Countries navigate the problem of disinformation in various ways. In Brazil, the Brazilian Criminal Code contains three provisions dealing with an attack on a person’s “honor,” 32 but no current law specifically addresses disinformation. As of the writing of this paper, however, Brazilian Congressional Bill No. 2630, the Law on Freedom, Responsibility and Transparency on the Internet, is pending before Congress, already having been approved by the Senate. 33 Although Nepal does not have a specific law addressing information integrity, the Libel and Slander Act, 2016, grants people the right “generally to maintain their prestige, honor and dignity;”34 the Electronic Transactions Act, 2063 (2008) prohibits the publication of material in electronic form “which may be contrary to the public morality or decent behavior or any types of materials which may spread hate or jealousy against anyone or which may jeopardize the harmonious relations subsisting among the peoples of various castes, tribes and communities;” 35 and the Election Commission Nepal (ECN) Code of Conduct prohibits the transmission of “disinformation, misinformation and hate speech in social networks.” 36 In Kenya, several articles of the Kenyan Constitution address freedom of expression and its limitations, and certain sections of the Computer Misuse and Cybercrimes Act make the publication of false information a crime. 37 In Nigeria, a section of the Criminal Code addresses the publication of false news, including in instances when the person disseminating the news does not know it is false. 38 Furthermore, Nigeria’s proposed Hate Speech Bill (which, after sustained public backlash, did not pass) would have criminalized any actions a person took to stir up ethnic hatred, engage in ethnic harassment, or discriminate. 39 Such broad language would have granted the government arbitrary power to clamp down on free speech, including “critical opinion, satire, public dialogue and political commentary” – a serious problem, especially during election periods. 40 Supreme/apex courts often must determine whether newly introduced legislation regarding information around elections aligns with constitutional provisions by following their jurisdiction’s appropriate test for limiting free speech. Recently, supreme and constitutional courts globally have struck down a variety of “false information” The three provisions include 1) slander, or the false imputation of a crime to another person (Article 138); 2) defamation, or the imputation of something offensive to a person’s social reputation (Article 139); and 3) injury, or imputation of something offensive to someone’s dignity. Brazil Media Law Guide (n.d.) Defamation, Privacy and Data Protection Law in Brazil. Carter-Ruck. 33 The bill itself is quite controversial, with no guarantee of becoming law. Often referred to as the “Fake News Bill” by its supporters and the “Censorship Bill” by its opponents, it would require technology companies and social media platforms to be much more transparent with their users about their content recommendations and take on more responsibility for third-party content being displayed on their platforms. See Martins, L., and Spagnuolo, S. (2023, April 28). A General Review on the Brazilian Congress Bill Regarding Fake News. Núcleo.; Al Jazeera. (2023, May 2). “Brazil’s ‘fake news’ bill sparks outcry from tech giants.” 34 Libel and Slander Act, Preamble, 2016 (1959) (Nep.). 35 The Electronic Transactions Act, 2063 Sec. 47 (2008) (Nep.). Such illegal conduct is punishable by a fine or imprisonment or both. Critics of Nepal’s disinformation policies claim this provision does not do enough to combat disinformation. See also Shrestha, P. (2023, February 19). “No policy to counter disinformation.” The Kathmandu Post. 36 The Election Code of Conduct, Para. 4j (2022) (Nep.) 37 The Computer Misuse and Cybercrimes Act, Para. 22 (2018) (Ken.) 38 Criminal Code, Sec. 59 (1990). Under this provision, a person found guilty of disseminating false news is guilty of a misdemeanor, punishable by up to three years’ imprisonment. Not knowing the information is false is not a defense unless the accused can show that they took reasonable measures to verify the information before publishing. 39 A Bill for an Act to Provide for the Prohibition of Hate Speeches and for Other Related Matters. (Nig.). Under the proposed bill, any person could file a written complaint with the Independent National Commission for the Prohibition of Hate Speeches, which could lead to conciliation or a hearing (or a dismissal, if the Commission determined the complaint to be lacking). The Hate Speech Bill was eventually dropped after intense public backlash. See Opejobi, S. (2019, December 4). "We won’t pass hate speech bill – Senate President, Ahmed Lawan." Daily Post. 40 Amnesty International (2019, December 4). Nigeria: Bills on hate speech and social media are dangerous attacks on freedom of expression - Amnesty International. See also Okegbile, J. (2023, July 18). Nigeria: Revisiting Nigeria’s Legal Framework On Hate Speech And Fake News Post 2023 General Elections. Mondaq. In recent years, Nigeria has grappled with the issue of hate speech and fake news, particularly in the context of elections. “The use of certain ‘foul’ and ‘hateful’ language and strategic misinformation can be highly divisive and can fuel violence, leading to significant harm to individuals, communities, and the country as a whole.” 32 11