Answer:
The United States first amendment carried more protection and less restriction in its implementation and here is why.
The edict of the United States does not qualify the application of the clause granting freedom of expression. That of the United Kingdom does. In doing so, it ensures that Freedom of Expression is used appropriately in that it must be targeted at the common good and the well being of the state.
It states, for instance, that
"Public authorities may restrict this right if they can show that their action is lawful, necessary and proportionate in order to:
- protect national security, territorial integrity (the borders of the state) or public safety
- prevent disorder or crime
- protect health or morals
- protect the rights and reputations of other people
- prevent the disclosure of information received in confidence
- maintain the authority and impartiality of judges"
Cheers!