DSK,UK tabloid case raise questions for Press in Europe

If Dominique Strauss-Kahn walks free now that the sexual assault case against him in New York seems to be weakening,will the French public have a right,or,indeed,an appetite to know more than what emerged in US courts? And if less-exalted people in Britain feel that their secrets should be protected too,how should they shield themselves from journalists hacking into their voice mails?

The questions underscore the contrasts between cultures that,in the past,have made Britain a temple to strident disclosure and France a whispered haven of discretion. In both countries,the debate has reached what might,at first,seem like a tipping point.

In London,tabloid newspaper,News of the World,was accused of eavesdropping on the cellphones of a kidnapped and murdered schoolgirl,the relatives of people who died in the 2005 London transit bombings and possibly the families of British war dead.

Such was the public revulsion that an embattled prime minister,David Cameron,was forced on Friday to order two separate inquiries one into the phone-hacking scandal itself and the other into the behaviour of the freewheeling British press. In a news conference,Cameron insisted that the British press tradition of self-regulation had failed. I believe we need a new system entirely, he said,prompting an outcry on Saturday from British journalists who have long resisted statutory restrictions on their freedoms. Yet,the broad rules remain freighted with ambiguity,governed by two apparently conflicting clauses of the European Convention on Human Rights: one endorses the right to privacy,another the right to free expression.

France like much of Continental Europe has long chosen a different,less swashbuckling attitude toward matters of privacy,offering the powerful a degree of protection that would be unthinkable in Britain or the US. French politicians have been able to hide behind some of Europes tightest privacy laws. The sexual reputation of Strauss-Kahn,for instance,was known to many journalists but rarely publicised. The extent of that knowledge emerged only when he was arrested in New York and charged with trying to rape a hotel housekeeper at the Sofitel in Manhattan.

In France and Britain,the past weeks have shown both models of reporting to be strained to the point of failure,leaving journalists to define the role they ought to play.