This master thesis deals with the current situation of the media environment in two selected countries from the Southeast Asia region - Hong Kong, Special Administrative Region of the People's Republic of China, and Singapore. The main object of the text is to create a descriptive analysis of Hong Kong's and Singapore's political and media systems and to compare the media environment of the two countries with a special focus on the freedom of the media. The comparison is based on the definition of their political systems, their constitutions and how they are respected, as well as on data published by international nongovernmental organizations focusing on the freedom of the press and the freedom of the speech. All findings will be illustrated with examples from Hong Kong and Singapore. The work is divided into four chapters. The first theoretical part defines basic terms and indexes, which measure the freedom of the press, as well as outlines the concept of Asian values and the concept of civil society. The descriptive section provides a brief summary of the history and political systems of both countries and introduces their constitutions, laws and power of political leaders. The third part of the thesis concentrates on the media environment of both countries and the role of local media. The...

La constitution du 22 janvier 2001 dispose expressément que la République du Sénégal garantit la liberté de la presse et le droit à l’information plurielle. Néanmoins, le journaliste sénégalais est resté justiciable des codes pénal et de procédure pénale, adoptés dans l’élan répressif des années 1960. Ce droit pénal commun qui intègre paradoxalement la loi française spéciale du 29 juillet 1881 sur la liberté de la presse, héritée de la colonisation, apparaît comme dépassé par l’évolution de la démocratie sénégalaise et l’aspiration du peuple à l’épanouissement et au progrès social. L’activité journalistique est une activité potentiellement délinquantielle. Il peut arriver que le journaliste abuse de la liberté d’expression en foulant au pied la loi et les règles de la déontologie de sa profession. La justice du droit pénal a vocation à lui être applicable. Mais, ce constat ne doit point occulter la nécessité dans laquelle se trouve le législateur de rendre sauve la liberté de la presse dans l’exercice de sa compétence exclusive de fixation et de détermination des abus intolérables de ladite liberté. Pour ce faire, l’adoption d’une législation spéciale, détachée de l’emprise tutélaire des codes pénal et de procédure pénale, s’impose. C’est une condition nécessaire, mais non suffisante. La prévisibilité de la loi applicable à la responsabilité pénale du professionnel de l’information, l’indépendance du juge qui l’applique, la non-ingérence du pouvoir politique dans la liberté d’informer du journaliste sont autant de conditions nécessaires à la répression des abus de la liberté de la presse. / Senegalese Constitution dated 22th January 2001 clearly provides that the country guarantees the freedom of the press and the right to multi-sourced information. And yet the Senegalese journalist remains subject to the Criminal Code and the Code of Criminal Procedure adopted in the repressive surge of the 1960’s.The local Criminal law which paradoxically includes French special 29th July 1881 Act on the freedom of the press seems outdated and overtaken by the evolution of the Senegalese democracy and the people’s yearning for development and social progress. The journalistic activity potentially brings forth offences. The journalist may take too much advantage of the freedom of the press violating thereby the law and his own deontology. Criminal law justice must therefore be applicable to them. However this must not conceal the law-maker‘s necessity to safeguard the freedom of the press. To that end it is necessary to set up a special legislation free from the Criminal Code and from the Code of Criminal Procedure. This is a necessity though insufficient. The predictability of the law applicable to the criminal liability of the journalist, the independence of the applying judges and the non-interference of the political power in the journalist’s freedom of speech are prerequisites to the repression of the abuses of the freedom of the press. Our present thesis aims on the one hand to diagnose the criminal liability regime of the Senegalese journalist and also to prove the inadequacy of the criminal law with its legal liability. We will then suggest a particular criminal liability system more respectful of the freedom of the press.

This dissertation deals with the topic of development of Czechoslovak press law during the First Republic, primarily through the legislative process of press law or of legislation related to press law, adopted by the National Assembly of the First Republic, and also by the impact that adopted legislation, and in particular the Act on Protection of the Republic in 1923 and amendments of press law in 1924, had on the rulings of the Supreme Court during the First Republic. It takes a comprehensive look at the development of press law during the First Republic based on the one hand on legislation carried over from Austro-Hungarian and later amended, and on the other hand on new legislation adopted during the First Republic. The study also analyses the common features of the legislative process of individual press regulations and at least in part the role of the Supreme Court in the interpreting of valid law.

本論文的時間斷限為1945至1987年，研究的重心主要集中在台灣傳播學界的新聞自由論述，並希望透過比較的方式，與當時英美各國的新聞自由論述相對照，以瞭解台灣新聞自由發展的特殊、扭曲與不足之處。本論文除緒論、結論外，共有六章，就內容而言，可分為三大區塊。第一區塊為第一、二章，主要探討國際社會對新聞自由的見解。第二區塊為第三章，主要探討戒嚴時期台灣的憲法學如何界定新聞自由。第三區塊為第四至六章，亦是本論文的主軸，主要探討戒嚴時期傳播學界所建構的新聞自由。 整體來看，歐美社會，尤其是美國新聞自由的最新進展，包括：1956年美國新聞界要求政府公開資訊、減少新聞封鎖、同年美國國內所發生，記者赴中國採訪權的爭議，以及1971年美國報紙刊載「越戰報告書」所引發新聞自由與國家安全的爭議等，大都能即時的傳入台灣社會。然而，關己則亂。戒嚴時期傳播學界面對台灣新聞自由受到種種限制的實況，基本上採取相對消極，甚至是迴避的態度。傳播學界一方面忽視政府對新聞自由的限制，一方面則將火力集中於媒體「責任」。 從「社會責任論」在台灣的發展觀之，引介人謝然之、胡傳厚與國民黨皆有深厚關係。而後續台灣自律組織的建立、相關會議所提出的社會新聞改進之道，亦與國民黨脫不了干係。對政府的態度，為自由主義與社會責任論者之間最重要的差異。然而，從相關的著作可看出，西方社會責任論的主催者，對於政府能否涉入，能介入多深仍存有許多疑慮。從自由主義到社會責任論，要求政府不要插足新聞事業的聲音一直存在。1950年的「歐洲人權公約」更特別明言「不受公部門干預」的表現自由。然而，在戒嚴時期台灣的傳播學界，拒絕政府干涉的聲音卻十分微弱。甚至在反共復國的重責大任下，新聞自由被降級到「法律保障」的層級，連僅存的社會新聞報導空間，亦與「國家利益」牽扯在一起。新聞事業被賦予超出歐美報人所謂的社會責任，進而需要「犧牲本身的自由和權利，以貢獻於國家民族」。 就結果來看，由國民黨主導的自律組織，以及社會新聞改進之路，在新聞界聘任與其立場相近的評議委員，與消極的不作為下，並沒有發揮國民黨所期待的效用。透過一些文章，我們可以發現，戒嚴時期台灣的傳播學界對其所屬的環境、新聞自由所受的限制是有一定的認識的。但在反共復國的大旗下，大都只能點到為止，或轉而要求新聞界必須瞭解國家正處於生死存亡之間。這樣的氣氛一直要到1980年代才有比較明顯的轉變。

Thesis (MPhil (Journalism))--University of Stellenbosch, 2006. / This study aims to locate the South African National Editors’ Forum (Sanef) within South Africa’s transformation from apartheid to a nonracial and constitutional democracy. This entails first examining the potential for participation demonstrated by editors’ societies at different democratic stages and defining the ideal democratic roles of journalism. The recent political history of journalism in the country is summarised to draw out the particular obstacles to editors’ unity and the transformation needs in South Africa’s racialised context. Then the forum’s history from 1995 to 2000 is reconstructed in detail using documentary sources. This covers the formation and launch periods of Sanef, and the next couple of years of the forum’s existence. This study is described as a historical, qualitative inquiry from the inside, observing both the sequence of events and the motives related to the context and to concepts of democratic role. It is unusual in that it is a historical study of a journalism society and it uses journalism theories to guide the research and the analysis. The research shows that despite having to overcome divisive issues from their past, the editors chose to play their part across all democratic roles: liberal, social democratic, neoliberal and participative. Activities were mostly linked to the current democratic stage. Many involved the self-transformation of journalism and journalists, leading to the suggestion of a fifth role for journalism in emerging democracies. However, some Sanef projects were not completed despite their significance for democratic journalism and others had no strategic rationale. This study recommends that Sanef be more strategic in its activities and look to other emerging democracies for appropriate solutions to problems. It is suggested that failing to do so could result in more complex problems for journalism in South Africa in the future. Finally, it is noted that the existence of a stable and prominent forum giving editors, senior journalists and journalism educators a united voice in areas of common interest in itself lends serious weight to their democratic participation.

Adolf Hitler advocated total control of the press for many years before he was elected Führer. Almost immediately after he assumed power in 1932, Hitler began writing new laws and regulations that totally exorcised all freedoms from the German press. This study follows the path that Hitler took to control the German press from 1920 until the end of World War II. It utilized translations of documents and statements by men whom Hitler appointed to control the press and books written by experts in the fields of communications as well as men who prosecuted Nazi war criminals after World War II. The study found that the control of the press was indeed a very necessary ingredient in Hitler's climb to power and remained crucial during his reign as Führer.

On July 29 2000, Uganda held a referendum to decide whether to continue with the ruling Noparty Movement system or to revert to the Multi-party platform. This research entails a qualitative content analysis of the role the media played in driving debate and understanding of the referendum and its role in the country’s democratisation process. The research is informed by Jurgen Habermas’s public sphere paradigm as well as the sociological theory of news production. The research covers Uganda’s two English dailies – The New Vision and The Monitor, examining whether they provided a public sphere accessible to all citizens and devoid of ideological hegemony. It concludes that the newspapers were incapable of providing such a sphere because of the structural nature of Ugandan society and the papers’ own capitalistic backgrounds and ownership interests. The research concludes that such English language newspapers published in a country with a low literacy rate and low income levels, can only provide a public sphere to elite and privileged sections of society. A case is then made that multiple public spheres would be better suited to represent the views of diverse interest groups.

During the Angolan War of 1975-6, whilst South African troops were actively engaged on the side of the Unita/FNLA alliance, news media in South Africa were prohibited from disclosing information about the country's role in the war. Under Section 118 of the Defence Amendment Act of 1967, no information about SA troop movements or plans could be published without the permission of the Minister of Defence or his nominees. This case study shows how the Government used the Defence Act to censor certain news while releasing other news which suited its political outlook and objectives. The study documents the history of the Defence Act and of the military-press liaison machinery which grew out of it. The introduction defines propaganda as a technique of ideological control designed to supplement the control of society by means of repression. The study sets in context the Government's propaganda strategy before, during and after the Angolan War, arguing that the structures of white domination, including the newspaper industry, are being drawn into the Government's scheme of total co-ordination to fight a total war.

On May 16 2006 the government of Zimbabwe embarked on a clean-up programme of urban centres, destroying informal human settlements and informal businesses. This operation, which the government called operation "Restore Order", resulted in the displacement of nearly one million people and left thousands of families homeless. This study is a discussion and an analysis of the coverage of the clean-up operation by two of Zimbabwe's leading Sunday newspapers, The Sunday Mail and The Standard. The Sunday Mail is owned by the Zimbabwe government and The Standard is privately owned and perceived to be oppositional to the current Zimbabwe government. The two newspapers, therefore, covered the clean-up operation from different perspectives and often presented conflicting reports explaining why the clean-up operation was carried out and the extent of its impact on the lives of millions of Zimbabweans. The chosen research approach is the Critical Discourse Analysis (CDA) framework as developed by Fairclough (1995). Using CDA, this study seeks to find out and expose the underlying ideological struggles for hegemony between different social and political groups in Zimbabwe and how the newspapers became actors in this process. This process is made possible by looking at how news reporting is organised in the two newspapers, issues of language use, sourcing and external factors that influenced the coverage of the operation.

This research focuses on the controversy surrounding the exhibition and media publication of Brett Murray’s painting, The Spear of the Nation (May 2012). It takes the form of a qualitative Critical Discourse Analysis (CDA), underpinned by Fairclough’s (1995) three-dimensional approach, to investigate how the contesting discourses articulated by the ruling political party (the ANC) and the news media have been negotiated in the City Press coverage in response to the painting. While the contestation was fought ostensibly on constitutional grounds, it arguably serves as an illustrative moment of the deeply ideological debate occurring in South Africa between the government and the national media industry regarding media diversity, transformation and democracy. It points to the lines of fracture in the broader political and social space. Informed by Foucault’s conceptualisation of discourse and the role of power in the production of knowledge and ‘truth’, this study aims to expose the discourses articulated and contested in order to make inferences about the various ‘truths’ the ANC and the media make of the democratic role of the press in a contemporary South Africa. The sample consists of five reports intended to represent the media’s responses and four articles that prominently articulate the ANC’s responses. The analysis, which draws on strategies from within critical linguists and media studies, is confined to these nine purposively sampled from the City Press online newspaper texts published between 13 May 2012 and 13 June 2012. Findings suggest the ANC legitimise expectations for the media to engage in a collaborative role in order to serve the ‘national interest’. Conversely, the media advocate for a monitorial press to justify serving the ‘public interest’. This research is envisioned to be valuable for both sets of stakeholders in developing richer understandings relevant to issues of any regulation to be debated. It forms part of a larger project on Media Policy and Democracy which seeks to contribute to media diversity and transformation, and to develop the quality of democracy in South Africa.