Freedom of expression is both a basic right and a basic need in all democratic societies. Without it, democracy itself cannot function. This is a comparative study. The protection, or more often the restriction, of freedom of expression in England before the American Revolution is considered first. Then two chapters outline the development and extent of freedom of expression, first in America, then in England, from 1776 up to the present day. There follows a direct comparison in two separate areas: the Fair Trial-Free Press tension which exists between the interests of those involved in judicial proceedings, and their rights to a fair and impartial hearing, on the one side, and the interests of the press and other media in reporting judicial proceedings on the other.
Shears, Peter G., "Freedom of Expression in England and the United States: A Comparative Study, with Particular Reference to Restrictions Imposed by Means of Prior Restraint" (1984). LLM Theses and Essays. 152.