Comparative citizenship
Week 21
Comparative Sociology
• Considered how health and welfare
policies are related to capitalism and
• But are often gendered in their design
• Looked at notions of a ‘clash in cultures’
• What is citizenship?
• Immigration and citizenship.
– France, Germany, Australia and the UK
• The issue of asylum
What is citizenship?
• Status within a nation-state
• Set of rights and responsibilities
• A social contract
Marshall’s three aspects
• T.H.Marshall divided citizenship into three
– Civil
• Freedom of speech, right to justice
– Political
• Right to participate in political decision-making
– Social
• Sufficient economic welfare and security to be
able to participate in the live of the nation
Citizenship ‘rights’
• Citizenship often involves organisation and
distribution of resources
• Gender, class, ethnic inequalities can led
to exclusion from these resources and
therefore impact on the ‘level’ of
Three key questions
• Who can be a citizen?
• What rights and responsibilities are bound
up with citizenship?
• How ‘deep’ should citizenship be?
– Should it take priority over other forms of
Getting to be a citizen
• Gaining citizenship
– By birth in a particular place
– By descent (parents and/or grandparents)
– By naturalization
What does citizenship mean to
• Do you think of yourselves as citizens?
• What form does this citizenship take?
• How important is it to you?
French citizenship
• In France, ideas about citizenship arose
following the revolution.
• Citizenship is a political
and territorial identification
• Citizenship is open to residents who
identify and participate in the national
• The issue of Muslim girls wearing
headscarves in schools caused a political
• Opponents upheld ideal of ‘secular
• Immigration seen as a threat to national
Problematic citizenship
• Formal citizenship based on
civic participation
• Citizenship is thus seen as ‘at risk’ from
• For ‘immigrants’ to be French citizens, their
identification with ‘white’ French
ideas should take priority over
their religious identity
German citizenship
• German citizenship based on a community
of descent
• Blood ties is the key element in defining
the nation
• First naturalization laws
only in 2004
Inclusion and exclusion
• Following collapse of the Soviet Block, Germany
welcomed thousands of ethnic Germans ‘home’
• Many couldn’t speak German, and had few
German cultural connections but they were
granted citizenship
• 2 million Turkish ‘guestworkers’ in Germany who
at that time did not have citizenship (including
right to vote)
• Many 2nd or 3rd generation
Problematic citizenship
• Ethnicity is the formal route to citizenship
• Guestworkers not able to participate as full
• Centrality of German ethnicity allows
denial of a multi-cultural society?
Citizenship questions
• Discuss with the person sitting next to you
how ideas about citizenship are invoked in
the issue of headscarves in France and
the exclusion of guestworkers in Germany.
Australian citizenship
• Establishment of citizenship excluded the
indigenous population
• Immigration Acts up to 1960s based on
• Immigration initially restricted to UK, then
other white Europeans accepted
Aboriginal identity
• White Australia policy lead to forced
assimilation of Aborigines
• Aborigines Protection Act 1909 supported
the forcible removal of Aboriginal children
from their parents. This
continued until 1970s.
UK citizenship
• After WW2, citizenship was extended to
encourage commonwealth members to
cure the labour shortage in Britain
• Immigration has become progressively
tougher since then.
• Professional migration welcomed,
unskilled workers excluded
Rights and responsibilities
• Immigrants can be excluded from the
social contract
• ‘No recourse to public funds’ clause
means that families whose financial
situation changed risk deportation
Asylum Seekers in the UK
• Moral panic over asylum seekers
• ‘Bogus asylum seekers’ an oxymoron
– Right to seek asylum enshrined in law
• Increasing numbers granted ‘leave to
remain’ but denied full citizenship rights
Asylum seekers as a ‘threat’
• Why do you think asylum seekers are
vilified in the media? What links can you
make to ideas about citizenship?
Link to US citizenship film
• Ideas about citizenship are linked to wider
• Rights and responsibilities are not neutral
but linked to class, gender and ethnic
• Categories of inclusion and exclusion do
change over time, but are always present

comparative sociology week 21 - C