UNITED NATIONS -- When Pakistani President Asif Ali Zardari took the podium to address the UN General Assembly on September 25, he wasted no time taking on one of the most divisive issues of the day.
"Before I take up my speech, I want to express the strongest condemnation for the acts of incitement of hate against the faith of billions of Muslims of the world and our beloved Prophet," Zardari said.
He could have specified many such "incitements" over the years, including Koran burnings and the publishing of cartoons portraying the Prophet Muhammad. The most recent example, of course, is "Innocence of Muslims," a film produced in the United States whose insulting depiction of the Prophet Muhammad prompted outrage and even deadly violence in the Muslim world.
"Although we can never condone violence, the international community must not become silent observers and should criminalize such acts that destroy the peace of the world and endanger the world security by misusing freedom of expression," Zardari said.
"Pakistan moves the United Nations to immediately address this alarming concern and bridge the widening concern and bridge the widening rift to enable the community of nations to be one again."
On one side of the cultural rift stands free speech, on the other religious sensitivities -- and as evidenced by the contrasting views expressed during the General Assembly, the divide is great
Aside from condemning both the denigration of Islam and the violence that can follow, however, what can states collectively do to prevent such incidents in the future?
One idea that has been floated for years is again gaining traction: establishing clear rules against blasphemy, protected by international law.
Currently there are about 30 countries worldwide that have instituted their own laws criminalizing blasphemy, including Pakistan, Iran, Indonesia, Egypt, Algeria, and Poland.
Iraqis hold a banner and shout slogans during a protest against a film seen as insulting the Prophet Muhammad in Basra.
Speaking at a Security Council briefing on peace and security in the Middle East, Arab League Secretary-General Nabil Elaraby provided his view of how such measures could be established universally.
"The League of Arab States calls for the development of an international legal framework which is binding in order to confront insulting religions and ensuring that religious faith and its symbols are respected."
Many have tried, and failed, to establish such frameworks before. Islamic countries have pushed resolutions through the UN's General Assembly and Human Rights Council. Because they were nonbinding, however, those initiatives had no real teeth.
One way to reverse course would be to go outside the UN. The Organization for Islamic Cooperation (OIC), which has 57 member states and a permanent delegation to the United Nations, is one option.
The grouping of mostly Muslim-majority countries has a history of developing legal guidelines in keeping with Islamic views. The Cairo Declaration of Human Rights in Islam, for example, was adopted in 1990. Nine years later, the OIC passed the Convention on Combating International Terrorism. And in 2005, after a Danish newspaper published cartoons depicting the Prophet Muhammad, the OIC called an extraordinary session in which the cartoons were condemned.
The OIC has previously pushed blasphemy legislation that would be agreed by legally binding treaty or international convention. That is until last year, when the cause was dropped.
In recent days, however, the OIC has released several statements in support of an international blasphemy ban. Turkey -- whose president has said he would speak out in support of a ban -- is now heading the OIC.
Even UN Secretary-General Ban Ki-moon's comments on the controversy reflect a sway in opinion toward the religious-sensitivities camp.
"Freedoms of expression should be and must be guaranteed and protected, when they are used for common justice, common purpose," Ban told reporters on September 19. "When some people use this freedom of expression to provoke or humiliate some others' values and beliefs, then this cannot be protected in such a way."
Abusing Laws For Repression
There appears to be growing support for some sort of blasphemy code of conduct to be worked out at some international level, even if not under the umbrella of the United Nations. And that is cause for worry for free-speech advocates.
Pakistani security personnel move Rimsha Masih, a young girl accused of blasphemy, to a helicopter after her release from jail in Rawalpindi.
Courtney Radsch, program manager for the Global Freedom of Expression Campaign at Freedom House, says it is important to note that the divergent views between Islamic leaders and the West are driven by each country's political history, as well as current state of affairs.
"In cultures, in countries where there is an authoritarian government, where there are restrictions on freedom of expression, and freedom of speech, and freedom of association, where criticism of ruling authorities -- whether those are political or religious -- is not tolerated, then yes, you see a much different relationship to freedom of expression, to satire, to what some people would see as poking fun at things," Radsch says.
In the case of the "Innocence Of Muslims," she says, the film itself was not the cause of the violence, but was used as a political tool to incite violence
Likewise, blasphemy laws are not the answer because they too can be used to oppress, rather than protect, religious minorities, according to free-speech advocates.
They point to a recent case in Pakistan in which a 14-year-old Christian girl was tried for allegedly burning pages of the Koran. Her case was moved on September 24 to a juvenile court -- but adults convicted of blasphemy could face a death sentence.
Such an outcome is anathema to the belief systems of some countries, such as the United States, where freedom of speech is enshrined in the constitution.
U.S. President Barack Obama laid out the general argument during his address to the General Assembly on September 25. "The strongest weapon against hateful speech is not repression, it is more speech -- the voices of tolerance that rally against bigotry and blasphemy, and lift up the values of understanding and mutual respect," he said.
And that is why, ultimately, without the support of the United States and key Western countries, the effort to criminalize blasphemy is unlikely to be enshrined universally in international law.