This month of bloody riots against blasphemy in the Muslim world is scheduled to end just as it began: with a provocation. Today, a scattering of atheists and freethinkers will celebrate something called International Blasphemy Rights Day, a coordinated recognition of the freedom to slander any religion or prophet. The day’s most prominent festivities will occur on college campuses, where in the three-year history of the event, students have arranged philosophical panel discussions, showings of blasphemous art, and open-mic nights that welcome speakers whose speech might in another context draw a barrage of rocks or bullets.

If Hallmark makes a card for this particular holiday, it’s unlikely to be sold in the gift shops of Cairo or Benghazi. Those cities are still recovering from reactions to a California-made YouTube video ridiculing the Prophet Mohammed, which caused riots in countries from Libya to Pakistan. It is tempting for observers in the West to write off these eruptions of street-level anger as local and temporary, fanned by religious sectarians and anti-US feeling. But the riots are also symptoms of a bigger clash in understandings of human rights, one taking place at the level of government and UN declarations, with one side defending the freedom to blaspheme, and the other calling for international law to enshrine a freedom from blasphemy.

The controversy over the right to blaspheme—and the counterclaim, by Muslims in particular, of a right not to be subjected to blasphemy—is a key sticking point in relations between the Islamic and non-Islamic worlds. Predominantly Christian societies have, over the course of history, burned or banned their fair share of heretics and blasphemers, not to mention (in very recent times) their share of allegedly blasphemous art. But they have, it seems, come to an agreement that blasphemy is a private matter rather than a legal one.

The Islamic world has, by and large, coalesced around a different view, and can cite international covenants to back its position up. Broadly accepted declarations of human rights do single out freedom of speech and conscience as inalienable, and International Blasphemy Rights Day was founded to help press that case globally. But the same declarations also safeguard countries’ rights to protect communities from the violence that hatred can incite. In many situations, merely to state something that most people find blasphemous is to provoke violence and, according to governments both Islamic and secular, give legitimate cause for censorship.

“Blasphemy” might sound like an old-fashioned word in the West, but it lies at the heart of a very active collision between two rights—the right to speak and think freely, and the right to protect one’s society from violence. When it comes to blasphemous speech, even in open societies like those of Western Europe, it’s far from clear which will prevail.

The one country where freedom to blaspheme is, at this point, legally uncontroversial is the United States. Courts’ interpretation of the First Amendment has protected even the grossest abuse of religion. But we’re an outlier, and one need not travel all the way to Tehran to find a place where blasphemy is potentially criminal. Toronto would be far enough. Canada, like just about all countries in Western Europe, has mechanisms to keep potentially harmful religious speech in check.

The concept of “blasphemy” we use today is the product of three historical stages, according to Austin Dacey, a secular activist who teaches philosophy at the University of Central Florida and who campaigns for an internationally recognized right to blaspheme. First came a period when blasphemy meant a sin against the divine—“a direct verbal affront to the Godhead”—followed by a period when blasphemy was primarily a political problem: Rule by divine right of kings meant that blasphemy amounted to a challenge to the authority of the state. In both cases the standard punishment was death. The rise of the modern secular state led, starting in the 1600s, to the notion of blasphemy as a form of disrespect less against God or the state than against one’s neighbors. It constituted an extreme form of disrespect, and has come today to be seen as a communal sin rather than a personal or political one. (“It’s a relatively new idea,” Dacey says, cautioning that “new” in the context of religious history still means “several centuries old.”)

Only around that time did Europe and the Muslim world really begin to diverge in how they treated blasphemy. But even then, they diverged less than one might think. In 1919, when George Bernard Shaw wrote “All great truths begin as blasphemies,” the line reflected his own Irish godlessness but not the legal systems of the British Isles. The United Kingdom continued to criminalize blasphemy—though only against the Anglican church; Islam was fair game—until 2008, although it rarely bothered to prosecute anyone. (The last successful prosecution, in 1977, targeted the publisher of a poem by James Kirkup about necrophilia between a Roman centurion and the crucified Jesus Christ.)

Today the most active antiblasphemy activists on the global stage are Muslim. Christians and Hindus, too, have reacted vigorously to perceived disrespect, for example by picketing Martin Scorsese’s film “The Last Temptation of Christ,” or attacking and vandalizing Andres Serrano’s photograph “Piss Christ” in a French gallery last year. They have also urged prosecution of blasphemers: In April, Indian skeptic Sanal Edamaruku demonstrated that the “miraculous” flow of water from the base of a statue of Jesus in Bombay was in fact the result of a plugged bathroom drain. He reportedly faces arrest for ridiculing Catholicism. But no Christian response to blasphemy has matched the violence of, say, Muslim protests against Danish cartoons of the Prophet Mohammed in 2005, or this month’s bloody riots over the

That fury has been channeled, with mixed success, into activism at the United Nations and in other international bodies. The Organization of Islamic Cooperation has for years urged its members to take legal action against blasphemy and lobby the United Nations to do the same. They have pointed to provisions in the International Covenant on Civil and Political Rights (first proposed in 1966) that reserve for countries the right to curb religious incitement, and use that provision as a basis for asking the UN General Assembly to adopt an explicit stance against blasphemy. In response, secular advocates like Dacey point out that other international agreements guarantee freedom of speech and conscience. The Universal Declaration of Human Rights, which since 1948 has been the central enumeration of human rights, explicitly preserves the individual right to speak one’s mind.

If the rights of individuals to speak and the rights of societies to censor look like they are in contradiction, that’s because they are. All over Europe, you’ll find blasphemy laws that attempt to navigate this incompatibility, not between human rights declarations and religion, but within human rights declarations themselves.

The old UK blasphemy law, for example, was stricken from the books not because blasphemy suddenly became accepted, but rather because Muslims demanded equal protection—and got it, through a new law against incitement of religious hatred. Dacey points to Danish law as one of the more restrictive, since in that case even truth is no defense. In Denmark you can be prosecuted for religious incitement, even if you do nothing other than publicly utter demonstrably true facts about a religion.

UN General Assembly resolutions aren’t binding on governments, but they carry moral force, and some Muslim leaders now want to push the international norms further in the antiblasphemy direction. In particular, they see the Mohammed video as essentially a hate crime that happens to enjoy state protection in the West, and would like to see more explicit backing for crackdowns on anti-Muslim provocation.

“The West hasn’t [yet] recognized Islamophobia as a crime,” Turkish Prime Minister Recep Tayyip Erdogan said at a press conference. With Indonesian President Susilo Bambang Yudhoyono, he plans to bring a United Nations General Assembly resolution urging the criminalization of blasphemy next week. The UN “needs to mull over international protocol to prevent [blasphemous speech like the YouTube clip] from happening again,” Yudhoyono said.

In speeches at the General Assembly, leaders of Iran, Pakistan, Egypt, and Yemen echoed the sentiments, though secular advocates said opposition from the West—particularly the United States and the United Kingdom—made the resolution unlikely to pass.

In one sense, Muslim advocates of antiblasphemy law can be seen trying to add one more layer to the global understanding of rights: Human rights might trump national law, but Islamic law is allowed to trump both. “That legal stuff is written by man, but our [rights] are written by the Prophet and directed by God,” says Sadat Sadat, a British Muslim bookseller outside the Finsbury Park Mosque, which has been a hub for radical Muslims in London. “If the man who made that movie came out here, within seconds he would be killed. I can guarantee that. The law written on paper does not protect everything.” He added, cautiously, that he himself would not do any killing.

Threats like this one have had the effect of steeling (as well as at times fraying) the nerves of some free-speech advocates. “It’s misframing the issue to ask whether any speech is ‘proper,’ or ‘disrespectful,’ ” says Michael De Dora, policy director of the Center for Inquiry, the secular advocacy group that sponsors and organizes the Blasphemy Day. “People have a right to say a lot of things that are profoundly stupid and wrong.”

He pointed out that anti-incitement laws are even more common, and more easily invoked, in Muslim countries than in Europe. In the Islamic word, not causing offense is widely viewed as a pillar of how societies function. So when intentional provocation occurs, the state is often prepared to react swiftly.

“What you see in these countries is that they might not have blasphemy laws but they do have laws against insulting people’s feelings, because insulting them will incite them to violence,” De Dora said. Merely stating aloud that one is an atheist, for example, might trigger an arrest. “We find that unfortunate.”

When I spoke to De Dora, he had just gotten into a Manhattan yellow cab outside the United Nations, where the Center for Inquiry has observer status as a nongovernmental organization and is lobbying hard against any resolution denouncing incitement. A few blocks later, when he was about to get out of the cab, I heard some impassioned but incomprehensible words from the cabbie, who overheard our chat and wanted to add his thoughts.

Mustafa Mahmoud told me he is from Alexandria, Egypt, but has lived in the United States for 17 years and loves his adopted country. But he said US laws needed to change.

“You can mess with anything,” he said. “But it should be illegal to talk about any religion.”

Would he be willing to let people talk about Jesus? “It should be illegal to let anyone talk about Jesus, unless he’s [working] in the religious field, like a priest. Muslims don’t talk about Jesus this way. People would flip!”

De Dora excused himself from the cab, and Mahmoud let him go without further argument. De Dora did, however, strike a slightly more conciliatory tone. “We’re not urging anyone to go blaspheme,” he said, although he continued to advocate an absolute right to do so. “As someone who’s interested in communicating ideas, the last thing you want to do is insult someone’s feelings, because then they won’t be as receptive to your ideas.”

Graeme Wood