Religious Boundaries to the Freedom of Speech in the Age of New ...

Religious Boundaries to the Freedom of Speech
in the Age of New Media: A Dutch Perspective 1
Abstract 2
The idea of freedom of speech is not alien to Islamic tradition; its need in society is supported in the Qur’an.
Contrary to public sentiment, freedom of speech in the European context has been emphasized on the
idea that the freedom is not absolute. Although the freedom of speech offers space to shock and disturb –
in a proportionate way – it carries with it duties and responsibilities, thus it may be subject to conditions
and restrictions e.g. necessary to uphold public order, safety, and to protect of the reputation and rights
of others. This is much aligned to the notion in Islam, that any freedom should be in observance of the
respect and tolerance for and dignity of others.
The trial of the Dutch politician Geert Wilders in 2011 and the controversy and public uproar surrounding
the Danish cartoons in 2006 are two examples in which the space offered in the European context of
freedom of speech were exploited. The very goal of any imposing any `limitations’ to freedom of speech in
the European context – i.e. maintaining public order and safety was jeopardized as the information
surrounding both the subject of the controversies as the hypes themselves seemed to only add fuel to the
fire.
New Media have provided a seemingly unlimited spectre of information sharing through among others
internet, blogs, social media. However, the emergence of new types of media have increased biased `news’
greatly, as many providers of `news’ seem to entertain the notion that the news should be consumed
maximally, even if this would lead to compromising normal journalistic standards of objectivity, balance
and accuracy.
The framework of Dutch law in regard to the freedom of speech on one hand, and the role of New Media
on the other hand has led to exacerbation of the tensions surrounding issues related to Islam and Muslims.
The ethics of a debate and law are not complementary in the case of the freedom of religion vis à vis the
freedom of speech. By not acknowledging that freedom of speech and freedom of religion in a democracy –
as any degree of freedom - are attached to responsibilities on part of all involved, as well as to norms of
ethics and of propriety, the two freedoms unnecessarily are placed diametrically opposed to each other.
Keywords: freedom, speech, religion, Islam, Dutch, law, Europe, boundaries,
democracy.
Introduction
Do not insult the idols of other people because they will insult Allah.....(Koran 6:108)
A Right isn’t always Right
Muslims in Europe in general, but in the Netherlands in particular experience the constant criticism
on Islam as offensive. Over the last ten years, they have had to endure a barrage of insults, ranging
from calling Islam backward to comparing the Qur’an to Hitler’s Mein Kampf and from claims that all
1 Sofjan S. Siregar, President of the Islamic University of Europe, Rotterdam the Netherlands,
sofjansir@mail.com
2 Presented at the 2nd International Conference on Islamic Media, 13 December 2011, Jakarta, Indonesia.
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Muslims are potential terrorists who are out to subdue the world to the extremely distasteful claim
that the Prophet of Islam was, by modern standards, a paedophile.
On the whole, Muslims in the West have remained very patient through all this. By doing so
following in the footsteps of the blessed Prophet of Islam, who is the best example to follow. As
Allah, Glorious and Exalted is he, says in the Qur’an: “Verily, in the Messenger of God you have a
good example who looks forward to God and the Last Day” (1). Even though they were surprised to
find that their non-Muslim fellow citizens apparently do not realise how hurtful offending and
mocking what is sacred to them. Moreover, Muslims were very surprised to see that most of these
distasteful claims were defended in the public sphere under the banner of freedom of speech.(2)
Allah prohibited the Muslim insulting the god of other religion, as He said: . “Do not insult the idols of
other people because they will insult Allah ” (3).
This article will explain the framework of European and Dutch law in this regard and will show what
the role of the New Media is in both giving a voice to the voiceless on the one hand and
exacerbation of the tensions surrounding issues related to Islam and Muslims on the other, with
special attention to online journalism.
Freedom of Speech
In the current discourse freedom of speech has become an umbrella term cited in and out of season.
In order to understand the importance of this, it is good to reflect on the notion of freedom in
general. First it should be said that the idea of freedom of speech is not alien to the Islamic tradition,
as the Qur’an is clear in what is expected of the believing men and women: “They all enjoin the
doing of what is right and forbid the doing of what is wrong” (4). In order to live this Qur’anic
injunction one actually needs to implement the freedom of speech. The way in which freedom is
used and has been institutionalised in the European (secular) context was heavily influenced by
Liberal thinker John Stuart Mill. The pivot of Mill’s body of thought is the idea that one should be
able to live their life without interference of others. Criticaster have dismissed this idea somewhat
due to the fact that people are shaped by their surroundings and that for example family,
institutions and governments help form individual choices, and that freedom can never be absolute.
Nevertheless, the individual European citizen is the starting-point of the European law.
So what does the freedom of speech mean within the European context and how does it relate to
freedom of religion In the European Convention of Human Rights a number of relevant issues have
been recorded:
1) Freedom of religion
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2) A prohibition of discrimination on the grounds of race, sex and religion
3) Freedom of speech
The European bill has a secular character, which means that there is a clear separation of church and
state. At a state level within Europe there are many differences among member states regarding this
character, which can be explained on historical grounds. Even though every country is free to
interpret the relationship between church and state in their own right, the way in which Europe has
shaped this relationship is more dominant, for a sentence by the European Court of Justice is
binding.(5)
In fact, the freedom of conscience and religion are of fundamental importance in this respect
because they are seen as the basis of democracy, and this goes for both religious and a-religious
citizens. The European Court of Human Rights does not force member states to follow a set model,
but places boundaries when tension arises between religious space and other norms and values.
Moreover, a delicate issue is the relationship between freedom of speech and freedom of religion.
Or to be more precise, the protection of religious feelings at the expense of the freedom of speech.
In the case of the Danish cartoon controversy (which will be discussed in detail later) the European
Court stated that the right to shock and disturb plays an indispensible role in a democracy, and is
thus (within limits) allowed.
In practice, this above mentioned right is not as clear cut as it was made out to be in the case of the
cartoons. There are examples in which the Court speaks out in favour of the freedom of religion and
against the freedom of speech. The case of Theresa in 1996 is an example of this. What is essential is
that the Court differs between limiting the public (political) debate on the one hand and personal
opinions in the atmosphere of morals or religion on the other when insults are being made. In the
case of the latter, Europe is more likely to be a bit more restrictive towards the offender.
It should be clear that freedom of speech, like any other form of freedom, is not absolute, even
though politicians and the media sometimes would like us to believe this. The European Court for
Human Rights has also made this very clear in their convention when they state that;
the exercise of these freedoms, since it carries with it duties and responsibilities, may be
subject to such formalities, conditions, restrictions or penalties as are prescribed by law and
are necessary in a democratic society, in the interests of national security, territorial
integrity or public safety, for the prevention of disorder or crime, for the protection of health
or morals, for the protection of the reputation or rights of others... (6).
Taking article 10 of the European Convention on Human Rights into account one could argue that in
the current social climate in Europe where there are tensions regarding the position of Muslims and
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Islam in society, the EU should be a bit more reserved with the freedom of speech used to miscall
religious sentiment.
The fact that article 10 exists indicates that apart from the legal perspective in regards to the
freedom of speech there is also a moral perspective. Because the freedom of speech implies
responsibility one should sometimes refrain from speaking in favour of the common good.(7) The
moral perspective is based on mutual respect and tolerance, two values which are crucial for a well
functioning society in which people live together in mutuality but cannot be enforced by law. God
commands people to be just to one another, even if they hold opposing views. “O you who have
believed, be constantly upright for Allah, witnesses with equity, and let not antagonism of a people
prevent you from being just. Do justice; that is nearer to piety”(8).\
The Wilders Trial
Being part of the public debate is the defining factor between limiting the freedom of speech in most
cases. Dutch right wing politician Geert Wilders, who is known for his anti Islamic viewpoints, seems
to be very aware of his position as a politician and the (extra) freedom that provides him with. He
has perfected the art of offending and disturbing fully. In recent year Wilders has created buzz
worldwide via his websites, YouTube film Fitna and twitter account by claiming that people ought to
speak out against Islam more and insinuated that the founding of Eurabia would only be a matter of
time. During a lecture in New York last year, Wilders underlined the above with the following
statement: “Today, I come before you to warn of a great threat. It is called Islam. It poses as a
religion, but its goals are very worldly: world domination, holy war, Sharia law, the end of the
separation of church and state, slavery of women, the end of democracy. It is NOT a religion, it is a
political ideology. It demands your respect, but has no respect for you.” The technique Wilders uses
is as clever as unfair; he avoids the live debate with people who have studied Islam and the lay
Muslims. All he does is drop bombs in parliament and online which have a shielding effect for him
and never fully explains himself in current affairs programmes. In a recent court case Wilders was
acquitted of hate mongering and insulting Muslims. The clash between the right to profess one’s
opinion and the prohibition of discrimination on religious grounds was won by the former in this
instance. Criticising Islam, or any other religion for that matter, is acceptable as long as one does not
directly and explicitly insult Muslims the judges stated.
The right to offend according to Dutch Law
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In Dutch law, as stated above in the Wilders court case, insulting a religion or insulting a religious
community are two different things. When insulting a religion, the intention of the person who
insults is the determining factor whether somebody is guilty or not (9)
However, when insulting a religious community, the intention of the insulter is no longer relevant
but the harshness of the insult (10)
In addition to this, there are other factors which can make sure that insult charges may be dismissed.
The most important three factors are artistic expression, religious motivation for insult and a
contribution to the public debate.
If the Danish cartoons had been Dutch cartoons they would not have been forbidden either under
Dutch Law. Cartoons fall under the category of satire, and satire is part of artistic expression. As long
as the cartoons were made without the intention of insulting someone, this would be acceptable
from a law perspective. Satire is part and parcel of the Dutch cultural landscape and therefore
acceptable. The same goes for insult coming forth from religious texts. One might take offence to
certain statements in religious texts, they will however never be forbidden as this would go against
the freedom of religion people have. nevertheless, if a person cites religious texts in such a way that
they become unnecessarily hurtful they would break Dutch law. The third, contributing to the public
debate, is a controversial one for it has to do with word use, and also how often the offensive words
were used. (11)
The case of Hirsi Ali, who claimed to fight for Muslim women’s rights, is an interesting one in this
respect; for she called the Prophet of Islam perverted and a paedophile in order to strengthen her
cause of liberating Muslim women. The judge ruled that even though Hirsi Ali had insulted the
Muslim plaintiff because of her words, the number of times which she had said it kept it within
proportions according to Dutch law.(12)
Now that the legal framework is explained, religious boundaries to the freedom of speech will be
linked to the changed media landscape and online journalism.
New Media, New Journalism
Internet is part of daily life for many people nowadays. A staggering one billion people have access
to the internet today, and the number is expected to grow rapidly. What started as a medium for
searching for information 15 years ago, is now an influential medium through which people stay in
touch with friends, do business, take in news and blog.
Of course, this easy access and the adjunct use of the world wide web had and still has a profound
influence in how humans take in information. A whole generation is coming to age that does not
know what it means to live without internet and being offline. This mediasavvy generation knows
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what is out there and can deal with information from different platforms all at the same time. This
Generation is also referred to as being Generation-C, because consuming media equals producing
content to them: SMS, MMS, email, chat, blog posts, podcasts, just sitting still and watching,
listening or reading is the exception, while collating, selecting and forwarding seems to be the rule.
This generation informs itself mostly through internet by surfing to news websites, reading blog
entries about certain topics and are kept up to date by online friends living all over the world.
This new way of using media has led to a clash between what we would call old and new media. Old
media, such as radio, TV and print media are finding it tougher and tougher to compete with new
media outlets such as internet, social media and smart phone applications. In 2008 a survey showed
that more Europeans and North-Americans got their national and international news online rather
than from a newspaper. It will not come as a surprise that print media suffered the heaviest blows
in this changing media landscape. The amount of newspapers have dropped tremendously over the
last 10 years as have the number of different magazines.(13)
Old media companies which survive, do so because they have changed the way in which they
provide their services, becoming (at least partially) part of the new media. Both Time Magazine and
the Economist are good examples of how established media companies anticipate on the consumer
change in using media: heritage brands which have successfully transformed itself from being a
current affairs magazine to a cross medial platform containing articles, videos, audio clips, photo
essays blogs and polls, all offered on different platforms and are flourishing because of it.
A change in use of media inevitably means a change in journalism. Internet has opened many doors
for what Richard Nixon once called the silent majority. The web has become a platform on which
everybody can give their two cents on any issue and run the risk of being taken seriously. Wikipedia
is a good example of an encyclopaedia which is taken very seriously by the public, while it is in fact
made by the same people who use it. When it comes to online journalism three main observations
can be made:
1) The 24/7 need for news has led to a decrease in accurate reporting.
2) Everybody is a journalist online, but required journalistic standards are often not met.
3) Web 2.0 has brought the journalist and his readership much closer together which raises
concerns about the ‘pleasing factor’ of journalists.
Accuracy and the 24-hour news cycle
The first 24-hour news cycle arrived with the advent of news channels on TV. The channels brought a
much faster pace of news production with increased demand for stories that can be presented as
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news because of the fact that they are continuously ‘on air’. This pace only increased with the rise of
online news. It is always prime time somewhere in the world.
The pressure of both commercial stakes and needing scoops constantly because it is always prime
time creates immense competition between different media organisations. This competition has led
to a movement away from traditional values such as verification, explaining context, relevance and
proportion. Former journalist Tom Rosentiel fears that “these values will be replaced by a
"journalism of assertion" which de-emphasizes whether a claim is valid and encourages putting a
claim into the arena of public discussion as quickly as possible”.
In a survey among Dutch journalists more than one third asserted that they fear that the credibility
of journalism in general is in danger because of this. In addition to this a staggering 60% does not
regularly verify information found on the internet through another source.(14)
When looking at the way in which Islam and Muslims are being portrayed in Western media, it is
clear that they are discussed from an Outsider’s view, which means that news regarding Muslims
and Islam is not contextualised in a way Muslims themselves would. For instance the attacks of
September 11 were explained in Western media in terms of ‘A holy war against the West’, and that
the perpetrators were driven solely by a desire to become martyrs. The political reality of the people
and countries involved was completely neglected. Many news commentators also simply assumed
that this was an act of Muslims hating the West because of its lewd morals in the West and did not
take into account US foreign policy in this regard. In some cases it was an attack of Islam aimed at
the West.
By equating Islam and terrorism, journalists reduced Islam to a political ideology instead of viewing it
as a dynamic religion, which has led to many problems in Europe.
Ultimately, society as a whole will pay the price for the unfair and daily bombardment of negative
news surrounding Muslims as it will become more polarised. Abrahamian (2003) states that aer
9/11 the was an increase in verbal and physical violence towards Muslims, and The European
Monitoring Centre on Racism and Xenophobia stated that “...relatively low levels of physical violence
were identified in most countries, although verbal abuse, harassment and aggression was much
more widespread. Muslims, especially Muslim women, asylum seekers and others, including those
who ‘look’ of Muslim or Arab descent were at times targeted for aggression. Mosques and Islamic
cultural centers were also widely targeted for damage and retaliatory acts.” (15)
This shows that accuracy of ‘facts’ and offering context instead of isolating incidents are of utmost
importance when trying to fight polarisation in society based on religious differences. From a
Qur’anic view God encourages people to understand each other in the light of pluralism and peace
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and co-existence when He says: “O humanity! Behold, we have created you all out of a male and a
female, and have made you into nations and tribes, so that you will get to know each other” (16) .
Blogs, Everybody can be a journalist
With the further development of the new media a new brand of journalism has emerged: Blogs.
They are opinionated, ranting, often incoherent and frequently biased with little regard for accuracy
or balance. A blog is simply a highly personalised series of updated posts on a web page in the form
of a diary or journal, often including commentary on, and hypertext links to, other web sites.
Perhaps one attraction of blogging lies precisely in its unmediated and dynamic quality."Readers are
flocking to online news sites by the millions for the latest news,” JD Lasica, senior editor of the
Online Journalism Review states."[The Public is] also streaming to weblogs for sceptical analysis,
critical commentary, alternative perspectives rarely seen in mainstream media. Unlike the large
media organisations, bloggers were unhindered by the normal journalistic standards of objectivity,
balance and accuracy. This amateur output was raw, subjective and honest as people sought
emotions, not detachment - finding solace and expression in the words of the thousands of blogs
that sprang up.
Moreover, the fact that established print journalists from outlets such as The Independent and
Guardian Unlimited started to create their own weblogs to sit alongside news and features, blurred
the distinction between ‘real’ journalism and blogging even more.
The question is why so many readers of online content have chosen to steer away from traditional
sources of news in favour of weblogs. Looking at the content blogs provide, such as alternative
perspective, first-person experiences and interactivity, one might conclude that readers want either
a balanced or more personal angle to their news and that standard and rigour do not necessarily
matter. Modern day Western society is individualised to such an extent that the way in which
individuals define and try to solve their own problems has become the lens though which the world
is viewed. Blogs have become in a sense a global conversation about how the world is viewed, an
individual network of personally tweaked news . The way in which Al Qaeda is used and uses
internet is a good example of this collation and expression of Islamic justifications on for instance
weblogs given by people (radicals) who have not even received proper religious training to do
so.(17)
Unfortunately, blogging is not the democratic innovator utopians hoped it to be. But it offered
freedom. Freedom to select and create content which, most often, does not live up to the standard
of traditional journalism as agreed on in the declaration of principles on the conduct of Journalists in
Bordeaux. This is something we have to deal with because of the fact that news on blogs is
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authentic, and that, more than anything else, is what today’s internet generation is actually looking
for.
A culture of pleasing
According to a Dutch survey amongst journalists more than 50% of them has more contact with the
audience because of internet. In a bid to win over readers in a very tough market, newspapers such
as the Guardian opened up a chunk of their website in order for readers to comment on articles
called comment is free which is more or less an open forum.(18)
This talkback option has asked of the journalist to change his role and become more flexible. Before,
the great wall of China divided the journalist from his readers. The Journalist never thought about
‘what the public’ wanted to read, but only what he felt they should know. This is impossible and
unthinkable nowadays. A journalist must work together with the critical and sometimes stubborn
citizens nowadays to spark interest in the pieces which he writes. This means updating and debating
constantly, and also look at news as a commercial venture: what does my reader want to read The
danger here is that journalists will adopt the slant and public displeasure in order to be read more.
The economic pressure has led to some parts of the press moving toward sensationalism,
entertainment and opinion. Through this stereotypes have been reinforced more than broken down
and has led to further negative framing of Islam in European society. A good example of this was
when a few hundred t-shirts with the face of Bin Laden were sold in Indonesia. This was news on all
possible news platforms available, giving people the impression that the whole of Indonesia was
supportive of Al Qaeda, whereas obviously it was a gross misrepresentation of the facts and that this
could not be further away from the truth.
The Qoer'an has clearly stated: O you have believed, if there comes to you a disobedient one with
information, investigate, lest you harm a people out of ignorance and become, over what you have
done, regretful. (19)
Tension Hype!
The Danish cartoon controversy is a typical example of how the tension between Freedom of religion
on the one hand and freedom of speech on the other was portrayed on different platforms of new
media, unleashing a hype of immense proportions.
On Thursday 30 September 2005 editor Flemming Rose of the conservative Danish newspaper
Jyllands-Posten publishes 12 cartoons of the prophet Muhammad in the Art section of the
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newspaper. In the months leading up to the publication the debate on censorship and self
censorship heated up in Denmark. After he hears that children’s book writer Kaare Bluitgen can’t
find an illustrator for her book on the life of Muhammad, Rose decides to ask 25 cartoonists to draw
up a satirical cartoon of which the Prophet of Islam is the subject. 12 people respond and their
cartoons are published. At that point Rose could not have realised that his publication of satirical
cartoons, would lead to riots, deaths, diplomatic rows and an economic boycott of Danish
products.(20)
Weeks after the publication Egyptian newspaper Al Fadjr reprints the cartoons in anger. Moreover,
at around that same time, a group of Danish Muslims travels to the middle-east bringing the
cartoons and other materials they find online. This lobby is supported and amplified by numerous
websites, blogs, emails and chain SMSes. The anger surrounding the publication also leads to a call
for boycotting Danish products though internet and mobile phones.
What started as an aempt to stir up a debate in Denmark in September 2005, was a full blown
media hype in 2006. Boosted by the many emails, text messages, blog entries and interactive polls
on websites everybody formed an opinion (whether pro or con) which was more often than not
nothing more than parroting. Facts became completely irrelevant and rumours spread so fast that
they are not checked on their truth. Many people protesting had not even seen the cartoons. In
protests things got out of hand and people crossed boundaries set by Allah when innocent people
died and protesters burnt and trampled the flag of Denmark which has a religious symbol on it. “Do
not insult the idols of other people because they will insult Allah ” (21).
The interesting thing about this media hype is the fact that it is very much a new-media hype.
Information was sent and received over a variety of platforms which were all connected one way or
the other. Also, because of the nature of new-media we see continuous real time updates which
means that it becomes increasingly more difficult to put out the fire as new sparks emerge from
everywhere. This is a reason why the uproar was so lengthy.
The cartoon controversy has reminded us of the fact that the traditional borders of a country no
longer depict the mental and moral borders of people. We are living in an age where because of
globalisation, the 24-hour economy and increasing (international) media literacy people are aware of
what is happening around them and are more likely to respond to issues which are close to one’s
heart.
Conclusion
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The world has changed significantly over the last decade. Technological advances in the field of the
media have made it possible to really view the world as a global village. This global village called the
world wide web, like any young nation, has its issues. It has given a voice to the voiceless, which can
be heard and read on millions of websites and blogs daily. One needs to shed a positive light on this
and see that this means that many people can now define themselves.
However, the hoped for democratic revolution of Internet has not taken place. In many instances
defining the ‘other’ is still prevalent and has led to social tension. Unfortunately, in a great number
of instances the voiceless have become the faceless, and it is this anonymity which has partially led
to the amount of offence at the address of religion in a rapidly secularising Europe.
Dutch law is very clear: When it comes to taking offence, one should be resilient, even when it
comes to religion. The public prosecutor has treaded lightly and has only in a rare occasion
prosecuted someone for crossing the line when it comes to offending people regarding their
religious beliefs. In the recent
hate mongering case against Muslims of Dutch MP Geert Wilders the public prosecutor even
demanded full acquittal.(22)
Apart from the legal side of the debate regarding religious boundaries to freedom of speech we also
have moral boundaries to take into consideration which are systematically crossed in this instance.
Van Stokkum (2009) argues that the intolerance towards Muslims in both the media and the public
debate stem from radical secular concepts and that the expression of these concepts are seen as less
problematic than intolerance towards other minority groups and religions.(23)
It is very unsatisfactory for Muslims to ascertain the fact that from a juridical perspective not much
can be done to stop the continuous flow of negativity surrounding their religion and Islamic Identity.
It is because of this that many Muslims feel pressured by Dutch society and insulted.
However, the fact that cases against Hirsi Ali (2005) and Wilders (2011) went to court gave Muslims
the opportunity to clearly expound on why things said in the media by both politicians and their
adherents were perceived as being hurtful to the community, which provided the debate with a new
angle from an ethical approach.
It seems that the laws regarding freedom of speech and religious boundaries have not taken the
zeitgeist of today’s world into account properly, and are therefore sometimes seen as unjust and
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arbitrary. It is too easy to state something in a blog-post or on twitter and simply hide behind
freedom of speech, for a debate needs to be open, respectful and honourable. Muslims are
commanded to do so through the following Qoer’anic injunction: “Invite to the Way of your Lord
with wisdom and fair admonition; and argue with them in ways that are best and most gracious”
(24).
It is precisely these above mentioned three adjectives which are more often than not absent in the
debate on Islam in the media. Interestingly enough European law places the right to shock, disturb
and offend over the ethical boundaries needed to engage in a debate, and by doing this showing
that the ethics of a debate and law are not complementary in the case of the freedom of religion and
the freedom of speech from a law perspective. This very incompatibility between ethics and law
will lead to numerous new skirmishes on the religious boundaries of the freedom of speech.
Roerdam, 2 December 2011
Footnote:
(1) Qoer'an 33 : 21
(2) Evers, H. Media, Extremisme en de grenzen van de uitingsvrijheid, in Media Ethiek, p. 139-
152 (Groningen: The Netherlands) 2007.
(3) Qoer'an 6 : 108
(4) Qoer'an 9 : 71
(5) European Court of Human Rights, European Convention on Human Rights,
http://www.echr.coe.int Last accessed 03/10/2011.
(6) European Convention on Human Rights
(7) Murdered Cineaste Theo van Gogh’s parents stated the same thing during his funeral in
2004.
(8) Qoer'an 5 : 8
(9) Van Het Reve trial 1967
(10) The Goeree family trial 1989.
Hermans, L Pleijter, A Tebbe, F. Nieuwe journalisten door nieuwe bronnen, (Rotterdam: The
Netherlands) 2002.
(11) Shadid, W. Moslims in de Media: De Mythe van de registrerende journalistiek, in Mist in de
Polder (ed: Vellenga, S et al) p.173-193 (Amsterdam:The Netherlands) 2009.
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(12) Blanken, H Deuze, M. PopUp De botsing tussen oude en nieuwe media, (Amsterdam: The
Netherlands) 2009
(13) Berger, M.S. Religieuze grenzen aan de vrijheid van meningsuiting: de Deense spotprenten
voor de Nederlandse rechter, in NCJM-Bulletin, p. 664-675 (Leiden: The Netherlands) 2006.
Loenen , T. Gelijkheid als juridisch beginsel, (Amsterdam: The Netherlands) 2009.
(14) Rechtspraak, de. Kort geding Hirsi Ali, Hoge Raad der Nederlanden
http://www.rechtspraak.nl last accessed 03/10/2011.
(15) Abrahamian, E. The US media, Huntington and September 11, in Third world Quarterly, p
529-544 (London: United Kingdom) 2003.
(16) Qoer'an 49 : 13
(17) Thomas, T.L. Al Qaeda and the Internet: The Danger of Cyber planning, Parameters, p112-
124 (Carlisle:USA) 2003.
(18) Stolwijk, S. De zaak Goeree, in AA p119-127, (Leiden: The Netherlands)1988.
(19) Qoer'an 49 : 6
(20) Shadid, W. Moslims in de Media: De Mythe van de registrerende journalistiek, in Mist in de
Polder (ed: Vellenga, S et al) p.173-193 (Amsterdam:The Netherlands) 2009.
(21) Qoer'an 6 : 108
(22) Geert Wilders is the chairman of political party PVV ( Partij Voor Vrijheid) Wilders, G. Geert
Wilders Weblog, http://www.geertwilders.nl Last Accessed 03/10/2011
(23) Stokkum van, B. Wat een Hufter! (Amsterdam:The Netherlands) 2010. Jenkins, H Thorburn,
D.
Democracy and New Media, (London: England) 2004.
(24) Qoer'an 16: 125
------- ,, -------
.
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