Restrictions of freedom of expression in the historical rocess and in the decisions of the US Supreme Court and ECHR

This thesis covers the historical and doctrinal perspective of freedom of expression as a concept, as well as the restriction of freedom of expression in the light of the decisions of the US Supreme Court and ECHR. The thesis consists of two parts. In the first part, the historical process of freedom, the forms of expression developed in this historical process, the transfer of the concept to positive law and the arguments of the theses on freedom of expression are examined. In the second part, restrictions on freedom of expression since the 20th century are evaluated within the scope of the decisions of the US Supreme Court and ECHR. In this thesis, we examine how the verdicts of the two largest courts in two separate geographies shape the limitation in time, how the limits of freedom are drawn, how these two courts set the ultimate in determination of criteria in terms of hate speech, the concept of blasphemy and conflict with pornography.