Life in the
Liberalism�s holy war
If there has indeed been, in Rana Kabbani�s words, a �transfer of contempt� from Jews to Muslims in secular culture since 1945 (see
A brief history of blasphemy), and if Western blasphemies against Islam are having the effect of intensifying this process, then this still does not add up to an argument either for suppressing The Satanic Verses or for restraining its publication in any way. For the belief in �freedom of expression� is an extremely powerful one. It is as precious to the West, almost, as the Koran itself is to Islam. It would be both foolish and naive to expect Western liberals to lay aside their most precious belief, simply because somebody�s feelings are being hurt � or even because deep distress is being caused to an entire culture.
It must be said, however, that, like every other question in this debate, the whole issue of freedom of expression is a complex one � a great deal more complex and many-sided than the black-and-white views favoured by some would suggest.
Some of the most elementary objections to the extreme libertarian position have already been made many times during the course of the Satanic Verses debate. But no harm can be done by repeating those objections here.
For a start it is wrong to imply, as some artists and intellectuals seem to, that all attempts to bridle the way in which people express opinions are necessarily harmful. In a number of European countries there are laws against the incitement of racial hatred. These laws impose a form of censorship. But they are not for that reason wrong. In most Western countries it has for a long time been illegal to incite people to murder. This is a restraint on our freedom of speech which we would be unwise to dispense with. The law of libel is another far more sweeping restraint on freedom of speech. Sometimes the effect of this law is to suppress truths which should be told. But no civilised, democratic country would ever consider simply sweeping the laws of libel away, any more than it would abolish laws against incitement. For words are not, as is sometimes claimed, neutral and harmless instruments. As the Ayatollah Khomeini�s fatwa itself demonstrated, they can, in certain contexts, be as lethal, almost, as bullets. They can also be used to destroy reputations and can cause great offence and personal distress. That is why absolute freedom of speech is ultimately no more desirable than absolute freedom to murder.
For centuries most democratic countries have recognised this and they have framed laws whose specific purpose is to constrain freedom of speech. Some of these laws are good, some, arguably, are bad. But one of the difficulties we have had throughout the duration of the Satanic Verses controversy is that a significant minority of artists and intellectuals appear to have succumbed to the liberal-democratic myth that none of these laws exist, that the purpose of democracies is to remove constraints on freedom and that our own democracy accords to all its members some absolute freedom of expression which is now under threat.
Whenever these same artists and intellectuals offer examples of this freedom of expression, they almost always draw them � understandably enough � from their own experience of artistic or intellectual activity. It is for this reason that their arguments tend to be so persuasive. For it is undeniably true that artists, novelists and intellectuals in modern Western societies are now accorded a degree of freedom which is extraordinary and unprecedented.
What is too rarely remarked on, however, is that this freedom is enjoyed only in extremely restricted contexts. One particular area of freedom which twentieth-century liberals have fought hard to establish is that found in the modern novel. In most European countries this struggle has met with a great deal of success � particularly with regard to the use of obscenities and the portrayal of sexual love. We should not for a moment conclude, however, that this story of reform indicates that we have moved into an area of unrestrained liberty. It may well be that in a certain compartment of society, obscene words are used a little more frequently and more fearlessly than they once were. But a moment�s reflection should suffice to reveal just how narrow is the �freedom� which we appear to have won. You only have to take your copy of Lady Chatterley�s Lover down to the local market-place and declaim it in a loud voice in the presence of a policemen and one or two witnesses and you will soon find yourself before a magistrate. And if a British daily newspaper were to report your arrest, it would in most cases almost certainly decline to reproduce verbatim � and without asterisks � the details of your crime. Nor for that matter would the nature of your transgression be accurately reported on the radio or television news.
Where, then, is our much vaunted freedom of speech? Where is the freedom to publish which we prize so much? The answer is that the freedom of expression we enjoy is very specifically limited to certain contexts. This is one reason why the arguments about freeedom of expression, which liberals frequently put forward in order to defend The Satanic Verses, are both ill-considered and, ultimately, dangerous. For these arguments are calmly advanced in a society where practically every medium of expression other than the novel is subject to the most complex and elaborate restrictions; where every programme that we watch on television has been vetted by guardians of public decency; where every film we see has been censored, and where the licence we extend to �art� encourages us to forget that every �non-artistic� picture ever published or displayed is subject to rigorous obscenity laws. These laws express, in their selective prohibitions and permissions, a seemingly profound antipathy to sexual love and a deep and almost insane horror of some of the most ordinary parts of the human body, particularly when these are conjoined in some of the most ordinary ways. Not only this, but in Britain, the very country which holds itself up as a model of the �free� society, a law has recently been passed in which civil servants have been deprived of one of the most important civil liberties which they had previously enjoyed under the law � the freedom to place the demands of conscience above the demands of their government.
If we are to have any hope of unravelling the terrible problems which have been brought to the surface of the liberal conscience by the publication of The Satanic Verses, we need first of all to recognise, however painful this may be, that we do not live in a free society, and that we do not generally enjoy freedom of expression.
Secondly we need to recognise that democracy itself is not synonymous with liberty and that in some very important respects it is antipathetic to liberty. For democracies are not built on accumulated layers of freedom; they are built upon the rule of law, which in its turn consists in the selective deprivation of freedom. In this respect it is quite wrong to see some absolute disjunction between totalitarian societies and democracies. The relationship between the two forms of government was perhaps best illuminated by one of George Orwell�s remarks, in which he observed that the perfect totalitarian society was one whose citizens were so drilled to conformity that there was no need for a police force. The citizens of such a perfect totalitarian state would presumably be free in all outward respects. They would be free to express subversive opinions and formulate �revolutionary� philosophies because these would almost certainly turn out to be disguised forms of authoritarianism. They would be free to engage in all manner of sexual activities in private, because the rule of puritanism and sex-hatred over public life would already be complete and would be relentlessly maintained by a puritanical �free press� hungry for the titillation of scandals it felt duty-bound to expose. They would be free to vote � for the simple reason that all the major political parties would be pale reflections or mirror-images of each other�s conformity, who disagreed only about the different ways of managing the same structures of power.
The citizens of this perfect state would, in short, be free to do everything precisely because they were powerless to change anything. Most importantly of all, they would be free to blaspheme against the religion of the state. Indeed leaders of the perfect totalitarian state would rigorously protect the freedom of a tiny elite of artists and intellectuals to do just this. They would do so partly in order to perpetuate the myth of freedom which gave their regime legitimacy, but mainly because of their intuitive knowledge that, in a deeply conformist society, any criticism of the ruling ideology made in terms which are obscene, scurrilous, unruly or distasteful to the majority, actually has the effect of outraging moderate opinion, thus tightening social control and allowing ideological defences to be deepened.
The hypothetical perfect totalitarian society which I describe here does not exist. Nor is it likely, given the limitations of human nature, that it ever will. It must nevertheless be conceded that such a society does bear at least a passing resemblance to our own � and to Western democracies in general.
In view of some of the events in Eastern Europe in recent years, perhaps this should not surprise us. For one of the many messages which are inscribed on developments in the Soviet Union and Eastern Europe since the fall of the Berlin Wall in 1989 is that our long established democratic perspective on totalitarian states is based upon a false understanding of our own history. For more than a century � and particularly since 1917 � we have consoled ourselves with the fiction that totalitarianism is what happens when democracies collapse. Recent events in the Soviet Union, in Poland, in East Germany, in Czechoslovakia and in Romania suggest that the reverse may be true: democracy is what happens when totalitarian regimes collapse. For it is in the nature of totalitarian regimes that they do not collapse �outwards� into unrestrained liberty. They tend, rather, to collapse �inwards� into a state of authoritarian democracy, which can be maintained precisely because the restraints and disciplines of totalitarianism have already been deeply internalised during long periods of terror, tyranny and cruelty.
If we were more familiar with our own history this pattern would not be so surprising. For, as I have tried to emphasise already, our own history is deeply marked by cruelty and repression, and by the use of religious terror as a means of enforcing social and ideological conformity. That is why we should pause before celebrating the �freedom� we now enjoy. For to a very large extent the history of that freedom is a history of internalised repression.
In this respect the battle which has taken place over The Satanic Verses is itself very revealing. In theory � in the theory, that is, of the liberal intellectuals who are most involved in the controversy � the battle is one between rigidity and religious authoritarianism on the one side and tolerance, flexibility and democratic freedom on the other. The question which must be asked, however, is whether that theory will stand up if we test it against the reality of what actually happened in the year which immediately followed Khomeini�s death-threat. I do not believe that it will. Moreover, I believe that the more searchingly the question is asked, the more we are likely to find that the account which I have already given of our own conscience-centred �cultural revolution� can be used to throw a disquieting light on the affair in general and on the ethos of liberalism in particular.
In the first place it must be conceded that Rushdie affair has been the occasion of a great deal of authoritarianism as well as much rigidity and intolerance. Anyone who ever doubted that great religions have been among the most significant begetters of authoritarianism, and that they can encourage others to behave with cruel and murderous rigidity, should have had their doubts laid to rest by the way in which the most extreme Islamic fundamentalists � and above all the Ayatollah Khomeini himself � reacted to the publication of The Satanic Verses. But it would be quite wrong to suggest that Islam has been alone in displaying rigidity and intolerance. One of the earliest campaigners against The Satanic Verses, Dr Hesham El-Essawy, first voiced his objections to the book shortly after it was published in September 1988. As chairman of the Islamic Society for Religious Tolerance, he was subsequently invited by BBC television to take part in a debate with Salman Rushdie about The Satanic Verses. The debate took place on 30 January 1989, some two weeks before the Ayatollah pronounced his death-sentence on Rushdie. Shortly after Khomeini�s threat Dr El-Essawy wrote to Rushdie again. In his open letter, which The Guardian described as �most friendly and respectful�, he recalled their earlier meeting:
It is not very easy for me in a place of relative freedom to write to you in your place of relative captivity, but I must. You will remember that on our train journey back from the BBC debate in Birmingham on January 30, I went to you, extending my hand in peace and asking you to bring this matter to an end by agreeing to a simple erratum for historical and factual mistakes. You refused, saying: �You want me to apologise. I will never apologise. I said what I said and will never stand down.�
The half-apology that you later offered was quickly accepted by this society and myself as a full one � Unfortunately by then it wasn�t my acceptance that mattered �I do not think that it will make you happy to stay where you are and watch people die. I do not think you will be happy to see a crisis of an unprecedented nature.
Your fellow writers, who are supporting you to the last drop of their ink, are making it much more difficult for you to make a brave move. They seem to be driving you into a position of enforced martyrdom. For them, freedom of expression has become a . To them that alone is sacred, but if this crisis has proved anything to us it is the fact that it will never do to divorce what you say from your freedom to say it. Both you and the Imam Khomeini have demonstrated that very adequately. Please do not be tempted to indulge their cause � first take good care of your own.
As the holder of the copyright to The Satanic Verses please put an end to all the suffering. Instruct your publishers here and abroad to stop publishing.
The letter is significant in a number of respects. What is perhaps most interesting is the privileged access it gives us to a meeting which took place well before Khomeini pronounced his death-threat. In this meeting the request for �a simple erratum� which is put to Salman Rushdie seems, with hindsight, a mild and reasonable one. Its mildness should not betray us into thinking that it is made gently. For behind it there is evidently the same kind of iron resolution which has been shown by many Muslims throughout the affair � a rigid determination to preserve the sanctity of the Koran against all insult. But the rigidity is by no means all on one side. For Rushdie�s response is very far from being accommodating or flexible. He does not simply refuse the specific request, he refuses in the most general terms to consider any form of compromise or apology.
In the circumstances such seeming intransigence on Salman Rushdie�s part is perhaps not surprising. For we must bear in mind that, even before the Ayatollah Khomeini issued his death threat, the storm of opposition which had met The Satanic Verses, both in India and in the Muslim communities of Britain, had already placed Rushdie in a uniquely terrible position. Under this kind of stress most people tend to react by clinging desperately to any ideological certainties they may possess and may well behave with a degree of rigidity that is unusual.
Rushdie�s own reaction, then, is not difficult to understand. What is much more difficult to accept is the manner in which some people offered him the support which he needed so badly at the time. For some did this not unconditionally but in such a way that it became almost obligatory for him to maintain the rigidity of his initial response.
This tendency, which is noted by Dr El-Essawy in the words I have quoted above, can be seen clearly in a contribution to the debate made by the author of an editorial which appeared in The Observer, the liberal-left British Sunday newspaper for which Rushdie himself used to write. The editorial appeared on February 19th, 1989 the day after Rushdie had responded to Iranian demands for an apology by issuing a statement profoundly regretting �the distress that publication has caused to sincere followers of Islam�. The Observer argued that �neither Britain nor the author has anything to apologise for�.
Both can, as Rushdie has done, regret the offence caused or the anger stirred, but not the act itself. For the right to perform that act, to create and publish a book, has been fought for too painfully to be tossed aside in the desire for a quieter life. Those who ask that it should be are forgetting their own history � from Socrates to Stalin. Galileo is admired for his intellectual courage, not his retractions before the Inquisition.
In this light the British Government�s response has been cautious and late �
The harsh lesson of the past � a lesson thousands of people have died to defend � is that it never pays to compromise � In the end, Mr Rushdie must have the right to publish his book and the freedom and security to publicise it. He is entitled to nothing less.
It is interesting that a few days later, writing in The Guardian on the same issue, the politician and former Labour party leader Michael Foot different lesson from history. He suggested that the lesson of the past was that endless bloodshed could be avoided only when each side learnt that it must be ready �to abjure absolute victory � The great persisting threat to our world derives from this pursuit of absolute victory. Once it was Hitler�s creed, and once it was Stalin�s � � Michael Foot went on to suggest that the fundamentalist voices who had denounced any move towards detente or rapprochement were �strident, absurd, or indeed wicked�.
Having started from a premise diametrically opposed to that adopted by The Observer, Michael Foot managed to reach, by the end of his article, exactly the same conclusion. There can be no doubt, however, which view of history is the saner of the two on offer. It is most certainly true that there have been moments in history when any compromise would have been wrong. But this does not change the fact that the entire history of successful international diplomacy has been, very largely, a history of compromise. When compromises have been abjured by both sides on principle, the result has in many cases been war � very often a Holy War.
By far the most disturbing feature of the whole Rushdie affair is that the most vocal supporters of The Satanic Verses have, like the author of the Observer editorial, displayed a rigidity which sometimes seems to verge on fanaticism.
As a result the battle over the book at times itself came to resemble a Holy War. On the one hand were zealous Muslims who appeared to have made a fetish of their own sacred scriptures, and on the other hand an informal alliance of liberal intellectuals, journalists and writers who seemed, as Dr El Essawy himself suggests, to have made a festish out of their right to free expression, and were prepared to defend the integrity of a novel�s text with just as much rigour and literalism as some Muslims showed in defending the sanctity of the Koran.
To put the matter in this way is, I believe, to do far more than simply offer an ingenious analogy. For the more closely we examine liberal rhetoric, the more it seems that we are indeed dealing not with a battle between religion and secular liberalism but with a clash between two forms of essentially religious ideology. Indeed, some evidence for this view comes from no other quarter than Salman Rushdie himself, in one of the most interesting of all the contributions which have so far been made to the debate.
On January 22nd 1989, soon after The Satanic Verses had been burnt during public demonstrations in Bradford, The Observer published an article by Rushdie, in which he reflected on the recent events. In the course of this article he suggests quite directly and unequivocally that for him, at least, the art of the novel has been adopted as a substitute for religious faith � a faith which he is, by implication, prepared to defend with all the zeal shown by the Bradford Muslims in defending their faith:
Dr Aaadam Aziz, the patriarch in my novel Midnight�s Children, loses his faith and is left with �a hole inside him, a vacancy in a vital inner chamber�. I, too, possess the same God-shaped hole. Unable to accept the unarguable absolutes of religion, I have tried to fill up the hole with literature. The art of the novel is a thing I cherish as dearly as the bookburners of Bradford value their brand of militant Islam � So the battle over The Satanic Verses is a clash of faiths, in a way �
How fragile civilisation is; how easily, how merrily a book burns! Inside my novel, its characters seek to become fully human by facing up to the great facts of love, death and (with or without God) the life of the soul. Outside it, the forces of inhumanity are on the march. �Battle lines are being drawn up in India today,� one of my characters remarks. �Secular versus religious, the light versus the dark. Better you choose which side you are on.� Now that battle has spread to Britain I can only hope it will not be lost by default. It is time for us to choose.
The notion that the man who loses his religious faith is left with �a God-shaped hole� inside him is one which would, in all probability, strike very few chords among most religious fundamentalists. For traditional religions have not imagined God as existing in some way �inside� the human body or the human imagination. But the notion is supremely fitting to our own post-Puritan, largely agnostic culture. For it describes with considerable poetic force the end result of a cultural process in which the external God of the Bible � or of the Koran � is first internalised in order to become a God-within, and subsequently put to death by the stones of the rationalist consciousness.
In this whole violent process, however, the religious consciousness is not extinguished. It is preserved, as it were as a vacuum, whose zealous emptiness yearns to be filled once again with faith. It is into that zealous emptiness, as Rushdie himself confesses, that he has poured the art of the novel, so that the novel has become his religion, the faith which he is prepared to defend against all who challenge it.
His willingness to defend this faith is expressed in the traditional apocalyptic imagery of all the ancient religions. So familiar are we with this imagery and so dull have become our reactions to it, that the strangeness of what Rushdie is actually proposing in the last paragraph of his Observer article may escape us. We may fail to notice that, like religious leaders of earlier ages, he actually talks in terms of a battle, a Holy War. It is a Holy War to be fought out in terms of the same glib, implacable antitheses which have been encountered in earlier battles, a war between humanity and the forces of inhumanity; between the forces of light and the forces of dark. This, then, is a religious crusade. But it is a religious crusade to end all religious crusades. For this time the forces of light are represented by the troops of secularism, and the goal of their crusade is nothing other than to defeat religion itself. Nor are we allowed to be bystanders at this battle, however bloody it threatens to become. It is, we are told, time to choose.
Once again it is difficult to know just how much responsibility Rushdie himself should be required to bear for his own words. For although these words were written before the Ayatollah Khomeini�s death-threat, they were still written under very severe pressure indeed and show all the signs of great personal stress. But the words nevertheless remain, and the alarming thing is that their rigid crusading zeal has been generally accepted as being entirely compatible with a libertarian philosophy of tolerance and flexibility.
Indeed, if we look away from Rushdie�s own response, to the words of some of those supported him at the time, we will sometimes find even clearer signs of rigour and religious zeal, combined with hints of intolerance for the sincerely held views of others. �Who is this man of God,� asked Leon Wieseltier, during the course of an American writers� rally held after Khomeini�s death-threat had been issued, �who has no mercy in his heart? But then let us be his match, and in the defense of Rushdie, in the defense of the imagination, in the defense of the mind, show no mercy ourselves. Let us be dogmatic about tolerance �� The problem with this statement is that it modulates from an entirely justifiable condemnation of Khomeini�s death-threat into an acceptance of his example as the model according to which the defence of freedom must be conducted. Once again the shadow of the Crusades falls across the twentieth century, and religious rigidity is met with nothing other than religious rigidity.
This same writers� gathering in New York was addressed by some of the country�s best known literary figures, including Susan Sontag, Joan Didion and E. L. Doctorow. But according to one report it was the novelist Norman Mailer who seemed to capture the mood of the writers best. The duty of the novelist, said Mailer, was to engage in speculation:
That is what we are here for � to speculate on human possibilities, to engage in those fantasies, cynicisms, satires, criticisms and explorations of human vanity, desire, and courage, that the blank walls of the mighty corporations like to conceal from us. We are scribblers who like to explore what is left to look at in the interstices. Sometimes we make mistakes and injure innocent victims by our words. Sometimes we get lucky and make people with undue worldly power a bit uncomfortable for a short time. Usually we spend our days injuring each other. We are, after all, a fragile resource, an endangered species. It is not untypical of the weak and endangered to chew each other up a little on the way down. But now the Ayatollah Khomeini has offered us an opportunity to regain our frail religion which happens to be faith in the power of words and our willingness to suffer for them. He awakens us to the great rage we feel when our liberty to say what we wish, wise or foolish, kind or cruel, well-advised or ill-advised, is endangered. We discover that yes, maybe we are willing to suffer for our idea. Maybe we are even willing ultimately, to die for the idea that serious literature, in a world of dwindling certainties and choked-up ecologies, is the absolute we must defend.
Mailer�s words have a certain power. In them once again we are brought face to face with the fundamentally religious consciousness of the modern novelist. Indeed, what Mailer pronounces is nothing other than a creed. It is a creed written for a church whose members are so individualistic, so locked into their own creative consciousnesses that they rarely meet. But it is a creed which, given all the usual agnostic qualifications, they mostly share, and which, given the provocation of a seeming Antichrist who is most certainly a heathen, they are prepared, silently, to recite together. What is perhaps most alarming is that, in this creed, literature, which might best be seen as providing a haven from the vast and relentless absolutes of religion, has suddenly itself become a vast absolute, whose perfection and sanctity must be defended against all those who threaten it.
Yet again the shadow of the Crusades falls across the twentieth century. And lest we should mistake its outline Mailer was soon reminding both his fellow writers and the world�s media of the hugeness of his religious passion. For, if Salman Rushdie were to be killed, he later told a news reporter, we must, each of us, be prepared to step into his shoes and be killed in his place. Only in this way could serious literature be protected, along with that freedom of expression which is the democratic right of all.
Literature, then, was not simply an absolute. It was an absolute which was to be defended in the same way that the most precious absolutes of the West have always been defended � by the creation of a cult of martyrs.
All this religious imagery and passion should make us pause. Nor should we make the mistake of assuming that the imagery is merely fortuitous � that it has simply been improvised hastily from the materials which are nearest to hand. For the story which it tells is one that goes deep into the history of Judaeo-Christian culture. Behind all this imagery, and the unmistakably religious zeal which accompanies it, there is to be found nothing other than that profound internalisation of the religious consciousness which lies at the heart of our own continuing cultural revolution.
For the religion of Norman Mailer is not a distinctively modern religion. It is a religion whose ancestry can be traced back in a direct line to the religion of John Milton, and to Milton�s idealisation of the writer�s conscience as an authority more sacred than that of the holy scriptures themselves. This view of the writer had itself grown out of the central tradition of Protestant thought. It was, in effect, the cultural corollary of Luther�s rebellion against the Papacy. For where Luther had placed all his confidence in the ability of the individual Christian to interpret the Word of God, later Christian writers began to see it as their duty to heed the divine conscience within them.
Milton himself, of course, wrote quite unashamedly from within a Christian, Puritan tradition. His Paradise Lost was, in one sense, nothing other than a subjective redaction of scripture � a poetic version of his own personal �Bible-within�. Nor was this kind of literature exceptional. Indeed, the vast majority of English literature of the seventeenth and eighteenth centuries is profoundly Christian not simply by default but by passionate intent. This applies not onlt to those who were, like Milton on Samuel Richardson, Puritans themselves, but also to a whole host of other writers including the latitudinarian Fielding and the Anglican Swift � whose Gulliver�s Travels is not, as many assume, an exercise in sceptical agnosticism, but an exposition of the Christian doctrine of Original Sin so impeccably orthodox that it is now completely mysterious to the majority of modern literary critics, and, it need hardly be said, to practically all contemporary Anglican divines.
The consciously Christian character of most �serious� English literature was maintained, more or less, throughout a very large part of the nineteenth century. But the more the novel became established as the main vehicle of the internalised Christian � or Jewish � conscience, and the main seminary of �internalised theology�, the more confidently novelists began to seek to subvert old orthodoxies, to play with the god-like character of the novelist�s own fabulous creative powers and to transgress, through their fictional personae at least, old moralities.
As our own century has progressed this agnostic, experimental character of the novel has become so pronounced as to be almost tiresome. Not only this, but a restless and shallow critical concentration on the novelist�s transgressions has tended to obscure what exactly it is the novelist is seeking to transgress. This is not, ultimately, the tyranny exercised over the imagination by narrative form or structure; it is the much older and narrower tyranny of Judaeo-Christian ideology and morality.
For this was the terrible burdensome clutch of luggage which the Puritan novelist started out with in the eighteenth century, at the beginning of his Pilgrim�s Progress. Throughout the eighteenth, nineteenth and twentieth centuries, from the time of Sterne to the time of James Joyce and D. H. Lawrence, repeated attempts have been made to unpack this luggage or to throw it overboard altogether. But the attempts have failed and, as the tradition of the novel has become more complex, the moral burdens carried by contemporary novelists have become, if anything, even more weighty and more cumbersome. Whether we look to the novels of Samuel Beckett or William Golding, of Norman Mailer or Philip Roth, of Malcolm Bradbury or Iris Murdoch, of Margaret Attwood or Jeanette Winterson, of Ian McEwan or of Salman Rushdie himself, it is almost impossible not to perceive, beneath the playful or erotic or cynical or experimental surface of their fiction, the huge burden of moral earnestness which contemporary novelists continue to carry.
Although the internalised Christian conscience of the eighteenth century novelist has, in the centuries which have elapsed since, undergone a process of radical secularisation, it remains fundamentally Puritan in its form and is possessed of all the rigour and the implacable literalism which we associate with the most zealous forms of Christianity. So long as the faith of contemporary novelists in the redeeming power of serious literature is allowed to develop unchallenged, then this religious zeal is almost completely invisible. But if this faith comes under serious attack, or if the sanctity or integrity of its secularised scriptures is threatened, then the seemingly quiescent church recovers its internalised religious wrath and becomes what it has always been � a Church Militant, which is prepared to fight and even to die for its beliefs, and to campaign with implacable defiance for its right to express these beliefs without restriction, however hard and narrow they may be, however much hurt they may cause to the sensitivities of others.
This, I believe, is what has happened over the case of The Satanic Verses. For the furore which it has caused is not a simple battle between fundamentalism and freedom. It is a battle between two factions of the same religious tradition � the Judaeo-Christian tradition to which, ultimately, Islam itself belongs. It is a clash not between religious authoritarianism and freedom but between two kinds of rigidity, two forms of fundamentalism.
In this battle what the most extreme liberals are really advocating, whether by intention or by default, is not, after all, any principle of freedom or tolerance. What they are defending ultimately is the right � or the duty � which has always been most sacred to our intolerantly monotheistic religious culture. It is the right to proclaim the superiority of their own revelation, and to abuse the gods who are worshipped by other, supposedly inferior cultures. For since, as I have tried to show, Christian and post-Christian rationalism is itself a profoundly blasphemous religion, impervious because of its own narrow rigour to the blasphemous insults of others, hard-line liberals who campaign for completely unfettered rights to blaspheme are in effect campaigning for the right to offend the members of other cultures by abusing their religion. This, unwrapped from the scrolls of commentary which have already been written on the Satanic Verses affair, is the real principle which is at stake. And it really is high time that it was so unwrapped. For we can then decide whether this principle � which is a principle of intolerance � is indeed one we wish to go to war in order to defend.
One of the problems which has faced us throughout this whole controversy is that this substantive issue of doctrine has tended to be concealed behind a secondary debate which concerns the authority of the individual conscience. Because, historically, our culture has sought to extend to the dictates of the individual conscience � and particularly the conscience of artists and intellectuals � the same kind of inviolable sanctity which was originally enjoyed only by the holy scriptures, there has been a tendency to divorce the issue of freedom of expression from any moral question about what is being expressed.
It should be noted that, to the extent to which they take this view, liberal intellectuals are actually transferring to the question of the artist�s right to free expression the same kind of rigour and the same blind zeal that the most militant kind of religious fundamentalists bring to the exposition of their own holy scriptures. For the religious fundamentalist does not pause at the end of every verse of the sacred book in order to debate whether God was right or wrong, too lenient or too cruel, or whether a particular injunction should be accepted or rejected. He does not do so because, enjoying as he does the rich luxury of faith, he has long ago been able to pass the painful burden of his moral conscience into the safe-keeping of the God he worships. Having thus entirely surrendered his moral conscience, he is free to defend the sanctity of his holy book with a zeal which is undiminished by any direct responsibility for what it actually says.
Authoritarian liberals, it must be observed, do something very similar. For although they have given up the luxury of faith they have failed to recognise that such loss of faith brings with it the very kind of burdensome moral responsibilities which fundamentalists have fled from throughout the centuries. They have failed to recognise, in other words, that in a godless liberal democracy a novelist�s freedom of expression cannot ultimately be divorced from the moral and political implications of what he or she actually says. Instead, liberal intellectuals have gone on applying to the �bible-within� of the individual conscience, and to the redaction of that bible in the form of the modern novel, exactly the same habit of mind as our Puritan forbears applied to the Bible. Surrendering their own moral conscience to an abstract faith in freedom, they have defended the textual integrity of all novels with the same kind of blind zeal which Puritans once brought to their defence of the scriptures. The proposition that certain portions of a novel are deeply offensive to a particular religious group and should be retracted enrages these liberals just as much as a proposal to delete certain portions of the gospels would have enraged seventeenth century Puritans, or a request for a ban on certain parts of the Koran would enrage the true followers of Islam.
The hazards of such a position should be clear enough. Indeed this new form of fundamentalism-without-faith is ultimately far more dangerous than any form of religious fundamentalism. Extreme liberals, of course, are not so naive as to agree in advance that they will submit to any laws artists may propose, or even agree with any opinions they may express. But, misquoting Voltaire, liberals frequently do undertake to fight to the death to defend artists� rights to express any opinions they may choose to. The problem with this position, if maintained consistently, is that it leads directly, by unstoppable logic, into a completely amoral universe. It is a universe in which the novelist�s right to advocate torture, rape, murder and genocide must be defended just as resolutely and as zealously as the right to advocate liberty and laughter, and to celebrate affection and sexual love.
Extreme liberals have long been aware of this objection to their position and tend to react by shifting uneasily, like a policeman, from one foot of their argument, which advocates absolute freedom of expression, to the other, which advocates merely freedom within the law. They have also shown a tendency, having noisily driven traditional religious faith out of their house through the front-door, to re-admit it silently through the back-door in some secular disguise. They thus frequently attempt to resolve the dubiety of their position by taking refuge in the belief that art is in itself morally good � or at least that it is more good than bad. But a blind faith in the absolute or approximate goodness of art is ultimately no less dangerous than a blind faith in the moral goodness of God. The danger of traditional god-centred faith is precisely that the goodness of God, once established as a moral fact, may be used to justify all manner of cruelty and oppression. Exactly the same danger attaches to any belief in the moral goodness of art. For societies tend to get the kind of artists they deserve, and a cruel and narrow society is likely to breed cruel and narrow artists. Indeed, in our own secularised and agnostic culture the greatest threat to humane values seems increasingly likely to come not from murderous faith, as it has done for many centuries, but from murderous art.
It is because we need to guard against this ever present danger that any tendency to divorce the artist�s freedom of expression from what the artist actually says should be resisted.
To take this position does not mean that we should meekly submit to any form of censorship which governments care to impose upon us, or that we should defer automatically to any pressure group or religious group which takes issue with something that a novelist � or anybody else � has said. What it does mean is that we should stop propounding liberal myths and acknowledge quite openly that absolute free speech does not exist, either in this society, or in any other.
In every Western country both artistic expression and every other form of public utterance are constrained not only by the rule of law but also by internalised standards of decency, tact and morality. By their very nature artists will frequently wish to challenge both these forms of restraint. For one of the most vital tasks which faces all artists is not that of defending a vast area of freedom which we already possess. It is that of repossessing the vast areas of the imagination and of society itself which have already been annexed by the forces of repression. Because the human imagination can never be ultimately confined, artists will always be free to join the forces of subversion in order to engage in such raids on the occupied territories of the mind. But with this freedom comes responsibility.
The greatest responsibility which all artists must bear is that of discriminating between those restraints which are narrow, cruel or repressive, and against which the human imagination should rebel, and those restraints which are necessary for the preservation of tolerance and human decency. The great danger for all artists is exactly the same danger which faces those who would engage in political subversion � it is the danger of enrolling in revolutionary causes, or armies of liberation, which, because of the narrow rigour of their own militant ideals, are set upon a course which can only end by strengthening the forces of repression they set out to overthrow. It is against this danger that we should be eternally vigilant. Above all we should never encourage either artists or publishers in the belief that they may escape their civic, moral and political responsibilities simply by waving the flag of �democracy� or �free expression�. Perhaps more importantly still, no publishers should ever believe, or be put under pressure to believe, that they have an absolute obligation to publish a particular work simply in order to uphold some abstract �freedom to publish�. For one of the most precious components of the democratic freedom to publish is the freedom not to publish a particular work. In any society where tyrants and torturers press for a platform for their views, this freedom is zealously guarded by those publishers who possess it. Because neither art nor artists are immune from narrowness and cruelty, or from dangerous political misjudgments, we should guard it just as zealously in our own society.
So far as the role of the law is concerned, a different set of considerations applies. One of the main purposes of the laws which constrain freedom of expression is to maintain public order. In theory at least the laws achieve this end by restraining provocative and insulting behaviour, and discouraging those who have legitimate grievances from having recourse to violence by allowing them recourse to the courts.
The rationale for laws which restrain free speech on these grounds stretches back to the middle ages. By the seventeenth century it had been clearly articulated throughout most of Europe and therefore, by extension, in the territories which Europe had colonised, including America. This being so it might well be suggested that there are extremely strong historical arguments in favour of legislation outlawing the deliberate vilification of other people�s religious beliefs. In fact, however, as should by now be apparent, any such legislation could not but run counter to the conception of freedom which had grown up in all Christian countries, and which has been particularly strong in Protestant nations. For centuries, indeed, the answer to anyone who might have contemplated this reform was stark and simple; to enact such legislation would be to elevate the laws of men over the laws of God, and to do so in a way which was not simply unchristian but anti-Christian.
For the Bible itself implicitly makes the vilification of non-Christian faiths into a sacred right. So long as the Bible�s authority remained paramount in Christian Europe, and so long as literalist or fundamentalist interpretations of it prevailed, any attempt to reform the law along pluralist or multi-culturalist lines remained unthinkable. While protection against religious abuse was treated as an inalienable human right for Christians, the notion that this right should be extended to Jews, Muslims, unbelievers or, in extreme Protestant countries, Catholics, would have been profoundly heretical. To take away the right of Christians to anathematise Jews as �sons of the Devil� would have been to proscribe the words of Jesus himself. To deny to an extreme Protestant his right to vilify the Roman Catholic church as a prostitute � the Whore of Babylon � would have been to undermine the authority of the Scriptures. There are, indeed, some enclaves of extreme Protestantism � in Northern Ireland for example � where the right to vilify Roman Catholicism is still regarded as one of the most sacred civil liberties, even though it may run counter to the law.
Far from being challenged by John Milton in Areopagitica or John Locke in his Letters on Toleration this narrow conception of freedom was maintained, and in both Britain and America almost all �libertarian� theory remained profoundly authoritarian and anti-Catholic throughout the seventeenth and eighteeenth centuries. In the nineteenth century John Stuart Mill � who of all Anglo-Saxon philosophers of liberty is the most interesting, the most perceptive and the most profound � repudiated this view. But it is significant that he did so only in a footnote and that throughout his On Liberty he shows no awareness of the cultural forces which were massed behind the older, essentially Protestant conception of freedom. For at the heart of Mill�s philosophy is a species of rationalism not totally dissimilar from that of Marx, in which he looks forward optimistically to a social order without oppression or dogmatism, wrought out of reason, co-operation and consensus. Mill, no less than Marx, remains innocently unaware of the huge destructive forces locked up within Judaeo-Christian history. The almost complete breakdown of the historical consciousness, which is one of the most pervasive features of modern Christian and post-Christian cultures, runs like a subterranean fault-line through his entire argument.
In their different ways, liberals and Marxists clung to the humanist optimism of the Enlightenment and to nineteenth-century notions of progress. They continued to look forward to a Utopia in which a rational and reformed human nature would emerge from the chrysalis of history and triumph over poverty, hardship and oppression. In this world-which-was-to-come there would be no need for extensive laws to curtail individual liberty. The object of all true reformers, indeed, was to sweep away excessive legislation so that the spirit of truth, reason and justice could develop out of free debate and free discussion untrammelled by restrictions.
It was Auschwitz in particular, and the Second World War in general which woke the West from out of its Enlightenment dream. Faced with the fact that it had been possible for an anti-semitic political party to gain power within a democratic state, and to gain popularity and votes by inciting hatred against a racial minority, almost all legislators and politicians were forced to weigh more carefully the benefits of free speech against its apparent costs. At the international level one of the results of this process was the drafting of the International Covenant on Civil and Political Rights. The crucial item relating to free speech is Article 19, which upholds the right to free expression. The same article goes on to specify, however, that this right �carries with it special duties and responsibilities�. Article 20 specifies some of these restrictions:
(1) Any propaganda for war shall be prohibited by law.
(2) Any advocacy of national, racial or religious hatred that constitutes incitement to discrimination, hostility or violence shall be prohibited by law.
Given its own traumatic historical experience it is perhaps not surprising that Germany was one of the first countries to embody such principles in its laws. Although the right to free speech is guaranteed to all German citizens under Article 5 of the Basic Law (Grundgesetz), this right is limited by other basic rights, and in particular by Article 1, which holds that the dignity of man shall be �inviolable�.
Whereas the supremacy of the First Amendment in the United States has the effect of granting Americans a theoretical right to engage in racial abuse of all kinds, the importance accorded to Article 1 in Germany has been used to underwrite a series of laws which restrain free speech in the interests of preserving both social harmony and human dignity. These include Section 131 of the Penal Code which outlaws literature glorifying violence or inciting others to racial hatred, and Section 130 which makes it an offence to attack the dignity of other people in any way tending to disturb the peace by provoking hatred against groups in the population, or abusing or ridiculing them. Article 166 gives the same kind of legal protection against abusive attacks on the creeds or doctrines of religious groups and cultural associations.
In theory, at least, then, it would seem that Germany has been successful in escaping from Christian history, and in throwing off the legacy of what I have called the Protestant Inquisition. For its laws clearly seek to meet the needs of a plural culture and to ensure that both racial minorities and �infidels� are treated with respect and not with the contempt inherited both from the Inquisition itself and from Protestant transformations of it.
Other countries in Europe have introduced similar legislative reforms. France fell into line with international law in this respect in 1972. The law of 1 July prohibits incitement to discrimination, hatred, or violence with regard to any person or group on account of race, nationality and religion, and also makes group defamation on racial or religious grounds a crime.
English law went some way towards meeting international requirements with the passing of the Race Relations Act in 1965. This law, after its revision in 1976, made it an offence to publish written matter or make a speech which was threatening, abusive or insulting and likely to stir up hatred against any racial group. As its name suggests, however, the Race Relations Act made no provision against incitement to religious hatred, and the blasphemy laws were left in place.
In the wake of the Rushdie affair a number of humanist and libertarian groups in Britain have called for the abolition of the blasphemy laws without replacement. Other voices have called for the law on incitement to hatred to be brought into line with international law by including religious as well as racial hatred. There is at present, however, no sign that politicians are likely either to abolish the archaic and repressive blasphemy laws or to introduce any new legislation in this area.
In the United States the situation is different again. Although blasphemy laws remain on the statute books of several states, the ever-increasing importance of First Amendment rights to free expression makes it inconceivable that these laws could be invoked successfully. As long ago as 1952 a New York State ban on a supposedly sacrilegious film, The Miracle was unanimously overturned by the supreme court. Justice Tom Clark�s ruling was unequivocal: �It is not the business of government in our nation to suppress real or imagined attacks on a particular religious doctrine, whether they appear in publications, speeches, or motion pictures.�
The effective abolition of the offence of blasphemy in the United States does not in itself, of course, indicate any divergence from international law. But during the period since the Second World War, while most countries in Europe have been edging their laws into a closer fit with the International Covenant on Civil and Political Rights, America has refused to ratify this covenant and has moved steadily in the opposite direction towards a kind of First Amendment fundamentalism. Such fundamentalism was demonstrated clearly in the celebrated � or notorious � Skokie case.
In 1978 members of the American Nazi Party wanted to march through a Jewish community in Illinois, displaying swastikas. The Illinois Supreme Court overturned the decision of an intermediate court to restrict the use of swastikas. It declared that the Nazis� First Amendment rights to free speech were paramount. In the same year a Court of Appeal ruled that an ordinance prohibiting the dissemination of material which promoted racial or religious hatred, was unconstitutional. Once again First Amendment rights were held to be paramount and America moved a step closer to an absolutist conception of free speech. The clear implication of the Supreme Court�s 1978 ruling is that every American citizen enjoys a constitutionally protected right to incite religious or racial hatred.
One of the greatest problems in finding a way out of the vicious circle of the Rushdie affair is that the attitude which I have dubbed �First Amendment fundamentalism� can be found far beyond the shores of America. This is partly because of the cultural hegemony which America has achieved over Europe during the latter part of the twentieth century. But there is also a much simpler reason. For, as I have already pointed out, America�s extreme attitude towards freedom actually had its origins in Europe � in European Protestantism on the one hand and in the secularist ideals of the French Revolution on the other. If libertarian thinkers in Europe have tended to welcome this extreme attitude with open arms in the last forty years or so, it is partly because they are welcoming it home, and partly because it has never been away in the first place.
Some moderate liberals in Europe support laws which seek to restrain the propagation of racial hatred. But extreme libertarians, whether of the left or the right, tend to side with the American Supreme Court and oppose even these restraints on free speech. Any proposal to legislate in the sphere of religion, or to activate �dormant� legislation which already exists, usually evokes an even more hostile reaction. Both in Britain and in Denmark, to cite but two examples, legislation against incitement to hatred does not apply to religious groups. In Denmark Section 266b of the Penal Code makes racial slurs punishable by law. In 1985 this law was even used to prosecute two television journalists for broadcasting racialist insults uttered by a neo-fascist youth group they sought to expose. No action, however, was taken against a member of the right-wing Danish society who sent a letter to all members of Cophenhagen City Council, calling for a �public bloodbath� to stave off the �Mohammedan invasion�. In this case the police refused to prosecute.
According to one report Muslims are the main target of hate-propaganda in Denmark: �And the generalisations do not stop at making all Muslims accomplices in that which an individual Muslim commits. Islam, in its own right, is attacked in racial slurs reminiscent of anti-semitism in the 1930s.� The leader of the populist Progress Party, Mogens Glistrup, has described Muslims as �the arsenic in pure Danish water�. By 1990 the Progress Party, which calls for �a Denmark with no Musselmen� had already gained sixteen parliamentary seats out of 189 and was expected to gain as many as twenty-five in the next election. In order to compete with them at the polls Denmark�s Liberal Party has increasingly resorted to right-wing populism and anti-immigrant propaganda.
It was partly in order to guard against the electoral exploitation of hate-propaganda by political parties that the International Covenant on Civil and Political Rights sought to outlaw all forms of incitement to hatred. The widespread reluctance to legislate against incitement to religious hatred springs from a number of misconceptions and distortions. The first misconception is that there is no real link between racial and religious prejudice. What this view ignores is that modern �racial� anti-semitism is the product of a centuries-old tradition of religious hatred, and that the biological theories of race which were used to rationalise this ancient prejudice at the begining of the twentieth century belong entirely to the realm of pseudo-science.
The second misconception is that passing laws against incitement to religious hatred is the equivalent of extending the laws of blasphemy and that those who advocate such laws are motivated by a desire to privilege religion above other forms of belief. This view too rests on a misunderstanding. The main debate about legislative reform in this area has been prompted by a desire to move away from a theologically inspired framework which once helped sustain a form of tyranny, towards secular legislation which is designed to protect relatively powerless minorities against oppression or abuse by others. Such legislation is motivated not by any desire to afford special protection to religion, but by the recognition that many racial minorities tend to find their group-identity in their religious beliefs rather than in their racial characteristics, and that one of the easiest ways to wound and humiliate them is to subject these beliefs to scurrility, vilification or contempt. The objection to such attacks rests not on religious but on social grounds. The fear is that if they are permitted or encouraged they may lead to embitterment and hatred, and could destroy working relationships between different groups. In those cases where religion and race are intimately bound together they could easily increase racial tension and trigger racial violence.
The third misconception is based on the notion that legislation which outlaws the incitement of religious hatred may ultimately be used by religious groups to suppress any form of criticism which they find offensive. This criticism is clearly valid in the case of laws which have been badly drafted. But most of the existing legislation in this area has been deliberately framed in such a way as to guard against the possibility of religious groups gaining a tyrannical power.
Usually prosecutions for incitement can be initiated only with the authority of the government, so that abuse of the law by the frivolous or the over-sensitive is not possible. At the same time it should be noted that laws against incitement to hatred, whether in the sphere of religion or of race, are designed to �catch� only the most extreme, inflammatory or murderous statements. It is interesting in this respect that many versions of the law against incitement to religious hatred, including the version now in force in Northern Ireland, could almost certainly not be used to bring a successful prosecution against The Satanic Verses.
It is perhaps significant that it would be possible, in theory at least, to bring a prosecution against the German publishers of The Satanic Verses under Section 166 of the German Penal Code. The relevant part of this section reads as follows:
Anyone who, either by making public pronouncements or by disseminating written statements, insults the religious or philosophical beliefs of others in a manner which likely to disturb the peace, is liable to be punished by a custodial sentence of up to three years or by a fine.
To cite this law, however, is not to suggest that it should be invoked. For there is no good reason to believe that the Rushdie affair can or should be resolved by having recourse to this or any other law. Indeed, in the current cultural climate of Europe, attempts to ban Rushdie�s book are likely to be no more helpful than attempts to burn it. This applies with particular force to any attempt to use Section 166 against The Satanic Verses.
To say this is not to reject the rule of law or to suggest that legal action is always ineffective. Without the intervention of the law some disputes would never be resolved. But for laws to work effectively in any democratic society it is almost essential that they should be supported either by a broad consensus of public opinion or by a significant number of respected intellectuals, writers, journalists, politicians and other public figures.
Section 166 of the German Penal Code appears not to enjoy such support. Indeed it runs counter to beliefs about free expression which are held strongly and passionately by a large number of German citizens. Moreover, many of the specific objections which have been made to this law seem well-founded. Unlike most laws against incitement to religious hatred, Section 166 is loosely drafted, and seems particularly susceptible to tyrannical applications. In 1984 the law was used to prosecute Birgit Romermann. Her �crime� was that, having referred in a pamphlet to the involvement of the Christian church in witch-hunts, genocide, religious wars, crusades, the persecution of the Jews, the blessing of weapons and the condemnation of desire, she described the church as �the greatest criminal organisation in the history of the world� Because of this statement she was sentenced to a fine or twenty days in prison.
It would seem that the most significant effect of this deeply repressive and clumsy prosecution, and of a number of other actions which have been taken under Section 166, has been to permanently discredit this part of the Penal Code, and to engender bitterness and resentment among countless intellectuals. Such intellectuals, whose case has been forcefully put by the Freiburg lawyer, Gottfried Niemietz, have been given extremely good grounds for claiming that Section 166 is merely the 1871 blasphemy law in disguise, and that it has been used to silence entirely legitimate criticism of the church.
If the same law were to be used in order to bring a successful prosecution against the German publishers of The Satanic Verses, the result would almost certainly be seen as a triumph for the forces of repression and reaction, and yet more bitterness and resentment would be created.
Indeed, so long as the current cultural climate lasts, not just in Germany, but throughout Europe and America, legal action with regard to The Satanic Verses would be almost certain to deepen the conflict rather than resolve it.
The conclusion we should perhaps draw from this is that the reaction of European legislators to the trauma of the Second World War was noble and well-intentioned, but ultimately insufficient. Legislation may help to preserve a tolerant society. But it cannot in itself create one. The narrow and intolerant conception of freedom which we inherited from our own fundamentalist revolution (and from the Protestant Inquisition) is with us still. We can never move away from that conception of freedom without legislative reform. But a society cannot legislate against its own central orthodoxies and expect them simply to wither away. If we are indeed serious in our commitment to tolerance and sensitivity then what is needed is not simply more or better legislation, but a huge shift in some of our most basic cultural and intellectual attitudes. For any legislative reform which is not accompanied by widespread understanding of, and support for, its objectives, and by a profound increase in public awareness of the problems posed by religious and racial vilification, is unlikely to be effective. If we cannot systematically rethink all of our most fundamental beliefs about freedom and free speech, and effectively dismantle some of our most ancient cultural orthodoxies, then tinkering with the law will do little good.
The task of cultural reorientation is a huge one and in the current state of informed opinion there is no realistic prospect of any such reorientation taking place. For this reason, and for many others, it seems clear that the problem which faces us still over the troubled and terrible issue of The Satanic Verses, cannot be solved by the law. Perhaps, indeed, like most disputes between neighbours, it will be resolved more speedily if both sides forget about the possibility of legal redress, and spend a little more time considering each other�s point of view.
This version of Chapter 2 of A Brief History of Blasphemy: Liberalism, Censorship and the Satanic Verses, is based on the revised text prepared for the German translation, Erben des Hasses, Die Rushdie-Aff�re und ihre Folgen, Knesebeck, 1992
 George Orwell, �Politics vs Literature� (1946), in Inside the Whale and Other Essays, Penguin, 1962. Of Swift�s Houyhnhnms, Orwell writes: �They had reached, in fact, the highest stage of totalitarian organisation when conformity has become so general that there is no need for a police force.� p. 133
 cited in Lisa Appignanesi and Sara Maitland (ed.), The Rushdie File, Fourth Estate, 1989, p. 152
 ibid p 122
 ibid p 244
 ibid p 75. [Note added June 2002] As I observe in my review of Rushdie�s Imaginary Homelands, this article was silently omitted from his subsequent collection of reviews and articles.
 ibid p 178
 ibid pp 174-5
 Incitement to religious hatred is an offence in Northern Ireland, but not in the rest of the United Kingdom. See below, notes 10 and 17.
 John Stuart Mill, On Liberty, (1859). See footnote to Chapter 2, Penguin edition, 1985, pp 92-3
 Simon Lee, The Cost of Free Speech, Faber, 1990, pp 73-105 [Note added June 2002] In the aftermath of the events of 11 September, and in order to protect Muslims against intensified hostility, the British government attempted to introduce a law against incitement to religious hatred. The rationale of this law was widely misunderstood and its progress through parliament was eventually blocked. The attempt to include this measure in legislation relating to terrorism was finally abandoned by the government in December 2002. For a commentary on the misinformed reaction to this bill see the column by Guardian home affairs editor Alan Travis.
 quoted in Malise Ruthven, A Satanic Affair, Revised Edition, Hogarth, 1991, p. 50
 Lee. op cit, p 41
 Eric Barendt, Freedom of Speech, Clarendon Press, Oxford, 1987, p 167
 Bashy Quraishy and Tim O'Connor, �Denmark: No Racism by Definition� in Race and Class, Vol 32, Number 3, January-March 1991 pp 114-119
 For a fuller discussion of the debate in Britain, see Law, Blasphemy and the Multi-Faith Society, Commission for Racial Equality, London, 1990. See also Simon Lee, op cit, and the original English version of my book, A Brief History of Blasphemy: Liberalism, Censorship and 'The Satanic Verses', The Orwell Press, 1990, pp 63-67.
 �Wer �ffentlich oder durch Verbreiten von Schriften den Inhalt des religiosen oder weltanschaulichen Bekentnisses anderer in einer Weise beschimpft, die geeignet ist, den �ffentlichen Frieden zu st�ren, wird mit Freiheitsstrafe bis zu drei Jahren oder mit Geldstrafe bestraft.�
 Gottfried Niemietz, �The Middle Ages are Alive�, American Atheist, March 1989. See also Karlheinz Deschner, Die Beleidigte Kirche, Ahrimann-Verlag, Freiburg, 1986.
� Richard Webster, 2002