Citizenship, Nationality and Ethnic Minorities in Three European Nations

Citizenship, Nationality and Ethnic Minorities in Three European Nations*

DAVID M. SMITH AND MAURICE BLANC

Introduction In this paper we look at the question of citizenship in democratic society, by considering the treatment of ‘ethnic minorities’ in the UK, Germany and France. By considering their rights both of entry and as residents, we can observe the different implications to be derived from different national definitions of citizenship and of ethnicity. Partly as a result of the increasing numbers of economic refugees since the end of the 1980s, Germany has seen considerable changes during the last few years. The German constitution was amended on 26 May 1993 to restrict the right of asylum and a debate about the possibility of easing the process of naturalization for foreign residents continues to develop. In France, the conservative government has rapidly moved towards restricting access to French nationality and citizenship. A new Nationality Act was adopted on 13 May 1993 and most of its provisions’ were accepted by the Constitutional Court in September of that year. Through a constitutional reform adopted on 19 November 1993,

* The authors are grateful to Claudia Schoning-Kalender and to Karin Veith for their useful comments. The research underlying this paper is a product of a Tri-national Action Research Project on European Citizenship. The work was prepared within the Minorities Group of that project, which, in addition to the authors, consisted of L. de Almeida, M. Badjan, P. Calinicos, C. Delon, N. Derfouli, S. Lee, 0. Mimica, D. Richardson and C. Standhat. It was funded by the Deutsch-Franzosisches JugendwerW L‘Office Franco- allemand pour La Jeunesse (ParisBonn), Bureau VII. It is an updated and revised version of a paper already published in German in 1994 in Informationen zur Raumentwicklung, 5/6, 1994: special edition on Auslander und Aussiedler-Anforderungen an die Bundesrepublik Deutschland. Some of the material has previously appeared in the European Journal of Intercultural Studies, 2.3, 1992 and in Espaces et Sociitks, 68, 1992.

1 The Constitutional Court removed: (1) the link between sending back to the frontier and the ban on re-entry to French territory; (2) the ban on foreign students bringing their families with them; (3) the possibility of being held for 3 months for a foreigner without papers; (4) the right for the State Prosecutor to allow a mayor to postpone a marriage to a foreigner (Le Monde, 15-16 August 1993). On 17 June 1993 the National Assembly adopted an amendment proposed by M. A. Marsaud, a gaulist (RPR) member, allowing the police to check foreigners’ papers and assess their status ‘on any ground other than race’ (se fonder sur tout tltment permettant de prtsumer la qualitt d’ttranger autre que la race). As has been observed, this paradoxical assumption is a sort of psychoanalytical denial (Frappat, Le Mode, 24 June 1993). In France, ethnicity, like religion, is supposed to be a private matter. An ‘ethnic question’, either in a census or on an application form, would be contrary to the French constitution and would infringe the data Protection Act. This contrasts interestingly with the UK, where the Commission for Racial Equality was consulted on the drafting of ‘ethnic questions’ on the census form. Another notable difference is that whilst the UK Commission for Racial Equality is advocating ethnic monitoring, this is not allowed elsewhere.

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Citizenship, nationality and ethnic minorities 67

the Parliament restricted the right of asylum. Police controls have become stricter, even more so with the recent spate of bombings, with every ethnic minority being presumed to be ‘an illegal immigrant’, if not a terrorist. The debates in the UK have been less turbulent in comparison, though the implementation of a new Asylum and Immigration Appeals Act in July 1993, which removed most rights of visitors to appeal if they were refused entry, has been associated with the increasingly tough practices of police and the Immigration Service, culminating in the death of a black woman (New Statesman and Society, 13 August 1993). This, plus the election in October 1993 of a British National Party (fascist) local councillor in a predominantly Asian2 part of London, raised the temperature, though the councillor in question has subsequently lost his seat. The tougher approach of the Immigration Service nearly produced a diplomatic incident when in December 1993, a planeload of visitors from Jamaica was detained over Christmas and a large number refused entry. This led to fears that visa restrictions are about to be imposed upon Jamaicans, though the Immigration Minister has denied this. Jamaicans, along with Columbians and Bangladeshis currently have the highest ratio of refusals of entry into Britain.

To compare ethnicity and citizenship in these three countries in such a rapidly changing situation presents a considerable challenge. Nevertheless, we believe that such a comparison, embedded in a historical context, can offer examples of alternative patterns of relationship which are of value for the better understanding of the most recent developments. Using the conceptual framework of citizenship rights devised by T. H. Marshall (1950) and the definition of ethnic group used by Max Weber (1968), we offer a detailed analysis of citizenship rights and ethnic minorities using data from the UK, Germany and France. Using an ideal-typical approach and adopting the method of two by twocomparisons (De Rudder, 1984) we are able to demonstrate that the UK and Germany represent extreme cases on a continuum of conceptions of citizenship. We then outline how elements of these two extremes are combined in the case of France. Our comparison reveals that different definitions lead to very different implications for members of ethnic minority groups within each society.

The nature of the minority groups is different within the three societies. The ethnic minorities resident in the UK disproportionately originate from the countries which previously formed the British Empire and subsequently the Commonwealth. In Germany, on the other hand, ethnic minorities tend to come from neighbouring states, both within and outside the European Union. In France, minorities exist which originate both from the areas of French Colonial influence, particularly the Maghreb, and from neighbouring states. Concerning the UK, we will argue that the starting point for the understanding of citizenship is territoriality. Citizenship is not identified with nationality per se, so that one can enjoy extensive rights of citizenship without holding full British nationality. Entry into Britain is exceedingly difficult, even for many of those who hold a form of British nationality, as we will demonstrate. However, once in the UK with established residence, legal, political and social rights of citizenship follow automatically. For example, there is formal equality before the law and in access to social rights like social housing and welfare. There is also the right to register to vote in both national and local elections. As we will show, other legislation specifically protects ethnic minorities from discriminatory practices in a wide field of activities.

At the opposite extreme, Germany has a definition of nationality and citizenship strongly based in German ethnicity, understood in a very biological way. Formally, German nationality is open to anyone who can establish their German origin irrespective of country of residence, although, as we will demonstrate, the practice is more restrictive

2 ‘Asian’ is a term used in the UK to refer in the main to ethnic groups originating from the Indian subcontinent. This includes Indians, Pakistanis and Bangladeshis. The term is used sometimes to refer also to Chinese and other Asian people but is mostly, as in this case, reserved for the Indian subcontinent.

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68 David M. Smith and Maurice Blanc

than this. Whilst in Germany all citizens have full access to legal, political and social rights, ethnic minorities outside the German ethnic group have had little or no basis upon which to claim citizenship and so, full citizenship rights. This is particularly marked in the case of political rights which are restricted to access to the Consultative Councils for Foreigners, which, as the name indicates, are only consultative. There is no right to vote in even local elections except for citizens. Whilst some social rights are available to non- citizens they continue to have fewer economic rights than Germans, unless they are citizens of another European Union country, in which case they are covered by European law. Whilst Germany is currently engaged in a substantial debate on these issues, the definition of ethnicity continues to have the effect of severely restricting citizenship rights. We will further argue that, although there is legislation against direct discrimination, this is not effective in safeguarding social rights.

France, we claim, holds a position between these two extremes of the UK and Germany. Whilst foreigners resident in France remain foreign and so, typically lack full citizenship rights, long term residence does give their children, under certain conditions, the right to apply for full citizenship on attaining their majority. France, like Germany, continues to associate nationality with citizenship, so that failure to obtain nationality tends to severely restrict rights of citizenship. For example, like Germany, French non- citizens do not have political rights. Social rights, like social housing, are available - though these tend to operate through some sort of housing association anyway - and the French law against racial discrimination, like that of Germany, only deals with cases of direct discrimination.

We will subsequently go on to consider the implications of different definitions of ethnicity and citizenship for the European Union as it moves - post-Maastricht - towards greater unity. This raises the question as to what kind of unity is envisaged at the European level. A consensus on giving a modicum of political rights seems likely. However, this process is likely to continue to exclude non-European Union residents, like the Turks in Germany or the Arabs in France, unless such rights have a territorial element. Finally, we offer some recommendations for future development of European law of citizenship and its rights.

The concepts of citizenship, the nation state and ethnicity Citizenship Citizenship can be understood as membership of a national community which confers

Dimension Rights conferred Social institutions in which Historical location Rights are located

Civil Rights necessary for Rule of Law and the system Eighteenth Century individual freedom of the Courts

Political Rights to exercise Parliamentary institutions Nineteenth Century political power

Social Rights to standard of life Social Services and Twentieth Century and the social heritage of the Society

Education

Figure 1 Marshall on citizenship



certain rights and obligations. T.H. Marshall (1950) does not limit his definition of citizenship to traditional concerns about civil rights but recognizes three different dimensions of citizenship, each conferring different rights, located in different social institutions and arising in English society at different historical times. Changes in the nature of citizenship and its rights arise out of conflict between social institutions and between social groups within the society. Marshall’s argument might be summarized diagramatically (Figure 1).

Touraine, from a very different theoretical perspective, recognizes similar dimensions: ‘Democracy is only strong when it subjugates political power in respect of rights which are ever more widely defined, first as civil, then social and cultural’ (Touraine, 1992: 375). Dahrendorf (1990) also, though he is most concerned to argue that rights must be independent of obligations: ‘The key point about the obligations of citizenship is . . . that . . . they have no trade-off relationship with citizenship rights. Rights are absolute’ (Dahrendorf, 1990).

It is also necessary to distinguish between rights as absolute in principal and the problems associated with applying them in practice, for citizenship is surely a process. Deakin (1969) makes this point clearly: ‘Definitions of citizenship are simple enough to produce: they are part of a lawyer’s stock in trade . . . The key issue in assessing the real significance of citizenship in the broader sense is the terms on which rights conferred . . . are guaranteed and the manner and extent of access to them’ (Deakin, 1969: 24). This is nicely illustrated by the method of distribution of social housing practiced in the UK in the 1960s (Daniel, 1968). Housing was allocated to those who needed rehousing because of slum clearance and those who were homeless, but mainly through a system of waiting lists based on a rationing system, the criteria of which were length of residence, length of time on the list and urgency of housing need. Whilst ethnic minorities were legally free to apply for such housing, the criteria were such that they were very unlikely to be successful. Subsequent legislation altered the system of allocation (Deakin, 1969).

Others argue that there is a much more fundamental tension between the legal and social aspects of citizenship. Those of the political right have argued that a definition of social citizenship which includes universal rights to both income and welfare is both unsustainable and undesirable (Plant and Barry, 1990). Others (Roche, 1992) argue that social structural changes have had an impact upon the complexity of social citizenship. Contradicting Dahrendorf (above), Roche argues that: ‘A new generation of social rights appropriate to changing structural conditions will need to be fought for and developed. And finally a new approach to social rights, which explicitly connects them with obligations and responsibilities . . . needs to be developed’ (Roche, 1992: 245). Such attempts to redefine the universal nature of citizenship rights have important implications for the position of ethnic minorities.

Citizenship, cities and the nation state Marshall was particularly interested in exploring the development of citizenship in his own society - that of England up to the beginning of the twentieth century - and the conflicts between the institutions and the social groups which arose in that society, in that historical period. It is not surprising then that the particularities of his analysis were bounded by the circumstances of the state and that his conceptualization of citizenship was very much posed within the bounds of the nation state. Indeed, for Marshall, it is the industrialized and urbanized nation state which is the focus of interest. If, as writers from Aristotle onwards have argued, citizenship is about membership of or participation in a community, then what is distinctive about the modem nation state is the scale of that community. Marshall’s analysis of political and social rights is firmly bound up in an urban society. The tensions and conflicts between social groups out of which developed extensions of citizenship rights, only appear to make sense within the context of a city- based civilization. Marshall is particularly interested in the social conflicts between



classes within industrial capitalist society, the development out of this conflict of political and social rights and their mediation in subsequent conflict. However, the development of the necessary administrative structures for the institution and distribution of such rights is also important. So the city, within the modem capitalist nation state, has been a key focus in the development and the enhancement of the rights of citizens.

However, Held (1989) argues that modem urban societies have moved on and that Marshall’s emphasis upon the nation state is now a limitation upon his analysis and that of his followers, particularly Giddens: ‘Rights and duties are recognized in international law which transcend the claims of nation states and which, whilst they may lack coercive powers of enforcement, have far reaching consequences’ (Held, 1989: 176). Dahrendorf (1990) makes a related point, though he sees international intervention more in terms of establishing a sort of world citizenship. Whilst he acknowledges that this has not so far been very successful, he does point hopefully to the observation that ‘[mlost civilized societies have chosen to grant the strangers in their midst a modicum of citizenship rights’ (Dahrendorf, 1990). This whole debate has a significance for the issue of European unity and European citizenship. Within Europe, the various nation states operate different definitions of citizenship with different citizenship rights. They also apply these rights and provide access to them for minorities in widely differing ways.

Foreigners, immigrants and ethnic minorities The issue of the status of ethnic minorities can be usefully and effectively explored as a useful means of clarifying the nature of citizenship, its rights and obligations, for all. Deakin writes: ‘the best case, which, more than any other, helps to resolve this issue [of rights] is that of the individual who falls into one of the various groups classed as outsiders ... the minority’ (Deakin, 1969: 24). In some societies such minorities are literally outsiders - excluded from all rights. In others, they may constitute, in varying degrees, second class citizens to the extent that their rights are curtailed. Different nations use different expressions to describe the issue. In Germany, the common expression is no longer ‘guest workers’ (Gastarbeiter), supposed to be temporary (short term) migrants, but ‘foreign employees’ (auslandischen Arbeitnehmer) and their families, becoming permanent (long term) re~idents.~ This expression, ‘auslandischen Arbeitnehmer’, refers both to economic function and legal status. In Britain, the accepted term is ‘ethnic minorities’, which takes us back to physical appearances (Rex, 1986). The French term ‘immigrk’ can be located somewhere between the two, implying as it does both economic function and foreign origin (but not necessarily foreign status). In France, there are foreign immigrants and, increasingly, ‘immigr6s’ of French nationality who suffer discrimination and rejection because of their physical appearance (Blanc, 1991), although the social scientific analysis of immigration issues continues to concentrate on statistical analysis of numbers of nationals and foreigners (Noiriel, 1988). Since, according to the Statistical Institute, INSEE, in 1986 approximately one quarter of the French population could be classified as ‘immigr&’, the children of immigrks andor of foreign origin (see Figure 2), it is misleading to use the term ‘immigrk’ without qualification.

The use of the concept of ‘ethnic minority’ encourages a widening of debates and is the term most current in anglophone countries, particularly in the USA, the UK and Canada, as well as in Quebec (Lavigne, 1987). French researchers and, to a lesser extent, those in Germany have shown great reticence in using this term. Despite our espousal of the term we recognize that it has dangers. The adjective ‘ethnic’ presents a problem in so far as it may be a euphemism for race (Wallman, 1978). The noun ‘minority’ also

3 However, there is a wide spectrum of German terms in use: Gastarbeiter, auslandische Arbeitnehmer, Aussiedler, Uebersiedler, Fluchtlinge, Asylbewerber, etc. It is very difficult for non-Germans to grasp the subtle differences. The most important group is the auslandischen Arbeitnehmer (foreign employees) and their families.

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13.4 to 14.: million people of foreign origin

4 million immigrants

2.7 million 1.3 million are forei~ners are French

5 million children of immigrants

4.2 million are French (of whom 3.3 million are French

4.4 to 5.3 million children of immigrantsa

all are French

c

-I

9.4 to 10.3 million immigrants

and people of foreign origin

3.5 million foreigners

9.9 to 10.8 million French

foreigners

afollowing the hypothesis of ‘homogamie’

Source: ‘Les &rangers en France’, Econornie ez Statistiques, no. 242, 1991.

Figure 2 Estimated number of immigrants and people of foreign origin, 1 January 1986

presents difficulties: ethnicity is seen as an attribute of the minority except in the expression inter-ethnic relations. ‘Ethnicity is always used of the minority’ (De Rudder, 1987: 23).

Max Weber defines ethnic groups as ‘those human groups that entertain a subjective belief in their common descent because of similarities of physical type or of customs or both, or because of memories of colonization and migration; this belief must be important for the propagation of group formation; conversely, it does not matter whether or not an objective blood relationship exists’ (Weber, 1968: 389). The concept of ethnicity has



nothing to do with biology and is defined by subjective beliefs about group origin, real or imaginary, but always socially constructed. An ethnic minority is, then, a group which is believed to have a different common origin from that of the majority of the society where the difference lies in its physical appearance, its culture and, for the most part, its own language. The concept of ethnic minority has, as can be seen, many advantages over that of both ‘foreigner’ and ‘immigrant’: (1) It relativizes legal status. In French, as well as to some extent in English, the term

foreigner is ambiguous. It has a legal sense and also a common sense meaning which is very broad. It implies an outsider, so that in a village or a city, you may be thought of as a ‘foreigner’ if you obviously originate from another part of the country. Bretons and Auvergnats were foreigners in Paris in the nineteenth century (Noiriel, 1988). The concept of ethnic minority allows one to take account of this sense without inferring that legal status is secondary.

(2) It relativizes the reference to history. In insisting on the subjective character of the beliefs of the original group, the concept of ethnic minority paradoxically concentrates the analysis on the present day, since history is seen as constantly being rewritten and reinterpreted in terms of the needs of the present. M. Weber again notes that ‘the persistent effect of the old ways and of childhood reminiscences continues as a source of native-country sentiment (Heimsgefuhl) among emigrants even when they have become so thoroughly adjusted to the new country that return to the homeland would be intolerable (this being the case of most German-Americans, for example) (ibid.: 388.).

(3) The concept of ethnic minority is compatible with long residence in the new country. Unlike the terms ‘immigrant’ and ‘foreigner’ it does not have the connotation that migration is temporary and that everyone is a foreigner waiting to leave.

(4) It is even more valuable in studying second and subsequent generations. Such people are certainly not immigrants and may or may not be foreigners.

Despite the problems, the term ‘ethnic minorities’ is, we believe, the most inclusive and the most appropriate for a comparative perspective.

Citizenship based on territory and ethnicity : the United Kingdom case

Discriminatory legislation against ethnic minorities and their rights to citizenship Before 1962 all members of the Empire, and subsequently the Commonwealth, enjoyed political rights on the same basis as British citizens born in the UK. The 1914 Imperial Act gave everyone born within the allegiance of the Crown full British citizenship. Although this was modified in 1948, Commonwealth citizens continued to be allowed free access to the UK, and once in, received formally equal political, legal and social rights to UK citizens, including applying for full UK citizenship after a period of residence. The only immigration control was upon aliens. The distinction between UK and Commonwealth citizenship only became significant with the passing of the 1962 Commonwealth Immigrants Act which restricted entry into the UK for Commonwealth citizens through a system of work permit^.^

A further distinction was made in the 1968 Commonwealth Immigrants Act. Right of entry into the UK was restricted, for those who held British passports issued by High

4 These restrictions did not, however, apply to citizens of the Irish Republic, even though it was not even a member of the Commonwealth.



Commissions abroad, only to those people who could establish a close connection with the UK. All other United Kingdom Passport Holders (the new designation) had their rights reduced to the same as for Commonwealth citizens. Since ‘close connection’ was largely defined in terms of having a British resident grandparent, this measure had a strong racist element. It allowed many white East African British passport holders to retain full rights whilst excluding those same rights to ethnic minorities and as such was subject to complaints to the European Commission of Human Rights.

Many of the Commonwealth Citizens and UK Passport Holders who did come to Britain were men. Subsequent legislation sought to place stricter controls on the entry of wives and children, first by requiring certificates (1962) and then by requiring that such certificates be obtained from the local High Commission prior to the entry of the dependent relatives, whose blood relationship had to be proved. These acts were replaced by the 1971 Immigration Act and revised Immigration Rules (February 1980, HC 394). The 1971 Immigration Act distinguished between what it called ‘patrials’ and other^.^ Entry to non-patrials could be granted only in specified circumstances - normally the production of a work permit or on establishment of certain familial relationships. There remain no controls on the immigration of citizens of the Irish republic. In addition, the European Communities Act of 1972 gave to all citizens of the European Community the right of entry into Britain for a period of six months in order to seek work. One consequence of the 1971 Immigration Act was that New Commonwealth citizens6 must now apply for entry on the basis of work permits as though they were aliens, though they did still retain the right to apply to have restrictions removed after four years of resident employment.

The above legislation in effect created different types of citizenship through the application of selective immigration controls. In 1981, the government introduced the 1981 Nationality Act which was intended ‘to bring citizenship law in line with changes effected by immigration legislation’ (Pilkington, 1984). It replaced the single category of Citizen of the UK and Colonies with three separate categories of citizen: British citizenship, British Dependent Territories citizenship, and British Overseas citizenship. Only the first of these - British citizens -have full rights of entry into Britain and these are almost all ‘patrials’. Citizens of the Dependent Territories are mostly people permanently resident in the few remaining colonies. They have the right to settle in the dependency in question, but not in Britain. British Overseas citizens, whilst holding a form of British passport, have no rights to settle anywhere. Although these British Overseas citizens may hold dual nationality and so have rights of entry elsewhere, many hold no other nationality. Indeed, many newly independent nations were unhappy to allow joint nationality to their newly created citizens and as a consequence many Asians7 permanently resident in ‘Black’ African countries retained their British nationality rather than accept the local alternative. It is predominantly this group who have suffered from

5 A patrial is defined as those who: (a) have UK citizenship by birth, adoption, naturalization or registration in the UK; (b) are Citizens of the UK and Commonwealth who have at any time settled in the UK and have been

(c) are Commonwealth citizens born to or adopted by a Citizen of the UK and Colonies; (d) are the spouse of a patrial; (e) are a former wife of a patrial providing she is also a Commonwealth citizen; (f) are a Commonwealth citizen who has been previously admitted, in which case they retain the right to

6 In Britain, the distinction is made between ‘Old Commonwealth’, predominantly white (Canada, Australia, New Zealand), and ‘New Commonwealth’, predominantly black (West Indies, India, Pakistan, Bangladesh).

7 Asians are people originating from the Indian subcontinent (see note 2 above). Many of them moved to other parts of the Commonwealth (especially African countries) and set up businesses. The largest group to suffer were the ‘Ugandan Asians’ expelled by the dictator Idi Amin.

ordinarily resident for five years or more;

bring in certain close dependents.



this legislation. In times of crisis in their country of residence they may find themselves effectively stateless.

Further pieces of legislation bring the picture up to date. The 1988 Immigration Act repealed the right of unrestricted access for the wives and children of Commonwealth citizens settled in the UK prior to 1973. The 1990 Nationality Act introduced financial criteria, through a points system, for Hong Kong citizens wishing to enter the UK with the handing over of that colony to mainland China. Whilst this article does not deal specifically with asylum seekers, it is also worth noting the 1993 Asylum and Immigration Appeals Act which seriously restricts the rights of appeal for those visitors who are refused entry, and the introduction of working visas for people from the Old Commonwealth seeking to come to Britain for short working holidays. Whilst the latter has been interpreted as a quid pro quo for similar action by the New Zealand government, it may indicate an even greater tightening of restrictions for all categories of people seeking entry.

UK citizenship is not identified with nationality. It is possible to have extensive citizenship rights without having full British nationality, although nationality remains the central reference. Residence and ‘territorial rights’ play an important role in the acquisition of citizenship, but the territorial logic is subject to two important qualifications: (1) The territory referred to is subject to frequent redefinition, each time more restricted.

In less than a century the UK has passed from imperialism to postcolonialism. It is the logic of imperialism which maintained the fiction of a community embracing the colonizer and the colonies as citizens and explains the relative lack of use by members of the ‘new’ commonwealth of their rights of access to the UK. The subsequent move to more and more restrictive measures corresponds to the logic of withdrawal.

(2) The definition of the ‘territory’ which gives rights of access to the UK has been periodically redefined from as wide as the Empire or Commonwealth towards an ever closer association with the UK territories themselves and always in favour of those of the same ‘bloodright’. Such restrictions on immigration have hit disproportionately the New Commonwealth rather than the Old, seeking to preserve the identity and purity of nationality, whilst at the same time being contrary to both liberal doctrine and the needs of the economy.

Anti-discriminatory legislation and the positive definition of citizenship rights Although the 1948 Act made distinctions in types of citizenship, it did not really affect citizenship rights. Nevertheless, widespread racial discrimination was catalogued in a series of reports (Daniel, 1968; Smith, 1977; Brown, 1984). The first Race Relations Act, introduced in 1965, made it an offence to discriminate on the grounds of ‘race, colour, ethnic or national origin’ in such places as hotels, restaurants, places of entertainment or public transport and set up the Race Relations Board as a conciliation machinery. This first attempt was followed by the much stronger 1968 Race Relations Act which forbade discrimination in ‘employment, housing, the provision of goods, facilities or services to the public and the publication or display of discriminatory advertisements or notices’. The Race Relations Board was reconstituted with the additional power to investigate complaints and, if necessary, to bring proceedings in court. This Act also established the Community Relations Commission with a brief to promote harmonious community relations and to coordinate the work of independent, local Community Relations Councils.

In 1976 a new Race Relations Act was passed which considerably extended the brief of the national body. The Race Relations Board and the Community Relations Commission were both abolished and replaced by the Commission for Racial Equality,

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which was more pro-active. It was to be a ‘policy’ body with a strategic role in enforcing the law. Not only direct racial discrimination, but indirect discrimination could be dealt with (Home Office, 1977). Indirect racial discrimination was to be understood as a situation in which equality in a formal sense has the effect of producing discrimination (Blanc, 1991). The new body was able both to institute legal proceedings itself and assist individuals with their own cases. Where it instigates a formal investigation of its own this must lead to the publication of a report with recommendations. Although this Act does not legalize reverse discrimination as such, it does allow for the development of positive action to reduce racial discrimination (Blanc and L,e Bars, 1993).

Nationality and citizenship founded on ethnicity : the German case

Terminology Any attempts at comparison between the UK and Germany must be conducted on the understanding that apparently similar terminology does not mean quite the same things: ‘Burger’ means both ‘bourgeois’ and ‘citizen’ and makes reference back to the political autonomy of the Reichstadte and to the Hanseatic towns of the Middle Ages. We find the same connotation in the ‘citizenship initiatives’ of the 1970s which became parts of the Green Movement: citizenship is understood as an active involvement in the affairs of the city at the local level. Yet the technical term Staatsburgerschaft literally translates as ‘citizen of the State’ and is difficult to disassociate from the term Staatsangehorigkeit (nationality). The German notion predates the existence of Germany as a State. Prussian nationality was nearer to citizenship: ‘Die Preussische Nationalitat war eher eine Staatsburgerschaft’ (R. Von Thadden, interview, L.e Monde, 3 July 1993; Die &it, 6 August 1993). The unification of Germany by Bismarck is historically very recent. East and West Germany have been called ‘two states, one nation’ (Habermas, 1990). Extending the notion of Staatsangehorigkeit, there is also a notion of Volkszugehorigkeit. Numerous peoples in eastern Europe (Russia, Romania, Hungary, etc.) and the Americas (Canada, USA, Chile, Argentina, etc.), are regarded as still belonging to the German people providing only that they have preserved their German language and culture, or have been forcibly assimilated into other language cultures. This idea of belonging to the people is eminently subjective and founded on the belief in a common origin. It is an ethnic definition in a real sense. These Aussiedler - similar to the Pieds-noirs in France or Jews arriving in Israel - receive much more favourable legal treatment than do foreigners.

Nationality and citizenship of immigrants of ethnic German origin Article 116 of the German Foundation Law allows members of the German people who do not possess German nationality to more or less automatically obtain naturalization once they have settled within the national territory (Fijalkowski, 1989). All they need to do is to prove their German origins, though this does, in practice, sometimes present problems. Newly settled and naturalized members of the German people have tended to get considerable assistance in learning the language if necessary, with finding homes and with finding employment. They have been disproportionately young workers (often well qualified) and have contributed to the successful reconstruction of Federal Germany since the war (Reiffers, 1971). However, subsequently a hierarchy has been established distinguishing between those who spoke German well, were well qualified and so easily found work (mostly Ubersiedler before unification) and those Aussiedler who couldn’t speak German and who were not professionally qualified. The extent of ‘belonging’ of the latter has become in doubt and they are increasingly treated with suspicion, so that they have become the target for a certain amount of racism. In 1989, before the influx of the



Aussiedler and the Uebersiedler, the German Government launched a new project to build social housing for them. Before German unification, the Head of the Aussiedler office of the Ministry of the Interior had been trying to encourage public opinion to accept the value of widening the scope and diversity of the German people (Aussiedler, 1989). However, this political initiative is more muted today as the German authorities are now becoming increasingly worried about migration into Germany from the East. Whilst the same principles are adhered to as previously, in practice it is much more difficult for would-be entrants to prove their German origins.

Discriminatory legislation against citizenship rights for foreigners The idea of a ‘blood right’ makes it very difficult for foreigners to obtain German naturalization (Einburgerung). Since 1978, children have been able to claim double nationality as long as either the father or mother is German, even if they were born and brought up abroad. However, a child born in Germany of foreign parents, even if educated in Germany and totally ignorant of the country of nationality cannot become German. ‘They live in the paradoxical role of Germans with a foreign passport’ (J. Habermas, interview, Le Monde, 14 September 1993). Naturalization does exist but it is a long, difficult and very restrictive procedure (Fijalkowski, 1989). In June 1993, following racist attacks upon Turks in Solingen, the President of the German Republic and subsequently the Federal Chancellor both declared themselves in favour of easier naturalization procedures. However, this requires constitutional reform for which there is no political majority.

When the level of local manpower proved to be insufficient and also in order to maintain wages at a low level, the Federal Government had recourse to manpower from neighbouring countries, first Italy (1953, then Spain and Greece (1960), Turkey (1961) and later Portugal (1964) and Yugoslavia (1968), but continued to keep control of migratory movements arising from local economic needs. When immigration from neighbouring countries like Italy dried up, it came to rely on other, more distant countries (Greece, Turkey, etc.), so that Turks are now the largest foreign group. This is what might be called the logic of geographical proximity, as opposed to the postcolonial logic of the UK.

Thanks to European Union regulations, residents originating from the European Union now benefit from economic and social rights in the same way as do Germans. On the other hand, foreigners from outside the European Union continue to have fewer economic rights even after many years of work and residence. Residence and work permits were limited right from the beginning (Fijalkowski, 1989). Turks and ex- Yugoslavians (which represent two-thirds of foreign workers) still enjoy fewer economic rights. Before Maastricht, all foreigners had the same (low) level of political rights. They were only allowed to participate through the Consultative Councils for Foreigners, which are organized differently in each town. Their associations launched a campaign in the 1980s for the right of foreigners to vote at least in local elections. This has received support from the churches, the DGB union and the Greens and was taken up by the Land of Schleswig-Holstein and the City State of Hamburg, only to be abandoned when in October 1990 the Federal Constitution Tribunal gave a judgement that the participation of foreigners in local elections was unconstitutional. The Treaty of Maastricht imposes upon Germany a constitutional revision. At the same time, in the face of racist violence, the constitutional debate today is crystallized around asylum seekers and the naturalization of foreign residents. Both the majority and the opposition, in December 1992, signed an agreement in principle to revise the constitution so as to limit the number of asylum seekers. The socialist-democratic opposition sought at first to obtain by way of compensation a simplification of the naturalization procedures for resident foreigners. Despite criticism by its left wing, the majority of the SDP agreed in May 1993 to restrictions to access for asylum seekers without any compensation on naturalizations.



Law against racial discrimination in Germany Articles 130 and 131 of the German Penal Code suppress ‘incitement to racial hatred’. However, this carries little weight in practice and the British concept of ‘indirect racial discrimination’ is unknown in German law (Blanc, 1991).

Nationality and citizenship based on a combination of ethnicity and territory: the French case

Blood rights and territorial rights As far as citizenship is concerned, France is somewhere in the middle between Great Britain and Germany. In all three countries biological descent is, on the whole, the safest and easiest means of acquiring nationality and citizenship. ‘Blood right’ is the almost exclusive means available in Germany, whilst France and the UK accept ‘territorial rights’ as well, though with different rules applicable in each.

Until 1993 every individual born in France of foreign parents* who were settled there became French on achieving their majority (18 years), provided only that they had resided in France for at least five years. In 1993, the newly elected conservative majority tried to dramatically restrict access to nationality through residence. In the final version of the Act, the acquisition of nationality was no longer automatic. An individual born in France of foreign parents and residing there for more than five years is now entitled to apply for nationality between the ages of 16 and 21 (Kharbache, 1993) but does not receive it automatically.

Every individual born in the UK is able to obtain British nationality as long as one of their parents is settled there, and naturalization consists of a simple process of registration (Shutter, 1995).

The logics of postcolonialism and geographical proximity The UK has tended to follow a postcolonial logic in giving priority to people from the Commonwealth when recruiting manpower. Germany, on the other hand, has followed a logic of geographical proximity and made agreements with numerous neighbouring countries. France’s position is somewhere between the other two. It has made use of both the logic of postcolonialism and the logic of geographical proximity.

The postcolonial logic is shown in the importance given to the population of the Maghreb (North Africa) in France. However, unlike Britain, the original residents of the old French colonies have not gained increased political rights. The logic of geographical proximity is shown in the presence of Italians, Portuguese, Spanish, etc. France and Germany have significant communities of foreigners from the southern countries of the European Community as well as from outside the EC.

Citizenship and nationality The economic crisis of 1973 produced a similar response in the UK, in France and in Germany. That is to say, they all introduced draconian restrictions on the entry of migrant workers. Severe restrictions were introduced on family reunion, limiting this to close relatives only, with further restrictions on income and housing. As a result, the arrival of young adult immigrants has more or less stopped and the length of stay of the foreign populations already in the countries has increased, thereby making the question of citizenship rights for such minorities an even more important issue.

Despite a number of restrictions, the UK is alone in disassociating citizenship and nationality and giving the same political rights as for Britons to those originating from the 8 For a fuller account of citizenship in France, see Wihtol de Wenden (1988).



Commonwealth. In France, as in Germany, the citizen’s political rights are inseparable from nationality, which contradicts the universal aims of the Declaration of Human Rights and of Citizenship. Both countries have established a hierarchy between nationals of the European Community with a Christian cultural tradition, who are thought to be easier to assimilate, and those whose national origins lie outside the European Community, particularly Turks and Arabs with their Islamic traditions, who are thought to present problems of assimilation. The regulations of France and Germany pose a crucial question for a ‘multicultural society’, in that they implicitly assume that foreigners must renounce their culture of origin in order for them to become fully incorporated through naturalization and assume a new identity. Touraine argues against this:

It is not sufficient that (the newcomers to a nation) through social integration, cultural assimilation and naturalization acquire norms, ways of life and citizenship rights. It is also necessary that they actively remember that their place must in its turn change. They must also see that they are not satisfied with a multi-culturalism devoid of real content. The collective memory they acquire must be one that wants life, that wants to be constantly transformed in order to play a role in integration instead of imposing on newcomers an intangible history lesson and becoming a mythology (Touraine, 1992: 345-6).

Direct and indirect discrimination Finally, the French Law of 1972 against Racial Discrimination, like German law, only condemns direct discrimination, whereas in the UK it also condemns indirect discrimination. The British Commission for Racial Equality has gone further and argued (1992) for a new definition of indirect discrimination which would include practices like recruitment of personnel by word of mouth, the internal-only advertising of vacancies, giving preference to the children of present employees when offering apprenticeships, as well as preferential treatment to sons and daughters in the allocation of public housing, all of which indirectly discriminate against ethnic minorities. Of course, such practices in some restricted cases may advantage ethnic minority members in ‘ethnic’ neighbourhoods, but they are still to be condemned. The global trend strongly favours the ‘white’ majority, not minority groups.

Citizenship and ethnic minorities European dimension

The concerns of minority activists In France, as in Germany, the Associations for Foreigners originating from outside the Community are afraid of being forgotten as European unification proceeds. In Britain, the Commission for Racial Equality is equally concerned about the implied long term harmonization of rights, on the grounds that any harmonization of rights across Europe will necessarily lead to some revision of national laws and this could include the British 1976 Race Relations Act. Whilst the Commission itself has been highly critical of the implementation of the intentions of the 1976 Act, and the effectiveness of the Commission itself has also been criticized both by academics (Appleby and Ellis, 1984) and by pressure groups like the Society of Black Lawyers and the National Black Caucus (The Guardian, 29 January 1992), nevertheless the British Race Relations Act 1976 has no comparable legislation in the rest of Europe.

In 1990, the Commission for Racial Equality expressed concern about three aspects of the 1986 Single European Act: freedom of movement; mutual recognition of qualifications; and equal considerations in contract compliance (Commission for Racial Quality, 1990: 36). They feared that discrimination might arise from visa arrangements - particularly the right of appeal - and from the use of identity cards for internal control of movement, and because they believed that freedom of movement was clearly



established only for EC nationals and not for non-UK nationals resident in Britain. There was also concern that the Directive on the Mutual Recognition of Diplomas could in practice discriminate against those with foreign derived diplomas and so make their professional life even more difficult than before. The Contract Compliance requirements do not prevent member states from taking into account equal opportunity considerations, but neither, it was felt, did they specifically require them.’ For all these reasons the Commission argued that a European Social Charter must embody within it specific reference to the principle of race equality. The Standing Conference on Racial Equality in Europe has been able to maintain that pressure to the extent that at the Maastricht summit a declaration against racism was issued, but sadly, not within the treaty itself. In the event, the British Government has insisted on opting out of the Social Chapter of the Maastricht agreement. This will not mean that major European legislation on rights for ethnic minorities will not apply but it will mean that fundamental minimum standards and minimum social rights will not be guaranteed.

More recently, the European Migrants Forum has expressed concern about another aspect of the Maastricht Treaty. The prospect of a common European Union visa policy may end the preferential treatment currently given by Britain to those from New Commonwealth countries who wish to gain temporary access for the purpose of visiting relatives. It was people visiting Britain on this basis from Jamaica to whom we referred above. Their concern has been aroused by the Commission’s draft list of countries whose nationals would require visas, which included the names of 31 Commonwealth member countries. Tara Mukherjee, president of the EU Migrants Forum, is quoted as saying: ‘It is a blacklist in the true sense of the term. Not a single white Commonwealth country is included’ (The Guardian, 8 January 1994).

If European Union citizenship continues to be based on national citizenships of member countries, there is a danger that the situation of ethnic minorities may vary widely from country to country within the European Union and that rights which they hold in one member country will not be transferable to others. Clearly, any longer term move towards greater unity of legislation may adopt any of the models of citizenship rights operating within the various member states. A concern of many working in British race relations is that specific protections, however limited, have been fought hard for and should not be lost in the interests of uniformity of legislation. On the contrary, the protections gained so far in British law need to be extended to the whole of the European Union. Even this is regarded as insufficient by British activists. The Commission for Racial Equality has since argued (1992) for a statutory obligation upon employers to carry out ethnic monitoring, a new tighter definition of indirect discrimination, the extension of legal aid, as well as new laws on religious discrimination (The Guardian, 19 September 1992). It also wants the 1976 Act extended to include Northern Ireland, which it currently does not.

Citizenship and ethnic minorities The French writer, Dominique Schnapper (1989) has argued that what makes the UK distinctly different from France and Germany is its colonial heritage. We have argued that this is also partly true of France. However, Schnapper sees the French concept of the nation as founded on individual will: ‘Membership of the French nation is open (at least ideally) to all those who are prepared to adopt its values’ (1989: 23). She places opposite this the ‘closed’ right of Germany, linked, she believes, to an organic conception of nation existing outside the state. Whilst not wishing to underestimate the important differences between them, we would agree that all three countries do seem to share a common

9 For example, by requiring Local Authorities to give preference to f m s which employed appropriate numbers of ethnic minorities, women andor people with disabilities.



conception that nationality refers to ethnicity. The German conception is the strongest in its insistance on the ‘real’ character of the common origin, though recently there has been the beginnings of a debate about the possibility of introducing ‘territorial’ rights in the revised constitution. Then comes that of France with the idea of a ‘supposed’ communal origin” referring back to two different forms of social transaction (see Blanc et al., 1992). For Schnapper, ‘National identity is not a biological fact, but cultural: one is French by the use of the French language, by the internalization of the culture, by the will to participate in economic and political life’ (ibid.). It isn’t a biological fact; it is on the contrary, precisely, an ‘ethnic’ fact. All the restrictions carried by citizens of the Commonwealth can be understood in the same way: to privilege those who are ‘ethnic whites’.

In general this ethnic logic carries grave dangers. Jurgen Habermas’ warning (1990) does not only apply to his own compatriots: ‘Within any political association, every equivalence of ‘Demos’ like support for the sovereignty carries with it a specific ‘Ethnos’ conducted as an oppression, as an assimilation forced upon other ethnic, cultural, religious or socio-economic layers of the population’ (Habermas, 1990). Europe must move towards a concept of citizenship and nationality based on residence. As Bernard Poche (1985) argues, living in a territory ‘naturalizes’ those who live there so that the foreigner ceases to be a stranger and comes to be accepted (though not necessarily fully adopted as a compatriot). We might mischievously quote a French proverb: ‘La ou la chevre est attachCe, il faut qu’elle broute’ (where the goat is tethered, that is where it will graze). It is the same with political rights. Let us hope that Europe is not to become an Orwellian ‘animal farm’ in which ‘some are more equal than others’.

Conclusions All countries suffer from ethnic and racial tensions and one cannot blame nationality and citizenship laws for the existence of such things. All kinds of prejudices are common, so it is hardly remarkable that racial prejudice exists. Citizenship laws probably have very little effect upon prejudice per se. However, we have shown that citizenship laws do affect the consequences of racial tension, as, for example, in terms of access to basic citizenship rights in Germany (German ethnic) and the consequences of discrimination, as, for example, the British 1976 Act. In both of these examples, the dimensions of citizenship extend across all of those defined by Marshall.

We have also shown, by comparing the ‘ethnic’ basis of Germany to those of France and the UK, that nationality laws based upon ethnicity are more restrictive of access to all dimensions of citizenship than those with a greater territorial element. Furthermore, we have argued, most clearly in the case of the UK, for the importance of the separation of the concept of nationality from that of citizenship in giving greater civil, political and social rights to members of minority groups.

A third area of concern which we have expressed is that of the possible consequences of attempts to move towards greater European unity. This has implications - good or ill - for both the issues which we have just raised. At present, freedom of movement simply means the recognition of each states’ citizens within the territory of the European Union. However, if full European citizenship is to develop, will it lead to a standardization on lesser citizenship rights, like, for example, a definition of citizenship

10 France publicly declares a very open approach to citizenship, but it is in practice very restrictive. In 1987 (the last year for which comparative data is available), there were 60,000 naturalizations in France and 36,600 in West Germany (OED, 1989: 15). The French ‘openness’ is not so obvious. (We are grateful to A. Cordeiro (CNRS, Paris) for these data.)



based solely on nationalities within the European Community and, perhaps, based on ethnos? Alternatively, it could mean a standardization upon greater citizenship rights, with, perhaps, the separation of citizenship rights from nationality and more emphasis upon territorial definitions of nationality. Note, for example, the demand of the activist group VOICE” which has has called for: ‘Equality of treatment for all citizens legally residing in Member States and provisions to combat all forms of discrimination’ (Venables, 1992: 37).

We would like to express our hope that the European Union, as it continues its deliberations on the long term nature of citizenship in a fully united Europe, will give serious consideration to three issues which we regard as paramount. The first is that it seeks a concept of European citizenship based more upon territoriality than upon ethnicity. The second is that, irrespective of the definition of European citizenship, the European Union considers extending citizenship rights along all the dimensions which we have indicated to members of minority groups within the member states. Thirdly, we recommend that other European states give serious consideration to legislation against indirect racial discrimination as exemplified in the British 1976 Act, since indirect discrimination inevitably restricts citizens’ freedom of action.

Finally, we hope that the European Union will seek new and exciting relationships with the ‘newly emerging democracies of eastern Europe’, from which will come many of the new ethnic minorities within the Union. It is important that this is linked to the condition that ‘democratic citizenship rights’ are instituted in these countries so as to secure ‘human rights’ for their own ethnic minorities as well as for the majority. Citizenship can then go beyond being ‘guaranteed only within the boundaries of the nation state’ (Dahrendorf, 1990) and we can see citizenship leading ‘ultimately to the world-wide recognition of the rights of every human being ... (by) ... cooperation between nation states through international agencies to establish minimum “rights and obligations“’ (Dahrendorf, 1990). Let us hope that Dahrendorf is right.

David M. Smith, School of Sociology and Social Policy, Middlesex University, Enfield Campus, Queensway, Enfield, Middlesex EN3 4SF, UK and Maurice Blanc, CUCES Universities, 32-34 rue du Saurupt, BP 3059-54013, Nancy, Cedex, France.

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Citizenship, Nationality and Ethnic Minorities in Three European Nations

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