"Hit list." So reads a newspaper headline shown in Fitna, a short film by Dutch MP Geert Wilders that correlates jihadist violence with Koranic decrees. Accompanying the headline are photos of the "hit list" members: murdered moviemaker and provocateur Theo van Gogh, human rights activist and then-parliamentarian Ayaan Hirsi Ali, and Wilders himself.

With van Gogh long dead and Hirsi Ali having been run out of the Netherlands years ago, the final element of the trio is now being targeted — only this time it is the Dutch legal system doing the heavy lifting on Islamists' behalf. Last week, an appeals court instructed prosecutors to put Wilders on trial for his criticisms of the Islamic faith:

The three judges said that they had weighed Mr. Wilders' "one-sided generalizations" against his right to free speech, and ruled that he had gone beyond the normal leeway granted to politicians. "The Amsterdam appeals court has ordered the prosecution of member of parliament Geert Wilders for inciting hatred and discrimination, based on comments by him in various media on Muslims and their beliefs," the court said in a statement.

That a citizen will be dragged before magistrates to be judged on his negative opinions about Islam and Islamists is disturbing enough. More disturbing is that such instances are far from uncommon in this new century. Among the most infamous examples:

In 2004, two pastors were found guilty of violating hate speech laws of Australia's Victoria state following remarks made during a seminar on Islam.

Journalist Oriana Fallaci spent the final months of her life preparing to go to trial for "defaming Islam" in Italy. She succumbed to cancer in 2006.

Due to her strident critiques of Islam and Muslims, actress Brigitte Bardot has been repeatedly convicted and fined for "inciting hatred," most recently in June 2008.

A Canadian tribunal heard a complaint that Ezra Levant had promoted hatred by reprinting the Danish Mohammed cartoons. The charges were dropped last year.

Maclean's was cleared of official wrongdoing for running an excerpt from Mark Steyn's controversial book America Alone.

Some have suggested that Wilders' high-profile case could be a blessing in disguise by helping to shine light on the Islamist agenda in the West. Perhaps. But win or lose, one thing seems certain. Wilders will not be the last citizen made to answer for speech that Islamists and multiculturalists alike yearn to silence. The only question is: who's next?