Defamation in foreign countries on the example of the criminal legislation of Russia, Sweden and the Republic of Korea

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Purpose: The article describes the foreign legislation in the field of criminal law protection from defamation. Methodology: Were used in article theoretical - applied, system, comparative legal methods. Results: On the basis of a comprehensive study, it was concluded that the concept of «defamation» should be introduced into the Criminal Code of the Russian Federation and that norms and its components should be placed in a separate chapter. Novelty/originality/value: The value of the article is that the conclusions and recommendations made in it are based on the analysis of foreign legislation and are the basis for improving the Criminal Code of the Russian Federation. They can also be the subject of scientific discussions. In addition, the issues raised in the article will contribute to a unified practice of applying the norms analyzed in it.


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