Multiculturalism in France and the Policy of Laïcité: the Source of Potential Contradictions?
By Lucy Rebecca Anns (2015)
This dissertation aims to improve France’s policy of laïcité, or radical secularism, in order to help it specifically accommodate its Muslim population. It is split into four in-depth case studies, each centring on a different country: France, Britain, the USA, and India. These case studies each focus on a different form of secularism, apart from Britain and the USA, which comprise two separate versions of one form of secularism. They will be compared and contrasted in regard to three core elements of laïcité: national cohesion, unity, and integration; equality and neutrality, and state control and the public/private divide, in order to determine what France can learn from these other forms of secularism to improve its policy of laïcité and better accommodate its Muslim population. The first two chapters focus on France and laïcité, the third chapter focuses on Britain and the USA and moderate secularism, and the fourth chapter focuses on India and contextual secularism. These case studies have been chosen in order to allow this dissertation to take a global approach to secularism.
Furthermore, this dissertation is based on two assumptions since it is beyond its scope to critically analyse them. Firstly, that secular states are better at dealing with religious pluralism than theocratic states. Secondly, that Britain is a secular state.
In conclusion, this dissertation will argue that laïcité is, in its current form, exclusive and therefore unable to truly accommodate its Muslim population and their needs. As such, several recommendations for France are suggested, based on the comparisons between the different secular conceptions in Britain, the USA, and India, so that its policy of laïcité can be improved and therefore so it can better accommodate its Muslim minority.
- National Cohesion, Unity, and Integration
- Equality and Neutrality
- State Control and the Public/Private Divide
- The USA
- National Cohesion, Unity and Integration
- Equality and Neutrality.
- State Control and Public/Private Divide
- Further Research
The past three decades have seen large numbers of immigrants, predominantly from Northern Africa as a result of colonialism, migrating to France. It is now the country with the greatest population of Muslim immigrants in the European Union, with 4.7 million Muslims, about 7.5% of the total population (Pew Research 2015). These immigrants have come over with their own set of cultural identities and their own personal as well as communal religious convictions, which have created problems for the French state. These problems have become increasingly politicised, for example Marine Le Pen, the leader of the National Front, compared Muslims praying in the street to a Nazi occupation (Telegraph 2010). They have ranged from the headscarf affair of 1989 to the recent Charlie Hebdo attacks in January 2015.
Over the last seven or eight years, there has been a cacophony of debate about whether this has led, or will lead to, a period of ‘secularism in crisis’ (Modood 2012) as demands for religious pluralism become more widespread. Arguably, this debate became mainstream due to Jürgen Habermas’ argument that ‘…modernity no longer implies the march toward secularism, and in a democracy, the secular mentality must be open to the religious inﬂuence of believing citizens…’ (Habermas 2008: 17). There has also been debate over whether secularism as a form of state governance can meet the challenge of this growing religious multiculturalism, and if it can, what type of secularism it should be.
This research aims to improve France’s policy of secularism, or ‘laïcité’, in order to help it specifically accommodate its Muslim population.
Discussion on Secularism
Secularism is particularly hard to define. There are several concepts related to it including: secularism relating to a ‘secular society’ (BBC 2013); secularism relating to a ‘form of state governance’ (Haynes & Guy Ben‐Porat 2010: 127); and secularism relating to a historical process, usually termed ‘secularisation’ (Haynes & Guy Ben‐Porat 2010: 126). This dissertation will make reference to the former two concepts, primarily focusing on the second. These concepts are not mutually exclusive and are sometimes interchanged when talking about ‘secularism’ in academic literature. One of the most commonly accepted premises of secularism as a form of state governance is that it relates to the separation of religion (or church) and state (Cantle 2009: 1) but, as will be shown, such a distinction is not always necessary for a state to be classed as ‘secular’. There are many different types of secularism across many different countries such as the USA, Australia, and India, including many European countries such as Britain, Germany, and Denmark, and even states such as Turkey and Israel. For the purposes of this dissertation however, three different types of secularism, as a form of state governance, in four countries will be analysed.
The primary research question of this dissertation which will be answered in the conclusion is: What can France learn from moderate secularism in Britain and the USA, and contextual secularism in India in order to improve its policy of laïcité and therefore better accommodate its Muslim population?
This dissertation will use a qualitative approach since it is not based on data but primary and secondary sources, and will be discursive in nature. It will use content analysis of some primary, but mostly secondary sources in order to gain valuable historical and cultural insights through the analysis of these texts. The disadvantage of this methodology in this case is that it is reductive and therefore the texts will only be analysed for specific aspects relating to secularism as this dissertation cannot probe deeper into other interdependent factors such as gender roles. The primary methodology used will be case studies. There will be four in-depth case studies, each centring on a different country: France, Britain, the USA, and India. These case studies each focus on a different form of secularism, apart from Britain and the USA, which comprise two separate versions of one form of secularism. They will be compared and contrasted through the use of substantiated examples. The method of triangulation will increase the validity of this qualitative research by juxtaposing three principal sources: peer-reviewed academic journals, newspaper articles, and books. However, the literature will also include books, Heads of State speeches, and NGO sources to provide sufficient information in order to develop the argument. Bias inevitably contained within at least several of these sources, especially within newspaper articles and speeches, will be taken into account.
Significance of Dissertation
This research will add to the growing body of literature on how best to accommodate religious minority groups through the policy of secularism, and more specifically, it will enhance an understanding of the differences between various secular forms of governance and what can be learnt from their comparison. This body of literature is still in its early stages and is arguably dominated by two principal authors, Tariq Modood, a professor of Sociology, Politics and Public Policy at the University of Bristol, and Rajeev Bhargava, a former professor of Political Theory at the Jawaharlal Nehru University in India. Modood discusses the concepts of radical and moderate secularism in many of his articles and advocates the latter concept. Bhargava refers to these concepts as the mainstream conception of secularism but criticises them advocating contextual secularism. These two authors form the basis of this dissertation and the three concepts are the titles of the three main chapters.
Scope of Dissertation
Since there are many different types of secularism and also many secular states, the scope of this dissertation is quite limited. Britain, the USA, and India have been specifically chosen to be compared and contrasted with France for several reasons. Firstly, all three countries are religiously pluralistic in terms of their Muslim populations. Britain has around 2.9 million Muslims, which is 4.6% of its population (Pew Forum 2011), the USA has around 1.4 million Muslims, which is about 0.6% of its total population (Pew Research 2007), and India, a predominantly Hindu nation, has around 176 million Muslims, which is roughly 14% of its total population (Pew Forum 2012). Secondly, all four countries take a very different secular approach to religious pluralism which allows effective comparisons, and therefore criticisms and suggestions, to be made. Thirdly, analysing the case studies of both Britain and the USA within ‘moderate secularism’ illustrates that the categories are not black and white but complex. Fourthly, these countries allow the dissertation to go beyond the limits of Europe in order to take not only a wider Western approach but also an Eastern approach.
It is also important to note that this dissertation will be based on several assumptions since it is beyond its scope to critically analyse them. Firstly, that secular states are better at dealing with religious pluralism than theocratic states, for example, Iran. There are claims to the contrary, however secularism is supposed to be a basis of neutrality between all religions and theocracies in their very nature explicitly privilege one religion over another. Secondly, that Britain is a secular state. There are arguments that it is not since it has an established church. However, as will be shown, the separation of state and religion is not necessarily obligatory for a state to be classed as secular.
Organisation of Dissertation
The first chapter of this dissertation will focus on the history of laïcité as it is important to see its original purpose in order to frame my argument and see how the principle of laïcité has evolved over the years. The second chapter will focus on laïcité, or radical secularism, in France and three core elements of laïcité will be analysed in order to assess whether or not France is able to accommodate its Muslim population. The third chapter and fourth chapter will focus on moderate secularism in Britain and the USA and contextual secularism in India respectively. These case studies will also be analysed in terms of the three elements in order to determine whether France can learn from either or both moderate and contextual secularism regarding its Muslim population. To conclude, this dissertation will argue that laïcité, France’s policy of radical secularism, is in its current form, exclusive and therefore unable to truly accommodate its Muslim population and their needs. As such, several recommendations for France are suggested, based on the comparisons between the different secular conceptions in Britain, the USA, and India, so that its policy of laïcité can be improved and therefore so it can better accommodate its Muslim minority.
Laïcité is a founding principle of the French Republic and was born out of the 1905 law separating the State from the Church. It was hard-fought for with a long and complicated history and is therefore staunchly protected by many French people (Astiers 2004). However, in more recent times, governments have been faced with new challenges, not least the strong presence of Islam, and thus there is a recurring question in French politics of whether the laïcité of 1905 should be kept as a timeless concept or whether it should be seen as a value that should be continually revised in accordance with changing circumstances. However, if it should be seen as a value, in what way does it need to be revised? The latter question is the general focus of this dissertation and will be addressed in the final chapter, but the former question, which needs to be answered first, will be addressed in this chapter. In order to do this, the chapter will examine a brief history of laïcité, its original purpose and conception.
Before the French revolution of 1789, France was made up of three ‘estates’ in what was called the ‘Ancien Regime’. These estates were: firstly, the clergy; secondly, the nobility; and thirdly, the commoners (Merriman 2010: 442). The clergy, as the first estate, wielded considerable power. The Church was responsible for collecting the tithe from the commoners, managing the hospitals and schools, and it also had powers of censorship and owned around 15% of the land in France. However, the Upper Clergy, Bishops and Abbots for example, often abused their power in order to exploit the workers, the third estate, and were, as a result, strongly resented by them.
By 1789, France was in a deep economic downturn and was suffering from major food shortages (Kropotkin 1927). Resentment of the peasants, and to some extent the middle classes, towards the social and political system as well as towards the monarchy led to the first French revolution. This revolution was characterised by urban revolts in the storming of the Bastille, and rural revolts against the estates of landlords. In the aftermath of the revolution, the three estates were abolished and the Declaration of the Rights of Man and the Citizen was formed.
This Declaration set forth new principles that were to govern the lives of France’s citizens and reflected some of the ideas encapsulated in the American Declaration of Independence of 1776 (Merriman 2010: 448). Article 10 of the Declaration stated that, ‘No one shall be disquieted on account of his opinions, including his religious views, provided their manifestation does not disturb the public order established by law’ (Yale Law School). This right of every French citizen to follow his or her own religion is the basis of the country’s modern day principle of secularism, ‘laïcité’, which was expanded further in the 1905 law. And although the word laïcité was not used in 1789, this is arguably the first written evidence of the principle in French documents. The declaration thus created a new ‘enlightened’ France which placed its emphasis on individual freedom, civic equality and reason (Merriman 2010: 448).
A further result of the revolution was that the property and land of the Catholic Church was confiscated and auctioned off to wealthy commoners which helped reduce France’s debt. The Church became essentially a department of the state, which henceforth would pay clerical salaries, the expenses of worship, and poor relief (Merriman 2010: 451). All priests were made to swear an oath of loyalty to the revolution, and thus accept the Civil Constitution of the French Clergy in 1790, legislation which effectively created a national church (Merriman 2010: 451). The constitution however was strongly resisted (Merriman 2010: 451).
Not all the onlookers of this revolution were pleased. Edmund Burke, an Irish political theorist and philosopher wrote, ‘…the age of chivalry is gone….—that of sophisters, economists, and calculators, has succeeded; and the glory of Europe is extinguished forever…’ (Burke 1909-1914). Furthermore, the Pope denounced the Declaration of the Rights of Man and condemned the Constitution (Merriman 2010: 451). The dispute was only resolved in 1801, when Napoleon Bonaparte signed a ‘Concordat’, a reconciliation agreement, with the Pope, which allowed the Roman Catholic Church to be the established church of France (Berkley Center). However this meant that the State remained ‘entwined’ under the 1801 Napoleonic Concordat with the ‘…intrusive theocratic disposition of a pope…’ (Saunders 2009: 62). The enlightenment ideology of the revolution was thus forgotten for a time. Rome would exercise control over civil matters including the school curriculum until the late 1880s (Saunders 2009: 62). Roman Catholicism was recognised as the faith of the majority of French citizens, but Napoleon also named Judaism and the Lutheran and Reformed Churches as being officially recognised by the state.
Despite the revolution, Catholicism remained for many a ‘plausible political doctrine’ (Saunders 2009: 60). The revolution had failed to rid the country of religion (Saunders 2009: 60). The Catholic Church guarded its powers and did not cease to expand them when it could throughout the 19th Century (Ardant et al. 1995: 20. My own translation). However, there were many who still opposed the Catholic Church and this opposition to Catholicism structured the Republican or ‘Secularist’ side. In the famous words of Gambetta, a French Statesman, ‘Clericalism, this is the enemy’ (Ardant et al. 1995: 20. My own translation).
Struggles between the Royalists, supporters of the monarchy and the clergy, and Republicans characterized much of the nineteenth century, with the ‘…former promoting a closer Church-state relationship and the latter representing a further break from tradition…’ (Berkley Center). These struggles were seen through the formation of governments during the Third Republic. One example of this was the MacMahon government. The monarchist majority in the National Assembly diminished at each by-election and as a result they elected Marshal MacMahon in 1873 as their President due to his desire for the return of the monarchy (Merriman 2010: 735). MacMahon’s government censored newspapers and banned the celebration of July 14th. However, despite all the efforts of the MacMahon government, the Republicans won a majority in the Chamber of Deputies, part of the National Assembly in 1876 (Merriman 2010: 735). As a result, MacMahon was forced to elect a Moderate Republican as Premier. The Republican majority tried to limit the power of the monarchist President, who in 1877 caused a political crisis by forcing the Premier’s resignation and electing a monarchist in his place (Merriman 2010: 735). The Chamber of Deputies withheld its approval, and MacMahon thus dissolved it and called for new elections. He ‘embarked…on a bitter campaign to defeat…the republicans…’ (Merriman 2010: 736). France’s voters continued to vote Republican, however, retaining the Republican majority in the National Assembly, and this led to MacMahon’s resignation in 1879 (Merriman 2010: 736).
Splits between Republicans and Royalists also spurred many other confrontations during this time period, and one of the fiercest fights was over schools (Saunders 2009: 61). Schools, in the mid-18th century, were a crucial ‘vector of civil power and controversy’ caught between the enlightenment cause of the Republicans and the divine cause of the Catholic Church (Saunders 2009: 61). The tide began to turn in favour of the Republicans however, and in 1880, Jules Ferry, the Minister of Public Instruction, undertook educational reforms aimed at encouraging literacy and expanding the new Republican order by removing religious staff from state-run schools (BBC 2004). Following this, the law of 1882 established the first ‘free, secular, and compulsory’ school (Saunders 2009: 61). Ferry commented that this was ‘one of those great organic laws destined to live in harmony with the country, and to enter our way of life’ (Saunders 2009: 61). The ‘laicisation’ of the school was a significant moment for the Republicans as it established the new regime by conveying its values: ‘the Republic has made the school, the school will make the Republic’ (Ardant et al. 1995: 20. My own translation). This was an important landmark in France’s transition to secularism.
During the years 1901-1904 the Republicans gained power over the Catholic Church. The Neo-Jacobin figure of Emile Combes as Prime Minister went further and closed the majority of religious schools. He also, in the law of 25th July 1904, broke off diplomatic relations with the Holy See (Saunders 2009: 63), although the Concordat had not yet been dissolved. This ‘…slow quarantine of public life from clerical interventions served as preliminary to the 1905 law of separation…’ (Saunders 2009: 61).
Emile Combes was a strong supporter of the 1905 law of separation and although he resigned as Prime Minister in early 1905, to be replaced by Aristide Briand, the law was passed later that year. This law was significant in several ways: firstly it ‘…enshrined a number of already-applied principles in law…’(BBC 2004) and secondly, it ‘…officially ended Napoleon’s Concordat and imposed a number of new measures…’(BBC 2004). Although again not actually mentioned in the text, ‘laïcité’ is most commonly traced back to this law as it was the first piece of legislation to codify the separation of church and state, a ‘…fundamental law of institutional disconnection and non-establishment whereby…after 50 stormy years of political strife and religious confrontation, the National Assembly legislated the separation of churches and the state…’ (Saunders 2009: 57). This therefore meant the strict religious neutrality of the state, a guarantee of the freedom of religious exercise, and the prohibition of public funding of all religions (Concordat Watch). Article two of the 1905 law states; ‘The Republic does not recognize, remunerate or subsidize any religion…all expenses concerning the practice of religion shall be abolished from the budgets of the State, Departments and municipal councils…’ (Concordat Watch).
After the 1905 law was passed, the principle of laïcité ‘…became increasingly entrenched in the fabric of French political culture during the early twentieth century…’ (Berkley Center) even though most French people still identified themselves as Catholic. This law signified the end of the movement towards laïcité. However the social power of Catholicism only declined slowly (Ardant et al. 1995: 20. My own translation).
This chapter reflects on the ‘single history and conflictual turn by which laïcité gained prominence in France…’ (Ardant et al. 1995: 14. My own translation). This French secular principle is an important element of what can be termed the French exception (Ardant et al. 1995: 14. My own translation), and is regarded highly amongst French citizens along with the other three founding principles, ‘liberté, égalité, fraternité’ (liberty, equality, fraternity). However, is it a truth revealed, fixed, and constituted once and for all or an adaptable instrument for creating a legal middle ground? (Saunders 2009: 73). From this context, the laïcité of 1905 can be seen as a political settlement of religious affairs born out a specific historic setting that no longer exists, in which one religion had too much power over the state. Laïcité at that time was like the middle ground in the face of sectarian extremes, religious and secular (Saunders 2009: 70). Baubérot, a sociologist and founder of the sociology of secularism, said, ‘…this ‘laique’ law seemed to be an intermediary between a consensus of actors and a formal contract which was the deliberate result of negotiations between both sides of the conflict…’ (Baubérot 1998: 182. My own translation). However today, circumstances have changed and Islam is now the second biggest religion in France due primarily to immigration from its former colonies. But Islam was not a part of the 1905 settlement (Saunders 2009: 71). Therefore, laïcité cannot be a fixed but must be an ever changing concept in keeping with the evolution of society. In what way therefore, must it be changed for France to accommodate its Muslim minority?
Radical secularism is just one form of secularism among many. It is most commonly associated with laïcité in France and therefore this chapter will mostly focus on this principle. Laïcité, as was established in the previous chapter, needs to be seen as a social construct which should be changed in accordance with new circumstances. The current form of laïcité has, as this chapter will explore, changed quite radically since its conception in 1905. However, this does not mean that it has changed for the good of its Muslim population. In fact, in recent times one could argue that it has become a lot stricter and therefore less tolerant of religious and cultural difference. Both Amelie Barras, a faculty member at York University, and Modood advocate this view (Barras 2010) with Modood calling laïcité ‘anti-multiculturalist’ (Modood 2012), and therefore incapable of dealing with religious pluralism. On the other hand, Bhargava, as well as a majority of French citizens, see it as a champion of national cohesion, a unifying force, which is good at integrating its citizens (Weill 2006: 63 and Bhargava 2009: 93). To what extent then is the current form of laïcité able to accommodate the Muslim minority in France?
To deal with this question, this chapter will analyse three of the most distinct elements of the secular system of governance in France in relation to the accommodation of its Muslim population. Firstly, issues of national cohesion, unity, and integration; secondly, issues of equality and neutrality; and thirdly, issues of state control and the problem of separating the public from the private sphere. If there is a lack or exploitation of these three elements in French society, then it can be concluded that this form of state governance is not able to accommodate the needs of its religious minorities, specifically Muslims.
France’s religious institutional organisations are one way for the country to preserve national cohesion and unity. Since 1990, each French government has tried to create a national Muslim council that would be a corporate representative of Muslims in France and the official government consultee (Modood 2012). After at least three failed attempts by previous governments, the Interior Minister at the time, Nicolas Sarkozy, created the French Muslim Council (CFCM) in 2003 (Modood 2012). In his book, ‘The Republic, Religions and Hope’, Sarkozy defends the French Muslim Council stating that religion is the ‘cement of society’, and that being a Muslim is not just a matter of faith but is also a matter of cultural identity (Sarkozy 2004 cited by Akan 2009: 238/239) However, this council has still not yet been accepted by most French Muslims, and has had little influence on the government, civil society, or media (Modood 2012). The CFCM, arguably the most important religious institutional organisation for Muslims in France, though finally created, is not helping to create national unity between French and Muslim residents since it has had very little impact and does not even represent the views of most Muslims.
On the other hand, the principle of laïcité in France is revered by many of its citizens for creating a strong sense of national cohesion and unity among its many different and diverse communities. In January 2004, in the midst of the debate around the banning of wearing religious symbols in schools, a survey was conducted on ‘The French, integration, and laïcité’. This survey found that 55% of the interviewees thought that laïcité was the fourth most important aspect of French identity, and 57% saw ostentatious religious symbols as a ‘threat for national unity’ (Weill 2006: 64). Furthermore, as Jean-Louis Bianco, the President of the Laïcité Observatory, says, ‘…the Republican protest on 11th January [in the aftermath of the Charlie Hebdo incident] proves the attachment of French people to laïcité…’ (Jean-Louis Bianco 2013 cited by Leroy 2015: 47. My own translation). According to Meer, an academic writer, and Modood, social cohesion in France is often seen as more important than group difference with nationality and citizenship remaining formally inseparable (Meer and Modood 2012: 61) This sense of national cohesion and integration is often invoked as a positive aspect of laïcité, as Bhargava argues, as it gives primacy to ‘equality of citizenship’ making laïcité a good model of Western secularism (Bhargava 2009: 93).
However, paradoxically, at the same time as attempting to integrate its non-native citizens this form of radical secularism can exclude them. Amelie Barras writes in her article that the headscarf controversy in 1989 accentuated an exclusive understanding of laïcité so that it became more than a legal principle simply separating religion and state (Barras 2010: 230). This exclusion particularly affects Muslim women who wear the headscarf, according to her article, and these women are becoming slowly excluded from society and now face two options: either to ‘create and participate in communal spaces’ such as faith schools; or move to another country for better employment prospects (Barras 2010: 247/248). This form of laïcité does not simply emphasise similarity over difference, it leaves no room for difference between French citizens. Dalil Boubakeur, the president of France’s Council of Muslims, commented on the new Charter of Laïcité sent to all state schools confirming the law of 2004 by barring any display of ‘political and religious’ convictions by staff or pupils. He said that Islamic believers ‘will feel stigmatised by a charter which…requires them to behave like robots [and]…leave their faith in the cloakroom’ (quoted in the Catholic Herald 2014). President Hollande is also reported to be willing to consider the extension of the 2004 law to all companies (quoted in Huffington Post: 2013). Christophe Caresche, an MP for the Socialist Party, has denounced any extension of the ban on religious symbols to private companies, arguing that “French universalism, in the name of which republican principles are invoked, is less and less universal and more and more French” (quoted in the Huffington Post 2013). He warned that these proposals could produce greater exclusion (Huffington Post 2013).
Furthermore, one could argue that this exclusion has meant that France’s religious minority groups, particularly its Muslim minority, are often segregated (Ware 2015: 186). Many of these ‘public housing complexes’ are neglected and physically deteriorating. Poverty, substandard schools, low levels of educational attainment, and crime and unemployment are common features in these communities. The minority residents, ‘banlieusards’, are regarded as “immigrants” even though many of them are second and third generation citizens who were born in France. Police brutality towards these banlieusards sparked large-scale riots in 1983, the 1990s, and 2005 (Ware 2015: 186).
This shows that while laïcité attempts to promote national unity and integration, which can be extremely helpful in dealing with religious pluralism, it can often lead to exclusion, a distinct lack of integration, especially of Muslim women. It has also not dealt with France’s segregated minority communities.
While France’s segregated minority communities are an issue, it could be argued that Islamic believers are not being any more excluded from the French public sphere than other religious believers; that it is in fact this quality that makes French laïcité an instrument of neutrality and equality. Bhargava states that political secularism, which identifies separation with exclusion of religion, as laïcité does, means that ‘a particular religion is excluded from politics on the same grounds as other religions’ (Bhargava 1998: 8), creating a neutral sphere. Furthermore, Wheeler, a former employee of Amnesty International, advocates that, while the French system may not be perfect, it could show other European states how not to subjugate religious minorities, ‘crosses are banned just as much as Burqas; it is an even playing-field on the point’ (Wheeler 2013).
In contrast, in an anonymous article which talks about the crisis of secularism, the author argues that French laïcité reacts to the pluralism challenge with ‘…religious-blind policies that sustain the inequalities faced by immigrant religious minority groups…’ and that ‘…on the grounds of an alleged principle of state neutrality…the French state seeks to banish the presence of minority religions from the public sphere…’ (Eurasia Review). This could not be any more contradictory to the idea that laïcité promotes equality and neutrality towards all religions. Not only does laïcité not promote equality in this argument, it does not do anything to change the status quo of the unfair treatment of minority groups, and in fact only sustains these inequalities. As extreme as this may seem, several reports actually suggest that Islamic believers, particularly Muslim women, are being discriminated against. In 2012, a report by Amnesty International found that Muslim women have been denied jobs, and Muslim girls have been unable to attend classes because they choose to wear the headscarf (Amnesty International LTD 2012: 5/6). In addition, Marwan Muhammad, from the Collective against Islamophobia in France said, ‘Public opinion is progressively realising the abuses occurring under the pretext of laïcité and an increasing number of people are realising that you can’t ban people from workplaces or you risk affecting social cohesion. There is no French cultural exception which can justify racism towards Muslim women’ (quoted in the Huffington Post 2013).
Furthermore, laïcité can be accused not only of sustaining inequalities and encouraging discrimination but also of maintaining certain Catholic privileges which suggest that this ‘neutral sphere’, supposedly created by laïcité, does not in fact exist. Mayanthi Fernando, associate professor of Anthropology at the University of California, outlines some of these privileges in one of her articles. One such privilege is that although the government is not allowed to finance new religious buildings, it pays maintenance costs for religious buildings built before 1905, most of which are Catholic churches. In addition, the state subsidises private religious schools, most of which are Catholic, and still conforms to the public school calendar which is organised around Christian ‘holy days’ (Fernando 2015).
Laïcité then, although aiming to create a neutral and equal public sphere which would encourage religious pluralism, seems to have had some severe difficulties in upholding and protecting such principles. This has resulted in various forms of discrimination against Muslims and has also meant that there are still Catholic privileges in French society.
However, if the equality and neutrality principles of laïcité were being properly implemented laïcité could, as Wheeler argues, be used as ‘…a tool in which to create a suitable division between the private life of a citizen where free practice is acceptable and the public sphere where all citizens are equal and devoid of ethnic, racial or religious differentiators…’ (Wheeler 2013). According to Oxford Reference, the public sphere can be roughly defined as the realm of politics and public institutions with shared norms and values, in contrast to the private sphere which can be roughly defined as the domestic world of family relations and identified with personal identity and free will (Oxford Reference). In light of this, there is a major fault with Wheeler’s argument. It suggests that citizens can somehow separate themselves from their ethnic, racial, or religious identities as soon as they enter the public sphere, and that this public sphere can be clearly differentiated from the private sphere. This however, according to the definition, would be almost, if not completely, impossible as personal identity and free will cannot by their very nature be confined to the domestic world. A person would have to change their whole being as soon as they left their front door. Indeed, the law banning the wearing of burqas and niqabs in France is a good example of this contention. Nicolas Sarkozy said in his first Presidential address that the burqa was ‘not welcome’ in France, and that people should not display religious affiliation in state institutions (quoted in the Telegraph: 2009). This law therefore expects Muslim women to separate themselves from their religious identity as Muslims by stopping them from practising what some would consider to be an important, or even obligatory (BBC 2011) aspect of Islam, and no matter how much of a minority that group may be they deserve the same respect as all other citizens. It is ‘state-led identity politics’ Murat Akan, an assistant professor at Bogazici University, argues. The French state has come to treat identities ‘like skins rather than shirts’ (Hobsbawm 1996 cited by Akan 2009: 239), meaning that you can only have one identity, and as Barras writes, this threatens the secular status quo as a Muslim’s allegiance doesn’t belong first to the state but to God and a religion (Barras 2010: 229). This not only affects the public sphere in which Muslim women must not wear full coverings in public institutions, but also encroaches on the private sphere in which Muslim women can no longer walk down the street wearing a niqab or burqa, and thus, for some, they are unable to express a significant aspect of their personal identity. These recent developments are, as Akan asserts, an expansion of the ‘control’ aspect of laïcité from when it was originally founded (Akan 2009: 239), as they are interfering more and more with people’s personal lives. It could therefore be said that this current form of laïcité is attempting to separate what cannot really be separated and is thus too controlling over private affairs in a way it never was before. Interference in order to control aspects of people’s private lives is an abuse of a state’s power, and therefore cannot possibly hope to foster a peaceful pluralistic society since religious freedom is not being respected.
Moreover, Human Rights Watch and Daniel Barton, a PHD student at the Faculty of Law in Prague, argue that recent laws passed in the name of laïcité actually violate human rights legislation. The Executive Director of Human Rights Watch stated that the 2004 law banning ostentatious religious symbols in schools was an ‘unwarranted infringement on the right to religious practice’ (Human Rights Watch 2004). These symbols ‘…do not pose a threat to public health, order or morals; they have no effect on the fundamental rights and freedoms of other students; and they do not undermine a school’s educational function…’ (Human Rights Watch 2004) Furthermore, according to Barton, the French burqa ban also violates human rights legislation (Barton 2012). He comes to this conclusion by looking at three main factors: whether the ban interferes with religious freedom; whether this is a necessary interference; and whether the ban is proportionate in regard to its objectives. Firstly, he notes that the UN Human Rights Committee considers that to prevent a person from wearing religious clothing constitutes an interference with his or her religious freedom (Barton 2012: 10/11). Secondly, he argues that the reasons given for this interference, such as public security, safety, and order and gender equality, human dignity and liberty, were unjustifiable. Furthermore, the concepts of gender equality, human dignity and liberty cannot be realistically invoked as a justification since they suggest that the state knows what is best for its citizens, and this would be ‘…at variance with most fundamental freedoms…’ (Barton 2012: 26). Thirdly, since the supporters of the ban did not prove a ‘pressing social need’ for it, nor were their reasons for the ban justifiable, the law itself was not a proportionate means of dealing with the issue and as such is in breach of human rights legislation (Barton 2012: 22).
In conclusion, these aspects of laïcité demonstrate that, though the principle has been adapted by French governments over the years, these interpretations and adjustments have not always been to the benefit of the Muslim minority and other religious groups. There have been some attempts to try and accommodate for the new Islamic culture and religion, but France’s religious institutional organisations have not helped maintain national unity, and the focus on integration seems to have created a form of exclusion and segregation. Similarly, while trying to make the public sphere equal and neutral, this has paradoxically led to certain forms of discrimination against Muslims whilst still privileging Catholicism. Furthermore, the high levels of state control over the life of its citizens have restricted religious freedom, and have in some cases, according to some people, led to a violation of human rights legislation. These three fundamental elements of laïcité then appear to be lacking in French society. A conclusion can thus be drawn that laïcité, as currently applied, is not apt at dealing with religious pluralism, and is unable to fully accommodate its Muslim population and their needs. Therefore if laïcité and other radical forms of secularism are not accommodating enough to deal well with religious pluralism, perhaps the more moderate form of secularism found in Britain and America would be a better model to follow.
Moderate secularism is a second form of secularism found in Britain and the USA. As was concluded in the last chapter, laïcité is quite a strict form of secularism which does not accommodate its Muslim minority particularly well and seems to view religion as contrary to the ideals of a secular French Republic. However, Modood argues that religion should not pose a challenge to political secularism (Modood 2012). This chapter therefore will focus on one way of uniting religion and political secularism: moderate secularism. Modood sees it as much more tolerant and accommodative than radical secularism (Modood 2012), however Bhargava argues that it does not grant proper respect to religious voices (Bhargava 2009: 98) and it often, whether de jure or de facto, accords religious privileges. To what extent is moderate secularism better at accommodating Muslims than radical secularism and laïcité?
To deal with this question this chapter will look at moderate secularism in Britain and the USA in relation to laïcité’s three main elements: national cohesion, unity and integration; equality and neutrality; and state control and the public/private divide. However, it is important to note here that the ‘picture’, as Modood puts it, is ‘quite complex’ as there are many versions of moderate secularism (Laegaard 2008: 161). Britain can be considered moderately secular as it has a strong secular society, with a relatively neutral political core, yet at the same time it has an established church. The USA on the other hand, has a deeply religious society, a relatively religious political core, and yet it can be considered moderately secular as it deliberately has no established religion (Amendment 1 of the Bill of Rights). This chapter will therefore analyse each case study separately in order to compare two different versions of moderate secularism according to these three aspects.
National cohesion and unity in diverse Britain is also partly achieved through the establishment of several different religious institutional organisations. These organisations give Britain’s minority religious groups a public voice and include them in the affairs of the state. One example is the Muslim Council of Britain (MCB) which was set up as a consultee by the New Labour government in 1997 (Modood 2012). It is an umbrella body that represents 500 Islamic organisations around the country, including mosques, schools and charities (Guardian 2015). However, according to the Guardian this year, one study found that only 6% of Muslims felt the MCB actually represented their views. In addition, the MCB have not had any recent engagement with the government (Guardian 2015). This example shows that religious institutional organisations set up by governments in even moderately secular countries are not always representative or productive, and therefore do not always contribute to maintaining national cohesion and unity between British and non-native residents.
Moreover, Didier Lassalle, professor of British studies at the University of Paris-Est-Créteil, argues that Britain’s religious communities have become ‘monolithic, self-absorbed and independent’ (Lassalle 2011: 240) much like France, as was illustrated in the last chapter. However, unlike France this has not happened through an exclusionary process but through the complete opposite, a ‘celebration of diversity’ (Lassalle 2011: 239). This version of multiculturalism has been perceived to be a ‘hindrance to communities’ interaction with each other, making assimilation into British society harder (Lassalle 2011: 239). On the other hand, over the last few years, Britain, according to Lassalle, has changed its policy from a ‘celebration of diversity’ to ‘interculturalism’ (Lassalle 2011: 239). This new policy emphasises ‘integration’, the assimilation of immigrants and minority groups through the English language and the adherence to British principles of a democratic and constitutional society, and ‘interaction’ between communities (Lassalle 2011: 240). As Lassalle points out this could be seen as a convergence between France and Britain, with the French secular emphasis on ‘integration’ and the new British principle of ‘interaction’ (Lassalle 2011: 240).
It would seem that Britain struggles just as much as France when it comes to representative and productive religious institutional organisations. Britain’s ‘celebration of diversity’ could be considered to be a threat to the development of real religious pluralism in society, and since both moderate and radical secularism struggle with segregated communities, Britain’s situation may be no better than France’s. However, perhaps France could look at incorporating the new model of ‘interculturalism’ which may help alleviate this problem.
State control and the distinction between the public and private spheres is potentially another area in which France can learn from Britain. In moderate secularism religion is not hidden from the public sphere in the same way as France but is allowed to be expressed in public institutions and in the street. Britain has no laws concerning the wearing of ostentatious religious symbols and even allows street preachers; for example Speakers Corner in Hyde Park in London. Treating religion as a ‘public good’ in this way (Modood 2012), instead of banishing it into the private sphere, could be a way to ‘pluralise the state-religion link instead of severing it’, which Modood deems necessary in light of the ‘multi-faith situation’ (Modood 2010: 6). Myriam Francois-Cerrah, an academic, expressed a similar point of view in a BBC debate on secularism when she asserted the ‘true value of religion and religious individuals to the greater good of our society’ (BBC 2013).
However, despite Britain being a moderately secular state, there are still issues of overpowering state control and a lack of religious freedom. According to the Telegraph, a girl was banned from wearing the jilbab, a long or loose-fit garment, to school as it could be a divisive issue among Muslims, ‘…the wearers considering themselves better Muslims than those who preferred the tunic and trousers of the shalwar kameez…’ (quoted in the Telegraph 2004). The young 15 year old claimed that this deprived her of her right to education and the article concluded that the aforementioned grounds for the ban were not sufficient to reprimand her for her religious beliefs calling the ruling a ‘regrettable limitation of personal freedom’ (quoted in the Telegraph 2004). Even in a moderately secular state such as Britain then, which tries to represent all religions, religious freedom is still an issue, and can be considered a limitation of moderate secularism.
State control and the public/private divide in Britain seems to be more relaxed and flexible than in France with less restrictions on religious expression in the public sphere. This may be something the French could learn from if they intend to foster a more tolerant society. However, in light of the religious freedom issues that also exist in Britain, neither moderate secularism in Britain nor radical secularism in France have the perfect solution.
It could be argued that the principles of equality and neutrality in Britain, though not leading to discrimination as in France, are not particularly strongly established. Though Britain may see religion as a public good, it certainly hasn’t pluralised the state-religion link due to the institutional privileges of Protestant Christianity. Britain not only has an established church, it also allows bishops to sit in the House of Lords by right, and only the senior archbishop can crown the new monarch (Modood and Kastoryano 2006: 164). ‘These are the visible signs of a still substantial power in the land’ the Independent said in 2012 (quoted in the Independent 2012). In spite of this, Modood believes that Britain can still accommodate religious minorities and treat them with equality without having to abolish the established church since it is a very weak form of establishment (Modood 2010: 7). However, although the church may have created a more positive view of religion in general, these privileges, whether weakly established or not, mean that religious believers are not treated equally, and as such this is a substantial limitation of moderate secularism in Britain.
On the other hand, Britain’s core political sphere is kept mostly neutral much like France. Apart from Tony Blair, who proved a slight exception, our politicians do not usually use religious arguments to justify their positions in Parliament and are not quick to talk about their faith, ‘…the British state may have an established church but the beliefs of the Queen’s First Minister are his own concern…’ (Modood and Kastoryano 2006: 165). Bhargava argues that this ‘requirement’, though it is not an official law, that religious reasons be excluded from liberal-democratic politics is ‘…offensive to religious persons who like others wish to support their favoured political commitments on the basis of their conscience…’ (Bhargava 2009: 98). This is a limit of moderate secularism in Britain as the neutral core political sphere leaves no room for religious convictions which are an integral part of personal identity.
Though Britain does not actively disrespect religions in the same way that the French state could be seen as doing, its institutional privileges do not provide any more for the equality rights of its citizens than in France. Britain does have a neutral core political sphere in a similar way to France, but from an alternate perspective, this leads both countries to offend their religious believers. The USA, however, does not have such a strong neutrality in its core political sphere and often has politicians evoking policies on the basis of their conscience.
The USA, though also being moderately secular, is very different to Britain. The New York Times states that, ‘As for the American experience, it is utterly exceptional; there is no other fully developed industrial society with a population so committed to its faiths (and such exotic ones), while being equally committed to the Great Separation’ (quoted in the New York Times 2007). Whilst there is clearly some bias in this statement, the USA can be considered, at least to a moderate extent, a secular state whilst at the same time having a more religious society than arguably any Western European state.
National cohesion and unity in the USA is also partly achieved through the establishment of several different religious institutional organisations like Britain. The Muslim American Society (MAS) is one of several national organisations which dominate the political space of the Muslim-American mainstream. Others include the Islamic Society of North America (ISNA), the Muslim Public Affairs Council (MPAC), the Islamic Circle of North America (ICNA), and the Council on American Islamic Relations (CAIR) (Skerry 2011). According to Peter Skerry, a lecturer of political science at Boston College, these groups ‘…define and articulate the Muslim-American agenda and they are where non-Muslim elites in the media, the government, and the academy turn for Muslim interlocutors…’ (Skerry 2011). This suggests that these organisations seem to be much more productive than their counterparts in France or Britain. Moreover, in contrast to Britain, these national organisations were all initiated and shaped by Muslims which may be a factor in their success. However, though it might be expected that Muslim-run organisations would be more representative of the Muslim population, a recent survey confirms that only a small percentage of American Muslims (12%, at most) regard any one of these organizations as representing their interests (Skerry 2011). Whilst these organisations seem to be much more included in the affairs of the state than in France or Britain, they are by no means representative, and thus are not able to contribute to the American national unity very effectively.
In terms of integration, unlike Muslim immigrants in Europe who live in ghetto-like areas, Muslim immigrants in the United States are highly dispersed (Duran and Pipes 2002). According to the Pew Research Centre, Muslim Americans appear to be highly assimilated into American society and are largely content with their lives, and Obama, at a White House news conference with Cameron, said that the USA had had more success than others in integrating minorities (The Straits Times 2015). To confirm this, a majority of Muslim Americans (56%) say that most Muslims coming to the U.S. today want to adopt American customs and far fewer, (20%), say that most Muslims want to be distinct from the larger American society (Pew Research Center 2011: Section 3). This is in part because foreign-born Muslim Americans are very diverse in their origins. They have come from at least 77 different countries, with no single country accounting for more than one in six Muslim immigrants (Pew Research Center 2011: Section 1). Most Western European states however, have one or two dominant groups such as Algerians in France. This is important because ‘…the jumble of groups in the USA makes it harder for Muslim immigrants and their descendants to lead a life apart…’ (quoted in the Economist 2014).
National cohesion, unity, and integration in the USA then seems to be more successful than in France or Britain due to the engagement of its religious institutions with the government and its remarkable levels of assimilation without segregation. However, there are obviously still some issues with representation. In spite of this, maybe France could encourage its own Muslim population to set up religious institutional organisations which would be more representative. In terms of the USA’s successful assimilation, this would be almost impossible for France to achieve given that its immigrants are much less diverse and therefore they have not been forced to integrate in the same way as in the USA.
In terms of neutrality and equality however, whilst the American Constitution emphasises the ‘protection of religious diversity as a value’ (Modood and Kastoryano 2006: 164), the USA accords privileges much like Britain, except these are not institutional but societal privileges. Churches in the USA for example openly campaign for political candidates and parties, raise huge quantities of money for politicians and push religion-based issues onto the political agenda such as abortion, homosexuality, and prayer at school (Modood and Kastoryano 2006: 164). According to Modood and Kastoryano, director of research at Sciences Politique in Paris, it has been said that no devout atheist has ever been a candidate for the White House and nor is it likely for one to be elected (Modood and Kastoryano 2006: 164). Societal privileges such as these mean that though the American courts are unbiased, religious minority groups can often be at a disadvantage in terms of political representation, and work place equality. The Center for American Progress concluded at its panel meeting in 2013 that ‘Christian conservatives use religion as a justification for their discriminatory behaviour’ (Breitbart 2013).
On the other hand, the USA does not prohibit, at least in practice, religious convictions being used as justification for decisions made. Presidents such as George Bush and Jimmy Carter talked openly about their beliefs, appealed to religion, and even held prayer meetings in government buildings (Public Broadcasting Service 2010). American secularism allows its politicians to make decisions and take action based on their personal religious beliefs which are a part of their identity. However, although this policy may be deemed less ‘offensive’ to religious believers, it is really only beneficial to those of the Christian faith and therefore reaffirms the idea of societal privileges. As Bhargava states, the USA has ‘no resources to cope with religions that mandate greater public or political presence’ (Bhargava 2009: 99), and this cannot be doubted as being at least partly the responsibility of Christian privileging. According to them, this makes it a lot harder for America to accommodate ‘community-specific rights’ and therefore to protect the rights of religious minorities (Bhargava 2009: 99).
Thus, despite the core political sphere being less strictly neutral and therefore more accommodating of religious beliefs and values, these societal and specifically Christian privileges are a limitation of moderate secularism in the same way as British institutional privileges and do not give equal opportunities to all religious believers.
However, and rather paradoxically compared to its openly religious presidents, the USA, institutionally, has a policy of no interference. This means that it has neither a negative relationship with religion, ‘…it is not within the scope of state activity to interfere in religious matters even when the values professed by the state are violated…’ nor a positive relationship with religion, ‘…there is no policy of granting aid to religious institutions…’ (Bhargava 2009: 93). This is what is called ‘negative liberty’, a form of mutual exclusion, much less extreme than France’s one-sided exclusion. The USA has succeeded in this form of moderate secularism due to its lack of an established religion. As Ahmet Kuru, professor at San Diego State University, argues this form of moderate or ‘passive’ secularism, as he calls it, is a ‘pragmatic political principle’ aiming to maintain state institutional neutrality towards various religions in comparison to radical or ‘assertive’ secularism, a ‘comprehensive doctrine’ which tries to eliminate religion from the public sphere (Kuru 2007: 571). It therefore has a strong capacity to deal with inter-religious conflicts, between Christians and Muslims for example, since it necessitates the disestablishment of the dominant religion and therefore theoretically gives equal rights to both faiths (Bhargava 2011).
However, as previously mentioned, although mutual exclusion grants more respect to religion than one-sided exclusion, it is not able to intervene in intra-religious conflicts in order to help minority religious groups, in cases of persecution for example. This intervention, though seen as a restriction on religious freedom, grants states the capacity to deal with intra-religious conflicts. Since religion is a private matter under mutual exclusion, if there is an issue it must be dealt with only by those who have a right to do so within the private sphere (Bhargava 2009: 93), thus limiting the state’s ability to protect its inhabitants.
On the one hand then, the USA respects religious groups and deals with them fairly, but on the other hands, it is not able to prevent certain forms of religious persecution. Whilst France can learn the art of mutual exclusion instead of one-sided exclusion from the case of the USA, neither France nor Britain nor the USA have the capacity to deal with significant religious conflicts due to their attempts at neutrality.
In conclusion, moderate secularism does address some of the issues of France’s radical secularism concerning national cohesion, unity, and integration; equality and neutrality; and state control and the public/private divide. Though Britain still has problems with its segregated communities, France could perhaps look to its new ‘interculturalism’ model for inspiration as a way of dealing with the issue. The USA’s communities, on the other hand, are well assimilated but in ways that prove almost impossible for France to emulate. Similarly to France, Britain’s religious institutional organisations do not seem to be very effective, and, though perhaps more effective, the USA’s religious institutional organisations are as unrepresentative as Britain and France’s. Moderate secularism in these countries as a result still has difficulty in creating national cohesion and unity, and the USA seems to be the exception when it comes to integration. In terms of state control and the public/private divide, both states allow more religious expression in the public sphere, but there are still issues of religious freedom. France can learn from the USA’s policy of mutual exclusion since it is more respectful of religious groups but it is not able to prevent intra-religious conflict. Both Britain and the USA attempt to preserve equality and neutrality. Whilst the USA allows religious convictions to be openly shared in the political sphere, both states accord too many privileges to Christianity which means that religious believers are treated unequally and Muslims are not granted the same political rights as Christians. France’s radical secularism also permits, (or at least has not eradicated) privileges to Christianity, or more specifically Catholicism, although these are not arguably as well established. One could argue that these privileges, whether institutional or societal, to the mainstream religion mean that it is difficult for Western states in general to truly be able to respect other ‘foreign’ religious traditions. The dominant religion is favoured, whether it is established or not, and therefore a fully respectful and accommodative secularism cannot arguably be found in Europe. As Pippa Norris, lecturer of Comparative Politics at Harvard University, and Ronald Inglehart, professor of Political Science at the University of Michagan, argue, ‘…even in highly secular societies, the historical legacy of given religions continues to shape worldviews and to define cultural zones….’ (Norris and Inglehart 2004 cited by Modood and Kastoryano 2006: 170). If neither radical secularism in France nor moderate secularism in Britain and the USA are fully able to accommodate their Muslim minorities due to their privileging of Christianity and the fact that neither creates a truly neutral and equal society in which all religions are fully respected, perhaps moving from the West and looking at secularism in the East will provide more answers for France. The next chapter will look at Contextual Secularism found in India.
This chapter will focus on the advantages of contextual secularism, a third form of secularism, coined by Rajeev Bhargava and associated with India. While Bhargava claims that it is a more culturally sensitive form of secularism than moderate secularism (Bhargava 2009: 106), others argue that it does not respect equality, neutrality, nor the public/private divide and panders to minority religious groups (Rajagopalan 2007). What then can France learn from contextual secularism in India in accommodating its own Muslim minority?
This chapter will look at contextual secularism in India in relation again to the three core aspects of laïcité: national cohesion and unity; equality; and state control, neutrality, and the public/private divide, to see what can be learnt from the Indian version in dealing with religious pluralism. Evidently, the principle of ‘integration’, which is an important aspect in dealing with religious pluralism in France, does not exist in India as India has been religiously diverse for centuries, and therefore India cannot offer France any guidance on integration policies.
Unity in Indian secularism is not defined in terms of similarity and homogeneity as it is in Western countries, particularly France, but in terms of a shared legacy and a commitment to diversity. As Mohandas Ghandi said, ‘…I do not expect the India of my dreams to develop one religion, i.e., to be wholly Hindu or wholly Christian or wholly Mussalman, but I want it to be wholly tolerant, with its religions working side by side with one another…’ (Dolek 2012). India’s socio-cultural mosaic is the true picture of ‘unity in diversity’, Sukh Deo Muni, a former professor at Jawaharlal University in India, argues, ‘…where every component, while retaining its specific identity, is a part of a larger whole…’ (United Nations University Archive). It may then be possible to be committed to both unity and diversity and this is seen in India’s acceptance of religious communities establishing and maintaining educational institutions. The state will even provide some conditional funding in specific circumstances, the provision of which is that religious instruction cannot be made compulsory and no one may be refused admission solely on religious or similar grounds (Rajagopalan 2007: 3). This protects national unity, and is, as Bhargava argues, crucial for the survival and sustenance of different religious traditions (Bhargava 2011).
It could be argued however that due to the rise of violent nationalist acts over recent years, for example the tearing down of the Babri Masjid in 2002 (Ganguly 2003: 19), Indian unity is in decline. There has been an emergence of new extremist voices in India, namely the RSS (Rashtriya Swayamsevak Sangh), a National Volunteer Corps founded upon paramilitary skills, ideological training and supreme loyalty to the Hindu nation (The Foreign Policy Centre). Their political wing is the BJP (Bharatiya Janata Party), currently in power with the main opposition party being the secular Indian National Congress Party (The Foreign Policy Centre). The RSS and the BJP subscribe to the Hindutva ideology, in essence Hindu nationalism, and it is this ideology which has led to a ‘…militant intolerance of religious minorities, especially Islam and Christianity, and it has led to a number of violent anti-Muslim and anti-Christian acts…’ including the destruction of the Babri Masjid and the burning of churches in Orissa in 2008 (Public Broadcasting Service 2013). The nationalists responsible for the violence argue that the targeted communities pose a danger to Hinduism. The BJP has ‘…fostered a significant body of antisecular sentiment and [has] exploited failures and omissions…’ by the Congress party (Ganguly 2014: 21). Moreover, Ganguly, a faculty member of West Bengal State University, describes the Congress party as ‘rudderless’ with its ‘…organisational base tattered, its vision occluded, its leadership in disarray…’(Ganguly 2014: 21). This suggests that the Congress Party was unable to fully combat these sectarian, Hindu nationalist threats, and in 2014 the BJP came into power with a landslide election victory (Burke 2014). However, this may not necessarily have been as a result of Hindu nationalism popularity since there are many reasons for a party to be elected. Either way, it remains to be seen how they will shape India over the course of their term in government. Contextual secularism therefore demonstrates that it is possible to have unity and a strong national identity while at the same time being respectful of religious minorities. However, this ‘respect’ may have led to the success of the BJP and Hindu nationalists who threaten India’s secularism.
Furthermore, the use of state control and the public/private divide in India are conceptualised very differently from Western forms of secularism. Instead of the state keeping out of religious affairs, it deliberately intervenes thus completely disregarding any principle of neutrality. The law against untouchability in Article 17 of the 1950 Indian Constitution (Indian Government 1950: 8) is a clear example of how the state has intervened in the practice of Hinduism, but seems less inclined to do so in minority religions such as Islam (Rajagopalan 2007: 4). However, it would be a mistake to judge Indian secularism based on the Western versions. Indian secularism is a ‘…contextual, ethically sensitive, politically negotiated arrangement rather than a scientific doctrine…’ (Bhargava 2011) of strict neutrality and non-intervention. Instead of erecting a wall of separation much like the USA, contextual secularism has porous boundaries which confirm this negotiated arrangement by allowing the state to intervene in religious affairs and religion to intervene in state affairs in order to promote freedom, equality, and other secular values (Bhargava 2009: 104). This idea of porous boundaries and state intervention has been called ‘Principled Distance’ by Bhargava, and it combines a ‘…unique combination of active hostility to some aspects of religion (a ban on untouchability…) with active respect for its other dimensions (…no blanket exclusion of religion as mandated by Western liberalism)…’ (Bhargava 2009: 102). This would horrify Western states as it completely violates the strict public/private distinction which indicates that religion should be confined to the private sphere. Perhaps then it teaches that France and other Western countries should be a little more flexible in their approach to religious minorities and not reject Werner Menski, professor of South Asian Laws at the University of London’s, idea of ‘legal pluralism’ (Menski 2009: 33) too quickly.
This said, it is easy to cross the line when trying to accommodate religious minorities by pandering to them. This is what Indian secularism has been accused of doing by the Hindutvavadins, those who adhere to the Hindutva ideology, who call it ‘pseudo-secularism’ and say that the claim to secularism by the Indian state is a ‘…cover for its partiality to the minorities…’ (Rajagopalan 2007: 12). Whilst the Hindutvavadins clearly do not fully understand the idea of ‘principled distance’ and ‘porous boundaries’, a claim can be made that the Congress Party overstepped the mark and was a little too accommodating at times. One example of this is when it overruled the Supreme Court which had correctly prioritised the Indian Uniform Civil Code, a code concerning matters such as marriage and divorce which can be applied to all citizens, over Muslim personal law, religious exemptions, in regards to alimony payments, since it had intervened in the name of ‘supreme public values such as equal justice’ (Ganguly 2003: 17). However, to accommodate Muslim anger after the ruling, the Congress Party granted a separate dispensation to Muslims in matters of marriage and divorce. This overruling of the Court was unnecessary (Ganguly 2003: 17). Contextual secularism and principled distance then is beneficial in that it does not attempt to try and control religion but intervenes in order to preserve equality between religions in the public sphere. However, with such a complex task, it is imperative that future secular states do not pander to minorities.
Equality then is not about treating all religions in exactly the same way as is theoretically done in Western countries, but about treating everyone as equals. This is called ‘differential treatment’, coined by the American philosopher Dworkin (Bhargava 2009: 104). Differential treatment allows a practice that is banned or regulated in one religious group to be permitted for a religious minority group because of the important cultural beliefs held by that group. For example, Jews seek exemptions from Air Force regulations to accommodate their yarmulkes (Bhargava 2011), an example of a ‘Personal Law’ previously referred to. This is a problem for mainstream secularism because of its ‘absolutist morality’ giving importance to only one value such as equal treatment or equality of citizenship instead of multiple values found in contextual secularism (Bhargava 2009: 105). Treating everyone equally but differently could be a lesson for France to learn from as it does not promote a negative liberty, but a positive liberty, and is therefore able to fully respect various religious beliefs.
On the other hand, promoting differential treatment means that there cannot be one law for all religious communities and therefore the state must deal with each dispute on a case by case basis, such as the Shah Bano case above. This works in India where the courts are used to making such judgements. Such a system is not only the status quo but a necessary way of dealing with religious conflict in India. Creating exemptions in Western countries, such as France, however which have always retained ‘uniform legal patterns’ (Menski 2009: 33) would potentially be beyond the competency of our judiciaries and would therefore require radical change and investment.
In conclusion, contextual secularism addresses some of the issues of both radical secularism in France and moderate secularism in Britain and the USA regarding the three core aspects of laïcité. It maintains national cohesion and unity through a shared legacy and a commitment to diversity rather than through homogeneity. Furthermore, contextual secularism does not try to create a strict public/private divide, but directly intervenes as part of ‘Principled Distance’ to preserve equality between the various religions in India instead of attempting to create a neutral sphere. In terms of equality, contextual secularism focuses on the notion of ‘differential treatment’ instead of wrongly trying to treat everyone exactly the same. It also obviously does not privilege Christianity and nor does it, one could argue, considering its interventionist policies, privilege any other religion. However, recently, instead of preserving equality between religions the secular governments carrying out contextual secularism have often not dealt strongly enough with sectarian threats, and pandered too much to minorities. Arguably, this is not a failing of contextual secularism but of the secular governments who failed to apply this version of secularism correctly. One could argue that these failings are inevitable due to the complex nature of contextual secularism. Contextual secularism also deals with many religious disputes on a case by case basis which could potentially prove too much of a challenge for France’s legal system.
This dissertation has aimed to do two things. First, to demonstrate that laïcité is not, in its current form, able to accommodate its Muslim population due to a lack, or in the case of state control an exploitation of, its three core elements: national cohesion, unity and integration; equality and neutrality; and state control and the public/private divide. Second, to show ways in which the policy of laïcité can be improved in each of these elements to better accommodate its Muslim population by comparing it to moderate secularism in Britain and the USA, and contextual secularism in India. This chapter will provide a brief summary of the key positive and negative aspects of each type of secularism studied concerning each of the three core elements of Laïcité. These will then be reflected on to see what France can learn from each type of secularism, and to therefore see whether this study has revealed ways in which Laïcité can be improved. It will then move on to reflect on how this could affect France as a whole before raising issues for further consideration.
France’s policy of laïcité or radical secularism allowed a national Muslim council to be created in order to help maintain unity between French and Muslim inhabitants, but this council has had little influence. Furthermore, France’s policy of integration focuses too much on similarity as the principal idea behind national cohesion and not enough importance is given to individual differences. This has led to exclusion and religious minority community segregation thus signifying a lack of national cohesion, unity, and integration.
Moderate secularism also has difficulty in creating national cohesion and unity. Whilst both Britain and the USA have religious institutional organisations, they are not very representative although the USA’s seem to be more productive. Furthermore, Britain also has problems with its segregated communities, although its new policy of ‘interculturalism’ may be able to alleviate the problem. The USA’s religious minority communities, on the other hand, are well assimilated due to their diversity, and therefore it seems to be the exception when it comes to integration.
India’s contextual secularism maintains national cohesion and unity through the idea of a shared legacy and a commitment to diversity rather than through homogeneity. However, the Congress Party has not dealt strongly enough with sectarian threats by the RSS and BJP who now threaten India’s policy of secularism.
France’s policy of laïcité attempts to create a neutral and equal public sphere but this has paradoxically led to certain forms of discrimination and has not disestablished the many noticeable Catholic privileges. This therefore suggests a lack of equality and neutrality.
Moderate secularism in both Britain and the USA attempt to preserve equality and neutrality. Whilst the USA allows religious convictions to be openly shared in the political sphere, both states accord too many privileges to Christianity, institutional privileges in Britain and societal privileges in the USA, which mean that religious believers are treated unequally.
India’s contextual secularism does not attempt to remain neutral but does adhere to a certain type of equality, namely differential treatment. This policy means that many religious disputes are dealt with on a case by case basis which may be too complex for France’s judiciary.
France’s policy of laïcité can be considered as one-sided exclusion in which the state exploits its control over its citizens by strongly interfering in religious affairs without allowing religion the same courtesy. This is not the best way to accommodate France’s relatively new religious minorities including its Muslim inhabitants.
Moderate secularism in both Britain and the USA, on the other hand, cannot be considered as one-sided exclusion. In the USA, it is mutual exclusion which prevents both religion from interfering in state affairs and the state from interfering in religious affairs. In Britain, there is an established church and a much less strict public/private divide. Moderate secularism in these countries therefore allows more room for religion and religious difference but there are still issues of religious freedom.
India’s contextual secularism does not try to create a strict public/private divide, but instead directly intervenes in religious affairs as part of Bhargava’s ‘Principled Distance’ idea to preserve equality between the various religions. It therefore tries not to privilege any religion, however, until the BJP came into power, the secular governments arguably pandered too much to minority groups.
In terms of national cohesion, unity, and integration France can learn from Britain, the USA, and India in order to improve its policy of laïcité in accommodating its Muslim population. Firstly, France needs to improve its engagement with its religious institutional organisations so that they are more effective. Secondly, and this also refers to the public/private divide, France ought to accept that there is unity in diversity and allow for religious difference by permitting more religious expression in the public sphere as this is an important part of peoples’ personal identity. It might mean that France needs to revoke the 2011 law or include religious teaching in schools but this might help it to include its Muslim minorities.
In terms of equality and neutrality France can also learn from the cases of Britain, the USA, and India. From the analysis of Britain and the USA, it seems important to disestablish any privileges in order to maintain equality between religious believers. France then needs to disestablish its Catholic privileges, and put more effective anti-discrimination measures in place to allow equal access to employment, housing, healthcare etc. France might also benefit from a policy of differential treatment in which it provides opt-outs or exemption clauses for religious reasons. This could mean stretching as far as allowing some separate religious personal laws, like in India, for its Muslim communities, but this would require additional training in the courts and would likely be very complicated.
Furthermore, in terms of state control and the public/private divide France can learn from Britain, the USA, and India. It must change its policy of one-sided exclusion so that it no longer actively disrespects religion. In order to best accommodate its Muslim minority, this may need to be more than just a negative liberty. France could try porous boundaries through which it is able to intervene fairly in order to preserve equality between religions instead of favouring Catholicism, and through which religion can have a greater involvement in state affairs.
Overall, France and its policy of laïcité needs to be more relaxed and flexible in order to better accommodate its Muslim population. This may also entail a less principled and more pragmatic outlook so that France does what is best for the people living in France, not necessarily just its citizens, rather than simply following the romantic ideals of the Republic in which citizens must ‘transcend their particularities’ (Barras 2010: 233) and first consider themselves French before anything else. Such a conclusion may be controversial in the French context as it demands not a rejection but a rethinking of French principles and laïcité, and though these changes may make France less ‘exceptional’, they will hopefully improve the way it governs and treats its people.
This dissertation has implicitly tackled several issues which have not been properly covered due to space constraints, but would make for interesting further research. Some of these include: How to embrace multiculturalism without diluting national identity? How well adapted are different religions to living under differing governmental structures? How differently do physical expressions of faith e.g. the burqa, and questions of morality adherence e.g. abortion, in religion, influence state policies?
AKAN, M., (2009). ‘Laïcité and multiculturalism: the Stasi Report in context’. The British Journal of Sociology, vol. 60, no. 2 pp. 237 – 256. URL: http://onlinelibrary.wiley.com/doi/10.1111/j.1468-4446.2009.01229.x/epdf [25/09/2014]
BARRAS, A., (2010). ‘Contemporary Laïcité: Setting the Terms of a New Social Contract? The Slow Exclusion of Women Wearing Headscarves’. Totalitarian Movements and Political Religions, 08/09/2010, vol. 11, no. 2, pp. 229-248. URL: http://www.tandfonline.com/doi/pdf/10.1080/14690764.2010.511457 [25/09/2014]
BARTON, D., (2012). ‘Is the French Burka Ban Compatible with International Human Rights Law Standards?’ Essex Human Rights Review, vol. 9, no. 1, pp. 1-26. URL: http://projects.essex.ac.uk/ehrr/V9N1/BARTON.pdf [23/03/2015]
BAUBÉROT, J., (1998). ‘La laïcité francaise et ses mutations’. SAGE Journals, Social Compass, vol. 45, no. 1, pp. 175-187. URL: http://scp.sagepub.com/content/45/1/175.full.pdf+html?hwoaspck=true [20/10/2014]
GANGULY, S., (2003). ‘The Crisis of Indian Secularism’. Journal of Democracy, vol. 14, no. 4 pp. 11-25. URL: http://muse.jhu.edu/login?auth=0&type=summary&url=/journals/journal_of_democracy/v014/14.4ganguly.pdf. [20/03/2015]
HABERMAS, J., (2008). ‘Notes on Post-Secular Society’. New Perspectives Quarterly, Vol. 25, no. 4, pp. 17-29. URL: http://onlinelibrary.wiley.com/doi/10.1111/j.1540-5842.2008.01017.x/epdf [20/11/2014]
HAYNES, J.; BEN-PORAT, G., (2010). ‘Globalisation, Religion and Secularisation – Different States, Same Trajectories?’ Totalitarian Movements and Political Religions, vol. 11, no. 2 pp. 125-132. URL: http://www.tandfonline.com/doi/abs/10.1080/14690764.2010.511464#.U8U6WO9wbrc. [25/10/2014]
KURU, A., (2007). ‘Passive and Assertive Secularism: Historical Conditions, Ideological Struggles, and State Policies toward Religion’. World Politics, vol. 59, no. 4, pp. 568-594. http://muse.jhu.edu/journals/world_politics/v059/59.4kuru.html [20/08/2014]
LAEGAARD, S., (2008). ‘Moderate Secularism and Multicultural Equality’. Politics, vol. 28, no. 3, pp. 160-168. URL: http://onlinelibrary.wiley.com/doi/10.1111/j.1467-9256.2008.00325.x/pdf [15/02/2015]
LASSALLE, D., (2011). ‘French Laïcité and British Multiculturalism: A Convergence in Progress?’. Journal of Intercultural Studies, vol. 32, no. 3, pp. 229-243. URL: http://www.tandfonline.com/doi/pdf/10.1080/07256868.2011.565734 [15/02/2015]
MODOOD, T., (2010). ‘Moderate Secularism, Religion as Identity, and Respect for Religion’. The Political Quarterly, vol. 81, no. 1, pp. 4-14. URL: http://onlinelibrary.wiley.com/doi/10.1111/j.1467-923X.2010.02075.x/epdf [20/08/2014]
WARE, L., (2015). ‘Color-blind Racism in France: Bias Against Ethnic Minority Immigrants’. Washington University Journal of Law and Policy, vol. 46, no. 1 pp. 185-244. URL: http://openscholarship.wustl.edu/cgi/viewcontent.cgi?article=1848&context=law_journal_law_policy. [10/04/2015]
WEILL, N., (2006). ‘What’s in a Scarf? The Debate on Laïcité in France’. French Politics, Culture and Society, vol. 24, no. 1, pp. 59-73. URL: http://docserver.ingentaconnect.com/deliver/connect/berghahn/15376370/v24n1/s5.pdf?expires=1429362686&id=81511377&titleid=75002109&accname=Loughborough+University&checksum=CAB7E9B047D7D09B31FB48893D17C286 [20/10/2014]
ARDANT, P., REMOND, R., BERGOUNIOUX, A.’.D., G., ZYLBERBERG, J., FINKIELKRAUT, A., WIEVIORKA, M., MADIOT, Y., FRANCHI, A., ERNENWEIN, F., JAFFRE, J., GAZIER, F., ABRAHAM, R., VILANOVA, P., ASTIE, P., BREILLAT, D., AVRIL, P. and GICQUEL, J., (1995). La Laïcité. Lonrai: Pouvoirs.
BHARGAVA, R (2009). ’Political Secularism: why it is needed and what can be learnt from its Indian version’, in, GB LEVEY; T MODOOD (eds.), Secularism, Religion and Multicultural Citizenship, New York: Cambridge University Press, pp. 82-110.
BURKE, E., (1909-1914, published online 2001). Reflections on the French Revolution. URL: http://www.bartleby.com/24/3/ [11/11/2014]
KROPOTKIN, P., (1909). The Great French Revolution 1789-1793. URL: http://theanarchistlibrary.org/library/petr-kropotkin-the-great-french-revolution-1789-1793 [13/11/2014]
MEER, N.; MODOOD, T., (2011). ‘The Multicultural States We’re In’, in: European Multiculturalisms: Cultural, Religious and Ethnic Challenges Edinburgh University Press, pp. 61-87. URL: https://books.google.co.uk/books?id=G-flrG_xRWkC&pg=PA27&lpg=PA27&dq=MODOOD,+T.;+KASTORYANO,+R+2006.+%E2%80%98Secularism+and+the+accommodation+of+Muslims+in+Europe%E2%80%99&source=bl&ots=fCMTR7WOr1&sig=Y15PsEdhJqk9kXWayKBK6ssgBJc&hl=en&sa=X&ei=mWQyVYP-PMbhaoSygIgM&ved=0CEIQ6AEwCA#v=onepage&q=MODOOD%2C%20T.%3B%20KASTORYANO%2C%20R%202006.%20%E2%80%98Secularism%20and%20the%20accommodation%20of%20Muslims%20in%20Europe%E2%80%99&f=false [25/10/2014]
MENSKI, M., (2009). ‘Indian Secular Pluralism and its Relevance for Europe’, in, R. GRILLO; R. BALLARD; A. FERRARI; A. HOEKEMA; M. MAUSSEN; P. SHAH (eds.), Legal Practice and Cultural Diversity Surrey: Ashgate Publishing LTD, pp. 31-49. URL: https://books.google.co.uk/books?id=bY1sReuxDy0C&printsec=frontcover&dq=Legal+Practice+and+Cultural+Diversity&hl=en&sa=X&ei=pWYyVbq0JdD5aoDWgNAG&ved=0CCoQ6AEwAA#v=onepage&q=Legal%20Practice%20and%20Cultural%20Diversity&f=false [20/02/2015]
MERRIMAN, J., (2010). A History of Modern Europe. S. FORMAN ed., 3rd ed. New York: W.W. Norton and Company.
MODOOD, T.; KASTORYANO, R (2006). ‘Secularism and the accommodation of Muslims in Europe’, in, T. MODOOD; A. TRIANDAFYLLIDOU; R. ZAPATA-BARRERO (eds.), Multiculturalism, Muslims and Citizenship: A European Approach London: Routledge, pp. 162-178. URL: https://books.google.co.uk/books?id=z7A97ag_KasC&printsec=frontcover&dq=Multiculturalism,+Muslims+and+Citizenship:+A+European+Approach&hl=en&sa=X&ei=OmYyVbz-OoPuaJmzgPAC&redir_esc=y#v=onepage&q=Multiculturalism%2C%20Muslims%20and%20Citizenship%3A%20A%20European%20Approach&f=false [25/10/2014]
SAUNDERS, SD (2009). ‘France on the knife-edge of religion: commemorating the centenary of the law of 9 December 1905 on the separation of church and state’, in, GB LEVEY; T MODOOD (eds.), Secularism, Religion and Multicultural Citizenship, New York: Cambridge University Press, pp. 56-82.
ALLEN, P., 2009. Nicolas Sarkozy says the burqa is ‘not welcome’ in France. The Telegraph. 22/06/2009, URL: http://www.telegraph.co.uk/news/worldnews/europe/france/5603859/Nicolas-Sarkozy-says-the-burqa-is-not-welcome-in-France.html. [12/12/2014]
BURKE, J., 2014. Narendra Modi and the BJP sweep to power in Indian election. The Guardian. 16/05/2014, URL: http://www.theguardian.com/world/2014/may/16/narenda-modi-bjp-sweep-power-indian-elections. [10/01/2015]
FRANCOIS-CERRAH, M., 2013. French Court Ruling Reignites ‘Laïcité’ Vs Headscarf Debate. The Huffington Post. 15/06/2013, URL: http://www.huffingtonpost.co.uk/myriam-francois/french-court-ruling-reign_b_3085656.html. [15/01/2015]
Freedom of dress. The Telegraph. 16/06/2004, URL: http://www.telegraph.co.uk/comment/telegraph-view/3607301/Freedom-of-dress.html. [25/09/2014]
LEROY, S. 2015. Laïcité et islam peuvent-ils faire bon menage?. La Voix Du Nord On vous en dit plus (Vendredi 23 Janvier 2015), 46-47.
LILLA, M., 2007. The Politics of God. The New York Times. 19/08/2007, URL: http://www.nytimes.com/2007/08/19/magazine/19Religion-t.html?pagewanted=8&_r=4. [27/02/2015]
LUXMOORE, J., 2014. How will Francis handle Hollande? The Catholic Herald. 24/01/2014, URL: http://www.catholicherald.co.uk/commentandblogs/2014/01/24/how-will-francis-handle-hollande/. [20/01/2015]
Marine Le Pen: Muslims in France ‘like Nazi occupation’. The Telegraph. 12/12/2010. URL http://www.telegraph.co.uk/news/worldnews/europe/france/8197895/Marine-Le-Pen-Muslims-in-France-like-Nazi-occupation.html [25/11/2014]
Muslim America Islamic, yet integrated. The Economist. 06/09/2014, URL: http://www.economist.com/news/united-states/21615611-why-muslims-fare-better-america-europe-islamic-yet-integrated. [27/02/2015
Muslim Americans: No Signs of Growth in Alienation or Support for Extremism
Section 3: Identity, Assimilation and Community. Online: Pew Research Center. 30/08/2011, URL: http://www.people-press.org/2011/08/30/section-3-identity-assimilation-and-community/. [27/02/2015]
No Headscarves in Schools, No Burqas in Public: Colorblind Racism in France. The Huffington Post. 09/02/2014, URL: http://www.huffingtonpost.com/leland-ware/burqa-ban-france_b_5555732.html. [25/11/2014]
Obama: Europe should better integrate Muslims. The Straits Times. 17/01/2015, URL: http://www.straitstimes.com/news/world/united-states/story/europe-needs-better-integrate-muslim-communities-obama-20150117. [25/01/2015]
POPHAM, P., 2012. No secularism please, we’re British. The Independent. 15/02/2012, URL: http://www.independent.co.uk/news/uk/home-news/no-secularism-please-were-british-6917549.html. [17/11/2014]
SANER, E., 2015. Shuja Shafi, head of the Muslim Council of Britain: ‘We’ve never claimed to speak for everyone’. The Guardian. 30/01/2015, URL: http://www.theguardian.com/world/2015/jan/30/shuja-shafi-head-muslim-council-britain-interview. [20/02/2015]
BHARGAVA, R. 1998. What is Secularism for?. What is Political Secularism and What Can We Learn from its Indian Version?. University of Victoria, Victoria, 2008. pp. 1-41. URL: http://law.uvic.ca/demcon/victoria_colloquium/documents/WhatisSecularismforPreSeminarReading.pdf [20/11/2014]
CANTLE, T. Secular Governance in a Multi Faith Society. British Muslims and the Secular State. London, 2009. URL: http://tedcantle.co.uk/pdf/Secular%20Governance%20paper%20Ted%20Cantle%202009.pdf [23/03/2015]
Amnesty International LTD., Choice and Prejudice. Discrimination Against Muslims in Europe. 2012. London: Amnesty International LTD. URL: https://www.aivl.be/sites/default/files/bijlagen/Rapportchoiceandprejudice.pdf [20/02/2015]
ASTIER, H. The deep roots of French Secularism. BBC News. 01/09/2004. URL: http://news.bbc.co.uk/1/hi/world/europe/3325285.stm. [12/11/2014]
BHARGAVA, R. States, religious diversity, and the crisis of secularism. openDemocracy. 2011. URL: https://www.opendemocracy.net/rajeev-bhargava/states-religious-diversity-and-crisis-of-secularism-0. [25/09/2014]
BRIAND, A. Law separating Church and State (1905): Excerpts. Translated by Fraser, M. Concordat Watch. URL: http://www.concordatwatch.eu/kb-1525.834. [14/11/2014]
Declaration of the Rights of Man – 1789. Yale Law School. URL: http://avalon.law.yale.edu/18th_century/rightsof.asp [25/11/2014]
DOLEK, I. Secular Policies and Religious Freedom in Turkey and India. Paper ed. Academia.edu. URL: https://www.academia.edu/4125183/_Secular_Policies_and_Religious_Freedom_in_Turkey_and_India_T%C3%BCrkiye_ve_Hindistanda_Sek%C3%BCler_Politikalar_ve_Dini_%C3%96zg%C3%BCrl%C3%BCk [23/03/2015]
DURAN, K.; PIPES, D., Muslim Immigrants in the United States. Center for Immigration Studies. 08/2002, URL: http://cis.org/USMuslimImmigrants. [27/02/2015]
France: Headscarf Ban Violates Religious Freedom. Human Rights Watch. 27/02/2004, URL: http://www.hrw.org/news/2004/02/26/france-headscarf-ban-violates-religious-freedom. [20/09/2014]
France: The Third Republic and the 1905 Law of Laïcité. Georgetown University: Berkley Center for Religion, Peace and World Affairs. URL: http://berkleycenter.georgetown.edu/essays/france-the-third-republic-and-the-1905-law-of-em-laïcité-em. [14/11/2014]
FRANCOIS-CERRAH, M.; HILL, S., Perspectives: Should Britain become a secular state? BBC Religion and Ethics. 22/03/2013, URL: http://www.bbc.co.uk/religion/0/21883918. [20/02/2015]
French Secularism – Laïcité. The BBC. 15/10/2004. URL: http://www.bbc.co.uk/dna/hub/A2903663. [15/11/2014]
God in the White House. The Public Broadcasting Service. 11/10/2010. URL: http://www.pbs.org/godinamerica/god-in-the-white-house/. [27/02/2015]
HACKETT, C., 5 facts about the Muslim population in Europe. Pew Research Center. 15/01/2015, URL: http://www.pewresearch.org/fact-tank/2015/01/15/5-facts-about-the-muslim-population-in-europe/. [15/04/2015]
INDIAN GOVERNMENT. The Constitution of India. Indian Government. 1950. URL: http://india.gov.in/my-government/constitution-india/constitution-india-full-text [20/02/2015]
Is ‘Crisis Of Secularism’ In Western Europe Result Of Multiculturalism? – Analysis. Eurasia Review. 07/07/2014, URL: http://www.eurasiareview.com/07072014-crisis-secularism-Western-europe-result-multiculturalism-analysis/. [25/10/2014]
MODOOD, T., Secularism in crisis? Muslims and the challenge of multiculturalism. ABC Religion and Ethics. 08/08/2012, URL: http://www.abc.net.au/religion/articles/2012/08/08/3563265.htm. [20/07/2014]
MUNI, S.D. Ethnic conflict, federalism, and democracy in India. The United Nations University. URL: http://archive.unu.edu/unupress/unupbooks/uu12ee/uu12ee0j.htm. [20/03/2015]
Muslim Americans. Middle Class and Mostly Mainstream. Pew Research Center. 22/05/2007, URL: http://www.pewresearch.org/files/old-assets/pdf/muslim-americans.pdf. [15/04/2015]
OGDEN, C. FPC Briefing: India’s BJP Contemplate their Future. The Foreign Policy Centre. URL: http://fpc.org.uk/fsblob/1139.pdf [23/03/2015]
Overview: Public and Private Spheres. Oxford Reference 2015. URL: http://www.oxfordreference.com/view/10.1093/oi/authority.20110803100353296. [09/02/2015]
RAJAGOPALAN, S. Secularism in India: Accepted Principle, Contentious Interpretation. Paper ed. Academia.edu. URL: https://www.academia.edu/1368022/Secularism_in_India_Accepted_Principle_Contentious_Interpretation [23/03/2015]
Religions. Niqab. The BBC. 22/09/2011, URL: http://www.bbc.co.uk/religion/religions/islam/beliefs/niqab_1.shtml. [15/04/2015]
SKERRY, P., The Muslim-American Muddle. Brookings. 2011. URL: http://www.brookings.edu/research/articles/2011/09/muslim-americans-skerry. [27/02/2015]
The French myth of secularism. The Conversation. 15/01/2015. URL: https://theconversation.com/the-french-myth-of-secularism-36227.
The Global Religious Landscape. Pew Research Center. 18/12/2012, URL: www.pewforum.org/2012/12/18/global-religious-landscape-muslim/. [10/04/2015]
The Future of the Global Muslim Population. Pew Research Center. 27/01/2011, URL: http://www.pewforum.org/2011/01/27/future-of-the-global-muslim-population-regional-europe/. [10/04/2015]
‘The World Before Her’ in context. Background: Hindu Nationalism and the Miss India Pageant. The Hindu Nationalist Movement. The Public Broadcasting Service. URL:http://www.pbs.org/pov/worldbeforeher/photo_gallery_background.php?photo=2#.VRrokstFBLM. [20/03/2015]
WHEELER, N., The French secular approach. One Europe. 02/08/2013, URL: http://one-europe.info/french-seculiar-approach. [20/09/2014]