This study comparatively analyzes the legal regulations regarding the fight against disinformation in the European Union, Spain, and Türkiye within the framework of militant and defensive democracy theories. It emphasizes that the legal approaches of each entity are shaped not only by normative preferences but also by their understandings of freedom of expression and strategies for protecting democratic institutions. The European Union and Spain consider disinformation as a systemic threat and follow a defensive democracy model based on preventive and proportionate measures. In contrast, Türkiye defines disinformation as an individual-based criminal offense and adopts a punitive, content-focused regulatory approach, which aligns more closely with the militant democracy model. The study demonstrates how different political and legal traditions shape approaches to combating disinformatio...