Differing laws that regulate world's media: Legal restrictions on the press abroad include the right to reply and privacy legislation. Kathy Marks reports

A FEW months ago the Belgian current affairs magazine Knack published an article on a far right- wing Flemish party, Vlaams Blok, which included potted biographies of 20 of its leading members.

The magazine received demands for a right of reply from every person featured. Under Belgian law, which guarantees that right, it was obliged to comply. About half of the replies were published; seven court cases are pending against Knack in relation to the rest.

To Rik van Cauwerlaert, a reporter with the magazine, the situation sums up the difficulties of right to reply legislation. In Belgium, the law is particularly rigid; anyone mentioned by name in the press or broadcasting media can seek redress, even if the context is not obviously derogatory. They can also seek damages through the courts. Defamation laws are strict, although damages often amount to no more than a symbolic franc and publication of the judgment. Privacy laws, which prevent bugging and paparazzi-style long-lens photography, have recently been tightened.

Similar legislation is in force in France, where strict privacy laws enabled the Duchess of York to win substantial damages from the photographer who took explicit photographs of her with an American friend at a villa in the south of France. The right of reply entitlement, though less rigid than Belgium's, has brought similar problems. The respected daily newspaper, Le Monde, has given up all mention of a revisionist historian who has had so many replies published that the situation became absurd. 'You can call it censorship, but it is not good for our readers to get the impression of a permanent confrontation between one man and the newspaper,' Manuel Lucbert, a director of Le Monde, said.

On the Continent, the greatest degree of press freedom is enjoyed in the Netherlands and Scandinavian countries, which have minimal restrictions and freedom of information acts. Constitutional protection of the press dates from 1814 in Norway.

In Germany, a free press is constitutionally guaranteed and there is additional protection at regional level. Journalists' sources are protected and prior restraint is used only in exceptional circumstances. There is no freedom of information legislation, but the level of open government is similar to that in Washington.

Josef Joffe, a leader writer with the Munich-based Sueddeutsche Zeitung, said that although libel laws were strict, with the burden of proof on the defendant, fines were moderate.

A right of reply exists in Germany and is frequently used by ordinary citizens, less so by public figures. It is a criminal offence to publish photographs of private individuals without permission.

In the United States, the First Amendment guarantees freedom of speech, while freedom of information legislation guarantees access to most government files. Journalists can be subpoenaed to reveal sources and may be forced to claim the Fifth Amendment.

The libel laws are much less strict than in Britain, with complainants obliged to prove that the offending lines are not only false, but written wilfully and maliciously. The level of damages, however, for successful litigants is potentially massive.

Former Commonwealth countries such as Australia operate systems similar to the British - with parliamentary privilege, tough defamation laws and a self-regulatory press council - but have the advantage of freedom of information legislation.

In Australia, unauthorised bugging of private conversations is illegal. Publication of transcripts of such conversations is also prohibited, but has never been tested in the courts. 'I can't see New Idea getting into trouble over the Camillagate transcript,' Dinoo Kelleghan of the newspaper, the Australian, said.

Around the world, the press operates under the most restrictions in Africa, the Middle East and Communist countries such as Cuba, Vietnam and North Korea. The situation in Africa has improved in recent years. Press curbs were lifted in Kenya about a year ago and in Zambia about two years ago.