Зарубежный опыт правового обеспечения защиты чести, достоинства и деловой репутации

Abstract

The article examines the concept and development of legal relations in the field of the protection of honor, dignity, and business reputation in foreign legislation, where they are part of the legal institution of defamation. The research involved the formal-legal and comparative-legal techniques based on the principles of historicism and objectivity. The article features a retrospective summary of theoretical, normative, and practical approaches to the conceptual application of the institute of defamation in the countries of the Anglo-Saxon and continental law. The Anglo-American defamation law is formed both within the general and statutory framework. Special legislative acts of the United Kingdom define the conditions (criteria) for classifying these legal relations as essentially defamatory. The peculiarities of the continental defamation law can be attributed to its mainly criminal-legal regulatory component, rather than civil or administrative law. The comparative legal review of the foreign experience of legal support for the protection of honor, dignity, and business reputation proved relevant and practically significant.