It's important to be precise because everything is not the same. In the German case the ruling was not because someone posted a critical meme, but because it was not entirely obvious the picture was edited (as in: you and I can immediately see the photo was edited, but some people will not recognize the edit). I do not agree with the ruling, but as a citizen I am happy that in Germany we still care if claims are true or not (and try to prevent people from lying).