like “public scorn or hatred.” In other words, it refers to elements that can only be defined by the judge ex post facto. To this extent, Article 444 of the Venezuelan Criminal Code cannot provide reliable guidance to individuals in their conduct, given the serious consequence of the deprivation of personal liberty and the revocation of political rights. It does not establish a bright line to identify when it is legal or illegal to publicly denounce criminal acts or express a critical opinion about a government authority. On the contrary, the vagueness of the provision opens the door to the use of the criminal law for the creation of an intimidating environment that inhibits speech on matters of public interest.90 72. Bearing in mind the ambiguity and imprecision of these statutory definitions, and pursuant to the recommendations of the IACHR and the Inter-American Court, several countries in the region have introduced legislative reforms to either repeal crimes against honor or better define their scope. 73. In Mexico, for instance, the Federal Criminal Code provisions on crimes against honor were repealed in their entirety in 2007.91 Later, in 2011, the National Congress deleted Articles 1 and 31 of the Law on Press Crimes. Those articles referred to “attacks on privacy” and the penalties applicable to those infractions, respectively.92 74. The Supreme Court of Mexico has similarly ruled that state criminal laws that protect the honor and privacy of public servants are incompatible with the Mexican Constitution and Mexico’s international obligations on the issue. In a June 17, 2009 judgment, the same Mexican Supreme Court that ruled Article 1 of the Press Law of the State de Guanajuato unconstitutional93 held that when provisions establishing subsequent liability “are criminal in nature, and allow for the deprivation of a person’s assets and core rights—including, on occasion, his or her liberty—the requirements on [the strict formulation of the law] are even more stringent.” Examining the facts of the specific case, the Court concluded that the provision on which the appealed conviction was based94 did not “meet the requirement of exhaustiveness contained within the general principle of criminal legality, or the requirement—functionally equivalent in this case—that every restriction of freedom of expression must be provided for in advance in a clearly and precisely drafted law.” The Supreme Court explained that, first, there is “a patent lack of clarity […] resulting from the defective structuring of something that in our legal system […] is subject to strict requirements: the statutory definition of a criminal offense.” Second, it found that parts of this provision were vague and overly broad because they referred to merely hypothetical damages, and covered both direct harm to a person’s reputation and the simple “discrediting” of it, and the potential effects “on the interests” of individuals. In the Court’s opinion, “The inclusion of the latter irremediably obscures the interest or right that the legislature supposedly aims to protect from the abusive exercise of freedom of expression and leaves the definition of the offense completely open.”95 75. In 2013, Jamaica passed the Defamation Act,96 which completely eliminates the use of the criminal law in defamation cases. The law amended the defamation laws in force at the time, which had been enacted 90 IACHR, Report No. 88/10, Case 12.661, Merits, Néstor José y Luís Uzcátegui et al., Venezuela, July 14, 2010, para. 279. DOF. April 13, 2007. Decreto por el que se derogan diversas disposiciones del Código Penal Federal y se adicionan diversas disposiciones al Código Civil Federal. See also, House of Representatives. May 2012. Criminal defamation and defamatory libel [Calumnias, difamación e injurias]. Estudio Teórico Conceptual, de antecedentes, de las reformas al Código Penal Federal, iniciativas presentadas, y de Derecho Comparado. 91 92 Mexico. Law on Press Crimes. Available at: http://www.diputados.gob.mx/LeyesBiblio/pdf/40.pdf 93 Supreme Court of Mexico. Direct Amparo 2044-2008, http://www2.scjn.gob.mx/juridica/engroses/cerrados/publico/08020440.010.doc. June 17, 2009. Available at: 94 Art. 1 of the Guanajuato Press Law. Available at: http://docs.mexico.justia.com/estatales/guanajuato/ley-de-imprenta-delestado-de-guanajuato.pdf 95 Supreme Court of Mexico. Direct Amparo 2044-2008, http://www2.scjn.gob.mx/juridica/engroses/cerrados/publico/08020440.010.doc. June 17, 2009. Available at: 96 On November 28, Sir Patrick Linton Allen, Governor General of Jamaica, assented the Defamation Act. Jamaican Parliament. Defamation Act, 2013. Act No. 31.