Table 3. Penalties for hate speech and blasphemy Country Offline penalties Online penalties Cambodia Article 516, Criminal Code: Insult of Buddhist monks, nuns and laymen: Imprisonment from one day to six days and a fine from one thousand to one hundred thousand Riels. No online counterpart. India Section 295A, Indian Penal Code: Imprisonment of three years, or with fine, or with both. Section 298, Indian Penal Code: Imprisonment of one year, or with fine, or with both. No online counterpart. Offline law used to charge online offences. Malaysia Section 298, Malaysia Penal Code: Imprisonment of one year, or with fine, or with both. Section 298A, Malaysia Penal Code: Imprisonment for a term of not less than two years and not more than five years. No online counterpart. Offline law used to charge online offences. Myanmar Section 295A, Myanmar Penal Code: Imprisonment of either description for a term which may extend to two years, or with fine, or with both. Section 298, Myanmar Penal Code: Imprisonment of either description for a term which may be extend to one year, or with fine, or with both. No online counterpart. Pakistan Section 295A, Pakistan Penal Code: Imprisonment of 10 years, or with fine, or with both. Section 295C, Pakistan Penal Code: Death, or imprisonment for life, and with fine. Section 298, Pakistan Penal Code: Imprisonment of either description for a term which may extend to one year, or with fine, or with both. Section 298A, Pakistan Penal Code: Imprisonment of three years, or with fine, or with both. Section 10A, Prevention of Electronic Crimes Act, 2016: Imprisonment for a term which may extend to seven years, or with fine, or with both. Thailand Article 44, Sangha Act 1962: Fine of not more than five thousand Baht or an imprisonment of not more than one year or both. Section 206, Criminal Code: Imprisoned as from two years to seven years or fined as from two thousand Baht to fourteen thousand Baht, or both. Section 207, Criminal Code: Imprisonment not exceeding one year or fined not exceeding two thousand Baht, or both. No online counterpart. Cambodia, the requirements are far less: (1) there must be an allegation or charge, (2) the allegation or charge must be made in bad faith, and (3) the allegation or charge must tend to injure the honour or reputation of the natural or juristic person. There are no exceptions as to truth, holding an opinion, or public good. In Thailand, (1) there must be an imputation made to a subject, (2) the imputation must be made before a third party, and (3) the imputation must be likely to damage the reputation of the subject of the imputation. Thailand is different from Cambodia in that there is no need for bad faith in making the imputation, and moreover, Thailand also creates the exception of good faith imputations to the crime of defamation. Punishments for offences differ across states While the six states share similar laws and provisions, they differ, if but slightly, in the way they punish these offences. For instance, in the case of hate speech, each state offers different punishments (imprisonment as well as fine). As can be expected, Pakistan offers the greatest punishment, from 10 years to life imprisonment. Cambodia offers the least punishment, with imprisonment of only days, but with a large fine. In the case of defamation, however, while Cambodia prescribes a maximum of ten million Riels as punishment, in Thailand, an individual may be imprisoned for five years. The penalties for these offences in the six states are compared in Tables 3 and 4. Regional trends / 31