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It is important to begin with a definition of citizenship. Held offers the following definition:
`Citizenship has meant a reciprocity of rights against, and duties towards, the community. Citizenship has entailed membership, membership of the community in which one lives one's life. And membership has invariably involved degrees of participation in the community.' [34]
This definition immediately raises the notion of `community': is the EU a `community' in this sense? Significantly, Held does not refer to a `state' as being the entity of which the individual has membership. Nonetheless, the history of citizenship has seen it consistently and closely associated with nation states, and it is only very slowly that the issue of `post-national' membership [35] has been raised - a point which will be discussed in more detail below.
The definition suggested by Held also raises three elements which offer a useful framework when looking at the evolution of citizenship in the EU:
- Rights and duties: what is or should be the scope and nature of such rights and duties, specifically in a supranational context? - The definition of who is a `member' of the `community', and the issues of inclusion and exclusion. Like the concept of `community', the question of `membership' raises important questions of identity which the EU is only just beginning to address. In particular, it must be examined whether the question of `membership' is solely to be determined in formalistic terms, for example, using a criterion of nationality which is inherently `statist' or whether a broader approach might be taken which includes as `members' of the EU third country nationals who are not citizens of the EU Member States, but are nonetheless lawfully resident and enjoying an `economic' or `personal' stake in the EU. - Participation raises the relationship between citizenship and questions of democracy and government. The EU, as is well known, has a number of acute difficulties in the sphere of democracy and the so-called democratic deficit, and a variety of possible solutions at national and supranational level have been suggested, some of which include the enhancement of the status of citizenship.
Held's definition self-consciously acknowledges the centrality of the work of the sociologist TH Marshall in creating something approaching an orthodoxy in thinking about citizenship in the postwar years (at least in the Anglo-American literature, on which this section largely concentrates). [36] Marshall [37] defines citizenship as full membership of a community, and argues that full membership has been gradually achieved through a process of historical development of individual rights, matching the acquisition of those rights to a process of English historical development through three centuries: [38]
- civil rights (basic freedoms from state interference), which arose in the eighteenth century; - political rights (electoral rights, etc.), arising in the nineteenth century; and - social rights, including rights to health care, unemployment insurance, old age pensions, characteristic of the (mid)-twentieth century evolution of the welfare state.
Underlying the characterisation of citizenship in these terms is the fundamental value of equality: everyone is entitled to be treated as a full and equal member of society, and to be given the means to enjoy that equality.[39] Under this view, the welfare state of the postwar era appears to represent a final stage of achievement of citizenship rights, a culmination of a process in which not only the range of citizenship rights has been greatly extended, but also the class of citizens has gradually expanded beyond a class of white property-owning Protestant men to include women, the working class, Jews and Catholics, blacks and other previously excluded groups. This is essentially a sociological not a political concept of citizenship. It explicitly develops the links between citizenship and social class, and links the development of citizenship to the development of capitalism in the modern nation state. [40] It also projects a picture of `passive' citizenship, in which citizenship rights are given to citizens, rather than achieved through constructive participation in government or even through `struggle' against the status quo.[41] However, it is an unrealistic view of citizenship even in the advanced capitalist or post-capitalist countries where the demands of an ageing population in an era of slow economic growth and increasing environmental degradation are proving unsustainable, and where the `practice of citizenship'[42] is ever more frequently being played through in the competing claims of new social movements.[43] It is also a view which manifestly fails to offer a model of analysis for the situation of the majority of the world's population to be found in so-called third world countries, or in newly industrialising countries.
Above all, from the perspective of the topic of `European' citizenship, the Marshallian orthodoxy offers little insight into the links between citizenship and nationalism and national identity, or the possibilities and challenges of multiculturalism.[44] Marshall has often been criticised for being too British,[45] and for his failure to offer a concept of citizenship operating within a broader frame than the nation. Yet, despite all of the criticisms which have been levelled at Marshall's work, and its self-evident inability to provide a complete set of explanatory tools for understanding citizenship in the contemporary world, his work remains a vital starting point and building block for a very substantial proportion of more recent work which is self-consciously preoccupied by problems such as economic decline, globalisation of economic forces, social disintegration, multiculturalism and environmental degradation. It is, however, generally acknowledged that social citizenship in the national context cannot be regarded as a `final' stage in the development of citizenship, and that the benefits which it confers cannot be assumed to be in any way irreversible. [46]
The current intellectual challenges to the liberal democratic orthodoxy of citizenship based on Marshall, which incorporates the classic welfare state argument, can be reduced to three main strands. Each of these strands is reacting to the others as well as to the liberal democratic orthodoxy. The first is neo-conservative libertarianism, which emphasises the individual freedom strand of citizenship, at the expense of collective rights or duties.[47] The second challenge comes from the politics of identity, and argues that citizenship should take account of the differences between people in a pluralist and multicultural society, as well as the similarities between them as members of a community.[48] The argument is that so-called `universal' citizenship in fact imposes a norm which prevents minority groups from living their lives as fully as members of a majority. It may, therefore, be necessary to build models of differentiated citizenship which focus on collective or groups rights, as well as upon the individual.[49] The third main challenge comes from a new `school' of active citizenship often termed `civil society theory'. It is summarised by Kymlicka and Norman in the following terms as a `recent development from communitarian thought' whose theorists:[50]
`emphasize the necessity of civility and self-restraint to a healthy democracy but deny that either the market or political participation is sufficient to teach these virtues. Instead it is in the voluntary organizations of civil society - churches, families, unions, ethnic associations, cooperatives, environmental groups, neighborhood associations, women's support groups, charities - that we learn the virtues of mutual obligation.'
It is from a combination of the latter two strands that theorists and writers associated with the `new left' or radical democratic movements, such as Mouffe, see the possibility of a `new social justice', which moulds a sense of belonging or identity, with a body of rights which recognise difference as well seeking to ensure equality and equity. But in the search for this social justice, Mouffe warns, `the individual is not to be sacrificed to the citizen'. [51]
In the review which follows, it is not possible to offer a full discussion of contemporary strands of thought on citizenship. [52] In order to develop the resources from which the underlying argument of the paper are drawn, the focus in this review will be on contemporary `social citizenship' specifically in a transnational context, and on the links between citizenship, nationality, nationalism and national identity, incorporating a brief discussion of problems and challenges of multiculturalism and international migration. It is these issues which present the most useful insights for the purposes of the analysis of European Union citizenship which forms the primary concern of this paper. The main argument in this paper is that there are the two central pillars to an EU conception of citizenship: the problem of identity in a transnational polity, and the achievement of the rights associated with social citizenship in the specific [single] market context offered by the European Union at its present stage of development. This insight is constructed by developing a version of the `postnational membership' thesis, drawing upon Soysal's dualism of identity and rights[53] as emblematic of the current tensions in citizenship. However, the insight is completed through a presentation of how citizenship can be conceptualised in the light of contemporary understandings of the dynamics of the integration process (Section III).
As Habermas notes, [54] the geographical arena of the continent of Europe offers two historical movements which touch upon the relation between citizenship and national identity. The first stems from the break-up of the Soviet Union, the decline of communism and state socialism in Europe, the reunification of Germany, the reinvention of many of the countries of Central and Eastern Europe as liberal market democracies, and finally the re-emergence of some age-old ethnic conflicts in some of the Eastern European countries and those carved out of the former Soviet Union. A dramatic modernization process in many of these countries has thrown questions of citizenship into sharp relief. The second historical movement is the process of economic and political integration within the states of the European Union, which calls for a reconsideration - amongst other matters - of democratic processes hitherto strongly associated with the modern liberal nation state. With the latter movement should also be coupled a trend towards regionalization within Europe.[55] As Kirsch puts it
`At a time when Western Europe strives to impose its new-found supranational identity on future history, it is rediscovering its own plurality, as infranational identities from past history are reborn.' [56]
In order to understand these issues fully it is necessary to turn a critical eye upon the linkages between citizenship and nation, nationality, nationalism and national identity. Assumptions about citizenship being an essential national concept[57] are closely intertwined with the rise of the phenomenon of modern nationalism. The point is made very clearly by Hutchinson and Smith:
`It is generally accepted that the institutionalization of citizenship differentiates post-eighteenth-century nations from earlier ethnic and territorial communities.' [58]
While they have drawn together in the post-Enlightenment modern era, citizenship and the concepts associated with the nation stem from very different roots. As Held's definition has shown, and as becomes plainer if one returns to the Greek and Latin roots of `citizenship', citizenship is to be understood primarily as a political concept. Walzer reminds us that the word comes from the Latin civis, the Greek equivalent of which is polites (member of a polis), from which comes the word political. [59] The strongest sense of this political understanding can be located in the period of the French Revolution, when
`citizenship, virtue, and public spirit were closely connected ideas, suggesting a rigorous commitment to political (and military) activity on behalf of the community'.[60]
This form of citizenship encompasses both the active and passive elements: the citizen is both governor and governed.[61] From these roots are derived, for example, what is called the `neo-republican' tradition in citizenship thinking, which seeks to combine protection for the status of the individual as an autonomous free-thinking person, with a relationship to the public community organised as a democratic republic.[62] The distinguishing feature of that relationship is the `intrinsic value of political participation for the participants themselves',[63] which is `the highest form of human living-together that most individuals can aspire to'.[64] It is this trend of citizenship thinking which most strongly influences the so-called civil society argument cited above as one of the central challenges to the Marshallian liberal orthodoxy.
Nationality, on the other hand, can be understood quite separately, a point illustrated by reference to the early French republic in which citizenship was granted to those who contributed to the republic - including non-nationals - rather than to those with `French' nationality. Nationality is membership of a national community, and consequently raises the acute question of nationhood, and its link to the concept of a `state'.
At this point, it is essential to suggest some definitions for key terms. Those proposed by Smith offer a useful starting point, [65] although it should be recalled that his definitions are best understood within the framework of his own position on the origins and current relevance of nationalism, briefly discussed below. He defines an ethnic community (or `ethnie' in his terminology) as a `named human population of alleged common ancestry, shared memories and elements of common culture with a link to a specific territory and a measure of solidarity'. A nation is `a named human population sharing a historic territory, common myths and historical memories, a mass, public culture, a common economy and common legal rights and duties.' Both of these definitions should, it has often been argued, be treated as essentially empirical, and not normative.[66] Nationalism, finally, is `an ideological movement for the attainment and maintenance of autonomy, unity and identity on behalf of a population some of whose members deem themselves to constitute an actual or potential `nation'.' Seen in its political clothing, nationalism is viewed as having at least two faces: on the one hand, it may be a constructive force for liberation of a self-identified grouping from an oppressive dominator; alternatively, it may be a destructive and illiberal force giving rise to significant geo-political instability.
There is one trend of thinking about nationalism and nations which is termed `state-centered'. [67] It regards modern nationalism as essentially a political movement to ensure that the political and ethnic boundaries of a state coincide. [68] Taken further, the argument can also be used in order to show that it is political action and the modern state which are themselves responsible for bringing into being, or at least rendering politically coherent, ethnic groups and nations. A contrary strand of thinking - well exemplified by the work of Smith himself[69] - would emphasise instead the continuing importance of pre-modern ethnic ties for modern nationalisms, arguing that (purely) political theories have as little explanatory value in relation to, for example, the widely differing forms which ethnic nationalism can take (varying between fiercely xenophobic to broadly multiculturalist and pluralist), as the widely discredited view of ethnicity and nationalism as primordial and perennial.[70]
Smith's work, and that of Armstrong,[71] which has been termed `ethnicist',[72] should be contrasted with so-called `modernist' strand of thinking on nationalism.[73] Modernist thinking sees the development of nationalism as a characteristic feature of modernization, linked to the development of modern industrial capitalism, the creation of mass educational systems, widespread access to print media, and changes in demographic patterns. In its most extreme form, posited by Gellner, the modernist thesis holds that `nationalism is not the awakening of nations to self-consciousness; it invents nations where they do not exist.'[74] In fact, it is the political elites, on this view, which have been responsible for `inventing' and articulating nationalisms, in order to strengthen the claim to nationhood and to give meaning to modern states. Although the modernists differ amongst themselves as to questions such as the key causal factors in the modernization process (e.g. industrialization, print capitalism, the modern bureaucratic state), they agree on the central thesis that the nation is a `modern artefact', and that the existence of `old' nations (e.g. England before the modern era) is essentially an accidental phenomenon. In contrast, the ethnicists look at nationalism over a longer time span. According to Hutchinson,
`this leads them to contextualize the emergence of nations within the larger phenonenon of ethnicity which shaped them.....[They reject] as the core of nationality the political definition focusing on citizenship which is preferred by the modernists. The nation is thus an ethno-cultural community shaped by shared myths of origins, a sense of common history and way of life, and particular ideas of space, that endows its members with identity and purpose.'[75]
In fact, the cleavages between the different strands of thinking are not so stark as might be thought. For example, in a recent essay Armstrong states that
`to a considerable extent...one may agree with .... [Hobsbawm and Anderson].... that, like other human identities, national identity has been an invention. The principal remaining disagreement is over the antiquity of some inventions and the repertory of pre-existing group characteristics that inventors were able to draw upon.'[76]
Hutchinson helpfully summarises the similarities and continuing differences between the modernist and ethnicist approaches in these terms:
`[Ethnicists] would accept that post-eighteenth-century nations differ significantly from earlier forms of community in several respects, including their political conception of human identity, the democratic character of their societies and the intensity of social and economic interactions. But there is dispute about three major issues: firstly, about the degree of overlap between modern nations and earlier ethnic formations; secondly, about conceptions of modernity and premodernity and the idea of a transition; and thirdly, about the extent to which nations are to be seen as inventions or reconstructions shaped by earlier ethnic sentiments.'[77]
It seems clear that whatever position one takes on the question of the origin of nations and the nature of nationalism, issues of identity with particular communities appear central to the understanding of the role and function of citizenship both as a status of individuals, and as one means of buttressing a sense of community. But there are bound to be substantial differences in how such conceptions of identity are seen as being constituted. Some might, for example, take the position that it is through citizenship that communities (and identities) are constituted, not vice versa, and that it is misleading to begin the search for European citizenship through the constitution of communities. [78]
The next part of this section will deal with these questions by examining the positions taken by a number of authors. First we shall examine the question of transnational polities. We begin with Habermas' argument that the nation state (at least in Western Europe) is in terminal decline, [79] and that there needs to be a decoupling of citizenship and nationality.[80] Building on that, we shall examine one approach to the question of identity and identification in transnational contexts which is offered by Breton. We shall then turn to the challenge to the nation state centred concept of citizenship posed by international migration, using the work of Koslowski and Soysal.
Habermas takes a position on nationalism which falls broadly within the modernist camp. He argues that `citizenship was never conceptually tied to national identity'.[81] The only connection between citizenship and national identity has been a `sociopsychological' one, with
`that nationalism which was inspired by the works of historians and romantic writers [founding] a collective identity that played a functional role in the implementation of citizenship that arose in the French Revolution'.[82]
In another paper, [83] he has again described how the modern conception of the constitutional state made use of `nation' and `national identity' in order
`to substitute the integrative force of democratic citizenship for outworn traditional forms of social integration.'[84]
To that extent, the marriage of `state' and `nation' was a success, enabling the creation of a `double code' of citizenship, based not only on civil rights but also on membership of a `culturally defined community.'[85] But things may go too far.
`This republican core of the national state is endangered when the integrative force of the nation, which was meant only to support democratization, is traced back to a prepolitical fact, the quasi-natural features of a historical community, that is to say, to something given independently of the political opinion - and will-formation of the citizens themselves.'[86]
In other words, the `ethnic' element of the nation may `take over', filling a `conceptual gap in the legal construction of the constitutional state which invites a naturalist interpretation of the nation to fill in'.[87] Moreover, this form of nationalism and national consciousness is a `cheap resource' constituted by the efforts of intellectuals and spread easily through the mass media, which political leaders and governments can draw on where necessary in order to focus attention away from internal social conflicts. The example of the war between the United Kingdom and Argentina over the Falkland/Malvinas Islands in 1982 is apt. From that war and the feelings it aroused, Margaret Thatcher drew the strength for an overwhelming victory in the 1983 UK General Election.[88]
Quite apart from what he would see as the dangerous tendencies which emerge from the combination of nation and state, and the `hijacking' of the mechanism of democratic citizenship, Habermas points to other reasons for the decline of the nation state as we know it, including forces of globalisation particularly in the economic sphere.[89] Because nation states can no longer control the forces which determine their economic fate, forms of transnational or supranational organization are called for. Habermas wishes to preserve the republican heritage and to maintain democratic citizenship through forms of organization such as the European Union:
`Our capacities for political action must keep up with the globalization of self-regulating systems and networks.'[90]
Habermas suggests that a form of `constitutional patriotism' may supercede the role of nationalism in the providing the `bond' which holds together complex societies.[91] We shall return to this concept as the basis for EU citizenship in the next section. Habermas acknowledges that it may be too thin a bond to hold together such societies,[92] and consequently it is useful to look further at other ways in which a sense of identity may engendered at, for example, the transnational level. Alternatively, an appropriate model may be to look at literatures on multiculturalism within states, and the basis for social unity in what Kymlicka terms `multination states' (e.g. Canada or Belgium).[93] Dismissing the liberal argument that a shared conception of justice may form the basis for social unity, he suggests a positive accommodation of `deep diversity',[94] including the ability on the part of members of each `nation' or culture to value the particular ethnic cultures and national groups to be found in each state. This must include the valuing and recognition o f minority rights,[95] including cultural rights, rights of representation, and, where necessary, self-government rights. These arguments could usefully be extrapolated `upwards' as to offer some pointers on how to construct the `glue' which could hold together the European Union.
A different approach is suggested by Breton.[96] His starting point is that it is not historically or sociologically necessary for a sense of identity to operate at any given level. The `socio-psychological' process whereby particular social structures or institutions become meaningful objects of identification by individuals is part of the creation and elaboration of new social systems, including transnational systems which are becoming ever more common phenomena in contemporary life. He describes and analyses a number of ways in which a system of collective organisation (here one could insert `the European Union' and its conception of citizenship, but the argument applies equally well to other contexts such as Canada) can
`shape individual and social identities - that is, people's conceptions of themselves and of the groups to which they belong'.[97]
In other words, Breton is arguing that elements of a transnational polity and of what it does, including its policy-making activities - including the evolution of a conception of citizenship - can feed in a number of different ways into the creation of identity. There are three primary `types' of identity or systems of identification which he separates out.[98]
The first are utilitarian identities arising from the creation of
`a network of opportunities and constraints that impinge on people's interests and partly determine their life chances';
This form of identification depends upon a means-end calculation, and is contingent upon a sense of benefitting from the enterprise with which identification is sought.
Second, there are `pragmatic solidarities', or `communities of fate' identities resulting from de facto interdependencies among individuals and groups. The effectiveness of such identities depends upon the efficacy of the relevant institutions created for pooling joint-decision-making, and the evocation of symbols stressing values of collaboration and resource sharing and joint achievements.
`Identification with the system of organized interdependence is based on reciprocity, on joint investments and participation in collective achievements, and on the perceived fairness of the distribution of costs and benefits.'
Finally, there are questions of common heritage, including historical experience, cultural heritage, religion and language which may constitute identity. These may include democratic traditions, or historical educational practices. These are the `sense of peoplehood' identities which the ethnicist school of the study of nationalism would probably stress as being the most important and historically and geographically pervasive elements of identity. Breton, however, stresses that
`a `sense of peoplehood' can develop at all levels of social organization, whether subnational, national, or transnational. Also, it should be emphasized that these levels are not necessarily mutually exclusive.'
The essence of Breton's argument is that all of these aspects of identity formation and identification are necessary in a multi-level system such as a federal state, or the EU.
`Multiple identities and loyalties are required for the existence and effective functioning of a multi-level system of collective organization. If social identities and identifications operate entirely at one level, the overall structure is likely to be unstable.'[99]
Amongst the several processes and factors (in the context of which the agency of the transnational polity and its institutions must be assumed to be a vital element) which facilitate the creation of what - at least initially - he would expect to be utilitarian or perhaps `community of fate' identities operating at the transnational level, Breton focuses on the exercise of citizenship as one key factor.[100] His discussion is further broken down into three elements:[101] the role of citizen input into decisions, and the breaking down of the distance between the citizen and the formal political institutions of the transnational level; the issue of social rights - which will be explored further below; the `duty-problem': it is one thing to grant additional rights to `transnational' citizens, but another to impose additional or different burdens such as the payment of taxation, or the requirement to do military or community service. Breton's conceptual frame for the discussion of processes of identity formation linked to the policy activities of transnational polities provides vital tools for a closer empirical examination of citizenship rights (and duties - so far as they exist) in the EU in Section IV. The linkage of citizenship and policy-making will also be further explored in Section III.
It should be noted that the argument put forward by Breton (in common with many of the arguments about transnational or postnational identity outlined in this paper) does not necessarily contradict the relevance of nationalism, in the broad sense encompassing both political/civic/statist nationalisms and cultural/ethnic nationalisms.[102] Rather, the key to this thesis lies in the possibility [103] - denied by some - of multiple identities operating in different ways at different levels. The extent to which notions of transnational identification are actually arising in the EU context will be examined further in Section III.
The problem of identity formation is not always one of `levels'; it arises also in a specifically `horizontal' sense in the context of international migration[104] - which Preu? describes as the second great challenge to the nation state-centred concept of citizenship,[105] along with the issue of transnational political formations.
The principal challenge offered by international migration concerns the status of the migrant. Migrants may not wish - for cultural or practical reasons including issues around property and succession - to relinquish the citizenship of their country of origin, in order to take on that of their country of residence by means of naturalization or registration, even if that is a possible option for them. Furthermore, states may not allow for dual nationality, thus removing the possibility for the migrant, or his/her children, if they should so wish, of straddling the nationality and citizenship divide between two countries. [106] There are broad differences between countries which ascribe nationality on the basis of so-called ius soli (i.e. those born in the territory of a given country), and those (e.g. the majority of the Member States of the EU) which use ius sanguinis to ascribe citizenship on the basis of ancestral lineage, in accordance with a pre-political sense of an original population from whom all nationals must be descended. As Koslowski [107] argues, the continued application of ius sanguinis in countries where there are significant populations of migrants - particularly in combination with restrictive rules on naturalization - raises the questions of democratic inclusivity and legitimacy since the exclusion from the franchise of, for example, second generation migrants may be highly problematic. He therefore suggests the need for further investigation of a number of alternative solutions in the European `federal' context:[108] these include the uniform adoption of ius soli by all the Member States (which would obviously have the effect of conferring nationality on second generation migrants from third countries), or the adoption of a `European' ius sanguinis giving nationality to all nationals of other Member States, but excluding third country nationals. All of these solutions presume a continuing national focus, looking at the substitution or combination of different nationalities, and therefore, if one follows the argument about the symbolic combination of nationality and citizenship, of identities. Another possibility might be to look for additionality, rather than a process of `substitution', in defining the `membership' entitlements of individuals. This is canvassed by Soysal. It could also be added that Koslowski's focus is solely on questions of democratic legitimacy, primarily fostered through the electoral process. In fact, the question of incorporation and integration of `immigrant populations' extends further into the cultural domain, with a need to examine also labour market processes, unionisation, education, and other cultural processes.[109]
Soysal's [110] starting point is the breakdown of a closed or particularistic concept of the citizen which is based on nationhood, in favour of a `more universalistic one based on personhood'.[111] Evidence for this thesis is to be found in the growth of international and national instruments protecting human rights on a universal basis, in the historical expansion of the rights and privileges accorded to citizens along the lines set out by Marshall, and in the de facto development of a category of person termed `denizen', a notion first clearly articulated by Hammar [112] and used regularly since then in various related forms by scholars of migration. [113] The `denizen' is a long-term, legally settled, migrant whose legal status is best characterised as a halfway house between citizen and alien. In many respects, including legal, civil, social, economic and often cultural rights, denizens are `members' of a state. They pay taxes, have households, bring up children, and are often involved in the cultural life of the community in which they live. As Layton-Henry argues
`It might thus be more sensible to suggest there is continuum of rights attached to the membership of a state rather than a sharp distinction between citizen and non-citizen.'[114]
Only access to the `quintessential right of citizenship - the franchise for a national legislative body' [115] might legitimately be withheld under this model (but not the franchise for local elections), and limited only to those who take the decision to naturalize. In almost all other respects, the denizen has `substantial citizenship',[116] in a model which relies on a principle of territoriality, rather than nationality. Soysal then goes on to develop a theory of postnational membership, based on the following principles:
- it is a model of membership which has arisen since the Second World War, and can be seen to a certain extent in parallel with the growth of postwar welfare states; - it is characterised by a fluidity of boundaries, rather than a rigid national territoriality, allowing individuals to hold membership rights in more than one national polity, either on the basis of dual nationality, or through a combination of citizenship and a form of denizenship; - the types of rights and privileges enjoyed are not necessarily uniform, given the different statuses an individual may enjoy; - universal personhood is the basis and legitimation for postnational membership, rather than the classic conception of equality of citizens; - finally, it may be a transnational entity which offers the basis for the organization of membership, an insight which leads inevitably to a discussion of the role of the EU in organizing a form of `citizenship'. In this latter respect, the model proposed by Soysal clearly differs from a classic `horizontal' model of denizenship, or indeed dual nationality, which looks at the juxtaposition of the rights granted by two, or more states.
Underlying these principles is an argument that the two primary elements of citizenship - identity and rights - have become increasingly decoupled as a result of key developments such as the internationalization of labour markets, the process of decolonization, the emergence of `multi-level polities' such as the EU, and the intensification of a global discourse of human rights which has a powerful legitimating effect even if such rights are not always actually observed.[117] As Soysal argues:[118]
`the nation state as a territorial entity is no longer the source of legitimacy for individual rights.... The post-war changes in the organization and ideologies of the global system have increasingly shifted the institutional and normative basis of citizenship to a transnational level and have extended rights and privileges associated with it beyond nationals.'
Consequently,
`classical conceptions of national citizenship are no longer adequate in understanding the dynamics of membership and belonging in contemporary Europe.'
To bring this discussion of the perhaps remarkable fragility of national conceptions of citizenship to a close, it is worth noting that it was very often merely a presumed ethnic homogeneity in the countries of Western Europe which engendered the conceptualization of citizenship and democracy primarily within a national context. The continuing influence of that figure of ethnic homogeneity makes it difficult for some countries to ease their rules on naturalization (e.g. Germany), or to countenance flexible rules on dual nationality which might promote the legal and `citizenship' status of long term lawful residents from other countries.[119] Meanwhile, the rise of regionalism in Europe, taking a variety of forms including strong claims - e.g. amongst Basques - for secession, as well as claims for milder forms of cultural and political autonomy, has exploded the myth of the homogeneity of European nation states. As Kirsch puts it:
`More often than not the European nation states were created not because one nation wanted its own state, but because one state welded together several groups of people who shared the feeling of togetherness and wanted to manage their own political affairs. This was partly done by blackmail, corruption, and sheer force, as in the case of Bismarck's `Deutsches Reich'; partly by more subtle and sophisticated means, as in France; partly by more terrorism and war, as in Italy.'[120]
According to Kirsch, attitudes towards European unification and regional plurification seem to go hand in hand, with resistance being strongest in those countries which are most centralized, such as the United Kingdom and France:
`The self-definition and self-perception of these states is such that a European supranational state and regional infranation states are likewise perceived as mortal threats.'[121]
What can usefully be drawn from such a diverse range of ideas to assist in the study and analysis of the concept of EU citizenship? Does the key lie in sorting through the formal and conceptual links to nationality and citizenship at the national level, as might be suggested by the link to the nationality of the Member States formalised by Article 8 EC? The problem then arises that there can be intense frictions between the different legal structures for the giving and removing of nationality as between the various states. Should instead the approach be one of accepting national identity - a phenomenon which Smith, for example, sees as both global and pervasive[122] - as a starting point for all systems of identity in the EU, so that a system of identity in relation to the EU itself must necessarily be subordinate, and constructed of very different materials? Or might a viable alternative be to show the plasticity of so many of the concepts under discussion, such that there remains a fertile and relatively untouched terrain at the transnational level for institutional innovation, in accordance with a set of principles driven by liberal values of equality, justice, democracy and legitimacy such as they should operate in a pluralistic community? It is in this context that a non-state/postnational concept of membership may prove an ideal vehicle for expressing both the ideals of citizenship, and also the de facto citizenship practice which is empirically observable in fora such as the European Union. To this end, it will prove useful to return, as so many authors have done, to the Marshallian conception of social citizenship as `full membership', and to suggest, with Preu?,[123] that it is through (social) citizenship that the `community' can be built, not the reverse.
Ward has suggested that
`a participatory and pluralist model of Union government, complemented by a non-exclusionary concept of social citizenship, might provide a means towards creating [a European] `identity'....'[124]
This would seem, therefore, to invite an examination of national models of `social citizenship', to see whether, notwithstanding the limited competence of the EU in the sphere of welfare and social rights, it is possible to shift the debate specifically linking citizenship and social rights entitlements to the larger European arena. By far the most pressing reason for following this line of argument lies in the possibility of the creation, within the medium term, of an Economic and Monetary Union with the consequential knock-on impact for national social and welfare systems, and the inevitable question marks which may arise about the sustainability and affordability of current levels of welfare provision for an ever-ageing population.[125] However, even if EMU were not to be attained, there remain substantial and important debates about the relationship between the EU and the social rights of those who fall under its (legal) jurisdiction, that is issues about the scope and content of social policy, about the competence of the institutions to make social policy legislation, and about the social dimensions of both the single internal market and the EU's trade relations with third countries. What is at issue here is the contribution - if any - that the EU can make to the continuing attempts (revisited in slightly different terms post the emergence of the new right and the end of the Cold War with the break-up of the USSR-based `communist empire') to reduce the `intolerable moral contradiction' between the `promise of citizenship' (in terms of equality) and the `reality of a market economy' (in terms of inequalities). [126] How can one ensure the best possible combination of `freedom to' and `freedom from' in the conditions of the `post-modern' welfare state?
To review social citizenship at the present time, it is necessary to refocus on citizenship understood in sociological terms, looking not only at relationships between individuals and the state, but also between individuals inter se. The discussion moves in this section from a focus on citizenship as membership of a community (the identity issue), towards citizenship as full membership of a community (the rights issue). There has not in recent years been the degree of focus on issues of social citizenship, as there has been on questions associated with civil or political citizenship, and the relationship to nationalisms and related political movements. For example, Fraser and Gordon state that `the expression `social citizenship' is almost never heard in public debate in the United States today'. [127] While there may be good pragmatic reasons in many political fora for the divorce of `welfare' (a negative term) and `citizenship' (a positive term), the separation is not absolute. For example, scholarship emanating from Scandinavia (or out of similar or parallel traditions of social democratic thinking) continues to struggle to formulate conceptions of citizenship predicated on models of substantive equality. However, since much of that scholarship also seeks to incorporate elements of a feminist conception of citizenship which stresses the need for a differentiated perspective and the need to avoid universalizing `manhood' into a conception of `personhood', a certain amount of care has to be taken in the use of the term equality.
As we have already seen,[128] the analysis of social citizenship by TH Marshall resulted in a close link being drawn between the development of postwar welfare state capitalism and the moral entitlements of equality and egalitarianism in a liberal democratic society. Since the mid-1970s, however, the tenor of the debate has changed, with New Right ideologies and the re-emergence of the `Enterprise Society' dominating the debate about welfare and social policy. [129] This leads to the argument that the `able-bodied poor have become locked into a culture of dependency' and this can only be changed by restricting benefits or access to benefits.[130] In similar terms Adriaansens argues that the welfare state became too strongly associated with a passive form of citizenship. [131] He declares that
`a more active implementation of citizenship by way of creating a participatory structure (instead of concentrating merely on the moral level of individual and `passive' social security rights) will form the ticket under which the welfare state can embark on a new future.....The task for the `new' welfare state is therefore to arrange the safety net in such a way that it acts for most citizens not as a snare but as a trampoline providing them with a soft landing and a fresh chance of establishing a place in society'.
This will avoid, or eradicate, the primary impact of the reduction of entitlements characteristic of the 1980s, which is the production of a so-called `underclass'.[132] The increased marketisation of social entitlements sees the majority obtaining what they need through consumption processes marked by contract, with the minority remaining dependent upon increasingly inadequate and underfunded public services, which carry the flavour of charity.[133] To respond to the challenges, Adriaansens proposes
`a new link between work and welfare, a link that takes account of changes in the economy on the one hand and in household formation on the other. The most important element in this new link consists in a higher and better labour force participation.'[134]
To that end he suggests measures in relation to the labour force participation of older members of society, including the chance for second careers with less exacting productivity requirements, changes to the education system which take account of the qualitative demands of the labour market, active labour market policies, the individualisation of tax arrangements, which would be particularly beneficial for women, and the individualisation of wage structures combined with the eradication of the idea of a family minimum wage.
At a conceptual, as opposed to a policy level, Turner has argued that those who defend welfare need to offer explanations as to why it should continue to exist or be developed which derive from an intellectual understanding of the nature of social membership and political participation.[135] That is why citizenship is relevant to issues of social policy, for it offers a normative frame to the claim that treatment on the basis of egalitarianism for those in need is morally superior to a laissez faire attitude. One notion, more familiar in the social policies of Member States such as France and Germany where Catholic social teaching has had an input, which may be of assistance is that of solidarity. As Spicker puts it, solidarity is about
`seeing welfare as a form of collective activity and so the responsibility of the wider society rather than of individuals.' [136]
Perhaps the most constructive suggestions at the conceptual, as opposed to the policy level for taking forward the conception of social citizenship come out of a feminist critique which shows how the liberal postwar orthodoxy was implicitly predicated on a set of male norms: a male breadwinner model for social security and for conceptions of basic minimum incomes; a masking of women's role within the private sphere through caregiving and in the public sphere through marginal employment; a failure to take into account women's role in negotiating with welfare state institutions.[137] As Lister points out,[138] it is particularly in Scandinavian feminist writings that attempts to synthesise the `rights' (passive) and `participatory' (active) strands of thinking about citizenship have been seen most clearly. She cites the example of Hernes:
`The welfare state literature, to the extent that it deals with individual citizens, deals with those aspects of citizenship that are related to social policy entitlements. Democratic theories and empirical studies of democratic politics emphasise the participatory aspects of citizenship. Any adequate account of contemporary citizenship in Scandinavia must include all these dimensions if the interplay between material rights, multi-level participation, and political identities is to be grasped.[139]
Case studies derived from the history of welfare state formation in Sweden, for example, have shown the role of the agency of women's collectivities in the struggle for social rights in crucial periods such as the 1930s.[140] The model of power resources and consequential policy regimes developed from the Marshallian paradigm focused on working class power primarily expressed through the politics of left wing parties which failed to take account of a gender perspective. One response to works such as Esping-Andersen's The Three Worlds of Welfare Capitalism[141] - seen as innovative in approach in creating a typology of welfare states, but ultimately gender-blind in so far as they fail to take account of women's specific situation in relation to welfare - has been a proliferation of work examining welfare states from a self-consciously gendered perspective.[142] These accounts incorporate the role of women in the formation and evolution of welfare states, but also provide a gender sensitive analysis of the impact of policy. In that analysis, women are not seen as a unitary category, but differences amongst women - in particular migrant women and women of colour - are brought into the framework. The universalising tendencies of citizenship's rhetoric of equality, therefore, are treated with a certain degree of scepticism.[143] Moreover, such accounts adopt a critical perspective vis-‡-vis the classical Nordic conception of the woman-friendly state, where additional collective responsibilities in relation to family-based activities such as care-giving are incorporated fully into public policy. Although such policies may be helpful at the practical level, they also display weaknesses in so far as they may lead to excessive state intervention in the private sphere, and to a loosening of the individual element of citizenship and identity. [144]
As the quotation from Ward used at the beginning of this section indicated, there is scope to see how a form of European `identity' can be generated out of the development of a conception of social citizenship. Identity does not, on this argument, need to be generated from a sense of nationalism, ethnicity or regional belonging. It can be mediated through positive social institutions which empower individuals and collectivities through both participation and entitlements. Furthermore these positive social institutions may lie both in the public and private spheres, and may cut across the worlds of work, family and politics. The argument defended in this paper is that the form of citizenship appropriate to the EU must, in view of the polity within which it is based, as well as the types of nation states which make up the Member States of the EU, be a type of social citizenship, indeed be one which resists, in particular, the effects of social exclusion as one possible by-product of the enhancement of the market `ideal' as a potentially self-contained goal of integration since the mid-1980s. Moving now to a closer examination of the interactions between European integration and citizenship ideas, we may see to what extent it might be possible to realise such possibly idealistic sentiments within the European Union.
[34] Held, `Between State and Civil Society: Citizenship', in Andrews (ed.), Citizenship, London: Lawrence and Wishart, 1991 at p20.
[35] A term used, inter alia, by Soysal, op. cit. supra n.1.
[36] See Kymlicka and Norman, `Return of the Citizen: A Survey of Recent Work on Citizenship Theory', (1994) 104 Ethics 352.
[37] Marshall, Citizenship and Social Class, Cambridge: Cambridge University Press, 1950 esp. pp28-29.
[38] An English male perspective, it could be added, for many of the rights in question were only acquired much later by women; see Vogel, `Is Citizenship Gender-Specific', in Vogel and Moran (eds.), The Frontiers of Citizenship, Basingstoke: Macmillan, 1991.
[39] Marshall, op. cit. supra n.37 at pp28-29.
[40] Barbalet, Citizenship. Rights, Struggle and Class Inequality, Milton Keynes: Open University Press, 1988, at p8.
[41] Turner, Citizenship and Capitalism: the Debate over Reformism, London: Allen and Unwin, 1986.
[42] A term developed in detail by Wiener: see Della Sala and Wiener, op. cit. supra n.32.
[43] See in the North American context the work of Herman on conflicts between gay rights discourse, and the discourse of the anti-gay Christian Right, especially `(Il)legitimate Minorities: The American Christian Right's Anti-Gay-Rights Discourse', (1996) 23 Journal of Law and Society 346 and Rights of Passage: Struggles for lesbian and gay equality, Toronto: University of Toronto Press, 1994.
[44] Barbalet, op. cit. supra n.40 at p93.
[45] Or perhaps better, too English; see Haseler, The English Tribe. Identity, Nation and Europe, Basingstoke: Macmillan, 1996, who describes the relationship between Englishness and Britishness. For a systematic critique of Marshall from this perspective see Mann, `Ruling Class Strategies and Citizenship', (1987) 21 Sociology 339.
[46] For a contemporary analysis of citizenship in Europe which continues to draw strongly on issues of social class and equality/inequality see Close, Citizenship, Europe and Change, London: Macmillan, 1995.
[47] Commentators note the absence of a definitive statement of the libertarian conception of citizenship akin to those statements of the liberal position provided by Marshall or Rawls (Political Liberalism, New York: Columbia University Press, 1993). For summaries and critiques of the libertarian position see Miller, `Citizenship and Pluralism', (1995) 43 Political Studies 432; Bellamy and Greenaway, `The New Right Conception of Citizenship and the Citizen's Charter', (1995) 30 Government and Opposition 469.
[48] E.g. Young, `Polity and Group Difference: A Critique of the Ideal of Universal Citizenship', 99 Ethics 250.
[49] See Kymlicka, `Three Forms of Group-Differentiated Citizenship in Canada', in Benhabib (ed.), Democracy and Difference. Contesting the Boundaries of the Political, Princeton, NJ: Princeton University Press, 1996.
[50] Kymlicka and Norman, op. cit. supra n.36 at p363.
[51] Mouffe, op. cit. supra n.25 at p5.
[52] For fuller discussions see inter alia Mouffe, op. cit. supra n.25; van Steenbergen (ed.), The Condition of Citizenship, London, etc.: Sage, 1994; Beiner (ed.), Theorizing Citizenship, Albany: State University of New York Press, 1995; Lister, Feminist Perspectives on Citizenship, London: Macmillan, 1997 forthcoming.
[53] See supra at n.1.
[54] `Citizenship and National Identity', in van Steenbergen, op. cit. supra n.52 at p20.
[55] See Harvie, The Rise of Regional Europe, London: Routledge, 1994.
[56] Kirsch, `The New Pluralism: Regionalism, Ethnicity, and Language in Western Europe', in Knop, Ostry, Simeon and Swinton (eds.), Rethinking Federalism: Citizens, Markets, and Governments in a Changing World, Vancouver: University of British Columbia Press, 1995 at p59.
[57] E.g. by Aron, `Is Multinational Citizenship Possible?', (1974) 41 Social Research 638 who denies the possibility of European citizenship.
[58] Hutchinson and Smith (eds.), Nationalism, Oxford: Oxford University Press, 1994, p132.
[59] Walzer, `Citizenship', in Ball, Farr and Hanson (eds.), Political innovation and conceptual change, Cambrige: Cambridge University Press, 1989, at p211.
[60] Walzer, op. cit. supra n.59 at p211.
[61] Ignatieff, `The Myth of Citizenship', in Beiner, op. cit. supra n.52 at p55.
[62] E.g. van Gunsteren, `Four Conceptions of Citizenship', in van Steenbergen, op. cit. supra n.52.
[63] Kymlicka and Norman, op.cit. supra n.36 at p362.
[64] Oldfield, Citizenship and Community: Civic Republicanism and the Modern World, London: Routledge, at p6.
[65] Smith, `Culture, community and territory: the politics of ethnicity and nationalism', (1996) 72 International Affairs 445 at p447.
[66] E.g. by Keldourie, Nationalism, London: Hutchinson, 1961.
[67] E.g. Breuilly, Nationalism and the state, Manchester: Manchester University Press, 1982; Giddens, The nation-state and violence, Cambridge: Polity Press, 1985; Mann, `A Political Theory of Nationalism and its Excesses', in Periwal (ed.), Notions of Nationalism, Budapest: Central European University Press, p44.
[68] See Hutchinson, Modern Nationalism, London: Fontana Press, 1994, at p40.
[69] For summaries of his position see `Culture, community and territory', op. cit. supra n.65; `National identity and the idea of European unity', (1992) 68 International Affairs 55; `The problem of national identity: ancient, medieval and modern?', (1994) 17 Ethnic and Racial Studies 375.
[70] E.g. the classic statement of Renan, Qu'est-ce qu'une nation, Paris: Calmann-Levy, 1882, extracted in Hutchinson and Smith, op. cit. supra n.58 at pp17-18; see also more recently Seton-Watson, Nations and States, London: Methuen, 1977.
[71] Nations before Nationalism, Chapel Hill: University of North Carolina Press, 1982.
[72] E.g. Hutchinson, op. cit. supra n.68 at pp7-9.
[73] Exemplified in a number of variants in which marxism plays a greater or lesser role by the work of Gellner (e.g. Nations and Nationalism, Oxford: Blackwell, 1983), Hobsbawm, (e.g. Nations and Nationalism since 1780, Cambridge: Canto, 1992 (2nd edn.)), and Anderson (e.g. Imagined Communities, London: Verso, 1991 (revd. edn.)).
[74] Thought and Change, London: Weidenfeld and Nicolson, 1964, at p169.
[75] Hutchinson, op. cit. supra n.68 at p7.
[76] Armstrong, `Towards a Theory of Nationalism: Consensus and Dissensus', in Periwal, op. cit. supra n.67 at p36.
[77] Hutchinson, op. cit. supra n.68 at p10.
[78] See for example Preu?, `Citizenship and Identity: Aspects of a Political Theory of Citizenship', in Bellamy, Bufacchi and Castiglione, op. cit. supra n.29 at p119.
[79] For further arguments on the transmutation of the nation state and sovereignty see MacCormick, `Liberalism, Nationalism and the Post-sovereign State', (1996) 44 Political Studies 553; ibid, `What Place for Nationalism in the Modern World?', in Caney, George and Jones (eds.), Naional Rights, International Obligations, Oxford/Boulder: Westview, 1996.
[80] See also Oommen, Citizenship, Nationality and Ethnicity, Cambridge: Polity, 1997, esp. pp240-242.
[81] Habermas, op. cit. supra n.54 at p23.
[82] Habermas, op. cit. supra n.54 at p23.
[83] `The European Nation State. Its Achievements and Its Limitations. On the Past and Future of Sovereignty and Citizenship', (1996) 9 Ratio Juris 125.
[84] Habermas, op. cit. supra n.83 at p131.
[85] Habermas, op. cit. supra n.83 at p130.
[86] Habermas, op. cit. supra n. 83 at p131.
[87] Habermas, op. cit. supra n. 83 at p131.
[88] Jessop et al, Thatcherism, Oxford: Polity, 1988, at pp63-64, 86.
[89] Although not all would share his thesis here. See the sceptics of globalisation Hirst and Thompson, Globalisation in Question, Cambridge: Polity, 1996.
[90] Habermas, op. cit. supra n.83 at p137.
[91] Habermas, op. cit. supra n.83 at p133.
[92] As indeed it is also insufficient as a bare postwar substitute for Nazi nationalist patriotism as a means for creating a sense of belonging within Germany itself: see Dijkink, National Identity and Geopolitical Visions. Maps of Pride and Pain, London/New York: Routledge, 1996, p34.
[93] Kymlicka, Multicultural Citizenship, Oxford: Oxford University Press, 1995 esp. pp187-191.
[94] A term borrowed from Taylor, `Shared and Divergent Values', in Watts and Brown (eds.), Options for a New Canada, Toronto: University of Toronto Press, 1991.
[95] Baub^ck, `Cultural Minority Rights for Immigrants', (1996) 30 International Migration Review 203.
[96] `Identification in Transnational Political Communities', in Knop et al, op. cit. supra n.56.
[97] Breton, op. cit. supra n.96 at p41.
[98] The quotations and terminology used in this section are drawn from Breton, op. cit. supra n.96 at pp41-44.
[99] Breton, op. cit supra n.96 at p52.
[100] He also examines `bottom-up processes' (the way we live our lives), `top-down processes' (including the creation of symbols and symbolic meaning for the transnational entity), the nature of the system of belief adopted by those involved (isolationist or collaborative), competition for citizen support (e.g. by assistance programmes), inequalities among constituent units (which can be a significant barrier to processes of identity formation). Significantly, good illustrations of all of these processes can be found in the range of EU policies and institutional processes. The point will be reviewed again briefly in Section 4.
[101] Breton, op. cit. supra n.96 at pp50-52.
[102] See MacCormick, op. cit. supra n.79.
[103] E.g. see Guetzow, Multiple Loyalties: Theoretical Approach to a Problem in International Organization, Princeton: Princeton University Center for Research on World Political Institutions, 1955; for more recent support in the form of `concentric circles' see Garcia and Wallace, `Conclusion', in Garcia (ed.), European Identity and the Search for Legitimacy, London: Pinter, 1993. More scepticism is to be found in Obradovic, `Policy Legitimacy and the European Union', (1996) 34 JCMS 191 esp. pp214-215.
[104] For details of the scale and nature of intra-EU migration see Rees, Stillwell, Convey and Kupisweksi, Population Migration in the European Union, Chichester: Wiley, 1996.
[105] See `Two Challenges to European Citizenship', (1996) 44 Political Studies 534, esp. pp544-549.
[106] As Gamberale (`National Identities and Citizenship in the European Union', (1995) 1 European Public Law 629) notes, the terms nationality and citizenship are not used in a uniform or necessarily consistent way by different countries or legal systems. However, international law recognises a distinction whereby `nationality' is seen as the external aspect of membership, necessary so that states can determine the scope of their responsibilities in international law for given populations, whereas citizenship is the internal aspect of membership which governs the status in law of those who are members of a polity. Some countries (e.g. Italy) have no conception of `nationality' as such, using only the term `citizen', since nationality is seen as an ethnic term with unpleasant historical connotations.
[107] `Intra-EU Migration, Citizenship and Political Union', (1994) 32 JCMS 369.
[108] Koslowski, op. cit. supra n.107 at pp394-396.
[109] See Baldwin-Edwards and Schain, `The Politics of Immigration. Introduction', in Baldwin-Edwards and Schain (eds.), The Politics of Immigration in Western Europe, Ilford: Frank Cass, 1994, at pp11-14.
[110] Limits of Citizenship. Migrants and Postnational Membership in Europe, op. cit. supra n.1 esp. pp136-143; see also for a summary Soysal, `Changing Citizenship in Europe. Remarks on postnational membership and the national state', in Cesarani and Fulbrook (eds.), Citizenship, Nationality and Migration in Europe, London: Routledge, 1996.
[111] Soysal, op. cit. supra n.1 at p137.
[112] `Citizenship: Membership of a Nation and of a State', (1986) 24 International Migration 735; International Migration, Citizenship and Democracy, Aldershot: Gower, 1990; Democracy and the Nation-State. Aliens, Denizens and Citizens in a World of International Migration, Aldershot: Gower, 1990; `The Civil Rights of Aliens', in Layton-Henry (ed.), The Political Rights of Migrant Workers in Western Europe, London: Sage, 1990.
[113] E.g. Baub^ck, Transnational Citizenship. Membership and Rights in International Migration, Aldershot: Edward Elgar, 1994; Layton-Henry, `Citizenship and Migrant Workers in Western Europe,' in Vogel and Moran, op. cit. supra n.38.
[114] Layton-Henry, op. cit. supra n.113 at p118.
[115] Baub^ck, op. cit. supra n.95 at p239.
[116] Baub^ck, op. cit. supra n.115 at p239.
[117] Soysal, `Changing Citizenship', op. cit. supra n.110 at pp18-19.
[118] Soysal, op. cit. supra n.110 at p21.
[119] See further Gamberale, op. cit. supra n.106; on dual citizenship generally see Shevchuk, `Dual Citizenship in old and new states', (1996) 37 Arch. europ. sociol. 47.
[120] Kirsch, op. cit. supra n.56 at p66.
[121] Kirsch, op. cit. supra n.56 at p73.
[122] Smith, National Identity, Harmondsworth: Penguin, 1991, p143.
[123] Preu?, op. cit. supra n.78.
[124] `(Pre)conceptions in European Law', (1996) Journal of Law and Society 198 at p210.
[125] See for example Twine, Citizenship and Social Rights, London: Sage, 1994, esp. pp151-162.
[126] Ignatieff, `The Myth of Citizenship', in Beiner, op. cit. supra n.52 at p66.
[127] `Civil Citizenship against Social Citizenship? On the Ideology of Contract-versus-Charity', in van Steenbergen, op. cit. supra n.52 at p91.
[128] See supra at n.36 et seq.
[129] See Plant, `Welfare and the Enterprise Society', in Wilson and Wilson (eds.), The State and Social Welfare, London/New York: Longman, 1991.
[130] Plant, op. cit. supra n.129 at p86.
[131]Adriaansens, `Citizenship, Work and Welfare', in van Steenbergen, op. cit. supra n.52 at p67.
[132] See the analysis by Dahrendorf, `The Changing Quality of Citizenship', in van Steenbergen, op. cit. supra n.52 esp. pp14-16 and Wilson, `Citizenship and the Inner-City Ghetto Poor', in the same volume.
[133] See also Fraser and Gordon, op. cit. supra n.127.
[134] Adriaansens, op. cit. supra n.131 at p71.
[135] `Outline of a Theory of Citizenship', in Mouffe, op. cit. supra n.25.
[136] Spicker, Social Policy. Themes and Approaches, London, etc.: Prentice Hall/Harvester Wheatsheaf, 1995, at p60.
[137] See for an early example of a critique of Titmuss's `seminal' exposition of Marshallian social citizenship and social policies (`The social division of welfare', in Titmuss, Essays on `the welfare state', London: Allen & Unwin, 1963), Rose, `Rereading Titmuss: the sexual division of welfare', (1981) 10 Journal of Social Policy 47.
[138] `Citizenship: towards a feminist synthesis', Paper presented at the Women and Citizenship Conference, University of Greenwich, July 1996.
[139] Hernes, Welfare State and Woman Power, Oslo: Norwegian University Press, 1987, at p138; see also Hernes, `The Welfare State Citizenship of Scandinavian Women', and Siim, `Towards a Feminist Rethinking of the Welfare State', both in Jones and JÛnasdÛttir (eds.), The Political Interests of Gender, London: Sage, 1988; Siim, `New Dilemmas in the Theory and Practice of Women's Citizenship', Paper presented at the Second European Sociological Association Conference, Budapest, August 1995.
[140] See for example Hobson and Lindhom, `Collective Identities, Women's Power resources, and the Construction of Citizenship Rights in Welfare States', forthcoming Theory and Society, special issue on Citizenship.
[141] New Jersey: Princeton University Press, 1990.
[142] E.g. Sainsbury (ed.), Gendering Welfare States, London: Sage, 1994; O'Connor, `From Women in the Welfare State to Gendering Welfare Regimes', Trend Report (1996) 44(2) Current Sociology.
[143] For other broader based feminist critiques of citizenship see Mouffe, `Feminism, Citizenship and Radical Democratic Politics', in Butler and Scott (eds.), Feminists Theorize the Political, New York/London: Routledge, 1992; Lister, `Dilemmas in engendering citizenship', (1995) 24 Economy and Society 1; Bubeck, `A Feminist Approach to Citizenship', EUI Working Paper EUF No. 95/1.
[144] See Everson, `Women and Citizenship of the European Union', in Hervey and O'Keeffe (eds.), Sex Equality Law in the European Union, Chichester: Chancery Wiley, 1996; Siim, `Welfare State, Gender Policies and Equality Policies: Women's Citizenship in the Scandinavian Welfare States', in Meehan and Sevenhuijsen (eds.), Equality Policies and Gender, London, etc.: Sage, 1991, esp. pp188-9.
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