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You're missing the point. The difference in freedom of speech between the US and Canada and the UK is not because of the first amendment. Canada and the UK also have laws protecting freedom of speech in basically the same language, but they've been interpreted differently. The first amendment also used to be interpreted very loosely, resulting in the US having many laws restricting speech in the past that would not be allowed today.
The UK doesn't have constitutional freedom of speech; it has no constitution. Yes, there are laws saying free speech is a right, but those laws are automatically overridden by any subsequent laws that breach freedom of speech under the doctrine that Parliament can't bind itself. In this case (though not the Canadian or EU case), it's not a matter of interpretation.
Yes, there has been a miscommunication here. You said "the UK and Canada actually do have freedom of speech", which I interpreted as meaning "the state of speech in the UK and Canada is what I, Glassnoser, would describe as 'free'". Lots of people, including the governments of Canada/the EU/the UK, agree with that latter sentence, because they are naïve and/or in denial regarding the result of "freedom of speech, unless your ideas suck". Hence, I assumed you were one of these people and attempted to correct your understanding. It would now appear that what you meant was "the UK and Canada actually do have a constitution requiring them to respect free speech, but they flagrantly ignore it, pretending that free speech is some pitiful, mutilated version of itself that doesn't accomplish its purpose". This is still untrue with regard to the UK (see #1), but I agree with it in regard to Canada. I apologise for misunderstanding your sentence, but I hope you'll agree that your actual meaning was not exactly clear.
The UK has an unwritten constitution. But that's irrelevant. I didn't say it had a constitutional guarantee of freedom of speech. It has freedom of speech. They could repeal that law, but they haven't. They've simply interpreted it to not be as restrictive as the first amendment. The US Supreme Court has done the same in the past.
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