Watching the hostile response to the Leveson inquiry from the British press and prime minister David Cameron has been a thoroughly depressing experience for Matthew Ricketson — if only because it’s been so familiar.

Ricketson is the media academic and former Age journalist who assisted Ray Finkelstein’s inquiry into the print media — the one that recommended the creation of a government-funded council to oversee all Australian media outlets. This recommendation, widely portrayed as an assault on press freedom, is still to receive an official government response nine months after the report’s release — but whispers from cabinet say there’s virtually no chance of it getting up.

Over in the UK, the press — with the exception of papers such as The Guardian — has been campaigning hard against Leveson, with The Daily Mail slamming the report as a “mortal threat to the British people’s historic right to know”.

Ricketson tells Crikey the campaign against both the Leveson and Finkelstein recommendations raises the “looming prospect” that nothing significant will ever be done to make the media more accountable. Getting the balance right between free speech and upholding press standards is already difficult; throw in self-interested media campaigning and it’s almost impossible.

British PM David Cameron came out against Leveson’s key recommendation — the creation of a new press trust — only 90 minutes after the report’s release.

“What does that tell you about the power of the media and the willingness of politicians to kowtow to the news media? It’s a deeply disturbing issue for the way our society operates,” Ricketson said.

“If significant progress can’t be made on this issue after England has been through the worst media ethics scandal in living memory, when will progress be made? Here, the news media framed the issue by saying there is no problem, we don’t have phone hacking therefore we don’t need more regulation. You can’t run that line of argument in England.”

Both the British and Australian press, Ricketson argues, have not served the public interest through their reporting on the media regulation debate.

“The way the media covers this issue is largely by acting as a mouthpiece for their own industry,” he said. “That’s something they wouldn’t allow to happen and would abhor in other industries. They would say, ‘this is a view from a vested interest and it needs to be subject to scrutiny’.

“The Leveson Report has moved very quickly to commentary about how it won’t work, how it’s the worst thing since the Spanish inquisition. The average citizen has had very little chance to assess the report in any detailed way and arrive at an informed view themselves.”

Although similar, there are important differences between Finkelstein’s proposed New Media Council and Leveson’s press trust (as thoroughly outlined by the University of Melbourne’s Denis Muller). In many ways, Finkelstein’s approach is tougher and Leveson’s more nuanced despite everyone agreeing press behaviour has been far worse in the UK.

Finkelstein’s council would be a statutory body funded by government and covering all media outlets (even websites with tiny readerships). Its main power would be ordering the publication of prominent corrections — with the option to use contempt of court powers (which carry a potential jail term) against those editors who refuse. This often gets reduced, in media shorthand, to “locking up journalists”.

By contrast, Leveson’s press trust would be funded by the industry and outlets would join voluntarily — presumably lured by incentives such as speedier and cheaper resolution of defamation cases. The big stick would be fining publications up to 1% of their turnover or one million pounds.

Ricketson wouldn’t be drawn on the pros and cons of the two approaches as the government hasn’t announced its response to Finkelstein. But doing nothing, he says, isn’t an option – even though no Australian journalists have been caught hacking phones.

“It’s the height of arrogance from people in the [Australian] media to say there is no problem. Any industry can be improved,” he said.