“Asian Values” in Different Forms: A Comparative Examination of How Singapore, Indonesia and Myanmar Address Insults to Religion

Insults to religion have the potential to stoke tensions and result in physical violence. To protect religious sensitivities, speech which insults religion may be criminalised, even in countries where freedom of speech is enshrined as a constitutional right. The purpose of this article is to look at the role played by the state in dealing with speech which insults religion, through an examination of three Southeast Asian case studies. This article attempts to provide a comparison of the constitutional provisions and specific legislation relating to the insulting of religion in the three countries, as well as consider how the laws have worked in practice. It finds that while the ‘law on the books’ across the three countries may have broad similarities in the way they are drafted, they differ vastly in the ways they are applied and enforced, due to differences in the state-religion relationship, religious demographics and the influence of religious nationalism. At the same time, despite the social, political and cultural heterogeneity of the three countries, the prioritisation of communitarian interests in the three countries over the freedom of speech suggests the continued salience of “Asian values” in Southeast Asia.