In addressing the situation of Muslim communities in Britain, it is apparent that one of the major frameworks for understanding their situation has been the notion of "Citizenship," for citizenship is a means of identifying critical aspects of the relationship between the individual and the state. Following Bottomore (1992), we may make a useful distinction between "formal" and "substantive" citizenship: the former being simply defined as "membership in a nation state" and the latter as "an array of civil, political, and especially social rights, involving also some kind of participation in the business of government'' (ibid.).
There are a number of salient points that should be made in relation to examining the implications of this distinction. First, we may note that the legal definition of citizenship is always informed by the cultural and ethnic agendas historically rooted in the foundation myths of each nation state. Thus in France, for example, just as the revolutionary iconography of the Tricolor, Marianne, and Liberty, Equality, and Fraternity continue to serve contemporary national sentiments (Hobbawm 1983), so today French legal framing of formal citizenship is infused with its revolutionary roots:
- La tradition centraliste francaise interdit la reconnaissance dans l'espace public des 'communautes', au sens au elles existent au Etats-Unis. (Schnapper 1990).
Consequently, in France neither ethnicity nor religion are formally relevant in determining access to citizenship.
Germany, on the other hand, is very much an ethnic state with citizenship conceived of in relation to an ethnic consciousness of kind. As Bottomore puts it:
- Because national feeling developed before the nation-state . . . the German nation . . . was conceived not as the bearer of universal political values, but as an organic cultural, linguistic, or racial community-as a Volksgemeinschaft. (Bottomore 1992).
A powerful idea of shared ethnic identity is at the core of German national identity and is therefore reflected in its citizenship policy.
Britain, on the other hand, with its self-image of monarchical continuity and historic parliamentary democracy had, until the 1981 Nationality Act, no legal concept of citizenship, since Commonwealth nationals and members had a common allegiance to the monarch. That demotic, nonethnic concept of allegiance to the state was in effect eroded by immigration legislation which, in seeking to exclude nonwhite immigrants from 1962 onwards, progressively moved to define blood links as an essential criterion of rights to entry and settlement in Britain (Gordon 1989). During the Thatcher era, this was heightened and focused by the neo-conservative racialized nationalism promoted by the new right in England (Gilmore 1987; Husband 1991). The Falklands War, the "Iron Lady" resisting European assaults upon British sovereignty, explicit anti immigrant rhetoric, and an attempt to define and assert the primacy of English-British culture in schools through the 1988 Education Act were part of a process to make "traditional" British values salient. British legislation and sentiments have moved citizenship policy from an open demotic concept of citizenship towards one based on an ethnic-state concept.