Two countries, two approaches, one problem. Last Monday, Singapore proposed a controversial anti-falsehoods law on fake news to be debated in its parliament. The next day, WhatsApp in India launched a fact-checking service ahead of national elections, which start this week.
Both are attempts to solve a major issue: the rapid spread of untruths and fake news across social media, sparking social divisions. This is a problem that has caused serious divisions across the world, from Mumbai to Washington.
They are attempts from two different directions, in Singapore, the policy-led approach of regulating content, and in India, the tech approach of amending the platform.
In this delicate dance between technology and politics, countries around the world are watching to see who gets it right.
There is no widely accepted definition of fake news, which can range from outright lies and conspiracy theories, to misinformation or facts presented in a misleading way. But the harm it causes is real and quantifiable.
In India, there have been a spate of attacks dubbed the “WhatsApp lynchings”, where rumours of crimes, often child-abductions, spread on the messaging app and result in mob-violence towards individuals who later turn out to be innocent. Dozens have so far died and plenty more have been injured. Although WhatsApp is not a social network per se, WhatsApp groups can grow to hundreds of users and very rapidly spread messages. India is the app's largest market, with more than 200 million users.
Each country that has sought to tackle fake news has done so in response to its own particular social problems, and sought a solution in line with its political culture.
Singapore's anti-fake news law is a case in point. A small country of mixed ethnicities and faiths, the success of Singapore has always depended on a certain harmony among the different groups. It is the government's contention that fake news threatens to create splits.
The proposed law would give the government the ability to determine what is true and what is not – and then force companies like Facebook or Twitter to either amend the content – for example inserting a warning that the post is considered untrue – or remove it entirely, under threat of heavy fines. Meanwhile, individuals who spread fake news could face jail terms.
One of the reasons why Singapore's law has received so much attention is because the tech giants are concerned it could catch on. Singapore is not alone in Asia or across the world in seeking to regulate online content or creating laws that punish those who share misinformation.
Egypt signed into law its first piece of cyber crime legislation in September. Russia followed up with its own fake news law in mid-March. In January, the European Union warned tech giants such as Google and Twitter that if they did not do more to combat disinformation, they would face regulation.
But whereas broadly those two laws are aimed at individuals, the Singapore bill goes further, seeking to amend the social media platforms themselves.
In fact, the Singapore law follows a precedent set last November in France, where a law was passed that allows judges to force the removal of fake news from websites. That law was narrowly focused and only applies in the three months before elections, but it has set a precedent that even in liberal democracies the spread of fake news can be subject to legal restraint.
On the other side, tech giants are also trying to halt the spread of fake news themselves.
Last week, WhatsApp launched a service that allows Indian users to check whether information is accurate. The service, called Checkpoint Tipline, is run in collaboration with three other organisations and allows users to forward a message to the service and have it classified as accurate or not.
Yet the service has some immediate and glaring issues. It is only available in four regional Indian languages; India's constitution recognises twenty-two. When a news agency tested the service, the message remained unclassified two hours later, a life-time in fake news. It also relies on individuals to use it and believe the results. In the case of an individual facing mob justice for a rumour, it is hardly clear who might message the service and what the mob might make of the response.
And therein lies the broader problem of fake news.
If fake news were simply a question of agreeing on facts, then it could perhaps be solved. But the phenomenon of fake news is an amalgam of several broader issues: deep political divisions, a lack of trust in politics and the media, a desire to be part of a particular community, the psychology of how people believe things, and a technology that breaks down national and international borders.
Tech companies and policy specialists come at it from two different angles, each believing the problem can be solved with more technology or more policy.
Both have a strong imperative to solve it; policy-makers privilege social harmony, and some may want to curb divisive opinions, while tech companies are wary of the threat of more regulation or expensive legal action and prefer to solve it themselves.
But precisely because these issues have rapidly become part of the modern landscape of political discussion, they are not likely to be solved easily, neither through technology nor policy alone.
What is happening instead is a delicate dance between the two, each side trying, in different countries, to find an answer. The two methods, in Singapore and in India, will be watched closely, far beyond Asia, to see whether the ordered city-state or the chaotic democracy can get the balance right.