Comparative Law of Privacy

At this time there is little doubt that the right of privacy is well established in most American jurisdictions. In Europe the situation is much the same. There the concept of Fault and Moral Injury affords the proper climate for its further development and continued protection. The fact that Continental countries have difficulty in tacking down the concept to a particular category of right, and even, sometimes, to a particular article in their Code, is, after all, inconsequential. Only in England is the right slow to come into its own, but the increasing awareness of the English Bench and Bar that there should be such a right would appear to be the harbinger for future recognition and protection. However, due to a certain traditional reluctance on the part of the English judges to blaze new trails in this area, it is more likely that the firs tbreakthrough of this right will come from Parliament