A Comparative Analysis of Cyberstalking Legislations in UK, Singapore and Sri Lanka
KS Harasgama1, MAPM Munasinghe2
Law School, Faculty of Humanities and Sciences, Sri Lanka Institute of Information Technology (SLIIT), Sri Lanka
[email protected] 1
[email protected]Abstract
The offence of cyberstalking involves an unwanted and repeated pursuit of a person by another
and includes a variety of threatening, harassing, distressing and potentially dangerous behaviors
on more than one occasion over the internet or on the cyberspace. Research indicate that over the
past few decades the prevalence rates of cyberstalking incidents have widely increased. This paper
seeks to analyze the legislative approaches adopted by three jurisdictions, namely, UK, Singapore
and Sri Lanka in addressing the offence of cyberstalking. The analysis reveals that both the UK
(except for Northern Ireland) and Singapore contain explicit legislative provisions on
cyberstalking which is mainly addressed through the stipulated non-exhaustive list of examples or
through illustrations. Although Sri Lanka lacks specific law on cyberstalking, some of the existing
criminal laws such as the Penal Code provisions on criminal intimidation, sexual harassment and
some provisions of the Computer Crime Act of 2007 and the Prohibition of Ragging and Other
Forms of Violence in Educational Institutions Act of 1998 can be used to a certain extent to
prosecute cyberstalking.
Keywords: Cyberstalking; UK; Singapore; Sri Lanka
1. Introduction
As cyberstalking is a subcategory of the general offence of stalking, it is important to first
understand what stalking in general means. The term “stalking” has been defined in many ways in
the literature. Pathe`and Mullen describe stalking as “a constellation of behaviours in which one
individual inflicts on another repeated unwanted intrusions and communications”.3 According to
Nicastro and others “stalking is generally defined as an ongoing course of conduct in which a
1
Senior Lecturer, Law School, Faculty of Humanities and Social Sciences, Sri Lanka Institute of Information
Technology (SLIIT).
2
Research Assistant at Sri Lanka Institute of Information Technology (SLIIT) – AHEAD DOR NO 11.
3
Michele Pathé and Paul E. Mullen, 'The Impact of Stalkers n Their Victims' (1997) 170 British Journal of Psychiatry
<https://doi.org/10.1192/bjp.170.1.12> accessed 22 March 2021.
Electronic copy available at: https://ssrn.com/abstract=3903800
person behaviorally intrudes upon another’s life in a manner perceived to be threatening”.4 Even
the stalking laws of various jurisdictions define the offence of stalking differently. Yet despite
these apparent differences, a closer examination of the above definitions reveals several common
characteristics of stalking. Firstly, stalking involves a course of conduct, with repeated actions over
time, and is not an isolated event.5Secondly, stalking typically requires evidence of threat and/or
fear/alarm. Thus, a mere course of conduct such as frequent messenger chats, emails etc. are less
likely to constitute stalking unless the nature of those communications are sufficient to elicit a
reasonable sense of fear. Thirdly, even though stalking is primarily directed at the target of the
communications, it may imply threats against members of the target’s larger network of
associations. E.g.: person’s family, friends, pets, or property.6 Lastly, the fact that the offence is
carried out using internet (through an online platform) also forms an important element of
cyberstalking as it is what makes it distinct from spatial stalking. However, it should also be noted
that even though cyberstalking may be viewed as quite distinct from spatial stalking, it often leads
to, or is accompanied by, physical stalking or may relate to explicit or implicit threats of physical
stalking. In this setting, the term cyberstalking can be generally defined as a course of conduct
directed at a person which involves a threat to his person, related persons or property or which
causes alarm or distress, and which is committed over a computer network.
Existing research indicate that cyberstalking is a prevalent and a growing problem worldwide
including in those jurisdictions considered in this paper. In 2016, an estimated 1.5% (3 million
persons) of all U.S. residents aged 16 or older reported to having been victims of stalking while
approximately 1 in 4 of such stalking victims also reported to having been subject to some form
of cyberstalking via e-mail (83%), instant messaging (35%) etc. According to the report, the most
frequent types of cyberstalking were sending the victim unwanted emails/messages using the
internet or social media apps/ websites like Instagram/Twitter/Facebook, monitoring victim’s
activities using social media apps/websites and posting or threatening to post
4
Alana M. Nicastro, Amber V. Cousins and Brian H. Spitzberg, 'The Tactical Face Of Stalking' (2000) 28 Journal of
Criminal Justice <https://doi.org/10.1016/S0047-2352(99)00038-0> accessed 9 March 2021.
5
However, as will be discussed below, section 7 of the Protection from Harassment Act 2014 of the Singapore law
on “unlawful stalking” marks a deviation from this common norm, as the stalking act does not require the alleged
conduct to be a repeated conduct on two or more occasions but it can also be only one occasion however it must be
either “protracted” or the stalker has to have a previous conviction for unlawful stalking in respect of the same victim.
6
Brian H. Spitzberg and Gregory Hoobler, 'Cyberstalking and the Technologies of Interpersonal Terrorism' (2002) 4
New Media & Society <https://doi.org/10.1177/14614440222226271> accessed 6 March 2021.
Electronic copy available at: https://ssrn.com/abstract=3903800
inappropriate/unwanted/personal information about the victim on internet.7 Moreover, a
nationwide survey conducted in US revealed that the prevalence rate of cyberstalking was higher
for females (2.0%) than for males (0.9%).8 At the 2011 cyberstalking survey conducted by the
National Centre for Cyberstalking Research in the UK, 324 out of the 353 participants had stated
that they considered themselves as having been subject to stalking through electronic
communication media.9A similar tendency could be seen in respect of Singapore and Sri Lanka as
well.10
Cyberstalking can have major physical and psychosocial impacts on individuals. Victims report a
number of serious consequences such as increased suicidal ideation, fear, anger, depression, and
post-traumatic stress symptomology.11 According to one study the most common traumatic
symptoms reported were sadness, insomnia, restlessness, sleep, tension and flashbacks.12Further
symptoms of dissociation, anxiety, depression and post sexual abuse trauma were more frequent
for women who were subjected to cyberstalking.13Apart from the psychological impact research
also reveals that cyberstalking had a considerable impact on academic/career functioning and on
the financial well-being of the victims14.
The present study seeks to assess the existing laws in three jurisdictions namely, UK, Singapore
and Sri Lanka. By doing so, this study endeavors to reveal the extent to which each of such laws
are effective in combatting or to mitigating cyberstalking.
7
The Bureau of Justice Statistics of the U.S. Department of Justice, 'Stalking Victimization, 2016' (2021)
<https://bjs.ojp.gov/library/publications/stalking-victimization-2016> accessed 7 March 2021.
8
ibid (n5)
9
National Centre for Cyberstalking Research, University of Bedfordshire, 'Cyberstalking in The United Kingdom'
(2011)<https://uobrep.openrepository.com/bitstream/handle/10547/270578/ECHO_Pilot_Final.pdf?sequence=1&is
Allowed=y> accessed 10 March 2021.
10
Majeed Khader and others, 'Unwanted Acquaintances: Cyberstalking As Experienced By Emerging Adults In
Singapore' [2016] Home Team Journal; Vishaka S Suriyabandara, 'An Analysis Of The Attitude Towards
Cyberbullying And Cyber Victimization Among The University Students Of Sri Lanka' (2017) 4 World Journal of
Social Science; Raisa Wickrematunga, 'Building Resilience: Responding To Cyber-Bullying In Sri Lanka - Firstpost'
(Firstpost, 2018) <https://www.firstpost.com/long-reads/building-resilience-responding-to-cyber-bullying-in-sri-
lanka-4776511.html> accessed 7 March 2021.
11
Emma Short and others, 'The Impact of Cyberstalking: The Lived Experience - A Thematic Analysis', Annual
Review of Cybertherapy and Telemedicine 2014 (2014) <https://ebooks.iospress.nl/volume/annual-review-of-
cybertherapy-and-telemedicine-2014> accessed 17 March 2021.
12
Nancy Felicy Hensler, 'Cyberstalking Victimization: Impact And Coping Responses In National University Sample'
(PhD, University of Maryland 2008).
13
ibid.
14
Emma Short and others, 'The Impact of Cyberstalking: The Lived Experience - A Thematic Analysis' (2021) 199
Annual Review of Cybertherapy and Telemedicine <https://pubmed.ncbi.nlm.nih.gov/ 24875706/> accessed 7 March
2021.
Electronic copy available at: https://ssrn.com/abstract=3903800
2. Criminalizing Cyberstalking-Legislative Approaches
2.1.United Kingdom
The offence of cyberstalking was recognized in the England and Wales by the Protection of
Freedoms Act 2012 which created two new offences of stalking by inserting new sections 2A and
4A into the Protection from Harassment Act 1997.
Under section 2A of the Act, it is an offence to pursue “… a course of conduct in breach of section
1(1), … [in which] the course of conduct amounts to stalking.’15 Accordingly, the actus reus of the
offence consists of a course of conduct that occurs on at least two occasions, which can be
considered as causing alarm or distress upon the victim. In addition, it must be found that the
complained about behaviour amounts to stalking under the law. The mens rea required is the
knowledge that such course of conduct would amount to harassment of the other person. In
determining whether the defendant ought to know that the course of conduct amounts to
harassment, the question to be considered is whether a reasonable person in possession of the same
information would think the course of conduct amounted to harassment of the other.16 The Act
does not contain a specific definition of stalking; instead, it encompasses a non-exhaustive list of
conducts which are considered to amount to this type of behaviour. This list provides among the
other examples, some instances of cyberstalking such as monitoring the use by a person of the
internet, email or any other form of electronic communication, contacting/attempting to contact a
person by any means or publishing any statement or to other material relating to a person or
purporting to originate from a person.17 Thus, it is evident to state that section 2A of the Act
recognize cyberstalking as a subset of the general offence of stalking. A person guilty of the
offence of stalking under this section is liable on summary conviction to imprisonment for a term
not exceeding six months, or a fine not exceeding level 5 on the standard scale, or both. Section
2B sets out new police powers to enter and search premises in relation to the section 2A offence.
Section 4A recognizes more aggravated forms of stalking which involve fear of violence or serious
alarm or distress. Accordingly, the elements of the section 4A offence are: a course of conduct;
15
Protection from Harassment Act s 2A(1).
16
ibid 1(2).
17
ibid 2A(3).
Electronic copy available at: https://ssrn.com/abstract=3903800
which amounts to stalking; and which causes another to fear, on at least two occasions, that
violence will be used against him or her; or causes another serious alarm or distress which has a
substantial adverse effect on his or her usual day-to-day activities. Thus, it can be interpreted
section 4A encompasses aggravated forms of cyberstalking as well since it represents an
aggravated form of section 2A. A person guilty of an offence under section 4A is liable on
conviction on indictment, to imprisonment for a term not exceeding five years and/or a fine, and
on summary conviction, to imprisonment not exceeding six months and/or a fine not exceeding
the statutory maximum.
Under Scottish law, the offence of stalking was brought in under section 39 of the Criminal Justice
and Licensing (Scotland) Act 2010. According to section 39, a person commits the offence of
stalking, where he/she engages in a course of conduct with the intention of causing the other person
to suffer fear or alarm or which he/she knew or ought to know was likely to cause such effect,18and
where in fact such course of conduct caused the other person to suffer physical or psychological
harm, or apprehension or fear for safety. Section 31 (6) of the Act identifies various types of
conduct covered by section 39 including instances of cyberstalking such as contacting a person
by email, text message or any other method, publishing any statement or other material relating to
a person, tracing the use by a person of the internet, email or any other form of electronic
communication. Since the list of examples given in this subsection is non-exhaustive, it can be
interpreted that all the other instances of stalking which takes place through the cyberspace can be
covered under this section. As regards the mental element of the offence, it is notable that the
mental element of the offence is quite broad as it consists both of subjective and objective
elements. Thus, the mental element can be satisfied either by showing that the accused subjectively
had intention to or knowledge of causing psychological harm etc., or by showing that the accused
ought to have known his conduct would cause the relevant harms. However, the physical element
requirement that the alleged course of conduct in fact caused the victim to suffer physical or
psychological harm can be seen as limiting the scope of the offence.
18
Criminal Justice and Licensing (Scotland) Act 2010, ss 39(3) and 39(4).
Electronic copy available at: https://ssrn.com/abstract=3903800
Under subsection (5) it is a defense for a person charged with an offence under this section to show
that the course of conduct “(a) was authorised by virtue of any enactment or rule of law, (b) was
engaged in for the purpose of preventing or detecting crime, or (c) was, in the particular
circumstances, reasonable”. However, since stalking by its very nature represents an unreasonable
behavior, the stipulation of reasonableness as a defense seems to provide an unnecessary
justification of such behaviour.
In Northern Ireland no legislation currently exists dealing specifically with stalking or
cyberstalking. Stalking is mainly dealt with under the Protection from Harassment (Northern
Ireland) Order 1997, which corresponds to the un-amended version of the Protection from
Harassment Act 1997 used in England and Wales prior to its recent reforms in 2012. However
Northern Ireland in January 2021 introduced to the Northern Ireland Assembly, the Protection
from Stalking Bill which is yet to become a law. The provisions in this bill corresponds with the
section 2A of the Protection of Freedoms Act 2012 of England and Wales. However the relevant
section in the proposed law does not require proof of actual physical or psychological damage
caused to the victim, as required by the UK Act of 2012.
2.2.Singapore
Singapore’s main piece of legislation which addresses online harassment related offences is the
Protection from Harassment Act of 2014. Section 7 of the Act criminalizes online stalking as a
subcategory of the offence of unlawful stalking. The section stipulates that an individual or entity
(accused) unlawfully stalks another person (victim) if the accused engages in a course of conduct
which involves acts or omissions associated with stalking; causes harassment, alarm or distress to
the victim; and the accused intends to cause harassment, alarm or distress to the victim; or knows
or ought reasonably to know is likely to cause harassment, alarm or distress to the victim. Although
the section does not explicitly refer to cyberstalking, the illustrations indicate that it applies to
cyberstalking too.
One of the noticeable features in the Singaporean stalking law is that the stalking act does not
require the alleged “course of conduct” to be a repeated conduct on two or more occasions but it
Electronic copy available at: https://ssrn.com/abstract=3903800
can also be only one occasion.19However in such a case the conduct it must either be “protracted”
or the stalker has to have a previous conviction for unlawful stalking in respect of the same
victim.20
More importantly, the Act offers a wider spectrum of remedies to victims. Firstly, once a person
is proven guilty of unlawful (cyber)stalking, on the first conviction he or she will be fined an
amount not exceeding $ 5,000 or imprisoned for a period no exceeding 12 months or both and on
a second or subsequent conviction, a fine not exceeding $ 10,000 or imprisonment not exceeding
two years or both. In addition, there are several other remedies by which the victim can seek
redress for cyberstalking. Accordingly, under section 11 of the Act, the victim can take an “action
for statutory tort” by instituting civil proceedings against the stalker and the court may award such
damages as it may deem just and equitable. Furthermore, under sections 12 and 13 of the Act, an
application may be made to a district court for a protection order or an expedited protection order
against conduct which fall within the offence of unlawful stalking. A protection order or an
expedited protection order may involve orders such as prohibiting the respondent from doing
anything in relation to the victim or any related person; requiring that no person shall publish or
continue to publish offending communication; referring the stalker or the victim or both to attend
counselling or mediation provided by such body; or giving any other direction as may be required
to effectuate a protection order.
Prior to the enactment of the Protection from Harassment Act of 2014, cyberstalking cases were
prosecuted under section 3 of the Computer Misuse Act21 and section 503 of the Singapore Penal
Code.22 Section 3 of the Computer Misuse Act criminalizes unauthorized access to a computer
material by knowingly causing a computer to perform any function. In the landmark case of Lim
Siong Khee v. Public Prosecutor,23 the accused was charged under section 3(1) of the Computer
Misuse Act in relation to his alleged tampering with the email account of a female acquaintance
and uncovering every intimate detail of her personal life, and using that information to stalk her or
harass her, and for using the email account to send out contemptible emails to her friends with
offensive descriptions of her purported intimate relations including certain pornographic
19
Protection from Harassment Act of 2014, s 7(10).
20
ibid a.
21
Computer Misuse Act No. 19 of 1993, s 3.
22
Penal Code Ordinance No. 4 of 1871 (as amended) (sg).
23
Lim Siong Khee v Public Prosecutor [2001] 2 SLR 342.
Electronic copy available at: https://ssrn.com/abstract=3903800
attachments. The accused’s defense was that the victim had in fact told him her email password
and had asked him on one occasion to check her email on her behalf. The court did not accept this
case of consent, and found the accused guilty as charged. He was sentenced to 5 months’
imprisonment. However, in the appeal the sentence was increased upto a 12 months’ imprisonment
the court considering the conduct to be completely malicious and vindictive.
Section 503 of the Singapore Penal Code which criminalizes criminal intimidation was also used
to prosecute a case of cyberstalking prior to the enactment of the Protection from Harassment Act.
The section stipulates that whoever threatens another with any injury to his person, reputation or
property, or to the person or reputation of any one in whom that person is interested, with intent to
cause alarm or to cause that person to do any act which he is not legally bound to do, or to omit to
do any act which that person is legally entitled to do, as the means of avoiding the execution of
such threat, commits criminal intimidation. In 2007, an undergraduate student, Song Yick Biau,
was sentenced to 27 months of imprisonment under the Computer Misuse Act for blackmail and
criminal intimidation under the Singapore Penal Code. The perpetrator was accused of stealing
online identities so that he could prey on women anonymously by threatening to circulate doctored
images (i.e. women with their faces superimposed over naked bodies) through the Internet. The
District Judge dismissed the defense counsel’s plea for leniency and reiterated that such offences
undermined public confidence in electronic communication, emphasizing the severity of damage
one could cause by cyberstalking another.24
2.3.Sri Lanka
Sri Lankan does not have any targeted laws which directly address the issue of cyberstalking. In
this context it is pertinent to examine to what extent some of the existing criminal laws in the
country can be used to prosecute cyberstalking.
The Computer Crime Act of 2007 criminalizes hacking and dealing with such data unlawfully
obtained etc. which can be used to capture certain instances of cyberstalking. Section 4 of the Act
provides that it is an offence to secure unauthorized access to a computer or any information held
24
Vivian Yeo, 'MSN Hacker Gets 27 Months' Jail | Zdnet' (ZDNet, 2021) <https://www.zdnet.com/article/msn-
hacker-gets-27-months-jail/> accessed 14 March 2021.
Electronic copy available at: https://ssrn.com/abstract=3903800
in a computer knowing or having reason to believe that he has no lawful authority to secure such
access and with intention to commit an offence. This section could be used to prosecute instances
of cyberstalking, i.e. where a victim’s computer was hacked by the offender with the intent of
engaging in a course of conduct involving threatening or harmful behavior towards the victim.
Similarly, section 7 of the Act which criminalizes dealing with information which the perpetrator
knows or has reasons to believe as having been obtained without lawful authority, can also be used
to capture individuals who uses such information to cyber stalk another.
Section 345 and 483 of the Penal Code may also be applied to cyberstalking. Section 483 of the
Penal Code, which is identical to section 503 of the Singapore Penal Code, creates the offence of
criminal intimidation and provides that “whoever threatens with injury to a person, to his
reputation or property or reputation of anyone whom that person is interested in, with intent to
cause alarm, or to compel the performance of an act to which he is not legally bound, or the non-
performance of any to which he is legally entitled, as the means of avoiding the execution of such
threat, commits criminal intimidation” .This provision can be used against persons who engage in
cyber-stalking by repeatedly threatening or harassing another with the intent of causing alarm or
with any other intent as mentioned under section 483. Section 3 of the Prohibition of Ragging and
Other Forms of Violence in Educational Institutions Act No. 20 of 1998 (also known as the “Anti-
Ragging Act”) contains a parallel provision which makes it an offence to criminally intimidate a
student or a member of the staff of educational institutions falling within the purview of the Anti-
Ragging Act.
Section 345 of the Penal Code on sexual harassment which provides that it is an offence to assault
or use criminal force to sexually harasses another or use words or actions to cause sexual
annoyance or harassment to such other person. Since this section covers causing sexual annoyance
or harassment by any words or actions, this presumably could cover instances of cyberstalking
which involves a sexual matter
As mentioned above, Sri Lanka’s existing penal laws has the ability to cover certain types of
cyberstalking conduct. Yet for a more effective approach, enactment of targeted laws on
cyberstalking should be encouraged.
Electronic copy available at: https://ssrn.com/abstract=3903800
3. Conclusion
As discussed above the UK and Singapore law contain provisions on cyberstalking but in varying
degrees. Every part of UK, except for Northern Ireland, have cyberstalking laws. Singapore law
uses illustrations that explicitly refer to cyberstalking recognizing such conduct as a sub category
of the offence of “Unlawful Stalking.” Sri Lanka is the only state which does not have targeted
laws on cyberstalking though the existing penal laws on criminal intimidation, sexual harassment,
ragging conduct and unauthorized access of data etc. can be utilized to a certain extent.
As noted above most of the laws in UK and Singapore refer to cyberstalking either as a separate
offence or a subcategory of the general offence of stalking. Yet, they are not without shortcomings.
To begin with, a clear cut definition for cyberstalking was rarely provided in any of the above
mentioned laws and the mens rea element most of the time required “intention of causing fear”.
Added to that some laws even require the proof of actual damage caused to the victim (i.e. Scottish
law), in which case the evidence of a repeated harassing or threatening behavior does not itself
satisfy the required actus reus of the offence. Further it should be stressed that a specific law on
cyberstalking would be encouraged since listing it out as a sub category of the general offence of
stalking can limit the clear interpretation of the offence. The above analysis reveals that each law
has its inherent strengths as well as weaknesses. Thus, what must be done is to enact a law
considering strong points and omitting the shortcoming while taking into account other possible
suggestions which would further perfect such law in order to provide a sustainable legislative
remedy.
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Table of Cases
Lim Siong Khee v Public Prosecutor [2001] 2 SLR 342
Table of Statutes-Singapore
Penal Code Ordinance No.4 of 1871
Protection from Harassment Act.17 of 2014
Computer Misuse Act No. 19 of 1993
Table of Statutes-UK
Protection from Harassment Act 1997
Protection of Freedoms Act 2012
Criminal Justice and Licensing (Scotland) Act 2010
Protection from Harassment (Northern Ireland) Order 1997
Table of Statutes-Sri Lanka
Computer Crime Act No.24 of 2007
Penal Code Act of 1883
Obscene Publications Ordinance No. 4 of 1927
Prohibition of Ragging and Other Forms of Violence in Educational Institutions Act No. 20 of
1998
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