State, Morality, and the Digital Public Sphere: A Comparative Study of Content Moderation Rationales in China and Pakistan

Abstract

Content moderation regimes are typically studied within their own national and political contexts, and rarely compared across ostensibly incompatible political systems. This paper compares the moral rationale of content moderation in China and Pakistan, two states that differ sharply in regime type, religious establishment, and legal tradition, to examine whether a common structural pattern underlies their otherwise distinct architectures. Drawing on China's Cyberspace Administration “Qinglang” campaigns and Pakistan's Prevention of Electronic Crimes Act (PECA) of 2016 and its 2025 amendment, the analysis compares three axes of moderation: the definitional vocabulary used to justify harm, the institutional authority empowered to adjudicate it, and the operational logic through which enforcement proceeds. Existing scholarship has treated Chinese cyber-sovereignty and Pakistani blasphemy-obscenity regulation as largely separate literatures, leaving open what, if anything, connects authoritarian and hybrid-democratic content regulation. This paper addresses that gap through a documentary comparative analysis of primary regulatory texts, government and non-governmental reports, and peer-reviewed scholarship, structured through a most-different systems design. The analysis suggests that despite divergent definitional grammars and institutional architectures, both regimes are consistent with a recurring pattern of regulatory and extra-legal attention to women's digital visibility. This pattern is conceptualized as digital pardah: a reconstruction of modesty governance in which platform infrastructure, statutory language, and informal social authority jointly, rather than singly, produce the conditions under which women's online presence becomes governable. The paper argues that digital pardah captures a mechanism, the joint and often uncoordinated action of state, platform, and family authority on the same body, that existing frameworks of platform governance, algorithmic visibility, and digital authoritarianism do not individually specify.