Introduction

1It is indeed a challenging task for us —both individually, and collectively— to reflect on the particularities of our own national and regional contexts, stepping out of our ‘assumed’ or ‘taken for granted’ theories and conceptions of citizenship and related conceptions of the ‘individual’, ‘social contract’, the ‘state’, ‘democracy’, ‘diversity’ and ‘human ‘rights’.1 Within Western academic discourses —there is a tendency to assume that these theories and debates are universal, linguistically, and conceptually (Kiwan, 2013a). In contrast, postcolonial critiques of citizenship influenced by Edward Said’s discourses on Orientalism, assert that these Western academic discourses do no more that present particularistic understandings of citizenship that masquerade as universal theories of citizenship. It is clearly a challenging task that faces theorists —a task of both abstracting from the particular, whilst at the same time being located in a particular context, aiming to generalize, and so providing an explanation of the issue in question. Indeed, the very framing of this task, as outlined in the call of this workshop ‘translating citizenship’ illustrates this challenge, where the presentation of citizenship is constructed predominantly in civic republican terms reflecting arguably, a predominantly French construction of citizenship. Subsequently, the structuring of thematic panels and their descriptions also reflects the tensions in attempting to provide a general structure to facilitate thinking through the issues in ‘translating citizenship’, whilst at the same allowing for concepts and structures to emerge from our discussions.

2Our task here is not only a question of sharing our research on citizenship in a comparative sociological frame, but it also raises an extremely important methodological question of how we ‘do’ theory’ —how we theorize, using the field of citizenship, as an example for this methodological inquiry. The issue of ‘how’ we do theory, can be considered both in terms of the act of theorizing, which relates to how language and concepts are employed in different contexts, but also in terms of the process itself —a question about the production of knowledge.

3Therefore, in this paper, I aim to explore this methodological issue, firstly at the level of language and concepts, and secondly in terms of the process of how such knowledge is constructed. The paper will be structured in three parts: i) The first part of this methodological inquiry highlights key features of an approach as advocated by the philosopher, Joseph Carens, which he calls ‘a contextual approach to political theory’. I consider the merits and pitfalls of such an approach, before suggesting that not only is such an approach important for the exercise of theorising, but may provide a particularly useful tool for those engaged in cross-cultural dialogues and debates, such as is entailed in this initiative of ‘translating citizenship’. ii) The second part of the paper attempts to reflect on the case study of the UK using this contextual approach. The UK, being both what is described as a ‘multi-nation’ and ‘multicultural’ state, provides an interesting example allowing for exploration of the issue of the methodological exercise of ‘translating citizenship’. In particular, I examine the phenomenon of the UK government making efforts to reassert the relevance and the significance of ‘post-national’ (or state-level) citizenship, in the context of forces of perceived internal division —increasing devolution over the last decade, and also concerns relating to community cohesion and integration. These policy initiatives are based on a hypothesis or broadly framed theoretical proposition/assumption that, firstly, increased ethnic and religious diversity challenges common citizenship, and that policy initiatives that promote ‘post-national’ or state level citizenship are a means to reduce internal division. Two additional sub-themes or arguments are that a) diversity as a result of immigration —‘multicultural’ diversity— is more threatening to state unity than ‘multi-nation’ diversity; and b) integrating immigrant newcomers into the ‘nation’ is primarily an issue of education, given the naturalization requirements of English language competence and civic knowledge. iii) The final part of the paper makes some preliminary remarks about the process by which we construct knowledge, in the context of this initiative of ‘translating citizenship’ and more particularly, in relation to our activities of this workshop. This consideration will draw on the work of Iris Marion Young who wrote extensively on the question of citizenship as an inclusive process as well as concept. She argues for a heterogeneous differentiated public where differences are publicly and explicitly recognized in an attempt to include often marginalized perspectives into the public. I propose that such an approach could be applied methodologically to the issue of ‘translating’ citizenship.

A contextual approach to political theory

4Carens (2004) advocates an approach to theorizing that he describes as ‘contextual’. This is an approach where actual ‘cases’ or examples are used in developing theory, as it should be recognized that ‘social and political practices sometimes contain embedded wisdom’ (ibid.: 122). This is not to say that Carens advocates endorsement of practice per se, but rather it is given ‘standing’. As such, policy and practice can allow for a critical perspective on theory, as well as theory allowing for a critical perspective on policy and practice. Carens’ argument that he lays out in this paper to his fellow philosophers and political theorists needs to be contextualized in an academic context where typically theory holds a privileged position over policy and practice (Kiwan, 2013a).

5So what is the aim of theory? Theories aim to generalize, entailing an abstraction from the particular. In this way, theories aim to provide an explanatory or clarifying role of a natural or social phenomenon (Carens, 2004). With normative political theory, what is outlined is the ‘ideal’ —what ‘should’ occur (Rawls, 1971). However, Carens argues that the ‘problem’ with theory is that the language used can be too abstract, can seem disconnected from reality, and can be ‘underspecified’ or indeterminate, which in turn can lead to interpretative disputes. Furthermore normative political theory can ignore that moral reasoning can serve particular interests, for example, class, ethnicity or gender interests. In addition, it should be remembered that such normative political theorizing takes places in particular institutional contexts that privilege some over others. Moreover, standards of justice are rooted in particular historical traditions that may not be shared with others. His characterization of a contextual approach to theory is an attempt to address these concerns. He highlights five key elements that characterize this approach.

6Firstly, examples should be used to illustrate theoretical formulations, thus having a clarifying function. Real cases are ‘messy’ and as such, are richer than hypothetical examples sometimes employed by normative political theorists. Secondly, the normative exploration of such actual cases or examples allows for us to consider whether there is a dissonance between theory and practice. This can lead to the revision of practice, but equally it can lead to the revision of theory. Carens advocates an approach of oscillating between theory and practice that he refers to as ‘reflective disequilibrium’, which he characterizes as the ‘mutual unsettling’ in theory and practice by juxtaposing the two in an ‘ongoing dialectic’ (ibid.: 123). This leads to, thirdly, allowing theorists to consider whether their theorizing is compatible with the normative positions that they actually take. Fourthly, it entails a search of cases that potentially challenge the theoretical position, and finally, this approach advocates the consideration of a wide range of cases, especially unfamiliar cases (Carens, 2004).

7In contrast to Caren’s position, Kukathas (2004) argues against a contextual approach to theorizing, asserting that the role of theory is to describe the world, and with respect to normative theory, it postulates what the world should look like if it conformed to particular values (Kukathas, 2004). He raises questions of the ‘usefulness’ of this activity, not only with respect to the development and refinement of theory, but also for policy and practice. He argues that it is not a practical enterprise. He elaborates, arguing that in the real world, policies, practices and institutions are shaped by many things. As such, it should be recognized that theory is just one potential influence on practical action. According to Kukathas, the theorist’s role is to assess and criticize. Rather than real cases being useful, he argues that their complexity confuses rather than clarifies. So for him, theory cannot fully describe or bring order to practice, as practice is full of contingency.

8Whilst Kukathas’ characterization of the differences between academic and policy environments are important points, the contextual approach, I would suggest, is nevertheless useful in developing theory. In particular, I propose that elements four and five —the search for challenging cases, and cases that are unfamiliar— have particular pertinence for us in the methodological consideration of ‘translating citizenship’. By considering the ‘translatability’ of concepts and theories of citizenship typically developed from a Western frame of reference and socio-political context with its concomitant implicit assumptions to other regional contexts, namely the Arab context for the purposes of this workshop, such a methodological stance allows for a more explicit scrutiny of these concepts and theories.

Constructions of citizenship in the UK context

9In this section, I outline and briefly discuss key features in the United Kingdom context, before examining recent policy initiatives in the domains of education and naturalisation. Drawing on Carens’ approach, I will then consider the extent to which the case of the UK allows for the development of our theoretical understanding of various citizenship concepts, before considering the extent to which these are ‘translatable’ across contexts.

10The United Kingdom is both a ‘multination’ state —made up of England, Northern Ireland, Scotland and Wales, and a ‘polyethnic’ state— in that there are a large number of different ethnic and religious groups, largely a result of mass immigration since the Second World War (Kiwan, 2008a; 2013b). British national identity has historically been an implicit rather than an explicit construction; historically, it was superimposed over internal differences between Wales, Scotland and England (Colley, 1992). Yet ‘British’ nationalism has not superseded Scottish, Welsh or Irish nationalism (Rex, 1991), explained in terms of globalization, Britain’s declining economic power coupled with the collapse of the Empire, Britain’s changing relationship with Europe, devolution, and increased pluralism (Runnymede Trust, 2000). ‘English’ nationalism, despite England’s relatively dominant position within the Union, has not developed to the same extent as Scottish, Welsh or Irish nationalism, although in recent years, this has been changing.

11So in conceptual terms, what is typically meant or invoked by the term, ‘British’? Are we talking about a distinctive national identity and certain shared values, a dominant ethnicity / or ‘race’, and religion (i.e. Anglo-Saxon or White and Protestant), or is it a ‘thinner’ more civic notion making reference to the political, legal and civic institutions of the UK, and broader conceptions such as ‘democracy’ and ‘human rights’?

12It has been argued that conceptions of Britishness from the mid-twentieth century onwards, have been linked to discourses on ‘race’ (Grillo, 1998), evident in the context of post-war mass immigration predominantly from the former colonies of the British Empire (Runnymede Trust, 2000), and more recently, perceived threats to liberties arising from international terrorism (Pattie et al., 2004). With regards to the relationship of religion to the state, the UK’s legal and political institutions are clearly shaped by Christianity and in particular Protestantism. Islam has become high on the public agenda, particularly since ‘9/11’, and more recently the London Bombings in July 2005. Public discourses on Islam question Muslims’ loyalty to the nation-state, and Islam is typically cast as being in opposition to Britain’s liberal ideals and secularism; it is also seen as inherently violent (Kiwan, 2008a; Kiwan 2013b).

Citizenship education in the UK

13I would now like to outline the approaches to citizenship education in England, Northern Ireland, Scotland and Wales. The responsibility for education is devolved to the regions, so that policy and curriculum for citizenship education is developed and implemented autonomously in the different nations (Kiwan, 2013b). I will examine the different constructions of citizenship in the different nations, asking how these different constructions of citizenship are reconciled within the UK as a whole.

England

14Until 2002, citizenship education was not a statutory requirement in schools in England. In 1997, the then Secretary of State for Education initiated a policy review of citizenship education, which recommended that ‘Citizenship’ be a statutory ‘entitlement’ and a separate subject (QCA, 1998). ‘Citizenship’ was conceptualised in terms of three ‘strands’ —social and moral responsibility, political literacy and community involvement. This conception of citizenship drew significantly on a civic republican understanding of citizenship, where identity is a private sphere matter, conceived of as distinct from the civic public sphere (Kiwan, 2008a; 2013b). There was an explicit avoidance of examining the relationship between citizenship and nationality or national identity (Kiwan, 2008a).

15Citizenship education was predominantly framed in terms of skills and participation, avoiding identity issues, given fears of politicizing education (Kiwan, 2008a)

16Expected policy aims and outcomes were framed in terms of concerns about the perceived political apathy of young people, coupled with notions of youth in society being in ‘moral crisis’ (Kiwan, 2008a). This model of citizenship education makes the assumption that providing skills and knowledge to learners will result in an engaged and inclusive citizenship. However, I have written elsewhere that such a model does not account for structural or personal barriers to being motivated to participate, lacking in contextualization with respect to how identity plays out in how individuals relate to the larger group, community or society within which they live (Kiwan, 2008a).

17There has been a significant reframing of the importance of citizenship education in relation to perceived challenges of ethnic and religious diversity from 2005 onwards, and since 2010 the importance of citizenship education as a subject in the curriculum at all has also been raised. Whilst diversity and immigration issues were not originally considered to be particularly important ‘drivers’ of citizenship, by 2006, these issues had become much more significant in the framing of citizenship issues both in media and policy debates, including the framing of the House of Commons Committee Inquiry into Citizenship Education in 2006 (Kiwan, 2006). In 2006, the government department of education — Department of Education and Skills (DfES), commissioned a ‘Diversity and Citizenship Curriculum Review’, launched at a community cohesion event, in order to address perceived threats of increasing diversity (Kiwan, 2008a; 2013b).

18The remit for the Review was to ‘review the teaching of ethnic, religious and cultural diversity across the curriculum to age 19’, and the report proposed an additional strand to the existing conceptualization of citizenship in the curriculum, entitled ‘Identity and Diversity: Living Together in the UK’ (Ajegbo et al., 2007). This aimed to address identity and diversity issues within citizenship, linked to active citizenship and political literacy (Kiwan, 2008; 2013b). Sub-themes included a conceptualization of the UK as a ‘multinational’ state, made up of England, Northern Ireland, Scotland and Wales, and as a ‘multicultural’ state, through immigration, understanding of Commonwealth and legacy of Empire, the European Union and extending the franchise. A pedagogical approach of emphasizing dialogue was proposed (Ajegbo et al., 2007).

Scotland

19Citizenship education in Scotland, in contrast to England, has not been the focus of such politicised debate (Andrews and Mycock, 2007). It is not a statutory requirement and it is taught across the curriculum rather than as a separate subject. Key themes include global citizenship, political awareness, human rights, appreciation of diversity, equalities, peace education, media awareness, science in society, arts in society, sustainable development, and enterprise in education (LTS, 2007). This contrasts with the English preoccupation with ‘Britishness’ and ‘shared values’ in the face of the challenges of diversity. The Scottish focus relates more to cultural, environmental and economic themes, and to political awareness of multiple levels of political representation, locally, nationally and internationally (LTS, 2007). Andrews and Mycock (2007) argue that the theme of ‘national’ Scottish identity (in contrast to ‘Englishness’, and by extension ‘Britishness’) has some political importance, whilst the themes of ethnic and religious diversity, immigration and ‘Britishness’ —dominant themes in the English citizenship education curriculum— have received relatively less political attention.

Wales

20As in Scotland, citizenship education in Wales is not a statutory subject in the curriculum. It is not a separate subject but is taught as a cross-curricular theme emphasizing a distinctive civic and cultural ‘Welshness’ (Andrews, Mycock, 2007). It consists of five themes: positive relationships, health and emotional well-being, active citizenship, sustainable development and global citizenship, with students actively encouraged to be engaged with the local community (Welsh Assembly Government, 2010). The pedagogical approach advocated proposes linking global citizenship themes throughout all school subjects, linking the local Welsh context with a global interconnectedness (National Assembly of Wales, 2005). For example, in History, teachers are advised to link the history of Wales and the UK to world history —around such themes as immigration, or coal mining. Yet there is relatively less reference to Wales’ position within the UK, or to its relation to the other UK nations.

Northern Ireland

21In 1989, Citizenship education was introduced as a statutory cross-curricular subject. In the context of Northern Ireland’s sectarian divisions, and after the signing of the Good Friday agreement in 1998, a pilot programme in citizenship education was introduced with a focus on citizenship in a divided society (Andrews and Mycock, 2007). Citizenship education in primary schools was introduced as ‘mutual understanding in a local and global community’, and in secondary schools as ‘local and global citizenship’ (CCEA, 2007). The curriculum constructs citizenship in terms of universal human rights, where ‘national’ citizenship —‘Northern Irish’ citizenship— is avoided with a focus on the less contentious sites of local community and global concerns (Kiwan, 2013b).

Concluding comments on citizenship education in the UK

22The conception of citizenship in the English curriculum places an emphasis on recognizing the ‘multicultural’, with a concomitant emphasis on ‘Britishness’ as an approach to unify the diversity arising from multiculturalism. There is relatively less reference to the potential challenges and debates arising from the context of the UK as a multinational state per se. The significant challenge to British citizenship is framed primarily in terms of the diversity arising from immigration, and the legacy of Empire. In contrast, the multinational context of the UK is presented in more stable and certain terms —an accepted and acceptable ‘backdrop’ to the multicultural challenges facing the UK, as opposed to England specifically. This is despite the fact that historically the greatest challenge to nation-states comes from its historical minorities, rather than from its immigrant communities (Kymlicka, 2011). English national identity is not a primary site for exploration in the curriculum (Kiwan, 2013b). Rather, the emphasis is reflected in terms of key concepts and values reflecting a ‘post-national’ unity around ‘Britishness’, in the context of a multicultural diversity. In contrast, Scotland, Wales and Northern Ireland advocate a more ‘glocal’ conception, by-passing the UK site of ‘Britishness’.

UK naturalization policy

23Naturalization policy, unlike education policy is not devolved to the regions but instead is a UK government responsibility. I have written elsewhere about the educative framing of UK naturalization policy (Kiwan, 2008b). Whilst citizenship and nationality were kept separate in the original policy and curriculum formulations for citizenship education for schools in England, these concepts were explicitly brought together in the domain of naturalization (Kiwan, 2013b). In 2002, a Home Office Advisory Group was set up to develop proposals for language and citizenship education for immigrants applying for naturalization to become British citizens. The rationale for this policy is presented as raising the status of becoming a British citizen as well as being positioned within a broader government citizenship agenda of ‘encouraging community cohesion’ and ‘valuing diversity’ (Home Office, 2003). The Nationality, Immigration and Asylum Act 2002, requires those applying for British citizenship to be able to show ‘a sufficient knowledge of English, Welsh or Scottish Gaelic’ and to have ‘sufficient knowledge about life in the United Kingdom’ (Home Office, 2003), through one of two routes, either passing a ‘citizenship test’ —for those with relatively higher levels of English language, or successfully completing an accredited English language course with embedded citizenship content. The rationale behind the proposal of these two routes was that the requirements should not be a significant barrier to British citizenship

24Legally, applicants can demonstrate sufficient language knowledge not only of English, but of Welsh or Scottish Gaelic. Yet, in practice, however, the majority of applicants all over the UK choose to satisfy the language requirement by the use of English. In linguistic terms, this supports a ‘post-national’ model of citizenship —that is, of becoming British, rather than becoming English, Northen Irish, Scottish or Welsh first. With regard to the civic content, the ‘Life in the UK’ Advisory Group Report (Home Office, 2003) recommended that language and citizenship education should be made available, outlining the following six broad categories: 1. British national institutions; 2. Britain as a diverse society; 3. Knowing the law; 4. Employment; 5. Sources of help and information; 6. Everyday needs. A handbook, upon which the test is specifically based was developed and published, entitled Life in the United Kingdom; a journey to citizenship (Home Office, 2004; 2006). A second edition of the Handbook was subsequently published in 2007 covering the history of the UK, basic demographic patterns, UK political institutions and governance; housing, education, health, employment, the law, community issues and sources of information (Home Office, 2007). Through the course route, materials are delivered through accredited courses with a more contextualised focus on the local community, in contrast to the test route (Kiwan, 2013b).

Key findings

25Citizenship education policy: It is evident that differing socio-political contexts and differing emphases lead to different conceptions of citizenship in citizenship education across the four nations. This also relates to the perceived role of citizenship education in the different nations. In summary, England presents a predominantly post-national yet multicultural framing, compared to a more ‘glocal’ presentation in Scotland, Wales, and Northern Ireland (Kiwan, 2013b).

26Naturalization policy: What emerges is that dependent on route, there are differing constructions of citizenship. Given that the course route is delivered through education, which is decentralised in its provision, it differs from the more ‘post-national’ presentation of citizenship in the test route (Kiwan, 2013b).

Theoretical reflections on ‘translatability’

27So if we stand back from the specificities of the case study, what can be ‘translated’ in conceptual and theoretical terms? Firstly, one can consider the meaning of the terms, ‘multination’ and ‘multicultural’. To what extent do such concepts have any import outside of the Western liberal democratic context of mass immigration, in societies with national minorities? Moreover, to what extent does the juxtaposition of these concepts of ‘multination’ and ‘multicultural’ have relevance outside of this context? Tentatively, I would suggest that, in general terms, it illustrates the ‘categorization’ of diversity, highlighting assumptions with regard to what ‘type’ of diversity is perceived to be the most ‘problematic’. These assumptions are made not only by governmental policymakers, but also pervade theoretical writings. Using what can be characterized as a contextual approach, the political philosopher, Kymlicka (2011) has critically examined the theoretical claim that multicultural diversity poses a greater threat to the unity of states, than do national minorities. Drawing on empirical evidence to assess and challenge this theoretical claim, he illustrates in the Western context, that this theoretical proposition can be refuted. Whilst not directly engaging with non-Western contexts, this contextual approach at least facilitates categorical thinking about what is ‘constant’ and what is more ‘variable’ (Kukathas, 2004).

28Similarly, one could also raise the question of whether there is translatability or relevance in relation to the theoretical proposition implicit in UK government policy that cohesion is best served through the promotion of state-level or ‘post-national’ conceptions of citizenship. What can be abstracted beyond the particularities of the UK context of mass immigration of relevance to the Arab context? Is the focus one of top-down government control of conceptions of citizenship superimposed over internal differences (rather than the focus on differences as a result of immigration)? This research indicated that not only are diverging conceptions of citizenship a feature in citizenship education across the four nations of the UK, but that also in terms of requirements for new applicants for British citizenship, diverging conceptions of citizenship are a feature both between the two routes to citizenship as well as between the four nations, given the combined centralized organization and regionalized provision of naturalization. It has been argued by Kymlicka (2011) and others (e.g. Miller, 1995) that citizens are well-able to negotiate multiple levels of citizenship, particularly important in the context of a multicultural and multinational and increasingly globalized world. However, others have expressed concern that the different nation states are sending out divergent messages (Andrews, Mycock, 2007), which has differential implications for the political identities of British citizens across the four nations.

29An additional theme to reflect on is the constructed understanding of citizenship, implicit in naturalization regimes. Given the central role of education in the naturalization of British citizens, it is evident that citizenship is constructed as something that can be learned. In addition, integration into a ‘common’ citizenship is considered important to the unity of the state. By considering the inter-relationship or lack thereof, of citizenship education initiatives in schools, and naturalization regimes in different state contexts, such a contextual approach, enables clarity of thinking with regards to varying governmental and public discourses on citizenship.

Thinking about the process of constructing knowledge

30In this brief section, I merely raise the issue that initiatives such as the one we are engaged in, in the workshop on ‘Translating citizenship’, are not only a question of examining the translation of theories and concepts. At stake is the process of constructing knowledge itself, and being aware of the power dynamics involved and the inequalities evident in ongoing processes of constructing knowledge. Iris Marion Young’s work on differentiated citizenship as group representation is potentially inspiring in this regard, as she notes that ‘the activities of citizenship express or create a general will that transcends the particular differences of group affiliation, situation and interest, and in practice has excluded groups judged not capable of adopting that point of view’, (1998, p. 264). She argues for the inclusion and participation of everyone in public discussion, with mechanisms for inclusion in the context of certain groups being privileged. It is with this final thought that I conclude my paper, with the hope that through this workshop we will engage with one another, in an open and inclusive dialogue.