the crimes of "illegal constraint" (Article 146 of the Penal Code) and "arbitrary exercise of discretion" (Article 345 of PC), defined as breaking the law as a vigilante. Bulgaria In Bulgaria, defamation is formally a criminal offence, but the penalty of imprisonment was abolished in 1999. Articles 146 (insult), 147 (criminal defamation) and 148 (public insult) of the Criminal Code prescribe a penalty of fine. Canada In Canada, the Criminal Code specifies the following as criminal offences: Defamatory libel, defined as "matter published, without lawful justification or excuse, that is likely to injure the reputation of any person by exposing him to hatred, contempt or ridicule, or that is designed to insult the person of or concerning whom it is published", receives the same penalty. A "libel known to be false" is an indictable offence, for which the prison term is a maximum of five years. The criminal portion of the law has been rarely applied, but it has been observed that, when treated as an indictable offence, it often appears to arise from statements made against an agent of the Crown, such as a police officer, a corrections officer, or a Crown attorney. In the most recent case, in 2012, an Ottawa restaurant owner was convicted of ongoing online harassment of a customer who had complained about the quality of food and service in her restaurant. According to an Organization for Security and Co-operation in Europe official report on defamation laws issued in 2005, 57 persons in Canada were accused of defamation, libel and insult, among which 23 were convicted – 9 to prison sentences, 19 to probation and one to a fine. The average period in prison was 270 days, and the maximum sentence was 4 years of imprisonment. Croatia In Croatia, the crime of insult prescribes a penalty of up to three months in prison, or a fine of "up to 100 daily incomes" (Criminal Code, Article 199). If the crime is committed in public, penalties are aggravated to up to six months of imprisonment, or a fine of "up to 150 daily incomes" (Article 199–2). Moreover, the crime of defamation occurs when someone affirms or disseminates false facts about other person that can damage his reputation. The maximum penalty is one year in prison, or a fine of up to 150 daily incomes (Article 200–1). If the crime is committed in public, the prison term can