. In that case, the question was not about foreign 

ownership, it was on how private media operate as agents for capitalistic interests. 91 If 

86 

Mboya, “Relations Between Press and Governments in Africa”, p 144. 

87 

Paterson, “Global Battlefields”, pp. 79-81. 

88 

Carrington and Nelson, “Media in Transition: The Hegemony of Economics”, pp. 226-232; and Abuoga 

and Mutere, The History of the Press in Kenya, pp. 94-95. 

89 

Makali (ed.), Media Law and Practice, pp. 60-61; and Abubakar, “The Mass Media and Ideological 

Apparatuses in Post-Colonial Africa”, pp. 55-56. 

90 


91 

Mytton, Graham, Mass Communication in Africa (London: Edward Arnold Publishers, 1983), p. 19, 

Ochieng, I Accuse the Press, pp. 52, 55, 115 and 167, Makali (ed.), Media Law and Practice, p. 71. 

93


profit is the sole purpose, such media owners would be vulnerable to corrupt practices as 

well as economic arrangements. 92 

Second, African elite tend to hamper press freedom and benefitted from the 

structures of the colonial system. Therefore, despite national liberation, these did not have 

the interest of press freedom at all. 93 The mass media were rather considered as vehicles 

for the rulers. 94 As a result, mass media were manipulated to be propaganda organs. 95 They 

justified control of media on grounds such as national unity, stability, development, culture 

and religion. The hidden selfish interest was to gain monopoly over state resources 

including information flow and media. So, the ruling elite manipulated public opinion. 96 

Democratisation processes have relied on this suppression of media, but many legal 

instruments such as defamation and false news are still valid and serve powerful 

individuals to control media. 97 One result is self-censorship to avoid conflicts. This 

weakness of press freedom is articulated by the senior Kenyan journalist and editor, Philip 

Ochieng, in this way: “…and freedom of the Press became widespread. But we proved 

totally unable to exploit it.” 98 

Third, there appeared to be contradictions between press freedom and national 

development. The core is a mix of press freedom with other purposes. Nyerere emphasised 

development including use of media. Nyerere wrote: “Freedom and development are as 

completely linked together as chickens and eggs… without freedom you get no 

development.” 99 Further, he stated that in a country faced with poverty, press freedom 

92 

Ochieng, I Accuse the Press , pp. 167-170. 

93 


94 

Mytton, Mass Communication in Africa, pp. 42-43. 

95 


96 

An-na’im, “The Freedom of Expression as a Universal Human Right”, pp. 23-24. 

97 

Makali (ed.), Media Law and Practice, pp. 58-59 and 114-124. 

98 


99 

Kunczik, “Closing remarks: Is there an international ethics of journalism?”, p. 247. 

94


should be limited just as liberal democracies had done in wartime. 100 Besides these, 

Tanzanian media were bound by development as a national ideology. 101 Thoughts similar 

to Nyerere’s wrapped into such terms as ‘national unity’ became widespread in Africa. 102 

Put to an extreme it could be interpreted as building loyalty to the ‘national father’ as 

during President Daniel arap Moi’s regime in Kenya. 103 However, press freedom and 

media have been inextricably connected with a development agenda in Africa. 104 

‘Development journalism’ seems initially to be in tune with ‘social responsibility’ 

but this is not necessarily the case. First there are assumptions that the audience will 

behave in expected ways, that they would accept media’s messages, and that media’s 

content would empower people to develop. It does not always happen. 105 In addition, it is 

argued that development issues do not work as attractive content in a way demanded by 

commercialised news values. 106 Second, ‘development journalism’ is said to be just 

another idea of the authoritarian press system which was a Soviet practice. 107 

‘Development’ will determine the framework for ‘truth’. Such a philosophy can be used to 

justify lying and limit information flow to ‘pedagogically skilful’ content. So, media’s role 

can be controlled to stabilise the regime and journalists would not be allowed to critisise. 108 

The whole game of building national image by using national and international 

media is included in this objection. 109 Development journalism was used as a term to alter 

100 

Mytton, Mass Communication in Africa, p. 59. 

101 

Kivikuru, “From State Socialism to Deregulation”, p. 150. 

102 


103 

Ochieng, I Accuse the Press, pp. 117-118. 

104 

Okolo, Dan Edogbo, “Agenda Setting Role of the Mass Media in Political Reporting” in Okigbo, Charles 

(ed.), Reporting Politics and Public Affairs (Nairobi: The African Council for Communication Education, 

1994), pp. 31 and 34. 

105 

Ochilo, “Africa : Perspectives for Editorial Independence”, p. 45. 

106 

Poland, Kate, “Development Moments: Radio’s Public Face of Development” in Journal of International 

Development (West Sussex, UK: John Wiley & Sons, 2004) volume 16, number 5, July 2004, p. 714. 

107 

Retief, Johan, Media Ethics : An Introduction to Responsible Journalism (Oxford: Oxford University 

Press, 2002), pp. 17 and 21. 

108 


109 

Boyd-Barrett and Rantanen, “The Globalization of News”, p. 5; and Dunn, Kevin C, Imaging the Congo : 

the international relations of identity (New York: Palgrave Macmillan, 2003), pp. 3 and 124. 

95


news values in developing countries to turn the press to benefit authorities. 110 Tanzania, as 

other African states, established a state owned news agency, SHIHATA, to control 

information flow out of the country, ensure Tanzania’s international image and support 

other political objectives. SHIHATA and similar agencies achieved low credibility and 

became unprofitable business. Independent media did not want to pay for a service they 

considered to be propaganda. 111 

When press freedom interacts with other purposes, the performance is a balancing 

art. A Kenyan notion of this is summed up by Mitch Odero, Chairman of the Media 

Council of Kenya: “Journalism is a national duty. But it is not so much a national duty as 

America’s, the homeland of freedoms, journalists do in the coverage of Iraq.” 112 In this 

statement, he recognised a journalist’s national duty as well as limitations of such a duty. 


Radio is definitely the most wide-spread mass medium in East Africa. 113 It is because radio 

is cheap compared to newspapers and TV, and because transport and illiteracy are no 

hindrance for radio. The UNESCO measure of minimal spread of radio is 20 receivers per 

1000 inhabitants. Together with radio, TV is ranked as the second most used comm- 

unication channel in Africa. 114 

Number of radio- and TV-receivers pr. 1000 inhabitants (1996) 115 

Country TV Radio 

Kenya 26 108 

Tanzania 3.3 280 

Uganda 16 130 

110 Ali, Owais Aslam, “Claiming that Differences in ‘Values’ Justify News Directions” in The World Press 

Freedom Committee, New Code Words For Censorship : Modern Labels for Curbs on the Press (Reston, 

USA: The World Press Freedom Committee, 2002), pp. 71-73. 

111 Kivikuru, “From State Socialism to Deregulation”, pp. 137-140. 

112 Odero, Mitch, in his closing address at The Media Council of Kenya’s public conferense on “Is There a 

Place for Unethical Journalism in Kenya?” at The Stanley Hotel, Nairobi, 1 st March, 2005. 

113 Carver, Coliver, Lauriciano, Lush and Maja-Pearce, Who Rules the Airwaves, p. 1. 

114 Ochilo, “Africa : Perspectives for Editorial Independence”, pp. 43-44. 

115 United Nations, Statistical Yearbook : Forty-fourth issue : 1997, table 18, pp. 130-137. 

96


Newspapers and other print media are regarded as a luxury. Spread of newspapers 

is far below UNESCO’s measure for minimum circulation, which is 100 per 1000 

inhabitants. 116 US$ 0.5 for a copy is expensive when efficient readership need a copy daily, 

and the majority do not have more than US$ 1 daily for survival. Poor infrastucture limits 

distribution of newspapers to urban areas. Content and advertising also indicate that 

newspapers are targeting the urban elites. 117 

Spread of daily newspapers (1996) 118 

Country Number of Total Circulation per 

titles circulation 1000 inhabitants 

Kenya 4 263,000 9.4 

Tanzania 2 40,000 2.1 

Uganda 3 120,000 3.9 

The figures are old, 1996, but are used because these are the available ones in both East 

Africa and Scandinavia. Since 1996, the number of daily newspapers in Tanzania has 

grown to ten; six in Kiswahili and four in English. 119 

Books are even a more elite medium than newspapers. 

Number of new published book titles (1996) 120 

Country New book titles Titles per 


Kenya (1994) 300 0.011 

Tanzania 288 0.009 

Uganda 172 0.008 

Internet is difficult to measure due to rapid changes. However, one indicator is 

Africa’s share of Internet host sites globally. That was 0.025% and continued to decline in 

1998. 121 The same year Africa’s share of global telecommunication between regions was 

116 Hydén and Leslie, “Communications and Democratization in Africa”, p. 9. 

117 Kilimwiko and Mapunda (eds.), A handbook on the State of the Media in Tanzania, p. 11. 

118 

United Nations, Statistical Yearbook : Forty-fourth issue : 1997, table 16, pp. 117-123. 

119 


120 

United Nations, Statistical Yearbook : Forty-fourth issue : 1997, table 15, pp. 111-116. 

121 UNESCO, World Communication and Information Report : 1999-2000, p. 185. 

97


2.7%. The United States and Canada had 55%. 122 If domestic traffic had been included in 

these figures, Africa’s share would have dropped further. 

Journalistic capacity is another indicator of the press’ potential power. Press free- 

dom is not a reality if the force to check institutions and powerful individuals is small. A 

rough survey of East Africa shows that the number of journalists in Kenya are 1,500- 

2,000, 123 in Tanzania 2,000, 124 and in Uganda 400. 125 In other words, there are about 

20,000 inhabitants per each journalist. 126 In practice, even if East African journalists had 

extensive freedom they would not have capacity to perform critical journalism in a broad 

manner. 

Four Aspects of Press Freedom in East Africa 

In East Africa, the growth of press freedom can be analysed in four ways. First is the role 

of the press. Second is news gathering. Third is publishing. Fourth is protection of 

journalistic activities. 

Role of the Press 

All the East African countries ensure more or less unreserved freedom of expression in 

their constitutions, 127 and at the same time have many laws regulating press freedom. 

Typical limitations are framed in laws on defamations or libels, sedition, penal codes, 

national security acts as well as acts on newspapers, broadcasting and films. 128 Altogether 

122 

Calculated on figures from: Aronson, “The communications and Internet recolution”, pp. 544-546. 

123 

Estimate made by Joseph Olweny, Editorial Manager at Nation Media Group Ltd., in conference in his 

office in Nation Centre in Nairobi, 1 st March, 2005. 

124 

Kilimwiko and Mapunda (eds.), A handbook on the State of the Media in Tanzania, p. iii. 

125 

Kemigisha (ed.), The State of the Media in Uganda, p. vi. 

126 

Number of inhabitants from: Microsoft, Encarta Interactive World Atlas 2000, CD-rom. 

127 

Kenya: Makali (ed.), Media Law and Practice, pp. 101-104, Tanzania: Kilimwiko and Mapunda (eds.), 

A handbook on the State of the Media in Tanzania, p. 1, Uganda: Kemigisha (ed.), The State of the 

Media in Uganda, p. 4. 

128 

Makali (ed.), Media Law and Practice, pp. 181-190 and 272-273; and Kilimwiko and Mapunda (eds.), A 

handbook on the State of the Media in Tanzania, pp. 1-9. 

98


these make up a web of strings to authorities, and any powerful individual, to interfere with 

the press’ conduct. In this way East Africa has a conditional press freedom. 129 

Laws protecting national interests are common in all democracies. But such laws in 

East Africa are extensive. One example is Tanzania’s Prisons Act of 1967 which bans jour- 

nalists to visit prisons, talk with prisoners, take photos, or for ex-prisoners to share their 

experience with journalists. 130 In that way Tanzania’s government removed a significant 

part of legal protection from public debate. 

Media is business based on incomes from markets. A major problem for East 

African media is small and poor markets due to poverty. Therefore it is difficult for 

African media to achieve economic growth and a sustainable economy which are supposed 

to support their independence. 131 Despite many attempts to start newspapers, bankruptcy is 

common. 132 Scanty advertising markets make governments advertising to be a major actor 

resulting in dependence. 133 One exception in East Africa is, however the Nation Media 

Group, based in Nairobi that runs commercial media business in all these three countries. 

In 2003 the group had a total sale of almost US$ 60 million where the profit before tax 

reached 20% of the sale. 134 There are some complaints on taxes, among these being the 

broadcast licence fees in Uganda. 135 Tanzania’s waiver of some taxes against media is an 

unusual example in East Africa of public subsidies to support media. 136 

The media ensure their role by creating self-regulating bodies such as The Media 

Council of Kenya whose purpose is to keep government out of media operations. 137 In 

129 

Ogbondah, “Media Laws in Political Transition”, pp. 63-64 and 67. 

130 

Kilimwiko and Mapunda (eds.), A handbook on the State of the Media in Tanzania, p. 7. 

131 

Carrington and Nelson, “Media in Transition: The Hegemony of Economics”, pp. 225-226. 

132 

Hydén and Leslie, “Communications and Democratization in Africa”, p. 18. 

133 

Ochieng, I Accuse the Press, pp. 168-170. 

134 

Nation Media Group Limited, Annual Report & Accounts / Ripoti Na Hesabu 2003, p. 22. 

135 

Nakkazi, “Uganda Cracks Down on Radio, TV Stations”. 

136 


137 nd 

The Media Council of Kenya, Code of Conduct and Practice of Journalism in Kenya : 2 Edition 

(Nairobi: The Media Council of Kenya, 2004 [2002]), p. iii. 

99


1992 Kenya opened up to multi party political system accompanied by expansion of press 

freedom. Some politicians asked for regulations of media. As a reaction, The Media 

Industry Steering Committee (MISC) started to advocate self-regulation in the form of 

code of conduct and a media council. The Media Council of Kenya became operative in 

2004. The very first case came from the Minister of Information, Raphael Tuju versus 

Daily Nation. 138 

Stakeholders in MISC which runs the Media Council are The Kenya Union of 

Journalists, The Media Owners Association, Editors’ Guild of Kenya, The Alternative 

Press, Media Training Institutions, Kenya Correspondents’ Association, Media NGOs and 

Public Media. 139 When a complaint is brought up, the procedure is first to try and mediate 

the dispute. If mediation does not work, the Media Council acts as a court. If dissatisfied, 

the complainant can bring the case before an ordinary court. The establishment of the 

Media Council is an attempt to enlarge the space for press freedom. 140 

Gathering Information 

The NWICO debate noted the lack of technology in poor countries and that the media in 

these countries are not properly equipped to access and gather information. In East Africa, 

lack of equipment is a bottleneck for access to information. 141 

The ethical side of information gathering is described in the Code of Conduct and 

Practice of Journalism in Kenya. The code points out that comments from anyone who is 

mentioned in an unfavourable context should be obtained and that it is a professional 

obligation to protect confidential sources. Journalists should generally identify themselves, 

and not tape or record anyone without the person’s knowledge. In cases involving grief or 

138 

Oral interview with Esther Kamweru, Executive Director of The Media Council of Kenya, in her office in 

Nairobi, 10 th March, 2005, about the Media Council. 

139 

The Media Council of Kenya, Code of Conduct and Practice of Journalism in Kenya, p. iv. 

140 

Oral interview with Kamweru. 

141 

UNESCO, World Communication and Information Report : 1999-2000, pp. 73-74 and 77-81. 

100


shock, journalists should behave with sensitivity and discretion. Media should generally 

avoid paying for information, unless public interest is involved. Financial information 

received in advance should not be used for own benefit, or be passed to others. As sources 

children have special protections. They should not be interviewed in the absence of a 

parent or other responsible adult, and not be approached or photographed at school without 

the permission of school authorities. 142 Concerning election coverage, there is a warning 

that media workers would be exposed to corrupt and manipulative sources and that media 

houses should provide journalists with adequate resources to cover elections. Journalists 

should resist gifts or favours from interested parties as this could compromise their 

impartiality. In addition, it is emphasised that journalists have a special responsibility to 

investigate electoral malpractices. 143 

Without free access to information, freedom of expression is like a vehicle without 

fuel. In East Africa, information and documents in public administration are not freely 

accessible. A journalist cannot invoke many legal rights to support a claim for information. 

As a result the practice of secrecy in East Africa creates informal business among officials 

where they leak to journalists for bribes. 144 

An example of how unauthorised information gathering is prevented is the 

Tanzanian Films and Stage Plays Act. Under this act it is illegal to use video camera for 

any purposes, even for private entertainment, any place in Tanzania without a ministerial 

permission. 145 In Kenya the practice is freer despite a similar law. 146 

142 

The Media Council of Kenya, Code of Conduct and Practice of Journalism in Kenya, articles 1, 5, 6, 8, 

12, 14, 16 and 17. 

143 

The Media Council of Kenya, Code of Conduct for Election Coverage (Nairobi: The Media Council of 

Kenya, 2002), articles 11, 13 and 14 as well as pp. 4 and 10. 

144 

Hydén and Leslie, “Communications and Democratization in Africa”, p. 12; and Ogbondah, “Media Laws 

in Political Transition”, p. 59. 

145 

Kilimwiko and Mapunda (eds.), A handbook on the State of the Media in Tanzania, p. 7, confirmed in oral 

interview with Makunga. 

146 

Barth, Kodi, “The laws needed for those with cameras” in The Sunday Standard (Nairobi: The Standard 

Ltd.), commentary, 6 th March, 2005. 

101


In practice, it should not be impossible for capable journalists to get the information 

they really want. 147 In Tanzania practice depends on the actual medium’s attitude to 

government. Friendly journalists are treated with an extraordinary service including trans- 

port to ministers’ activities. ‘Enemies’ get nothing but a barrier. 148 In a society with poor 

markets and poor journalists, such practice make media vulnerable to corruption. 149 

In Kenya, the mainstream press are lobbying for a Freedom of Information Act 

which would turn the present principle of secrets upside down. 150 The Official Secrets Act 

says that it is an offence for any government official to communicate any information that 

he has obtained owing to his position to any person he is not authorised to communicate it 

to. 151 The Kenyan press wants, in principle, that everything is open information. From the 

lobbying part it is claimed that the Official Secrets Act contradicts democratic rights in the 

Constitution. A democratic society should allow free flow of information to increase the 

level of democracy, they have argued. In their opinion ‘secrets’ are ‘interests’. The press is 

capable of getting information despite the law. However, the journalists have to trust 

officials and treat them as confidential sources. But a problem is that officials have 

interests too, so such information is not always reliable. The areas of military and police 

are most secret, and it is argued that these areas also are where there is most corruption. 

The previous Kenyan government refused any open information policy. The recent 

government gives mixed signals, however, positive enough to be interpreted optimistically 

by the press. 152 

147 

Oral interview with Onyango-Obbo. 

148 


149 

Kunczik, “Closing remarks: Is there an international ethics of journalism?”, p. 249. 

150 


151 

Ibid., pp. 115-116. 

152 

Oral interview with Muriithi Muriuki, Political Reporter at Daily Nation/Sunday Nation in Kenya, e-mail: 

fmuriithi@nation.co.ke. Interview with him at Nation Centre in Nairobi, 7 th March, 2005, about freedom 

of accessing information. 

102

Publishing 


Publishing transforms information into a force in society. Democratic values in conflict 

with publishing may be divided into categories as national and collective interests as well 

as private and individual interests. Each interest may have both legal and ethical aspects. 

National interests can be expressed in national security acts. The Tanzanian one, for 

instance, is modelled on a British act made in 1911. The act says that it is an offence to 

obtain, collect, record, publish or communicate to any person or any code, or password, 

article or information which might be or intended to be useful to a foreign power or 

disaffected person. The punishment of offence can be life imprisonment. Such conditions 

leave little space for press freedom. 153 Criminal laws that seek to protect the honour of the 

President or other state institutions and officials, is often wrapped up into laws on seditious 

libel. 154 The current Kenyan law on sedition has its origin in the colonial era whose 

purpose was to deny blacks freedom of expression. The law is still valid in Kenya but the 

practice has been lightened. 155 

Broadcasting media have superior positions in East Africa but airwaves are easy to 

control. Therefore, radio and TV, more than print media, have been controlled by 

governments in East Africa. 156 Despite liberalising, a firm grip is still maintained. For 

instance, in 2004 Uganda temporarily closed down 33 FM stations. The dispute was about 

broadcasting fees, but all these radio stations represented alternative voices including 

foreign programmes. 157 Commercial radio may survive better that non-profit operators. But 

commercial radios are concentrated in urban areas where they have markets. Therefore, 

153 

Kilimwiko and Mapunda (eds.), A handbook on the State of the Media in Tanzania, pp. 3-4. 

154 

Krug and Price, “The Legal Environment for News Media”, p. 198. 

155 


156 

Carver, Coliver, Lauriciano, Lush and Maja-Pearce, Who Rules the Airwaves, p. 1, 7-8 and 33-39. 

157 Nakkazi, “Uganda Cracks Down on Radio, TV Stations” 

103


rural people benefit less from this plurality. 158 That is also the case in Uganda where 

community and non-commercial radios were most vulnerable to the boradcasting fees. 159 

Limitations on publishing due to national interests are common worldwide. The 

East African level is considered to be more restricted than in Western countries, but not 

very different from other poor countries. 160 Collective interests are typically formulated as 

public peace, hate speech as well as protecting morality and religion. 161 For instance, 

Kenya is more conservative than Uganda in exposing body and sex, which makes a 

distinction in practice of publishing in the two countries. 162 Another collective value is 

democracy in itself. That is the reason for media to allow all parts to contribute in the 

public debate. The practice of this principle can be discussed. However, Kenyan media 

emphasise such an ideal in the very beginning of the Kenyan Code of Conduct of 

Journalism. 163 

Private interests may include both private institutions and individuals. There is 

danger of mixing private and national interests when the elite of political leaders and 

business peoples are the same ones. 164 In East Africa, liberalisation of broadcasting has 

increased number of licenses. Yet, these radio and TV channels are concentrated in a few 

political hands. 165 Another example is when the radio station Kiss FM in programs in April 

2004 used rough words about some Kenyan ministers as individuals. The ministers wanted 

to use government instruments as withdrawing of the licence to stop the radio station. 166 

158 

Carver, Coliver, Lauriciano, Lush and Maja-Pearce, Who Rules the Airwaves, p. 6. 

159 

Nakkazi, “Uganda Cracks Down on Radio, TV Stations” 

160 

Walden, Ruth, “Insult Laws” in World Bank, The Right To Tell : The Role of Mass Media in Economic 

Development (Washington: The World Bank/WBI Development Studies, 2002), pp. 212 and 220-222. 

161 


162 

Onyango-Obbo, Charles, “Ugandans like dirty pictures, so why faint at the V-word?” in The East African 

(Nairobi: Nation Media Group), commentary, 28th February, 2005. 

163 

The Media Council of Kenya, Code of Conduct and Practice of Journalism in Kenya, p. 2. 

164 

An-na’im, “The Freedom of Expression as a Universal Human Right”, pp. 22-24. 

165 

Kadhi, “Anglophone Africa: Puppets of the proprietors?”, pp. 120-122. 

166 

Daily Nation, “They want to kill Kiss FM, says Kalonzo” in Daily Nation (Nairobi: Nation Media Group), 

news article, 20 th April, 2004; and Shikwati, James, “It’s a potential threat to Press freedom” in Daily Nation 

(Nairobi: Nation Media Group), commentary, 22 nd April, 2004. 

104


The case of Kiss FM became hot due to underlying conflicts. Kiss FM’s owner Patrick 

Quarcoo has some connections with former President Moi and Kiss FM is adversarial to 

the present government. In addition, Quarcoo is a rival to Macharia, owner of Royal Media 

with Citizen’s radio and TV. Citizen FM even jammed Kiss FM’s broadcasting signals for 

a while without any subsequent consequences. 167 Just before this situation, Kiss FM also 

had poached and headhunted five of Citizen FM’s prime time presenters. 168 The Kiss FM 

example illustrates how a mix of interests influence publishing and reactions to it. 

A barrier between editorial matters and the interests of the medium’s owner is not 

developed much in East Africa. 169 The press history reports a great number of incidents 

where media owners have used their power to pursue private interests through editorial 

content. This is a source of censorship in Kenyan media, and illustrates the mix of private, 

commercial and political interests. 170 

Insult regulations are in a democracy meant to be the arrangement which make 

balance between rights of privacy towards other rights including freedom of expression. 

These laws are extensive in East Africa, and are useful for anyone who obstructs what 

media are publishing. 171 It is even possible for individuals to bring bankrupcty on a 

medium by libel law. 172 The Media Council of Kenya tries to turn this practice in a more 

favourable direction for press freedom. The attempt is to maintain balance between free- 

dom of expression and the right of privacy by use of code of ethics instead of the law. 173 

Reporting on tragedies and crime, the practice of East African newspapers is to 

publish details and identifying informations. Here are two examples: 

167 Oral interview with Opanga. 

168 Wachira, “The unlikely media mogul”. 

169 Retief, Media Ethics, pp. 141 and 144-146; and “Forces Around Press Freedom” above. 

170 For instance: Kadhi, “Anglophone Africa: Puppets of the proprietors?”, pp. 83-85 and 99, Ochieng, I 

Accuse the Press, pp. 55 and 63 (where Ochieng disagree with Kadhi); and Kadhi’s address “Is There a 

Place for Unethical Journalism in Kenya?” in Nairobi, 1 st March, 2005. 

171 Walden, “Insult Laws”, pp. 208-212 and 220-222. This general article also refers to Kenya and Uganda. 

172 Makali (ed.), Media Law and Practice, p. 227. 

173 The Media Council of Kenya, Code of Conduct and Practice of Journalism in Kenya, pp. i-ii. 

105


“TRAGEDY: Boy, 10, kills himself after book row with mother 174 

A 10-year-old boy killed himself after quarrelling with his mother over a 

lost textbook in Gatuanyaga village, Thika District. Police suspect Kelvin 

Muiruri Mburu wanted to escape his mother’s wrath. She is said to have 

threatened dire consequences if the mathematics book was not found. 

Central police spokesperson Dorothy Kavita said Ms Elizabeth Wangui had 

learnt of the book’s loss when a neighbour’s daughter stopped by to borrow 

it. […] the boy was found with a rope round his neck hanging from the grills 

of his bedroom window. […] ” 

“Girl, 4, is rescued by police after rape ordeal 175 

[…] the police yesterday rescued a four-year-old girl who had been denied 

treatment after a rape ordeal by her uncle at a remote Kilifi village. The girl 

was left to nurse her wounds after the incident last Friday after her family 

declined to report the matter, fearing a curse by the girl’s grandfather believed 

to be a wizard. […] repeatedly raped by her uncle […] The girl was too 

traumatised to speak about her ordeal. […] the minor’s grandmother, Elisabeth 

Muruu […] It is believed that several girls in the area have been defiled 

by their relatives […] When the girl was finally brought, she could not stand 

the sight of many people and immediately took to her heels. Her mother 

Mejumaa Bakari said she had caught the man red handed defiling her 

daughter. […] was shocked to find her daughter naked with the man lying 

on top of her. She said her brother-in-law left without uttering a word. On 

inspecting her daughter’s clothes she found out they had been soiled.[…] ” 

The first example shows the press covering single incidents of suicide. Even if it is a child 

who committed suicide, details of the act and possible motives are described. The article 

includes name of the victim who committed suicide, name of the mother who is both a 

victim and pointed out as ‘guilty’ as well as details about the course of events. The second 

example illustrates how the four year old girl is identified indirectly by use of the mother’s 

and grandmother’s names and location. The uncle is identified in the same way. Some 

details about the abuse are revealed to the public too. 

‘Privileged information’ explains why some Kenyan cases are covered freely when 

others are tied up with anonymity, hidden points and modest descriptions – if these are 

covered at all. The different publishing practices in different cases reflect areas which are 

or are not included in the parliamentary immunity. In Kenya that includes parliamentary 

174 

Daily Nation, “Boy, 10, kills himself after book row with mother” in Daily Nation (Nairobi: Nation Media 

Group), news article, 27 th January, 2005. 

175 

Mudi, Maureen, “Girl, 4, is rescued by police after rape ordeal” in The Standard (Nairobi: The Standard 

Ltd.), news article, 15 th January, 2005. 

106


committees and hearings as well as courts. The practice is that media are free to refer to 

what is said at these places and can cover cases almost without limits. Aspects which are 

not covered in these places, or other cases, are subjected to strong regulations of libels and 

so on. The result is a dual practice of news publishing. 176 

’National security’ is often a reason for interfering with publishing. The Ugandan 

newspaper The Monitor reported in October 2002 about a helicopter which crashed in 

action against rebels in North. In this area, a civil war with the Lord Resistance Army 

(LRA) is going on. The two decade old conflict is described by United Nations as “among 

the worst humanitarian disasters in the world” having produced more than 1.5 million 

internally displaced people. 177 The Ugandan government claimed that the article was likely 

to endanger national security. The Monitor was raided by security personnel and closed 

down for 10 days. One and a half years later, the Ugandan Supreme Court ruled that there 

was no evidence to show that the helicopter report prejudiced national security. 178 Yet, the 

government achieved its objective to intimidate the involved journalists and editors for a 

while. The Monitor’s management suspect the action against the helicopter article to be a 

result of critical reports in the newspaper which had been harsh to the government. 179 

Protection of Journalistic Activities 

Traditionally, it is the authorities’ treatment of journalists and journalistic activities which 

have been the issue in dispute. Reported harassments targeting journalists in East Africa 

stretch from arresting, imprisoning, questionning, charging and stripping of citizenship, 

suing, expelling from certain places as well as closing radio stations and banning sources 


177 International Crisis Group, Northern Uganda : Understanding and solving the conflict, an International 

Crisis Group Report (Nairobi/Brussels: International Crisis Group, 2004), ICG Africa Report Number 77, 

14 th April, 2004, pp. 1-2. 

178 Abdallah, Halima, “ ‘Monitor’ journalists win case over chopper report” in Daily Nation (Nairobi: Nation 

Media Group), news article, 1 st April, 2004; and Onyango-Obbo, Charles, “Ah, Unganda’s Press: So Free, 

So Terrorised” in The East African (Nairobi: Nation Media Group), commentary, 5 th April, 2004. 

179 Oral interview with Onyango-Obbo. 

107


from seeing journalists. 180 The course in Uganda illustrates an exercise in political control 

where journalists are jailed or brought before courts 10 times more than during the regimes 

of Obote and Amin before 1986. 181 

There are indications of improvements in free practice of journalism. For instance, 

in 2003 a delegate at Kenya’s National Constitutional Review Conference, Dr. Crispin O. 

Mbai, was killed. The Sunday Standard brought the story “Mbai killers confess” 28 th 

September, 2003. The newspaper’s Managing Editor, David Makali, together with a police 

officer, were arrested and charged with theft of a copy of a videocassette which the article 

was supposed to be based on. 182 When the court made its judgement in 2005, a premise 

was that the real interest of the State had nothing to do with a theft of a cassette worth 

Kenyan shillings 500 which is equal to between six and seven American dollars. The 

State’s interest was to maintain a monopoly to release or withhold information. However, 

the defendants were found not guilty. It became the first time for a Kenyan court to regard 

constitutional press freedom and public’s right to know to be superior to interests of the 

State. 183 

The behaviour of private persons towards media does not follow a certain pattern. 

The powerful ones have wide ranging possibilities. For instance in use of libel laws to 

influence journalists. Another indication of private individual’s practice is the code of 

conduct which warns against manipulative sources that may use bribes or gifts. 184 Incidents 

180 

International Press Institute, IPI Report 2003, pp. 27-28, 48 and 50. 

181 

Onyango-Obbo, Charles, “Ah, Uganda’s Press: So Free, So Terrorised” in The East African (Nairobi: 

Nation Media Group), commentary, 5 th April, 2004. 

182 

Kadida, Jillo, “Editor and CID officer on theft charge” in Daily Nation (Nairobi: Nation Media Group), 

news article, 2 nd October, 2003. 

183 th 

Mungai, Kibe, “Balanced justice” in The Sunday Standard (Nairobi: The Standard Ltd.), commentary, 10 

April, 2005. 

184 

The Media Council of Kenya, Code of Conduct for Election Coverage, p. 4. 

108


where the presence of journalists became controversial, resulting in attempts to lynch, have 

been reported. 185 

The editorial departments in media houses in East Africa are not protected from 

interference by its owners. The owners can influence editorial matters and single articles. If 

a journalist objects, he or she is vulnerable because of the high unemployment. The lucky 

ones who got a journalist’s job will not jeopardise it. To get fired means unemployment. 

To be safe, journalists do not challenge the bosses or owners. 186 Although the Nation 

Media Group has a declared policy that the editor has complete editorial control, that has 

not prevented editors from being dismissed when Muslim fellows of the dominant owner 

Aga Khan have been offended. 187 

“Mr Moneybags” is a case study in this aspect. It is a conflict between the press 

versus Kenyan cabinet ministers and other powerful individuals concerning use of criminal 

libel. It started when The Standard used four pages on a story called “Mr Moneybags”. It 

detailed how an economic elite controls politics and the economy. Many prominent people 

were mentioned. 188 The reactions were strong from people indirectly accused of corrupt 

behaviour which they rejected. The writer, Kamau Ngotho, was charged with publishing 

defamatory matter contrary to the Kenyan Penal Code. Even an Associate Editor of the 

same newspaper was questioned by the Criminal Investigations Department. 189 It was the 

press’ turn to raise voices, supported by foreign donors and NGOs concerned with press 

freedom and human rights. In an editorial Daily Nation wrote: 

“It is shameful that Kenya under Narc still retains such repressive laws as 

criminal defamation, publishing false information and the ridiculous 

185 

For instance: Daily Nation, “ ‘Nation’ writer’s ordeal at GSU officer’s home” in Daily Nation (Nairobi: 

Nation Media Group), news article, 24 th February, 2005. 

186 


187 

Ochieng, I Accuse the Press, pp. 60-61; and Odero, “Press in Kenya: an overview”, p. 13. 

188 

Ngotho, Kamau, “Mr Moneybags : EXCLUSIVE: In Kenya, politics and high finance are two sides of the 

same coin. And the game is played by the same people” in The Standard (Nairobi: The Standard Ltd.), 

news article, 8 th January, 2005. 

189 

Murimi, Joseph, “ ‘Standard’ writer faces libel charge” in The Standard (Nairobi: The Standard Ltd.), 


109


colonial offence of publishing an alarming statement. They are primitive 

laws […] It’s trying to intimidate the Press into not covering growing rot in 

government.” 190 

Eight foreign missions in Nairobi, including the United States and all the Scandinavian 

countries, followed up in a statement: 

“[…] use of criminal law is out of step with international practice. […] The 

criminal investigation department’s detention, upon orders of National Security 

Minister Murungaru, further heightens our concern. We would have 

expected that the police and the Ministry of Justice pursuit of accountability 

for corrupt activities would encourage investigations of those responsible, 

not seek to muzzle those who ask questions. […] must be aware that the use 

of criminal libel laws for political intimidation undercuts a vital pillar of 

society critical to the further development of democratic governance.” 191 

There was an ongoing conflict where the press and foreign missions frequently 

criticised NARC’s government of growing corruption within its own ranks. This conflict 

erupted after The Standard’s article. After two weeks the Kenyan Attorney General 

dropped the case. He described the criminal libel law as archaic and advised the public to 

file civil suits for defamation rather than turn to the police. 192 In this case a Cabinet 

Minister’s attack against the press led to a massive pressure from the press assisted by 

foreign missions and civil society. The final result was even a step in direction of enlarged 

press freedom. However, a commentary after the case described how the Attorney 

General’s dismissing not was a victory for press freedom because it was only words, and 

not a legally binding judgement. It would be better for press freedom if the case had come 

to court and the actual section of the Penal Code had been found unconstitutional, the 

commentary stated. The actual law is still Kenyan law – in the books. 193 

190 th 

Daily Nation, “Narc won’t cow the press” in Daily Nation (Nairobi: Nation Media Group), editorial, 13 

January, 2005. 

191 

Standard Team, “Outrage by donors over press harassment” in The Standard (Nairobi: The Standard Ltd.), 


192 

Kago, Tony and Kadida, Jillo, “State drops libel case : Outdated law will never be used again, says Wako” 

in Daily Nation (Nairobi: Nation Media Group), news article, 21 st January, 2005. 

193 

Mwaura, Peter, “Criminal libel: AG missed the real issue” in Daily Nation (Nairobi: Nation Media 

Group), commentary, 22 nd January, 2005. 

110


Chapter 5: Scandinavia and East Africa Compared 

The regions of Scandinavia and East Africa illustrate different practices of press freedom. 

The two regions have similarities and differences and still they interact. 

Contexts and Aspects of Press Freedom 


Among the similarities between the regions, is that each has some kind of press freedom. 

In both places, newspapers have spearheaded development of press freedom. Broadcasting 

has been more controlled, by regulations or as public broadcasters. Some liberalisation of 

the airwaves has taken place in all countries. In both regions, numerous organisations have 

emerged to advocate different interests, and these have big capacities in lobbying and 

international networking. Self censorship exists at different levels in both regions, and the 

influence of global media is felt in both regions. 

There are also differences. Scandinavia’s democratisation processes started almost 

200 years earlier than that in East Africa and the levels of press freedom are different. In 

Scandinavia, the media’s role as a democratic actor is highly recognised at all levels of 

government. Scandinavia, in particular Sweden, is the place of origin of codes of conduct 

and self-regulating systems within the press. Norway is the first place where the whole 

industry committed itself to regard the editor as the guarantor for editorial independence 

towards owners as well as other departments of the company. These Scandinavian 

arrangements have subsequently become universal models. The level and capacity of 

media education have grown properly in Scandinavia. 

East Africa, with its colonial history, still has laws constructed by colonial masters. 

Such laws have survived because these are useful tools for the ruling elite to control the 

media. However, East Africa is going through changes that increase press freedom. 

111


Another feature of growth of press freedom where East Africa is different from 

Scandinavia, is in the role of magazines and alternative press outside mainstream media. In 

East Africa these alternative media were key actors in challenging the limits to press 

freedom. They helped to expand the scope and the level of press freedom in all East 

African countries. 

Reasons for and Forces Around Press Freedom 

Both regions have adopted a common philosophical basis for press freedom. These are the 

search for truth, democracy, and support for individual liberty in a society. In practice, both 

regions object to interference from government in media operations. 

There are some differences. In Scandinavia, the editor’s judgement in all editorial 

matters is independent. In East Africa, editors are to a great degree affected by foreign 

owners and foreign commercial actors. Due to weak domestic markets, foreign media 

owners’ abuse their power and are a great threat to media in poor countries. 1 Another 

major issue in East Africa is how the elite influence and hamper media’s freedom. Finally, 

competing interests in East Africa use media to support their ‘development agenda’ which 

are not necessarily synonymous with press freedom. 


Despite different capacity, media have an important role all in these societies. These 

figures are calculations based on the surveys of each region in previous chapters. 

Number of radio and TV receivers per 1000 inhabitants (1996) 

Average per country TV Radio 

Scandinavia 525 998 

East Africa 15 173 

Proportion (Sc : EA) 35 : 1 6 : 1 

1 Okonkwo, “Journalists in a Developing Economy”, pp. 6-9. 

112

Spread of daily newspapers (1996) 

Average per country Number of 

titles 

Total 

circulation 


Circulation per 


Scandinavia 71 2,900,000 449 

East Africa 3 141,000 5 

Proportion (Sc : EA) 24 : 1 21 : 1 87 : 1 

Number of new published book titles (1996) 

Average per country New book titles Titles per 


Scandinavia 10,916 1.8 

East Africa 253 0.009 

Proportion (Sc : EA) 43 : 1 196 : 1 

Journalistic capacity 

Average per country Number of 

journalists 

Inhabitants per 

journalist 

Jour. per 1000 

inhabitants 

Scandinavia 11,333 548 1.82 

East Africa 1,383 19,545 0.05 

Proportion (Sc : EA) 8 : 1 1 : 36 36 : 1 

Access to internet and telecommunication media in East Africa is very low while it 

is high in Scandinavia. In 2000, access of internet in Africa was estimated at 1 of 1500 

persons. The worldwide average was 1 of 38, and in the West it was 1 of 4. 2 Scandinavian 

countries are even ranked at the top within the group of among Western countries. 3 

From all angles, the figures confirm one of the major issues in the NWICO debate, 

the great difference in means of mass communications in the North compared to the South. 

Further, the figures indicate how the differences are higest in elite oriented media, in 

particular books and daily circulation of newspapers. The differences are least in spread of 

radio. East Africa, as other poor regions, is poorly equipped compared to rich countries. 


3 UNESCO, World Communication and Information Report : 1999-2000, p. 270. 

113


There is also the questions of the capacity of a free press. East Africa has less 

capacity than Scandinavia. The ‘journalistic capacity’ indicates how strong media are able 

to play their role as watchdog. Even if the level of press freedom was similar in the two 

regions, it would be different in practice. Each journalist in Scandinavia caters for about 

500 people, in East Africa each journalist caters for about 20,000 people. This makes the 

abilities to fulfil media’s social responsibility different. 

The Aspect of the Press’ Role 

Similarities of the role of the press in these countries are to be found in the constitutions, 

they all guarantee freedom of expression although the practice is different. Countries in 

both regions regard media self-regulation as a way of maintaining independence. In this, 

the Scandinavinans are ahead of the East Africans. 

Countries in both regions have a number of laws whose purposes are different. 

Regulations in Scandinavia ensure diversity or other democratic values. Similar reasons are 

used for some arrangements of financial incentives to the press in Scandinavia. In East 

Africa such practice has recently emerged in Tanzania where some taxes on media have 

been waived. Other financial incentives to media in East Africa have been given due to 

rulers’ propaganda aims or national ownership. In all countries in these regions, public 

funded state owned broadcasters have had a prominent role. A major problem for East 

African media is poor markets due to poverty. Welfare and good markets can provide 

Scandinavian media with a quite different level of income. These resources are employed 

in an extensive journalistic capacity. Scandinavian media’s resources and position make 

them powerful in advocating their own interests in the society. 

114

The Aspect of Gathering Information 


Similarities are few in information gathering between the two regions. The major similarity 

is probably what codes of conduct advise on relations to sources. Ethical issues such as 

independence, fairness, securing sources, and modesty in some situations in particular with 

regard to children, are similiar. These common features illustrate how codes of conduct in 

these regions have similar roots. 

The differences are most clear when it comes to information from public admini- 

strations. In Scandinavia the principle is openness with some exceptions. In East Africa the 

principle is secrets with some exceptions. The outlet in East Africa is a journalistic practice 

which nevertheless may provide a lot of information into the public sphere. Due to this 

‘hidden game’ much of this information is controlled or coloured by actors with vested 

interests. Another major difference is in the tools available for information gathering. Due 

to widespread access to internet in Scandinavia and a huge amount of relevant information 

to dig up, the journalists there are far ahead of their colleagues in East Africa. 

The Aspect of Publishing 

Similarities seem to be evident because media in the two regions look similar. Commercial 

forces work in the same way. The same methods are used in Scandinavia and East Africa 

to attract audiences. Further, codes of conduct are guided by the same philosophy. That 

philosophy also explains why media practitioners in these regions share preferences in 

publishing policy. 

Differences are clear in balancing between laws and ethics. In Scandinavia the laws 

are not very restrective. Decisive factors in publishing are the medium’s own policy 

together with the national code of conduct. In East Africa the laws usually impose a 

restrective framework. Culture is a determinant factor for ethics. Taste, shame, respect, 

fear and faith, for instance, are interpreted differently in Scandinavian cultures compared to 

115


cultures in East Africa. Such values guide selection and approaches to content. Such 

cultural values explain differences in publishing practices. Further, East African practice is 

influenced by British traditions which are different from Scandinavia in these matters. 4 

Concerning reports on crimes, Scandinavian media ethics tend to support a Scandinavian 

criminal policy that is more concerned with rehabilitation than with punishment. 5 

The Aspect of Protection of Journalistic Activities 

Similarities in the two regions are most clear in declared media ethics. These concern 

protection and independence towards authorities, external commercial forces, owners and 

other private actors. The ideals within the press are similar in the two regions. 

Differences are large when it comes to the practice in Scandinavia and East Africa. 

A journalist in Scandinavia risks some harsh words. That is nothing compared to 

colleagues in East Africa who risk harassment and danger, even though the possible 

assassination of journalists has subsided. In Scandinavia, courts have expressed views that 

journalists should enjoy extraordinary protection, just the way it is for government officials 

on duty. The reason is that the media perform an important function in society. Such kind 

of notion has started to emerge in East Africa when an editor in 2005 was found not guilty 

of theft of a videocassette. The Kenyan court said the theft was not an issue when it 

considered the importance of the revealed information for the society as being more 

important than the State’s information monopoly. However, the everyday life for 

journalists in East Africa is different from that in Scandinavia. The Scandinavian model of 

barriers between owners and editorial departments is the ideal in East Africa, but it is not 

upheld as a principle. 

4 Herbert, Practising Global Journalism, p. 74. 

5 Jones, Mass Media Codes of Ethics and Councils, p. 31. 

116


Press Freedom Interactions Between Scandinavia and East Africa 

Interactions between Scandinavia and East Africa are conducted in several ways. There are 

direct links where press freedom is the matter. Further, both regions interact indirect 

because both are subordinated to the same global regimes of press freedom. 

Direct Links Between Scandinavia and East Africa 

Scandinavian countries do not have long traditions for activities in East Africa. From the 

time of independence, East African countries became recipients of development aid from 

Scandinavian countries. These regional connections emerged despite lack of earlier 

connections. 6 The level of trade between the two regions is modest. Aid was given both as 

bilateral and multilateral assistance. In addition, support from private institutions as well as 

Scandinavian governments through NGOs are common. 7 All the East African countries 

have been through periods where aid from Scandinavia more or less was cancelled. 8 On a 

personal level, the Tanzanian President Julius K. Nyerere developed strong bonds with the 

Scandinavians. 9 

All Scandinavian countries include media or press freedom as conditions for giving 

aid. This can be in policy declarations, as a part of ‘good governance’ conditionalities tied 

to aid, or as support to specific media projects. The following examples illustrate how 

Scandinavian aid influence press freedom in East Africa. First, Norway and Sweden, in 

Tanzania in 2004, sponsored the annual World Association of Press Councils Conference 

6 Simensen, Jarle, 1952-1975: Norge møter den tredje verden : Norsk utviklingshjelps historie 1 (Bergen, 

Norway: Fagbokforlaget, 2003), pp. 135-136 and 197. 

7 Ibid., pp. 135-170, 215 and 268. 

8 Ibid., pp. 182-183 (Uganda); and Ruud, Arild Engelsen, 1975-1989: Vekst, velvilje og utfordringer : Norsk 

utviklingshjelps historie 2 (Bergen, Norway: Fagbokforlaget, 2003), pp. 167-168 (Tanzania) and 257-258 

(Kenya). 

9 Simensen, 1952-1975: Norge møter den tredje verden, pp. 141-142. 

117


worth about US$ 50,000. 10 Second, Sweden supports training of journalists in Tanzania. 11 

Third, in Uganda, Denmark and Norway together made survey of hindrances for local 

media to report on human rights, corruption and conflicts. 12 Fourth, Norway has come up 

with a media plan for Uganda. This one includes proposals to establish a rural press club, 

a foundation for summoned journalists, developing of a diploma course in journalism, and 

a campaign for a new media policy. 13 Fifth, in 2004 Norway resumed bilateral aid to 

Kenya, 13 years after Kenya cancelled it due to bad diplomatic relations. The Norwegian 

Agency for Development Cooperation (NORAD) started a process which probably would 

end up with a media plan for Kenya. 14 Sixth, Sweden sponsored community radios in all 

the East African countries, and supported a media NGO training journalists in focusing on 

needs of the poor. 15 

At the level of NGOs concerning media, individuals from Scandinavia and East 

Africa interact with each other. For example, in IPI both members from Norway and Swe- 

den as well as Kenya have had prominent positions. The Scandinavian countries have been 

well represented in the Board of Executives since its founding, 16 had the directorship, 17 and 

hosted the General Assembly four times. 18 For Kenya, Tom Mboya became a key figure 

during the 1960s. He was invited as a prominent speaker to the General Assembly in Paris 

10 The Media Council of Tanzania, “Norwegian Embassy donates 24 m/- for WAPC conference” in Media 

Watch (Dar es Salaam: The Media Council of Tanzania, 2004), no. 56, Aug. 2004; and The Media Council 

of Tanzania, “Supporters of the WAPC conference in Bagamoyo” in Media Watch, no. 59, Nov. 2004. 

11 The Media Council of Tanzania, “SIDA okays 47 m/- for starting centre for training of journos” in Media 

Watch, no. 57, Sept. 2004. 

12 Norad, “Medierapport fra Uganda”, internal memo, Norad, Oslo, Norway, 12 th October, 2004, archive 

reference 842.0. 

13 Ibid. 

14 Correspondance with Tone Bratteli, Senior Advisor, The Norwegian Agency for Development 

Cooperation, received e-mail 24 th January, 2005. E-mail: tone.bratteli@norad.no. 

15 Correspondance with Cecilia Bäcklander, Diplomat at the Swedish Embassy in Nairobi, e-mail received 

11 th March, 2005. E-mail: cecilia@rosslyn.co.ke. 

16 International Press Institute, IPI – The First Ten Years, pp. 12-13, Coppard, IPI: The Defence of Press 

Freedom, p. 128; and The International Press Institute, 1950-2000, pp. 8 amd 82. 

17 The International Press Institute, 1950-2000, p. 29. 

18 International Press Institute, “IPI Congresses” in 10 Years IPI Headquarters in Vienna (Vienna: The 

International Press Institute, 2003), p. 49. 

118


in 1962, and was involved in IPI’s Nairobi training program for African journalists. 19 

Nairobi hosted the IPIs annual conference in 1981 and will do it again in 2005. 20 The 2005 

Chairman of IPI is Wilfred Kiboro, CEO of Nation Media Group. 21 

IPI is only one example of how international press freedom NGOs make up a 

network where individuals and institutions influence each other globally. In such a way, 

Scandinavian and East African individuals, institutions and NGOs participate in this global 

web for the spread of press freedom. 

Relations to Global Regimes of Press Freedom 

International regimes contribute to press freedom both in Scandinavia and East Africa, two 

regions which are minor actors in a global struggle for press freedom. All these countries 

are members of the United Nations and UNESCO. They are members of the same 

international regime on press freedom. Both regions are subordinated to the global 

influence of the United States on press freedom. Scandinavia has a lot of similarities to the 

United States because they are part of the common political philosophy and development 

in Western countries. Concerning self-regulation, Scandinavia has spearheaded a 

development which was adopted by the United States. 22 Scandinavia maintains its role as 

global spearhead for media ethics and has had great impact on new democracies in Eastern 

Europe. 23 Both regions are subjected to the international press freedom regimes, but the 

difference is that East Africa has less influence in the policy formulation. 

19 

Righter, IPI: The Undivided Word, p. 84. 

20 

International Press Institute, “IPI Congresses” in 10 Years IPI Headquarters in Vienna, p. 49. 

21 th 

The International Press Institute: “Executive Board”, http://www.freemedia.at/cvs.htm, downloaded 28 

March, 2005. IPI’s homepage: http://www.freemedia.at/ 

22 

Herbert, Practising Global Journalism, pp. 68-69; and Clement, Mass Media Codes of Ethics and Councils, 

pp. 30-32. 

23 

Carrington and Nelson, “Media in Transition: The Hegemony of Economics”, p. 235. 

119


While Scandinavian media have followed similar trends to those of other Western 

countries, 24 East Africa is new in media commercialisation. Conerning democracy, all East 

African countries have adopted liberal ideals including the principle of press freedom. But 

this has happened about 200 years later than in the West, which explains its moderate 

level. 

The conflicting issues on press freedom in East Africa today are similar to conflicts 

in Scandinavia decades or even a century before. One example is the freedom to access 

information which is an issue in East Africa. After years of struggle it was implemented by 

laws in Scandinavia in 1970. 25 Another example is establishing of self-regulation which is 

happening in East Africa now. 26 That was a reality in Scandinavia around the 1920s. 27 

Both Scandinavian and East African media and individuals are well connected to 

international NGOs concerned with press freedom. However, a difference is that East Afri- 

cans have client relations to these NGOs. A common pattern is that Scandinavians are 

donors and East Africans are the recipients. 28 Scandinavians are involved in formulating of 

policy, East Africans are adopters of that policy. 29 In education there are similar patterns of 

universal standardisation. The difference is that East Africa plays the role of client. Aid 

from Scandinavian donors has funded schools of journalism in East Africa. 30 The concepts 

in the dicipline of journalism is developed in the West and exported to journalism schools 

in poor countries. 31 Concerning codes of conduct Scandinavians have participated in 

24 

Dahlgren, “Media and power transitions in a small country: Sweden”p. 251 

25 


26 

Oral interview with Kamweru. 

27 

Clement, Mass Media Codes of Ethics and Councils, pp. 18-19, 28-29 and 30-32. 

28 

International Press Institute, “Press Freedom Fund” in 10 Years IPI Headquarters in Vienna, p. 7; and oral 

interview with Kamweru. 

29 

One example: Coppard, IPI: The Defence of Press Freedom, pp. 127-128 and 133. 

30 

Three examples: 1) Sweden in Tanzania: The Media Council of Tanzania, “SIDA okays 47 m/- for starting 

centre for training of journos” in Media Watch, Sept. 2004, 2) Norwegian and Danish survey conclusion in 

proposed support to education in Uganda: Norad, “Medierapport fra Uganda”, section 5, 3) Norway to the 

University of Nairobi: Bourgault, Mass Media in Sub-Saharan Africa, p. 128. 

31 

In general: Merrill, Global Journalism, p. 213. One example about Norway in Ethiopia: Eikje, “God 

journalistikk er en vaktbikkje”. 

120


development of globally accepted principles. In East Africa a common opinion has been 

that it is not necessary to invent the wheel again. The Code of Conduct and Practice of 

Journalism in Kenya was made after consultations with key players of press freedom in 

England, Minnesota and Australia in addition to Tanzania. 32 

The United States interferes directly with press freedom affairs. One example is 

how such a dominant player even has selected individuals from East Africa who became 

prominent international representatives. For instance, it is claimed that Tom Mboya, who 

was an early authority about Kenyan press freedom, was brought up as an international 

political representative by the British and Americans. 33 Another example is how 

Americans connected with Ronald Reagan funded the Nairobi Law Monthly during Moi’s 

dictatorship to ensure one of the few critical voices against the regime. 34 

Scandinavia and East Africa are subordinated to forces conducting economic 

globalisation which include influence over press freedom regimes. Scandinavian countries 

are included in international regimes on press freedom. They have a prominent position to 

influence and formulate global press freedom as well as influence agents supporting global 

spread of press freedom. The East African states have been members of the international 

regimes on press freedom. The difference is East Africa’s subordinate client role, and level 

of press freedom which reflects a shorter period of democratic rule. 

32 Oral interview with Kamweru. 

33 Munene, Macharia: “The Colonial Policies of Segregating the Kikuyu, 1920 – 1964” in Chemchemi 

(Nairobi: Kenyatta University and Acacia Publishers), volume 2, 2002, number 1, p. 40. 

34 Munene, “Africans and Intellectual Adventurism: East African Intellectual Warriors”, p. 8. 

121

Chapter 6: Conclusion 


Press Freedom and Globalisation in Scandinavia and East Africa 

Press freedom is rarely openly rejected. However, different forces compete to bend press 

freedom to serve their interests. The democratic purpose of press freedom is to create 

transparency and participation through free flows of information which maximise social, 

political and cultural outcomes in a society. The thesis has examined the spread of press 

freedom in context of globalisation. North-South perspectives have appeared due to the 

attention to the regions of Scandinavia and East Africa. 

The objective, to provide understanding of press freedom as a global concept, has 

employed four approaches. First, to establish understanding of globalisation context. 

Second, to establish understanding of the concept of press freedom. Third, to describe and 

compare practices of press freedom in Scandinavia and East Africa. Fourth, to give a 

balanced description of press freedom in context of globalisation. 

First, globalisation interconnects peoples in the world to be more influenced by 

each other. Yet, economic globalisation has concentrated power into a few hands which 

control a hegemony. These global economic interests create and benefit from a global 

audience which acts as like-minded consumers. The history of modern economic 

globalisation starts with colonial empires. After the Second World War the United States 

succeeded as the spearhead of globalisation. A world trade regime where American 

business people became masters was created. After the Cold War it became the worldwide 

order. 

Globalisation has a number of characteristic features. First is the hierarchy of states 

where the United States and a few others maintain a hegemony. Second, while some 

countries such as China, India, Malaysia as well as Mexico and Turkey benefit from 

increased global trade, countries in Africa have been further marginalised. Third, is the 

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declined role of state governments as the powers of business and civil society have 

increased. Economic power has moved to a global level, political power has mainly 

remained at state level. Media are among those whose power has increased. 

Mass media became global business, just as in other industries. News agencies 

created a global network between Western newspapers. Radio bypassed geographic 

borders. The film industry became global business linking Hollywood’s film production to 

Wall Street’s finance markets and to a global audience. Recorded music gave the pattern of 

concentrated ownerships. Television became powerful in spreading a global culture, shared 

news and has created an arena for global advertising. Internet was spread globally most 

rapidly. Despite internet’s openness, its dominant owners and content producers are the 

same who dominate other media. A few conglomerates have emerged as big transnational 

companies in media business, control global media, and heavily influence regional media. 

With such influence, the nature of the press became an issue. 

A functional definition of press freedom is media’s right to discuss whatever is not 

explicitly forbidden by law. Another approach is press freedom as a ‘regime’ which 

supposes that information resources are significantly independent of political or economic 

powers. The latter give attention to press freedom as means of power. Constructivism 

theory emphasises roles of regimes, agents and circumstances. Agents are actors that 

pursue or influence press freedom regimes. Press freedom itself is agent of democracy and 

globalisation. 

The idea of press freedom grew out of the Enlightenment. John Locke made basis 

for freedom of expression as a civil right. His theory says that government needs support 

from the governed, and that people have the right of revolution including a duty to rise up 

against tyrants. In the United States in 1735, John Peter Zenger was found not guilty in a 

case on seditious libel. The defence was that he had published the truth. This is the first 

known trial which accepted truth as reason for press freedom. In 1791 the United States’ 

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constitution made a model for press freedom in democracy: “Congress shall make no law 

… abridging the freedom of speech, or of the press”. In the mid of the 20 th century John 

Stuart Mill’s “Essay on Liberty” influenced further development of philosophy about press 

freedom. He was concerned with plurality including the right to be wrong. Mill made basis 

for the marketplace of ideas as it was termed later. In 1948 The Universal Declaration of 

Human Rights made freedom of expression and press freedom to universal rights. At the 

same time the press’ social responsibility was regarded as media’s democratic aim. 

Growth of press freedom followed democratisation. In the beginning decision 

processes were moved out of kings’ and rulers’ domains into the public spheres. 

Journalism and mass media emerged out of this development and new technology. As 

media and press freedom grew, everyone with access to media participated the democracy 

as the press served to check government and others with power. In the process measures 

favouring a free press developed in terms of constitutional support, reduced restrictions, 

efficient self-regulating system, and economic conditions which ensure financial 

independence. There was increased access to information, protection of sources, and 

freedom to publish without permission. Freedom to publish, however, took into account 

the need for self-restrictions on national security, sensitive state matters as well as 

protection of privacy or some other private interests. There was also protection of 

journalistic activities towards authorities, private actors or even the owners’ interference 

with editorial matters. 

The regions of Scandinavia and East Africa represent different practices of press 

freedom. Scandinavia ranks at the top of press freedom in the world. The growth started in 

the 18 th century as part of liberal trends in the Western world. The European Court of 

Human Rights harmonised Scandinavian practice with Europe. Among means of press 

freedom originated in Scandinavia are self-regulation, media council, media ombudsman, 

and the editor as guarantor of editorial independence. Reasons for press freedom have been 

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search for truth, democracy and individual liberty. Earlier, intereference from government 

was the concern of press freedom. Later years, external and internal commercial forces 

have got attention as a threat to press freedom. Mass media are extensively spread in 

Scandinavia, in particular print media and internet. Privatisation of public sector has made 

reduced access to information to an issue. Publishing has legal restrictions towards national 

security, discriminations of religious, ethnic or sexual character as well as blasphemy, 

pornography, regulations of commercial messages, and areas of privacy and libels. Yet, 

ethics is a chief guide for publishing. Journalism is regarded as an activity in society which 

deserve extraordinary protection. Harassment of journalists is uncommon. 

East African countries are still in an early phase of democratisation which is 

reflected in the level of press freedom. Democracy is a declared goal and a lot of processes 

are going on towards improved press freedom. A paradox is that East Africa still struggles 

with restrictive press laws enacted during the colonial period. Then, the colonial masters 

used media as propaganda and to achieve control of information. In East Africa, reasons 

for press freedom have been search for truth, democracy and individual liberty. Some 

specific matters surrounding press freedom in East Africa have been ownership and the 

impact of global media. 

The ruling elites manipulated media to serve their own interests and promoted 

development journalism as means of national building. Development journalism, critics 

noted, was a way of reducing press freedom. While all the East African countries declare 

press freedom in their constitutions, a web of restrictive laws reduce the scope of freedom 

considerably. Among the restrictions to press freedom are that government documents of 

public interest remain secret. Other obstacles include the poor training of journalists and 

weak markets that do not provide media with ability to operate as independent business. 

Within East Africa there are some different practices in terms of self-regulation. 

For instance, Kenyan media are relatively free from government, but suppressed by private 

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individuals who have many ways to sue the media. In Uganda it is the opposite. 

Government suppress media – as far as possible under sceptical donors’ monitoring. 

However, the level of press freedom in East Africa is increasing. 

Spread of media indicate media’s position in the societies, and is quite different: 

Comparing of spread of media 

in Scandinavia and East Africa 

Proportion 

Scandinavia : East Africa 

Number of TV receivers per 1000 inhabitant 35 : 1 

Number of radio receivers per 1000 inhabitant 6 : 1 

Circulation of newspapers per 1000 inhabitant 87 : 1 

Published book titles per 1000 inhabitants 196 : 1 

Journalistic capacity: Journalists per 1000 inhabitants 36 : 1 

The statistics confirm the existence of a big gap between the regions, and that print media 

are luxury items in East Africa. The figures on journalistic capacity indicate different 

media’s ability to fulfill their role. Different levels of press freedom increase the real gap in 

journalistic capacity. 

The NWICO debate exposed such differences between North and South. The 

debates exposed Western media’s dominance in agenda setting, definition of truth, and the 

West’s superiority in terms of technology. Although the debates have cooled down, the 

differences have increased between poor and rich countries. 

Links between the two regions support the spread of press freedom in East Africa. 

The Scandinavian countries impose conditions of press freedom in their aid policy, and 

also support to media projects in East Africa. There are also significant interactions 

through international press freedom NGOs. Yet, the most influential link is probably that 

both regions are exposed to the same international regimes on press freedom. 

In the context of globalisation, press freedom serves as a tool of political influence. 

International press freedom regimes can be legal conventions, institutions or NGOs. One 

such regime is the United Nations with its Article 19 on the Universal Declaration of 

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Human Rights concerning freedom of information. UNESCO is the United Nations special 

agency in this matter. Thus, the global human rights machinery promotes press freedom. 

Agents promoting press freedom regimes can be institutions, organisations, 

individuals and invisible forces. There are mainly four of these. First, the World Bank 

spreads press freedom because it is supposed to support development. Second, NGOs are 

agents and constitute a global movement and network for press freedom. Third, the 

globalising of media ethics narrows and strengthens the concept of press freedom. Fourth, 

harmonised journalism education and professionalisation strengthens press freedom 

globally. 

Circumstances supportive of international press freedom regimes are four. First, 

liberal market economy creates a symbiotic relationship with notions of press freedom. 

Markets provide media with economic independence to act freely. Second, a shared culture 

supports the growth of global media and promotion of global media freedom. Third, civil 

society develop partnership with media to promote free media. Fourth, in a democracy free 

media legitimises democratic rule. Those who benefit from a democratic system support 

media due to its stabilising effect. 

The spread of the global media raised three types of criticism. Firstly, the press has 

been accused of maintaining hegemony of ruling elites and being manipulated to benefit 

only the elite. Proprietors of global media are the same, or like-minded to, as other owners 

of global businesses. Press freedom is used to mean business freedom, and the spread of 

free media means increasing markets. Media’s social responsibility, therefore, ranks below 

profits for the media owners. Free media’s ability to stabilise existing order is also in the 

interest of the elite. 

Secondly, there are questions as to whether press freedom in reality supports 

democracy and human rights. There have been double standards in terms of application 

and expectations. The United States has been accused of double standards in its promotion 

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of democracy and human rights because it has supported regimes that violate these values. 

Some countries have claimed that the Universal Declaration on Human Rights is not their 

document. They were not members of the United Nations when the declaration was formu- 

lated in 1948. Those who issued the declaration in 1948 had colonies or denied large 

segments of their population democratic rights. 

Thirdly, from an African point of view, there are doubts as to whether concepts of 

press freedom have validity to Africa. The debate on neo-colonialism regards media and 

press freedom as means for the West to dominate the South. Other neo-colonial forces are 

foreign ownership of African media as well as the West’s dominance over the content. A 

ruling African elite has adopted Western values and style of media. They use media to 

maintain their own hegemony in the same way as a global elite uses global media. 

The picture that emerges is that press freedom is a universal concept but it has 

different practices. Globalisation has spread and harmonised press freedom globally and 

yet real threats to global press freedom exist because of the forces competing for power in 

globalised societies. These forces do not attack press freedom openly, they do it indirectly. 

They attack press freedom by creating conditions which subordinate the media’s social 

responsibility and at the same time stress profit, politics or power. This is the case globally, 

in Scandinavia, and in East Africa. 

128

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