Procedural Rules for the Prosecution and Trial of Journalists for Publishing Personal Data: A Comparative Analytical Study between French, Emirati, and Jordanian Laws

Tayil Shiyab, Mohammad Alkrisheh, Hakem Madhour Alserhan and Ali Hadi Al-Obeidi

Studies in Media and Communication, 2026, vol. 14, issue 2, 102-110

Abstract: This study examines the procedural framework governing the criminalisation of journalists' publication of personal data under French law. It compares it with the corresponding legislative approaches adopted in Jordan and the United Arab Emirates. It aims to analyse how criminal procedural rules seek to strike a balance between freedom of the press and the protection of individuals' private life, with particular emphasis on the procedural guarantees regulating investigation, prosecution, and judicial oversight in such offences.Employing a comparative analytical methodology, the study explores how each legal system defines the scope of journalistic liability, identifies the competent authorities responsible for initiating criminal proceedings, and determines the procedural safeguards afforded to both journalists and victims. The findings indicate that French law establishes a more coherent and comprehensive procedural framework, grounded in constitutional protections of privacy and freedom of expression, while ensuring adequate judicial supervision and proportionate sanctions. By contrast, the procedural rules in Jordan and the United Arab Emirates appear less harmonised and exhibit a degree of legislative insufficiency in certain respects.The study concludes by recommending targeted legislative refinement to enhance procedural clarity, reinforce judicial balance, and ensure adequate protection of fundamental rights in the context of media-related crimes.

Date: 2026
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