The same cartoon can raise mirth in one country, bile in another, and therein lies its beauty, says Nicholas Hiley

The dilemma seems a very familiar one. An English cricketer becomes a national hero. Searching for a way of representing this, the cartoonist of a London evening paper draws him towering over a group of smaller and overawed historical figures, one of them the Prime Minister and others labelled "Adam", "Caesar", "Mahomet", and "Columbus". The cartoon attracts admiring letters from regular readers, but a small London Muslim group sends a strong protest about the representation of Muhammad. The editor expresses regret, but the cartoon soon circulates among Muslims in India, protest meetings are held and there are demands for the British Government to punish the editor and to take steps to prevent such offences in future.

The suggestion that a sportsman might be more famous than Muhammad seems very contemporary, but this was 41 years before John Lennon made his equally controversial claim about The Beatles and Jesus, and 80 years before Jyllands-Posten published its own cartoons of Muhammad. The cricketer in question was Jack Hobbs, and the cartoon, by the famous political cartoonist David Low, appeared in The London Evening Star on August 17, 1925. The sense of outrage among Muslims was as intense as it is now. "When a picture of the Prophet appears in a cartoon, no explanation will suffice; it is an insult," reported the Calcutta correspondent of the Morning Post . "There is no doubt whatever that, quite unwittingly, the cartoon has committed a serious offence, which, had it taken place in this country, would almost certainly have led to bloodshed." The protests had a lasting impact on Low. "The whole incident showed how easily a thoughtless cartoonist can get into trouble," he wrote later. "I had never thought seriously about Mahomet. How foolish of me. I was ashamed - not of drawing Mahomet in a cartoon, but of drawing him in a silly cartoon." Low's cartoon belonged to a single moment of popular culture, and was a complex mixture of ironic references to religion, politics, sport and even slang - the title expressing the fact that Hobbs, not Muhammad, was absolutely "IT".

That complexity is central to the British tradition of political cartooning, and developed through 200 years of annoying and amusing the public. The Jyllands-Posten cartoons have little to do with that tradition, and that seems to have been an important part of the decision not to reprint them here. In the British context, an editorial in The Guardian explained, these are unsophisticated images that "many newspapers would reject on those grounds alone".

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The British tradition is caustic, detached, ironic and deeply embedded in British political culture. That makes it hard to understand in communities where irony is not a natural part of the political process, as the cartoonist Dave Brown found three years ago, on the eve of the Israeli elections. His cartoon for The Independent of January , 2003, drawn in the wake of an Israeli attack on Gaza City, was a dark comment on what he saw as a "pretty perverse" form of electioneering. As attack helicopters broadcast political slogans, Israeli Prime Minister Ariel Sharon was shown biting the head off a child, saying "What's wrong... you never seen a politician kissing babies before?". Brown's cartoon was a tangle of references from popular culture, classical mythology and fine art. The helicopters might come from Apocalypse Now , but, as he acknowledged in the margin, the main composition was taken from Goya's 1819-23 painting of Saturn eating one of his own children, fearful of a prophecy that they would eventually overthrow him. Using this image to suggest that Sharon was killing those he should protect made the cartoon especially powerful. But to the Israeli Embassy it resembled cartoons in some Arab newspapers, based on the ancient "blood-libel" that Jews slaughtered Christian children and used the blood in their rituals. The embassy condemned it as a cartoon that "would not have looked out of place in Der Sturmer " - the anti-Semitic Nazi magazine - and it took its protest to the Press Complaints Commission. But the PCC decided that the cartoon contained "nothing... that referred to Mr Sharon's religion", and was valid political comment.

In this case, the PCC also said it was "unreasonable to expect editors to take into account all possible interpretations of material they intend to publish", but that again raises the problem of moving cultural forms across national boundaries. Brown's cartoon had one set of meanings in London, but within months it was being carried by radical Muslims in India, demonstrating against Israel, to deliver a different message. As in the case of Jyllands-Posten , images change as they cross boundaries. If you're going to draw Muhammad, admitted the cartoonist Chris Riddell of The Observer , "it's got to be a hell of a cartoon. It's not worth playing with this stuff unless you really mean it."

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Given this complexity, it is not surprising that, in the wake of the Jyllands-Posten cartoons, many British cartoonists have taken refuge in the apparently simple concept of free speech. Peter Brookes of The Times believes that cartoonists "should have absolute freedom to express a point of view" and others have argued against even self-censorship. "Your job as a cartoonist is not to censor yourself," explains Kate Evans, environmental campaigner and Guardian cartoonist. "People are always going to threaten to kill each other."

But the argument that cartoons don't kill people, people kill people, makes meetings of outraged cartoonists feel more like rallies of the American National Rifle Association. It also encourages the belief that British newspaper cartoonists normally operate in complete freedom. In fact, British newspaper cartoonists are subject to a range of pressures that compromise, or at least define, their freedom of speech. The first set of pressures comes from the readers, who must at least understand and hopefully tolerate the cartoons. In July 1998, a cartoon by Martin Rowson in The Guardian carried a spoof list of Trade Secretary Peter Mandelson's platitudes, including "The Pope is Catholic...The Blairs shit in the woods". A reader, apparently taking this literally, complained to the PCC that the cartoon was "in extremely bad taste", and The Guardian made only a half-hearted defence, admitting that its cartoonists "often tread a narrow path of acceptability".

Newspapers are not always the best supporters of their cartoonists on this narrow path. In April 2003, Steve Bell drew another cartoon for The Guardian of a simian US President George W. Bush squatting on a toilet encrusted with excrement using paper printed with the UN emblem. The heading was "Of course there will be a role for the UN". The cartoon also featured Saddam Hussein as a sewer rat and Tony Blair as a poodle buried up to its neck in shit. Bell doesn't submit roughs, which makes censoring his cartoons difficult, but after careful thought the editor removed three turds. Pressure can also come from journalists. In October 1971, Michael Cummings of the Daily Express drew a cartoon of Soviet leader Leonid Brezhnev dressed as "Father O'Brezhnev Missionary to Ulster", arriving in Northern Ireland with a consignment of tanks, after guns and explosives from Czechoslovakia had been intercepted on their way to the IRA. Journalists on the Scottish Sunday Express objected and halted production, losing 350,000 copies, although the International Press Institute did afterwards condemn their action as "a serious threat to freedom of expression".

Cartoonists can even come under pressure from distributors, most famously in 1963 when Gerald Scarfe's cover for the Private Eye annual, showing Prime Minister Harold Macmillan as a naked Christine Keeler, led to a ban by the four largest book wholesalers, including W. H. Smith.

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Advertising can also offer the chance for censorship, as in October 1982 when, in the midst of an IRA bombing campaign, Raymond Jackson of the London Evening Standard drew a spoof film poster advertising "The Ultimate in Psychopathic Horror - THE IRISH". Ken Livingstone's Greater London Council complained that it was racist, and when the PCC ruled that it was simply a brutal cartoon on a brutal theme, the GLC cancelled all of its Evening Standard advertising.

For 200 years, British political cartooning has been an awkward compromise between what the cartoonist wants, what the editor can accept, what the readers can understand and what the law will allow. Against this background the attempt to claim complete freedom of speech looks like an effort to find comfortable certainties in a difficult secular democracy. Ten generations of political cartoonists have shown us that the search for truth isn't a simple process, but is grubby, challenging and difficult, as well as glorious and outrageous. The real loss of freedom comes in swapping this complexity for any simple set of beliefs.

Nicholas Hiley is head of the Centre for the Study of Cartoons and Caricature at Kent University.