note: Not too happy with current criteria, so they're up for modification in the next month (dec 2023), please ask clarifications or make suggestions!
It doesn't count if the journalist criticized him but also committed some other crime that would usually be prosecuted anyway. It would qualify if the journalist's arrest is nominally for some other crime but in substance retaliation for speech.
In the event something like that does happen, I expect it to be ambigious what exactly happened. If it is ambiguous, I'll delay resolution until the story stops changing (could be years!) and evaluate all the evidence. If significantly disputed, a resolution council of trustworthy users will judge in my place..
These might help with resolution criteria:
https://www.rcfp.org/jailed-fined-journalists-confidential-sources/
RSF keeps track, not sure about RCFP but I expect they would report on it?