for instance, men of the gown, this is no libel, but it must descend to particulars and individuals to make it libel." This jury believed that only individuals who believed they were specifically defamed had a claim to a libel case. Since the jury was unable to identify the exact people who were being defamed, there was no cause to identify the statements were a libel. Another early English group libel which has been frequently cited is King v. Osborne (1732). In this case, the defendant was on trial "for printing a libel reflecting upon the Portuguese Jews". The printing in question claimed that Jews who had arrived in London from Portugal burned a Jewish woman to death when she had a child with a Christian man, and that this act was common. Following Osborne's anti-Semitic publication, several Jews were attacked. Initially, the judge seemed to believe the court could do nothing since no individual was singled out by Osborne's writings. However, the court concluded that "since the publication implied the act was one Jews frequently did, the whole community of Jews was defamed." Though various reports of this case give differing accounts of the crime, this report clearly shows a ruling based on group libel. Since laws restricting libel were accepted at this time because of its tendency to lead to a breach of peace, group libel laws were justified because they showed potential for an equal or perhaps greater risk of violence. For this reason, group libel cases are criminal even though most libel cases are civil torts. As of 2017, at least 130 UNESCO member states retained criminal defamation laws. In 2017, the Organization for Security and Co-operation in Europe (OSCE) Office of the Representative on Freedom of the Media issued a report on criminal defamation and anti-blasphemy laws among its member states, which found that defamation is criminalised in nearly three-quarters (42) of the 57 OSCE participating states. Many of the laws pertaining to defamation include specific provisions for harsher punishment for speech or publications critical of heads of state, public officials, state bodies and the state itself. The OSCE report also noted that blasphemy and religious insult laws exist in around one third of OSCE participating states; many of these combine blasphemy and religious insult with elements of hate speech legislation. In Africa, at least four member states decriminalised defamation between 2012 and 2017. The