This piece appeared in the 2017 Acheson Prize Issue of the Yale Review for International Studies.
Singapore frequently comes under criticism from the international community for its violations of the Universal Declaration of Human Rights (UDHR), particularly Article Nineteen, which states that “Everyone has the right to freedom of opinion and expression; this right includes freedom to hold opinions without interference and to seek, receive and impart information and ideas through any media and regardless of frontiers.” To justify these violations, Singapore has responded in one of two ways: it argues that either the Declaration allows for states to impose restrictions on the absolute freedom of expression and that Singapore’s actions are an exercise of this provision, or the framework around which the UDHR is built is a Western concept that is inapplicable to governance in Singapore. By analyzing freedom of expression in Singapore regarding topics of race and religion, this essay will examine the applicability of the UDHR and argue that both points of rebuttal are fair; because the UDHR requires a belief in a minimum level of human universality and egalitarianism not yet uniform in the world, there is fair reason to doubt the universality certain articles such as Article Nineteen. This, in turn, questions the legitimacy of international bodies requiring states to conform to these standards universally.
This essay will theoretically evaluate Singapore’s opposition to freedom of expression’s status as a human right against arguments by John Stuart Mill, Jack Donnelly, Michael Ignatieff and Amartya Sen. Section II will first provide a brief background of human rights and clarify which conceptual definition of human rights this essay employs. Section III will evaluate whether Singapore’s interpretation of the freedom of expression article is fair, assuming the legitimacy and binding quality of the UDHR, while sections IV-VI will investigate whether the UDHR in itself should be seen as a set of universal principles binding on all states.
Background to the concept of rights
A right, in the context of this discussion, refers to the entitlement that one has to something, whereby its fulfilment takes priority over the competing needs of other individuals or of society on the whole. To have a human right to something is to claim that one’s status of being a human with intrinsic worth necessarily confers to them certain entitlements, which one can exercise at their will in order to obtain. These human rights exist regardless of whether they are exercised by the individual wielding the right, or if they are respected by the offending authority against which the right is exercised. Human rights can be protected and enforced within communities, organisations, institutions, or the state. However, human rights are essentially extra-legal with regards to a state’s domestic laws: if an individual’s claim to a human right is either violated or not enforced by the laws and customs of the aforementioned different levels of social organisation, the individual can appeal to the international community for the enforcement of their human right, against the legal system of any organisations within the state.
The preamble to the UDHR does not clarify the theoretical origins of human rights. It states that humans are equal in their inherent worth, dignity, and concludes that humans have these inalienable rights without providing a strong explanatory mechanism. The ambiguity of the preamble’s phrasing gives it the potential to be universal, for few societies or cultures around the modern world would deny an innate moral quality of human beings, and similarly few would deny that a human should never be subject to certain forms of abusive treatment. Academic and former Canadian politician Michael Ignatieff problematizes this philosophical shared ground: in light of the history of gross injustices that individuals have been subject to when legally unprotected by their own state, he argues that “People may not agree why we have rights, but they can agree that we need them.” Ignatieff hence takes a historical and pragmatic approach to human rights—even if theoretical justifications for human rights do not sufficiently convince, history makes plain the devastation that follows without them. Ignatieff argues for a minimal set of human rights that are absolutely necessary to protect individuals from abuse at the hands of larger collective groups.
However, one must convincingly defend a theoretical connection between human dignity and human rights in order to understand on what grounds human beings have an inalienable right to all provisions listed in the UDHR rather than just a minimal set of human rights. Jack Donnelly, who has written extensively on human rights theory, sketches the connection in the following manner: all humans have an intrinsic moral worth, and owing to their moral nature, their humanity only flourishes when they live a life of dignity. Thus, humans require a system of rights that ensures humans are never denied their humanity by being forced to live a life without dignity. Because the meaning of living a life with dignity changes depending on developments in the material and political world, human rights similarly contextualize themselves to protect individuals against anything specific to their circumstances that would force them to lead a life without dignity.
Two Southeast Asian leaders, Mahathir Mohamad and Lee Kuan Yew, have decried the imposition of human rights in Asia, claiming that it is a distinctly western concept at odds with Asian values. However, following the logic laid out by Donnelly, and economist and philosopher Amartya Sen argues that human rights cannot possibly be seen as a Western concept inapplicable to non-Western societies, because the respect for human dignity and the values that human rights seek to protect, such as toleration, personal liberty, and civil rights, are not specific to Western civilisation. Instead, Sen views the notion that every human being has inherent worth to be an extremely recent development, arising in the wake of the destruction of World War II, a sentiment Donnelly echoes when he argues that prior to 1948, human dignity was accorded to individuals of a certain identity or status rather than universally. Sen adds that all civilizations, Western and non-Western, have had schools of philosophical thought that promoted or dismissed the values seen in the UDHR. The contents of the UDHR are hence not any more Western than they are non-Western, suggesting that the enforcement of human rights in non-Western states therefore cannot be considered cultural imperialism.
However, Donnelly picks up on the lapse of logic in Sen’s argument when he differentiates societies’ respect for human dignity with that of human rights. Even though all societies and cultures agree that individuals have innate moral worth and that their human dignity should be protected, ensuring and protecting such concepts through a rights system remains an undeniably Western concept. Many ways of protecting the dignity of a human in society exist, and doing so through the idea of rights—a framework of achieving social and political protections that arose in the seventeenth century England—is merely one of them.
The legitimacy of different interpretations of Article Nineteen
One could deliberate on whether Singapore is legally bound by international law to observe all articles of the UDHR, but this is not the intended focus of this essay. The following section will evaluate Singapore’s actions in light of the UDHR, assuming that it accepts and is committed to upholding the UDHR of 1948, or the general concept of human rights.
In International Human Rights, Donnelly maintains that if radical universalism and strong cultural relativism constitute opposing ends of a spectrum along which human morality falls, the UDHR necessarily occupies the gradient between the two. The very notion of human rights mandates an acceptance of some degree of moral universalism, yet “[t]o insist that all human rights be implemented in precisely identical ways in all countries would be wildly unrealistic, if not morally perverse.” Donnelly further divides the “concept” behind an article in human rights from its “implication,” and attributes the universal aspect to the former, while suggesting that one can take a more relativist approach with the latter.
For the most part, the Singapore government often uses the distinction between concept and implication to justify restrictions on the freedom of expression. The Singaporean authorities recognize that international law and the Singapore Constitution protect the freedom of expression of individuals in Singapore’s territory, but they emphasize that this freedom is not absolute. Authorities’ actions correspond to the exemptions to the freedom of expression laid out by the International Covenant on Civil and Political Rights, which states that:
The exercise of the rights provided for in paragraph 2 of this article carries with it special duties and responsibilities. It may therefore be subject to certain restrictions, but these shall only be such as are provided by law and are necessary:
(a) for respect of the rights or reputations of others;
(b) for the protection of national security or of public order, or of public health or morals.
However, these restrictions must meet a strict three-part test approved by the UN Human Rights Committee and the European Court of Human Rights, which states that the freedom of expression can only be curtailed if it is:
a) provided by law;
b) for the purpose of safeguarding a legitimate public interest; and
c) necessary to secure that interest.
Restrictions on the freedom of race and religion-related expression in Singapore are not arbitrary but rather provided for in the Singapore Penal Code, in the Maintenance of Religious Harmony Act as well as a range of other acts that prohibit content circulation of “undesirable content” in the media. Furthermore, Singapore often cites both its history of devastating racial riots and its need to minimize conflict between ethnic groups within its multi-ethnic state as reasons enough to restrict freedom of expression on topics of race and religion. The freedom of expression article hence does not protect individuals who deliver statements or comments that can hurt or incite ill will toward other racial and religious groups. However, critics often point out that at this stage in Singapore’s development, the disorder that may result from ethnic conflict would be unlikely to cause enough economic damage to endanger the livelihood of Singaporeans. In other words, even if economic rights do necessarily precede social and political rights, Singapore has already developed to an extent that social and political rights can be upheld without threatening one’s enjoyment of their right to basic economic and material needs. Furthermore, as John Stuart Mill has also argued, the right to the freedom of expression may be necessary for continued economic prosperity. Even if it contributes to social destabilisation in the short run, an organic and evolutionary development of society can only occur with the free exchange of ideas and sentiments.
However, these critiques demonstrate that the freedom of expression is a means through which continued social and economic stability can be enjoyed. They do not demonstrate the primacy of rights over other concerns, nor do they show that freedom of expression is more important than these common goods. These arguments in fact prove the contrary—as long as Singaporeans and the government regard economic prosperity and social stability as a sufficiently weighty and legitimate public interest, the freedom of expression may be curtailed to attain the greater purpose that it serves. Therefore, while rights are precisely intended to have a ‘trump’ quality over social utility, because provisions make the right to the freedom of expression a prima facie right rather than an absolute one,  it becomes difficult to dismiss the manner in which Singapore has interpreted “implication” from “concept” as wholly illegitimate.
However, if one follows the path taken by philosopher Ronald Dworkin and demands an even more stringent approach to rights, in which rights are entitlements that truly can never be violated unless the exercise of these rights poses a real and imminent threat to other members of the public, many of Singapore’s restrictions on the freedom of expression become even more contentious. In 2015, sixteen-year-old Amos Yee was found guilty of having the “deliberate intent of offending Christianity” and for the “electronic transmission of an obscene image” after uploading a YouTube video of himself drawing offensive analogies between Jesus Christ and the late Prime Minister of Singapore, Lee Kuan Yew. Human rights activists quickly condemned this violation of human rights,,  presumably on the basis that the words of a teenager could not have the ability to offend Christians to the point of violent religious conflict, and that Singapore had gone “beyond recognised constraints” in its limitation of Yee’s freedom of expression. In contrast, the decision made by Times Printers, with the strong support from the Media Development Authority (of Singapore), to pull the controversial image of a Charlie Hebdo cover page from the printed copies of The Economist in Singapore met with little resistance from local or international critics.
These cases run parallel with Mill’s analogy that “an opinion that corn-dealers are starvers of the poor… ought to be unmolested when simply circulated through the press, but may justly incur punishment when delivered orally to an excited mob assembled before the house of a corn-dealer…” In light of the terrorist killings that had just occurred in Paris in response to the drawings, restricting the freedom of expression in favour of public security no longer seemed like a disproportionate response. However, the impossibility for governments to predict or control events that occur as a response to unrestricted speech make it harder to binarize the two situations, especially as governments and societies, rather than human rights critics, possess the responsibility for dealing with the effects of social unrest within a country. There is certainly no clear conclusion on how to determine the likelihood that an exercise of one’s freedom of expression will threaten public safety, but when lives are at stake, it seems judicious for the government to err on the side of caution. Therefore, the exercise of Amos Yee’s freedom of expression to make offensive remarks about Christianity may not have deserved punishment at that point, but may have had vastly different consequences in another context which may not necessarily be easy to predict.
Since it has been demonstrated that the freedom of expression can never be absolute, one could also go further to consider the extent to which a Singaporean must be able to express their views on race and religion in the public sphere for them to enjoy human dignity. If an individual derives human dignity purely from the exercise of one’s free agency, then the enjoyment of human dignity could arise from a person’s ability to express themselves and have those sentiments impact political and civil life. However, this line of argument sees human dignity in purely individualistic terms of a person’s agency, and the connection between human dignity and speech will be changed if an alternate philosophical framework is used. In Confucian thought, for example, a person’s human dignity is recognized when they display Rén, which translates to the concepts of “love,” “humanity,” “benevolence,” “goodness,” etc. This concept of Ren has both an individual and a social aspect to it; a person displays Ren by firstly cultivating their individual personality, and secondly by recognizing a responsibility to others. In this specific understanding of human dignity, an individual then enjoys human dignity through speech or expression not merely as an exercise of their agency, but when their duty toward others is fulfilled. This ‘duty’ may entail many things, including respect for the human dignity of others. While both individualistic and socially-constructed notions of human dignity undergird Singapore’s political and civil spheres, the banning of racist or insensitive speech that questions the dignity of others in society hence remains justifiable. This reasoning may not absolve the Singaporean government from the need to respect freedom of expression, given that the government has committed to upholding human rights, but that justification certainly problematizes how said rights are implemented and enforced, especially when Singapore prohibits remarks made with the intention of negatively inflaming public opinion rather than that of contributing to a healthy debate.
Evaluating the universal applicability of the UDHR
The previous section looked at the difficulties faced when critiquing the Singapore government’s implementation of Article Nineteen of the UDHR, protecting one’s right to the freedom of expression. The next three sections will consider the relative incompatibility of the UDHR with countries like Singapore, which do not operate within the Anglo-American political tradition or do not occupy the same stratum of socioeconomic and political development as the Western world.
Juggling with rights
The 1993 Vienna Declaration, which clarifies and reaffirms the principles of the UDHR, clearly states that ‘All human rights are universal, indivisible and interdependent and interrelated’. This means several things: one, the total effect of enjoying all of one’s rights is greater than the sum of its parts; two, the enjoyment of some rights are dependent on the enjoyment of others; three, the UDHR lists the ‘minimum conditions necessary for a life worthy of a human being’ and that the systematic violation of any one right disables an individual from ‘realising a life full of human dignity.’ Donnelly responds to Henry Shue’s notion of “basic rights” by agreeing that it is the goods that result from basic rights, rather than basic rights themselves, which are needed to ensure other rights. The rights themselves, differentiated from the goods that they procure, continue to be indivisible.
Yet, one would be hard-pressed to find a state that had the ability or motivation to enforce all thirty articles of the UDHR with equal vigor on the day it came to realize their national sovereignty. Even in the United States and Britain, countries that take credit for creating the language of rights, human rights still evolved to meet the demands of groups in power only in accordance with what the state was able to provide. When the universalization of rights threatened the economic prosperity and national unity of a state, as the question of slavery and the enfranchisement of women did in the United States, the project of handing rights to all persons was quickly filed away for future implementation. The US was hence free to undertake its desired state-building projects of industrialisation and political stabilisation, unhampered by the need to adhere to the requirements of a human rights regime, and could gradually develop a system of rights that would at no point outstrip the US government’s capacity to enforce these rights. For a state to even secure some human rights, such as education or freedom from poverty, an initial degree of political power and financial capability is necessary. The ability to further protect human rights requires resources achievable only through development. And, if Donnelly correctly says that no country has developed without repression, amassing the power and resources needed to uphold human rights at all may contradictorily require states to violate certain human rights.
Perhaps Singapore, with its economic prosperity far exceeding that of many other countries, has long lost its right to claim that providing Singaporeans with the freedoms of security and peace requires the state to violate the freedom of expression on the topics of race and religion. However, costs of effectively implementing human rights are not just fiscal: there are social and political costs as well. Although highly unlikely, the unregulated freedom of expression in multi-ethnic Singapore, where clear hierarchies of power exist between racial groups, may damage the ability of the state to protect other rights of individuals in society. It could, in fact, be highly beneficial,  for Singaporean authorities to loosen restrictions on the freedom of expression on divisive issues such as race and religion in order to foster a genuine exchange of ideas in society, but doing so would still be contingent on the government’s continued capacity to maintain the implementation of other human rights.
Exclusion of non-liberal and hierarchal regimes
Proponents of the Asian values debate such as Lee Kuan Yew and Dr Mahathir Mohamad have frequently rejected the universalism of the UDHR; they argue that by placing individualism as its cornerstone, human rights become incompatible with Asian societies that value collectivism and authority. The substantiation provided for this theory has proven to be weak, and critics have accurately pointed out that Lee and Dr Mahathir have a vested interest in using this argument to justify their own authoritarian rule rather than simply demonstrating a population’s preference for such governance. However, even if this thesis is poorly supported, the question at the heart of its debate remains, and is one that needs to be thoughtfully considered: how can human rights be universal if they rely on fundamental values that are incompatible with other societies, Asian or otherwise?
According to Donnelly, the UDHR presupposes the belief in equal concern and respect, which is the only common ground needed between vastly divergent contemporary societies. For him, any society and government that treats people as moral and political equals and that values personal liberty and autonomy is immediately compatible with the core values of the UDHR and hence should have no qualms with accepting its universality. He argues that the belief in equal concern and respect has become the international standard today, such that the refusal to see human beings as fundamental autonomous actors is regarded as legitimately “unreasonable” in the contemporary world. That this may not accommodate all societies today demands no apology, since they have proven to be unreasonable, but also because it because “[e]ven where citizens do not have a particularly sophisticated sense of what a commitment to human rights means, they respond to the general idea that they and their fellow citizens are equally entitled to certain basic goods, services, protections, and opportunities.”
When analyzing how Singapore aligns with the core values of the UDHR, one must acknowledge that differentiating the actual values of Singapore from the values that authorities project onto Singapore society can be a difficult task. The People’s Action Party (PAP) has paternalistically governed Singapore since it first came to power, only gradually loosening the reins in recent years. Relying on a system of hierarchy between politicians and the people, the population lends electoral support and confers legitimacy to the PAP in exchange for an elitist, top-down governance that stimulates economic growth and provides stability. Despite the rise of a talented and formidable opposition, PAP has continued to win a large majority of the vote share, receiving 69.9 percent of the vote in the 2015 General Election. Even if only implicitly, Singaporeans have demonstrated a preference for a hierarchical political structure with the power to curb civil liberties when it is exercised for their common good, or at least do not prioritise civil liberties sufficiently to give up efficient governance in exchange for it.
Assuming that Singaporeans have deliberately chosen a hierarchical political structure that contradicts the core values of human rights, how do we assess its place in the international regime of human rights? Firstly, to suggest that human rights are universal because most citizens would respond favorably to being awarded these rights after considerable thought seems disingenuous, for it is unsurprising that people would want these protections. However, whether human rights truly are society’s preferred political expression depends on how they are prioritised when stacked against other practical concerns and when they get in the way of a more effective governing system. Secondly, dismissing societies like Singapore that are not fully egalitarian as unreasonable suggests that attempts should be made to convert it into holding values that are more valid—yet simultaneously justifies Singapore’s refusal to accept the universality of the UDHR on the basis of incompatible values.
Two solutions have been presented to this problem by John Rawls and Ignatieff respectively. Rawls’ The Law of Peoples argues that there should be international toleration of Decent Hierarchical Societies, which do not have aggressive aims and which respect a minimal list of human rights, including the right to life, to liberty, to property and to formal equality. While he intends to incorporate non-liberal, hierarchical states into international society “in good standing,” the suggestion that Decent Hierarchical Societies are less just than liberal ones, even if hierarchies are used for the common good, is inherently condescending, especially in practice. This theory hypocritically prioritizes certain notions and methods of achieving justice over others, especially considering the fact that the countries at the forefront of promoting these universal standards, such as the United States and other European powers, have benefitted from a hierarchical world order that sustained their development since the modern era. To suggest that some forms of hierarchy are not necessarily unjust does not imply that hierarchical power structures are never used for the personal political gain of a government, as the PAP certainly has done so in Singapore in the past fifty years. However, this does argue that hierarchy can be used for just purposes, such as that of rapid economic development or the enforced equality of minorities who may otherwise be outnumbered in a majoritarian discourse. This point of argument brings up more issues with the application of human rights rather than its theoretical validity but is nonetheless important to consider when analysing the coherence of the UDHR’s claims to universality.
As mentioned in previous sections, Ignatieff acknowledges the impossibility of building a consensus on philosophical grounds for all the human rights articles in the UDHR. Instead, he takes a minimalist approach, arguing that an objectively universal consensus can be reached via a version of the common rule: “the basic intuition that what is pain and humiliation for you is bound to be pain and humiliation for me.” He does not intend to build a comprehensive system of political, social, economic and civil rights, but instead aims to prevent totalitarian regimes in which individuals have no protection against larger social structures, by pursuing a systematic agenda of negative liberty that equips the individual with the agency to submit themselves to a larger culture if they so wish. These core rights are further left to the individual to claim, and are enforced based on the victims and what they require rather than at the will of human rights activists.
Ignatieff lowers the bar on what constitutes universal human rights precisely to increase the scope of its universalism, and it is only logical that non-liberal societies that do not agree with the scope of the UDHR and its theoretical foundations will regard this as the most favorable solution. By tracing Ignatieff’s use of examples, the reader can get a better understanding of which human rights make up the irreducible core: the right to personal safety, security and liberty. However, where the freedom of expression lies in his human rights framework is unclear. If the freedom of expression is seen as essential to provide an individual with negative liberty from which one can exercise agency, then it is up to each individual Singaporean whether or not to claim their right to the freedom of expression. Ignatieff intends for this to give individuals the choice whether or not they would like to participate in collective or hierarchical customs. Yet, the difficulty in suggesting that Singaporeans can opt in to a system of curtailed freedom of expression for the common good is that it will only work if the entire population agrees not to claim their right to free expression. Unlike the case of female genital mutilation, because of the nature of the common good that may arise out of a restricted freedom of expression, the entire collective practice of accepting these restrictions for a common good collapses when even a few individuals opt out of the practice. A racial minority group in Singapore, for example, cannot enjoy the benefit of not being subject to racially derogatory remarks if a few members of society have decided to opt out of this practice, while a community can still continue practicing a certain custom even if the rest of society deems it unacceptable. If the freedom of expression is truly a right in Ignatieff’s framework, in that they are undeniable to ensure the basic liberty of an individual and which implies that an individual will be able to claim it against her society regardless of the circumstances, then Singapore’s practices are inconsistent with even Ignatieff’s minimal conception of human rights. However, if restrictions on the freedom of speech do not lead to pain and humiliation, which is the fountainhead for all rights for Ignatieff, then Singapore’s actions do not violate this alternate understanding of human rights.
The problem of human rights and individualism
The difficulty that tugs at the tails of all the previous arguments is this: if human rights evolved out of the Western liberal individualism, where the individual is intentionally prioritised over society’s interests or powers in most circumstances, how does the UDHR apply in societies where this arrangement of individuals over the community is neither philosophically accepted nor practically implemented? Again, this is not simply an issue of power-hungry tyrants who have systematically violated human rights in the name of “society’s interests” for their political gain. It is a question of whether it makes sense to discuss humans and their innate humanity without their society, not just in that states and societies are responsible for enforcing human rights, but that the very notion of human dignity, identity and desire is inextricable from the community in their construction. As Chris Brown writes describing the work of Hegel:
“[The] kind of individuals who make up the community are not a more or less random collection of people who happen to inhabit a particular territory at a particular time, but rather a group of people who are simultaneously the creators of community and created by it… The ‘rights’ that they assign each other are not the manifestation of a general moral code or the product of universal practical reason, nor are they simply the product of a political bargain; rather, they are more like reminders that the community gives itself as to what it takes to be proper conduct.”
States cannot enforce rights without society coming together to give it the power to do so, and neither can they enforce it without resources that need to be generated by individuals contributing to society. If rights are furthermore seen as “proper conduct” for a given society at a given time, they make no sense without corresponding duties and a general consensus on how these rights are exercised. Contrary to the UDHR, then, Singaporeans do not possess human rights because they are universal human beings that need all the listed articles to enjoy a dignified life, they attain these rights because their states can, and have agreed to, give it to them. Until Singaporean society evolves to see the freedom of expression as something they can and should protect at all costs, pressurising the Singaporean government to respect this right will continue to be a challenge for human rights activists. However, while human rights activists wait for this evolution to occur, the more fundamental question still must be asked: is it productive for Singapore to aspire to improve the lives of its citizens through a system of rights – even if scholars such as Donnelly believe it is the best method – when the histories and values of the Singaporean people seem to be at odds with the foundational principles of the UDHR?
This essay has examined four main reasons that Singapore’s violation of the freedom of expression article may be justified and that challenge the applicability of human rights on a universal level. Firstly, different interpretations of restrictions to the freedom of expression that are legitimate do exist; secondly, how rights are prioritised in a given society can be unclear; thirdly, the system of human rights naturally excludes non-liberal states and attempts to incorporate them on an inferior basis, and lastly, the individualism that is at the core of the UDHR is not fully compatible with some societies, including that of Singapore. It has been agreed that there are some rights in the UDHR that truly can be accepted as universal and where the individual always takes precedence over the society, such as the prohibitions on arbitrary killings and torture. However, these are not universal rights in the sense that the conceptualisation of these rights arose simultaneously from different communities; the notion of protecting an individual from certain circumstances through a rights framework is still Western in origin, but an individual-centred political expression for these core, fundamental issues is something that can be accepted by other communities. Lastly, the fact that they are Western in origin is not sufficient grounds for non-Western societies to reject them altogether, should they prove to be the most efficacious framework to bring goods to individuals and communities in society. Instead, their foreign origins decree that activists practice caution in the universal application of human rights, being aware of the fundamental changes in values that are demanded of a society fully embracing the UDHR. Lastly, noting the changes that must occur within a state for human rights to be effectively implemented, activists are asked to consider the possibility of bringing productive societal change through mechanisms more suited to the political, economic and social climate of the society in question, rather than viewing human rights as the only solution to the problem.
 “Universal Declaration of Human Rights,” UN General Assembly, 217 (III) A, 1948.
 “Government’s Response to UN Review a Major Setback for Human Rights,” International Federation for Human Rights, June 24, 2016.
 Jack Donnelly, Universal Human Rights in Theory and in Practice (New York: Cornell University Press, 1989), 9.
 Ibid., 10 and 12.
 Ibid., 14.
 Michael Ignatieff, Human Rights as Politics and Idolatry (Princeton: Princeton University Press, 2001), 55.
 Donnelly, Universal Human Rights, 26.
 Amartya Sen, “Universal Truths: Human Rights and the Westernizing Illusion,” Harvard International Review 20, no. 3 (1998): 40-43.
 Donnelly, Universal Human Rights, 129.
 Ibid., 53-55.
 Donnelly, Universal Human Rights, 57-58.
 Jack Donnelly, International Human Rights (Boulder: Westview Press, 1993), 36.
 Ibid., 37.
 James Gomez. Freedom of Expression and the Media in Singapore, (London: Article 19, 2005), 19.
 Ibid., 20.
 ‘World Report 2015: Singapore,’ Human Rights Watch, accessed December 15, 2016.
 Human Rights Institute Report: Prosperity Versus Individual Rights? Human Rights, Democracy and Rule of Law in Singapore, International Bar Association (July 2008), 8.
 Kishore Mahbubani, “An Asian Perspective on Human Rights and Freedom of the Press,” in Can Asians Think?: Understanding the Divide between East and West (South Royalton: Steerforth Press, 2002), 74.
 Whether or not prohibiting the freedom of expression is an effective means to social and economic prosperity is a question not intended for this essay.
 Donnelly, Universal Human Rights, 7.
 Ronald Dworkin, “Taking Rights Seriously” in Taking Rights Seriously (London: A & C Black, 2013), 195.
 “Public Prosecutor v. Amos Yee Pang Sang,” Global Freedom of Expression (Columbia University), accessed December 15, 2016.
 “Singapore: Exonerate 16-Year-Old Blogger,” Human Rights Watch, June 22, 2015.
 “Singapore 2015/2016,” Amnesty International, accessed on 15 December, 2016.
 Human Rights Institute Report: Singapore, 6.
 “The Economist magazine pulls controversial cartoon out of copies printed in Singapore,” The Straits Times, January 16, 2015.
 J.S. Mill, “Of Individuality, as One of the Elements of Well-Being,” in On Liberty (1859) and Other Writings, ed. S. Collini (Cambridge: Cambridge University Press, 1989), 56.
 Ibid, 65-66.
 Pilgrim W.K. Lo, “Human Dignity—A Theological and Confucian Discussion,”
Dialog: A Journal of Theology 115, no. 2 (2009): 169-171.
 Donnelly, Universal Human Rights, 3rd ed., 31.
 Donnelly, Universal Human Rights, 1st ed., 41.
 Ibid, 38.
 Jeremy Bentham, “Anarchical Fallacies,” in Nonsense Upon Stilts: Bentham, Burke and Marx on the Rights of Man, ed. Jeremy Waldron (London: Routeledge, 2014), 53-54.
 Donnelly, Universal Human Rights, 1st ed., 187.
 Ibid., 117.
 Bentham, “Anarchical Fallacies,” in Nonsense Upon Stilts, 53.
 Mill, “Of Individuality,” in On Liberty, 65.
 Donnelly, Universal Human Rights, 3rd ed., 146.
 Ibid, 63-64.
 Ibid, 70.
 Ibid, 56.
 Sumiko Tan. “GE2015: PAP vote share increases to 69.9%, party wins 83 of 89 seats including WP-held Punggol East,” The Straits Times, September 12, 2015.
 Donnelly, Universal Human Rights, 3rd ed., 71.
 John Rawls, The Law of Peoples (Harvard: Harvard University Press, 1999), 64-65.
 Ibid, 67.
 Ignatieff, Human Rights as Politics and Idolatry, 95.
 Ibid, 66-67.
 Ibid, 57.
 Ibid, 72.
 Ibid, 70.
 Donnelly, Universal Human Rights, 1st ed., 145.
 Ibid, 3rd ed., 35.
 Chris Brown, “Universal Human Rights: A Critique,” in The International Journal of Human Rights 1, no. 2 (1997): 50-51.