A Comparative Study of Pakistani and International Laws on Online Harassment: Challenges and Opportunities

Abstract

The paper is a comparison of the legal provisions in Pakistan regarding online harassment and newer international strategies in Europe, United Kingdom, United States, India, and Australia. The research depends on a qualitative doctrinal approach close reading of the statutes, regulatory guidance and intergovernmental reports and discusses definitions, scope, platform obligations, enforcement structures, remedies and due-process protections. It identifies the Prevention of Electronic Crimes Act, 2016 (PECA) and other instruments used in Pakistan as having significant points of attack against cyberstalking and crimes against dignity and modesty, but it is still not well-coordinated between criminal law and protection-based systems in the workplace, and the ability to apply it is uneven. International Newer platform-duty regimes (EU DSA, UK Online Safety Act, Australia Online Safety Act) place responsibilities on intermediaries, which have a risk assessment, removal order, and transparency requirement; whereas the U.S. mostly retains a riveter-of-news role under Section 230, and India is qualifying safe-harbor on due diligence under its Intermediary Rules 2021. The article names lack of definition, evidence and jurisdictional barriers, resource limitations, and threats to speech as the challenges and proposes opportunities that can help Pakistan modernise its situation through defining the offences (e.g., doxxing, deepfakes), enhancing victim-centred processes, and applying moderated platform-duty and transparency frameworks.