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1 Keyword: Citizenship By Barbara Hobson and Ruth Lister

In Contested Concepts; Gender and Social Politics. Eds. Jane Lewis, Barbara Hobson, and Birte Siim. Edward Algar, 2001


Citizenship is a concept that is very much at the centre of policy debates within and across national borders, either explicitly or implicitly. This is particularly true in the European context in which welfare states have recast and redefined notions of citizenship in an era of restructuring and retrenchment. Pivotal here have been both the shifting relationship between the rights and obligations of citizenship and questions of membership of national communities in an era of economic globalisation, migration and increasingly multi-ethnic populations. These developments are reflected in a parallel outpouring of academic works, debating and contesting established notions of citizenship. In terms of both the policy debates and the academic critiques, we are living in what might be termed a post-Marshallian age1. Of all the keywords in this volume, citizenship is perhaps the one where the exclusion of women has been most firmly imprinted within its historical template. It is, thus, not surprising that there now exists a rich, multi-disciplinary feminist literature that provides both a critique of and an alternative to this gender-biased template (see Voet (1998) for an overview). In a growing number of cases, this literature locates gender within a broader analysis of diversity and social divisions, in developing an understanding of both the nature of citizenship as membership of a

2 community and of the patterns of inclusion and exclusion, which shape that membership. This understanding identifies citizenship as `more than simply the formal relationship between an individual and the state presented by an earlier liberal and political science literature'; instead it conceptualises `citizenship as a more total relationship, inflected by identity, social positioning, cultural assumptions, institutional practices and a sense of belonging' (Werbner and Yuval-Davis, 1999, p4). In this chapter we concentrate mainly on the rights and obligations of citizenship; but also address the increasingly multi-tiered nature of the framing of membership, both in national and supra-national contexts, as well as the emergence of new citizenship claims and claims making. The chapter begins by tracing the historical origins of the keyword `citizenship' in the two main citizenship traditions of civic republicanism and liberalism. It describes how contemporary feminist analysis has demonstrated the ways in which women's exclusion was pivotal to these historical traditions. These traditions are reflected today in a number of `vocabularies of citizenship'. These provide `discursive frameworks' for understanding citizenship as part of a wider world-view (Bussemaker and Voet, 1998, p278). As well as the mainstream political vocabularies of liberalism and communitarianism (more dominant today than civic republicanism), it is possible to identify a set of more radical, alternative vocabularies, among which feminism is particularly prominent. We explore these vocabularies and the ways in which a gendered perspective has challenged established ways of thinking about citizenship in relation to contested notions of rights and an increasingly dominant discourse of obligations.

3 Having established the ways in which a gendered perspective has helped to reorient thinking about citizenship, we will look at different models for the `regendering' of citizenship. These different models have varying policy implications, which will, in any case, be interpreted differently in particular welfare regimes. Likewise, the prominence and precise meaning of citizenship as a concept in political debate varies between countries (Critical Social Policy, 1998; Siim, 2000). We then turn to the dimension of membership and belonging, which extends the terrain of citizenship into questions of political identities.2 New social movements and claimsmaking have challenged false universalism in the category of citizen as well as the unitary category of the woman citizen, through the articulation of multiple identities and interests around `race', ethnicity, class, sexual preference and disability. The final section addresses global and Eurocitizenship in the context of the changing role of nation states and the framing of citizenship rights in supra-national arenas.

The gendered historical template

Citizenship's roots lie in ancient Greece, the birthplace of the civic republican tradition. In this tradition, citizenship is above all a political ideal; one which holds out political participation both as a civic duty and as the highest calling through which the citizen's full potential as a political being is realised. The emphasis is on the political obligations due to the citizenship community.

In contrast, in the liberal tradition, developed since the 17th century, the citizen is the bearer of rights. In the classical liberal tradition, civil and political rights are the essence of citizenship; they are the guarantee of the freedom and formal equality of

4 the individual who is sovereign. Social liberalism extended the scope of rights to the social in recognition of the ways in which substantive inequalities can undermine the formal equality derived from civil and political rights alone. T.H. Marshall (1950), whose work influenced thinking on citizenship in many European countries, analysed civil, political and social rights as representing an historical progression from the eighteenth through to the twentieth century. Marshall's account of the development of citizenship has been criticised on a number of grounds, including its androcentric bias. What he provided was an account of the evolution of the citizenship rights of men; women were largely invisible. This androcentrism was typical of both the liberal and civic republican citizenship traditions in theory as well as practice. The ostensible gender-neutrality of the label of `citizenship' obscures the gendered exclusions constructed in its name. For much of history, ancient and modern, women were denied the formal status and rights of citizens. In ancient Greece, Aristotle conceived of citizenship as a male status and virtue; women, together with slaves, were non-citizens, excluded from political participation. Subsequent civic republican writers, such as Machiavelli and Rousseau, likewise conceived of the virtues and duties of citizenship in masculine terms. In response, some women such as Mary Wollstonecraft at the end of the 18th century, together with women's organisations in the late 19th and early 20th centuries, used the discourse of civic republicanism to argue for women's inclusion into the ranks of citizens (Bussemaker and Voet, 1998). In some cases, the emphasis was on women's contribution to citizenship as mothers, responsible for bearing and rearing the next generation of citizens.

5 Women were also excluded from the rights of citizenship propounded in the liberal tradition, for they were not conceived of as independent individuals. Instead, a married woman lived under the `cover' of her husband (coverture in legal terminology) who, as head of household, enjoyed the status of civil citizenship, together with various rights over his wife. Again, women used the arguments of liberalism to fight for their equal citizenship alongside men. The most famous example is, perhaps Olympe de Gouges' impassioned Déclaration des droits de la femme et de la citoyenne (1791/1986), which countered the French Revolution's Déclaration des droits de l'homme et de citoyen. From the vantage point of the late 20th century, when citizenship re-emerged as a central political and theoretical concept, it was easy for `malestream' citizenship theorists to dismiss women's exclusion from the historical template as an aberration, insofar as they acknowledged the exclusion at all. Thus, for example, according to Adrian Oldfield, it does not `require too much extend the concept of `citizen' to include women'; apart from Machiavelli's equation of citizenship with masculine virility and the idea of the `citizen-soldier', there is, he claims, `nothing aggressively male in the civic-republican conception of the citizen' (Oldfield, 1990, p59). Feminist scholarship, has, on the contrary, illuminated the ways in which citizenship, in both its civic republican and liberal clothes, developed as a quintessentially male practice and ideal. The gendered construction of citizenship was no aberration but was constitutive of the very idea of the citizen. Underpinning this gendered template was the public-private dichotomy, together with the malefemale qualities associated with it. On the `public side' the disembodied citizen qua man was elevated because he was thought to display the necessary qualities of

6 impartiality, rationality, independence and political agency. This public sphere of citizenship was supported by the `private' sphere, to which embodied women were relegated and from whence they were deemed incapable of developing the `male' qualities of citizenship (Pateman, 1989; Lister, 1997; Prokhovnik, 1998). This suggests that an understanding of the gendered nature of citizenship needs to focus on the male as well as the female side of the citizenship equation, as argued by Jeff Hearn. Writing from within critical studies of masculinity, Hearn (1997) has called for an interrogation of `the silence that has persisted on the category of men [as gendered actors] in both theory and practice around citizenship', but in a manner that both names and decentres men. By `naming men as men', he argues, `the gendering of citizenship is made explicit'. At the same time, like women, men do not constitute a homogenous category. Thus it is particular groups of men, `often white, heterosexual and able-bodied men (WHAMs)' in whose image the citizenship template has been forged. These were the groups of men who `awarded' suffrage to women and continue to dominate the political arenas. But other men have been excluded from citizenship-- at the extreme end of the spectrum are men who comprise the bulk of the prison population, who lose their civil and political rights. Immigrant, poor and black men are also excluded from full participation in their communities through lack of resources and the denial of their employment and social rights. Their sense of disempowerment and alienation is expressed in their disengagement from the civic community; they no longer exercise their voting rights. Gay men are treated as lesser citizens in most societies. With the exception of the Netherlands, Sweden and Denmark, gay couples are not recognized in law, lacking the civil right to marry. As Richard Collier has noted, the lack of recognition of homosexual couples is reflective

7 of the persistence and hegemony of the male/breadwinner and female childrearer dualism, as a functional economic unit (Collier, 1995, p198-199). Historically, men as a group have been tied to citizenship through their soldiering, and thus always have been treated as having stronger claims for political and social citizenship. They have gained recognition and rights that women have been denied. While white women have made claims as civilizers of nations and reproducers of the race, their claims have not had the same discursive power as those made on behalf of men who have `served their country' in war (Lake, 1994; Lewis, 1992; Pedersen 1993) Men's historical monopoly of citizenship and the continued power of the deeply gendered public-private dichotomy have meant that women's admission to citizenship has been on largely male terms.3 This helps us to understand the gendered implications of the more contemporary vocabularies of citizenship, which derive, at least in part, from the historical traditions that were predicated on the exclusion of the female and of embodied women.

Gendered contemporary vocabularies Rights Throughout the history of feminism, the discourse on rights has been central to women' s claims: such basic rights to education, property, to custody of children, and to suffrage. In current day feminism, liberalism and its associated rights discourse have been the subject of intense debate and feminist theoretical challenges. One could divide the feminist debate on rights into two strands: those engaged with classical liberal or neo liberal constructions of negative and abstract rights (which are a restatement of classical liberalism); and those in dialogue with the social liberal

8 tradition interpreted by Marshall, which synthesized a collective notion of rights with liberal ideas of individual freedom (which we refer to as social liberalism).4 In looking at the tenets of rights rooted in classical theories, Mary Dietz underscores the centrality of the pursuit of self interest in current day discourse on rights. Within this model of a citizenship, which constructs the citizen as the bearer of rights and the role of the state as protector of the individual's person and property, access to rights is conflated with power and citizenship limited to civil rights, leaving out participatory political rights and social rights. Dietz acknowledges these liberal tenets of equal treatment in law have overturned many of the restrictions on women as individuals, but they do not provide the language or concepts to articulate a feminist vision of citizenship (1992: p. 7). Along the same lines, Mary Ann Glendon in her critique of rights talk refers to the Lockean fable, which takes as its premise that men possess property in their own person in a state of nature and only give up those parts of this `natural liberty,' freedom, that are absolutely necessary. What follows from this narrative of the origins of rights is a highly individualistic view of citizenship rights that assumes rational man should be able to pursue his own interests without undue interference. This framing of negative rights tends to set up a series of dichotomies between public and private, active and passive citizenship, and individual and collective agency (Turner, 1993; Glendon, 1998; Dietz, 1993).

The US is the country where the vocabulary of rights talk (excluding social rights) is most audible and the notion of negative rights hegemonic in political discourse (Glendon, 1998). Reacting to the lack of collective social responsibility in liberal rights talk, some feminist theorists have found other idioms (Kittay 1998), in needs

9 talk or the ethic of care (discussed below) counterbalancing the ethic of justice. This position is compatible with a social liberal, social rights tradition. Whereas, some feminists have more consciously aligned themselves with a social rights perspective and have sought to modify the conceptual terrain of individual rights within a redistributive paradigm that is gender sensitive. In effect this is to extend the universal framing of rights to include gendered dimensions. For example Susan Moeller Okin (1989) has taken the Rawlsian formula for social justice, the veil of ignorance, and asked us to construct a system of rights without knowledge of our sex.5 She provides us with a visual demonstration of her theory in a series of cartoons in which judges are asked to rule on rights for pregnancy leave. In the middle of their deliberations, they grow enormous pregnant bellies. Others, such as Nancy Fraser (1989), argue for a synthesis of needs and rights talk, which allows us to `translate justified needs claims into social rights'. This is to recognize that the question of whose needs should be met exists in a highly contested arena, continually shifting from the domestic or personal to the political. Thus needs talk can act to politicise needs and bring them into the sphere of the public, or needs talk can result in reprivatising them, defining needs as private concerns.

One can view Fraser's approach to needs as a means of shifting the ground away from the neoliberal discourse on rights, in which social rights have been delegitimated, represented as interference with the market and an infringement on individual rights and property of the majority society (since they involve more state intervention and higher taxes). Though neoliberal discourses have play in European societies, the social liberal approach to rights has not lost its foothold and claims for social rights continue to

10 have legitimacy. Nineteenth century theorists, John Stuart Mill and the later British idealists of the late nineteenth century, to some extent broke with the classical liberal tradition on the non-active state. Those who built upon Mill's ideas of a `community of individuals' asserted that individuals should be able both to enjoy freedom and act for the good of the community (Faulks, 1998). However, it was the social liberals of the twentieth century, most notably T.H. Marshall, who extended the notion of `a community of individuals' to encompass a positive state that would provide citizens with a modicum of security and welfare and positive freedoms of opportunity and development. For Marshall the positive state was essential for the realisation of social citizenship (O'Connor, Orloff, and Shaver, 1999; Faulks, 1998). Exponents for the New Right have taken issue with Marshall's account of social citizenship as a natural outgrowth of civil and political citizenship and asserted that social rights are categorically different from civil and political rights, because they imply a claim on resources.6 The feminist position supporting the active state makes the opposite claim employing Marshall's logic of the interconnectedness in civil, political and social rights.7 Feminist social theorists, mainly located in Scandinavia, have argued that to deny women social rights is to limit their political and civil rights (Siim, 2000; Hobson 1998). Helga Hernes (1987) who coined the term Women Friendly, understood that being a full participant in the community was dependent on an active state that provided universalistic benefits and services that allowed women to enter paid work. This in turn led to an expansion of their political presence, their mobilisation around rights for women to combine work and family life and the greater representation of women in public decision making bodies.8 Embedded in the very concept of a Women Friendly state is a critique of neoliberal formulations of rights as individual (rather than collective) and negative (rather than positive) rights.

11 Furthermore, at the very heart of the feminist formulation of social citizenship as the right to exit untenable marriages and form an independent household, is the recognition that social rights are coupled to civil rights (Hobson, 1994; Orloff, 1993). One can view the cleavages in feminist theorizing within the context of rights discourses, and their encasements in frameworks of difference and equality. A frontal attack on liberal constructions of rights has come from relational feminists who see the liberal ideal as that which abstracts people from physical bodies and social relationships, treating them as autonomous individuals, what Alison Jagger refers to as `political solipsism' (1983; 9Selma Sevenhuijsen has used the example of equal parental rights in custody cases to illustrate dramatically the deficiency of equal rights reasoning; the discourse on equal parental rights should be replaced by discussion of what counts as good care (Sevenhuisjsen, 1991).

Realizing the limitations of formal rights to provide a framework for persons who are interdependent, such as parents and children, Martha Minow nevertheless argues for the rescue and reinvention of rights in order to challenge hierarchies of power: `There is something too valuable in the aspiration of rights, and something too neglectful of the power embedded in assertion of another's need to, to abandon the rhetoric or rights.' (Minnow, 1991, p307). Calling for a more complex analysis of rights discourse, legal scholar, Elisabeth Schneider (1991), claims that the assertion of rights in political struggle can affirm human values and promote collective identity formation. She admits that the reification of rights can result in alienation (autonomous individualism that allows each person to protect herself) ignoring the social embedded ness of rights, as the relational feminists have argued. Yet Schneider

12 re-affirms the importance of rights in empowering women. The articulation of women's rights in the women's movement was crucial for defining women's individual and collective experience as well as in shaping the discourse on equal rights an reproductive choice (Schneider, 1991, pp. 312-313). Rights in this context are dialectically connected to political struggles, linked to consciousness and social change. This is evident in the articulation of black feminism and feminist activism around disability. Postmodernists, take a different stance on rights, one of scepticism, maintaining that unitary categories of woman reify individuals into abstract categories ignoring their diversity of experience. They view rights- based claims as contingent, temporary and relative. This position undermines the deployment of rights based politics on two levels (though in practice many post modernists theorists might accept rights as a useful strategy): first there is a rejection of claims based on unchanging and universal rights: second, there is denial of a unified experience upon which women can frame claims for rights. The debates over reproductive rights bring into stark relief the tensions within the defence and critique of rights discourse. In some respects, they reflect larger politics over rights theorizing around liberal and relational feminism, but of course it is more complicated since it involves, the rights of the individual mother, the foetus and the state. Taking the most uncompromising stand on the rights position, Eileen McDonagh (1996) argues that even if one considers the foetus a life at the moment of conception, it does not have the specific right to occupy a woman's. Other feminists have criticized the framework of rights because it does not allow for discussions of the moral complexity abortion, the ethical and humanitarian questions (Colker, 1992).

13 Defending the rights- based claim to abortion as part of a larger debate on biopolitics, feminists have countered that the right to life movement does not concern itself with reproductive health of women or the right to a decent life (social rights to life). Rather its main focus is on the right to control women's bodies (Petchesky, 1990). Adding a further dimension to debate on the right to abortion is the argument propounded by disabled feminists, who are extremely critical of the position that a diagnosis of foetal impairment automatically justifies abortion. Jenny Morris (1991), for example, argues that this constitutes a denial of the right to life, never mind citizenship, of disabled people.

Some researchers have sought to extend the Marshallian frame of civil, political and social rights by including bodily rights. Sheila Shaver (1993/1994), considering abortion rights in liberal welfare regimes distinguishes between societies with a civil versus social right to abortion. She recognizes that civil and social rights to abortion do not necessarily fit with the conventional policy regime typologies. For example, the US, embodying the liberal regime type, has a strong civil rights basis for abortion, while Britain has treated abortion as medical expert issue, with social rights attached. In a later study with O' Connor and Orloff (1999), she underscores the links between civil and social rights to abortion. In effect for poor women, the lack of social rights to abortion is an abrogation of rights. Hence scholars, such as David Held (1989), view reproductive rights as a precondition of participatory citizenship: to deny women the right to choose, is to undermine their right to participate in civil society and the polity.

14 Gal and Kligman (2000), in their recent study of post-socialist societies, suggest that reproductive policies and ideology have been crucial components in nation building; reproductive discourses and practices provide a fulcrum for constructing the relationship between a state and its subjects. At issue were different constructions of rights, which was most visible in the unification of the two Germanys. Whereas in the West, the rights of the foetus took precedence over those of women, women in the East saw abortion restriction as a loss of individual rights women had had in the former regime. But there are also competing discourses over rights and obligations in many post Soviet regime societies: the appeal to nation-building in the face of falling birth rates on the one hand, and the liberal argument on the right t one's personal morality, which was denied under state socialism, on the other.


Appeals to nation and community are grounded in an understanding of citizenship that prioritises obligations over rights. Such an emphasis can be found both in a strand of neo-liberal thought and in communitarianism. These influential political philosophies have contributed to a shift in the late twentieth century, from a dominant Western European citizenship paradigm of social rights to an increasingly vocal discourse of citizenship obligations, duties and responsibilities (Roche, 1992; Bussemaker and Voet, 1998). The neo-liberal creed was imported from the US where one of its most influential exponents was Lawrence Mead. Here the emphasis was very much on paid work obligations as `a badge of citizenship' (Mead, 1986, p229). A broader challenge to the dominant rights paradigm came, however, from popular communitarianism, which has influenced a number of European

15 governments, most notably that of Tony Blair. Communitarianism shares with civic republicanism the prioritising of the common good over the individual and his or her rights. In its more popular forms, it has attacked a `politics of dutiless rights' (Selbourne, 1994, p54). This stance has informed thinking about the `third way'. The third way's chief intellectual exponent, Anthony Giddens, has suggested `as a prime motto for the new politics, no rights without responsibilities'. `Old-style social democracy' he argues, `was inclined to treat rights as unconditional claims. With expanding individualism should come an extension of individual obligations' (1998, p65). In their political exposition of the third way, Tony Blair and Gerhard Schröder argue: Too often rights were elevated above responsibilities, but the responsibility of the individual to his or her family, neighbourhood and society cannot be offloaded on to the state. If the concept of mutual obligation is forgotten, the result is in a decline in community spirit, lack of responsibility towards neighbours, rising crime and vandalism, and a legal system that cannot cope (1999, p28). They also explain that `modern social democrats want to transform the safety net of entitlements into a springboard to personal responsibility' (1999, p35). Here personal responsibility is equated with paid work, which has come to represent the most important citizenship obligation in modern welfare states. There is, though, at times, an unacknowledged tension between the heavy emphasis on paid work obligations and the more diffuse responsibilities to family and neighbourhood referred to by Blair and Schröder. Again in the UK, parents are exhorted to fulfil their responsibilities as parents, ensuring that children attend school, do their homework and do not behave anti-socially. The gendered nature of these obligations, in a

16 context where it is still primarily mothers who take responsibility for these matters on a day-to-day basis, are never spelt out. According to Roche, the shift to a duties discourse has been fuelled also by new social movements, most notably feminism and ecology, elements of which emphasise responsibilities as emanating not only from the state, but as representing `claims against other members of civil society and/or claims against ourselves' (Roche, 1992, p50). At the same time, though, these new social movements tend to be critical of the elevation of paid work into the citizenship obligation. This position is exemplified by an increasingly vocal strand of contemporary `woman-centred' feminism, grounded in an `ethic of care' (see also Chapter X). In a feminist reinterpretation of the notion of `obligation', Nancy J. Hirschmann rejects the construction of obligation, developed in social contract theory (see Chapter X), which is rooted in individual consent and choice. She argues that: A feminist approach to obligation does not merely wish to replace consent with something else but rather to decenter consent, and its underpinning of atomistic freedom, to the end of recognizing other values, such as care and connectedness, which may be equal to freedom in their importance to human social life (Hirschmann, 1996, p162). This gives rise, she suggests, `to another concept of obligation that does not depend on explicit choice and takes care and responsibility as central elements of a moral schema that has existed at least as long as the social contract' (ibid, pp162-3). She continues that `a theory that began with connection would try to determine how to carve out a space for the self without violating the imperative of care.....By placing obligation at the center, and making freedom something to be justified and explained, the importance of relationship to human life is brought out of the shadows of the

17 sequestered private realm and into the public discourse of political theory' (ibid, p170). Selma Sevenhuijsen's work has been important in developing this position explicitly in relation to citizenship. In a critique of Giddens' The Third Way she argues that `the basic problem with the concept of obligation in The Third Way inheres in the ease with which legalistic notions of rights and obligations are pasted onto notions of responsibility' (Sevenhuijsen, 2000, p27). This reflects a more general tendency to deploy `obligation' and `responsibility' interchangeably in everyday political discourse. Philosophically, though, there is a difference that is crucial to Sevenhuijsen's argument: obligations are generated from outside the individual whereas responsibilities derive from the individual herself in relationship with others. Sevenhuijsen contends that the conflation of obligation with responsibility obscures the different ontological and philosophical foundations of the two concepts: Giddens derives the need for obligations from a wish to build the bridges between individuals and society that seem necessary when one takes the detached autonomous individual right holder as the subject of normative argument. Obligations are then derived from rights in an urge to mitigate or counter the detachment that may arise in a society of atomistic, self-governed individuals. Conversely, the feminist ethic of care takes the idea of self-in-relationship as a point of entry for thinking about responsibility and obligation....The moral subject in the discourse of care always already lives in a network of relationships, in which s/he has to find balances between different forms of responsibility (for the self, for others and for the relationships between them' (ibid, p10).

18 This position provides the basis for a reconceptualisation of citizenship, grounded in an ethic of care and the responsibilities to which it gives rise, in place of the dominant conceptualisation predicated on paid work obligations (Sevenhuijsen, 1998). However, Sevenhuijsen's stance has been criticised in turn by feminists who fear that it disconnects care from the social rights necessary to safeguard the citizenship position of those who provide and receive care. Moreover, care can be experienced as an obligation as well as a responsibility.9The feminist critique of the growing policy emphasis on work obligations can be found in Ruth Levitas' work on social inclusion (1998; see also Chapter X). Here she argues that in the UK, the problem is not that New Labour ignores care responsibilities, which it does not, but that it does not acknowledge that such responsibilities involve work. This underlies, what she sees as, a contradiction between New Labour's emphasis on paid work obligations on the one hand and family and parenting responsibilities on the other. In many countries, this contradiction is felt most acutely by lone mothers, who are increasingly the target of activation policies designed to move workless benefit recipients into paid work (although the UK is still unusual in not imposing a formal work obligation on lone mothers). Such policies can, in certain policy contexts, give rise to conflicting interpretations of lone mothers' primary citizenship responsibilities and obligations. The shifting construction of lone mothers' obligations in the welfare state has been the source of considerable controversy, crystallising as it does the contested gendered nature of citizenship obligations and responsibilities. A study of lone mothers in the Netherlands and the UK suggests that the tendency to construct lone mothers primarily as workers rather than mothers does not accord with how some lone mothers themselves perceive their primary responsibilities: ``The qualitative evidence reveals the strength of the commitment of women in both

19 countries to care and the complexities of the balancing act that they must perform in order to combine care with employment, and the sacrifices that they must make' (van Drenth, Knijn and Lewis, 1999, p638). In other policy contexts, such as the Nordic countries, it is taken for granted that mothers in both two and lone parent families are worker-citizens alongside men. More attention has been paid, therefore, in these countries to the social infrastructure of support needed to help mothers generally to combine caring and paid work responsibilities. This reflects a framework of citizenship, responsibilities and rights in the Nordic countries, which embraces participation in different spheres of life--the political, the market, and family. Hence, the Swedish model of gender equality is constructed around an ideology in which men and women are expected to be equal participants in work and family life, though of course in reality, women continue to do the majority of the unpaid work. In the 1990s policy debates focused on a gendered division of unpaid work and the need for a fairer allocation of care responsibilities between women and men. Of particular significance has been the use of paid parental leave in Sweden and Norway to encourage paternal involvement in child care through the adoption of the `daddy quota', four weeks of leave reserved for the father. This policy innovation is cast in terms of responsibilities and rights, and viewed as enabling rather than coercive. It provides men with greater leverage in making claims for parental leave, since their families will lose the month of paid leave if they do not use the quota.10 To define citizenship in terms of care responsibilities is to challenge the narrow definition of work as paid work, which underpins the dominant discourses of citizenship obligations. This assumption that work is equated with paid work has also been criticised for ignoring the contribution to citizenship of other forms of unpaid

20 work, notably community and voluntary work, in which women tend to be particularly active (see, for instance, Young, 1995). In an essay on work and citizenship in the new Europe, Leisink and Coenen point out that according to this conception, a workaholic who works sixty or more hours a week and has no time to do community service like being on the board of a school is considered a good citizen, whereas the unemployed [sic] who is full-time engaged in community service activities but cannot find a job is not considered a good citizen. Yet, the unemployed citizen engaged in community service may be said to promote as much, if not more, the welfare of the community as his workaholic colleague (Leisink and Coenen, 1993, p17). They thus argue for a broader definition of work as citizenship obligation that embraces `unpaid work such as care-work and community service' (ibid, pp17-18). This broader understanding of work is also reflected in ecological thinking. Roche (1992, p52) suggests that `if anything, the ecological movement, even more clearly than feminism, is concerned with the politics and morality of duty'. Ecology broadens out notions of responsibility and duty to include our responsibilities to the planet and all creatures on it. It is thus a conceptualisation of citizenship responsibility that stretches beyond the temporal and geographical boundaries of the individual's citizenship community, constitutes one element in what has come to be known as `global citizenship' (as discussed below). Feminist theorists, such as Kathleen Jones, have likewise broadened notions of citizenship responsibility to embrace the global, arguing that a feminist citizenship politics cannot be confined to single nation states (Jones, 1994, Lister, 1997; Young 2000).


The `re-gendering of citizenship'

The importance of citizenship as a gendered keyword lies not simply in its dominance and its contested nature, but also in the aspirational politics that it inspires (Werbner and Yuval-Davis, 1999). Marshall's exposition of modern citizenship incorporated the idea of `an image of an ideal citizenship against which achievements can be measured and towards which aspirations can be directed' (Marshall, 1950, p. 29). In this way citizenship acts as a yardstick against which progress can be measured. The yardstick is a universalist one, but it has been a false universalism created in a masculine image. A key task, therefore, for the feminist project has been to refashion that yardstick so that it is no longer skewed in favour of male interests. There have been a number of approaches to this process of `re-gendering' citizenship'; they can be characterised in terms of the three normative images of the `gender-neutral' citizen, the `gender-differentiated' citizen and the `gender-pluralist citizen' (Lister 2001; see also Hutchings, 1999). The gender-neutral and genderdifferentiated citizens personify the long-standing historical tension within feminism. On the one hand are demands for women's inclusion into citizenship based on their equality with men; on the other hand are demands rooted in women's difference from men, reflecting their maternally-derived female qualities and values. The `genderpluralist' citizen represents a more modern, or post-modern, position in which both women and men are constructed as members of multiple groups and as holders of multiple identities. It reflects `an ethos of pluralization [which] makes possible a radically plural rather than dual way of thinking about citizenship and identity' (Isin and Wood, 1999, p23).

22 The gender-neutral citizen Sketching somewhat over-simplified pen portraits, the model of the gender-neutral citizen is most commonly associated with liberal feminism, although it is not necessarily confined to it. The emphasis is on equal rights and obligations; gender should be irrelevant to their allocation. The priority is to enable women to compete on equal terms with men in the political sphere and the labour market. The latter, in turn, opens up access to the social rights of citizenship linked to labour market status through social insurance schemes. Traditionally the key to the inclusion of the gender-neutral citizen has been located in the public sphere. Contemporary exponents of gender-neutral citizenship, such as Susan Moller Okin (1989) and Anne Phillips (1991, 1997), however, recognise the importance for citizenship of change in the private sphere, in particular in the gendered division of labour. Phillips holds out a vision `of a world in which gender should become less relevant and the abstractions of humanity more meaningful'. Nevertheless, she acknowledges that during the transition to such a world, strategies to promote gender differentiation are necessary in order `to redress the imbalance that centuries of oppression have wrought' (Phillips, 1991, p7). Phillips is thus alive to the dangers of promoting an ideal of the gender-neutral citizen in a gender-differentiated and unequal world and of the quicksands of a false gender-neutrality that in practice privileges the male. Others reject the very idea of the gender-neutral citizen as a dangerous chimera. Ursula Vogel, for example, dismisses attempts to insert women into the illusionary `ready-made, gender-neutral spaces of traditional conceptions of citizenship' as `futile' (1994, p86).

23 The gender-differentiated citizen

Kathleen Jones, another critic of the gender-neutral approach, contends that `the practice and concept of citizenship' must be transformed to accommodate the experiences of women, rather than `simply transform women to accommodate the practice of citizenship as it traditionally has been defined' (1990, p811). The dilemma, as she recognises, is how to achieve this `without constructing sexually segregated norms of citizenship?', in which different spells unequal (1988, p18).

Those arguing for the transformation of citizenship in the image of women tend to hold out the ideal of the gender-differentiated citizen, typically personified in the mother. It is a model that appeals to `difference' not `equality' in promoting women's claims as social and political citizens. Historically the gender-differentiated citizen has been promoted, in particular, through maternalist arguments for treating motherhood as the equivalent of a male civic republicanism rooted in active political participation and the ability to bear arms. Difference was embodied in motherhood, for only women, qua mothers, could bear the next generation of citizens (Pateman, 1992). Others have used maternalist arguments to make the case for women's political citizenship with reference to the qualities and values that women could bring to the political arena as mothers. According to Pnina Werbner, for instance, `the strength of political motherhood as an evolving social movement has been to introduce new human qualities into the public sphere, and to define them as equally foundational in the legitimation of the political community' (Werbner, 1999, p227).

24 Maternalist constructions of citizenship have, though, attracted criticism for constructing the very `sexually segregated norms of citizenship' against which Jones warns, in which difference translates into unequal and inferior (Pateman, 1992; Dietz, 1985). In response, a number of feminists, sympathetic to some of the values underlying the gender-differentiated model, are arguing for a non-maternalistic conceptualisation of difference around the broader notion of care and an ethic of care, which is not confined to women. This is underpinned by a belief in human interdependence rather than a preoccupation with (in)dependence, as in the genderneutral model. The case for care as a resource for political citizenship has been put by Diemut Bubeck (1995) on the grounds that the private concerns, values, skills and understandings associated with the practice of caring can all enhance public practices of citizenship. One arena particularly conducive to such practices is that of informal, often community-based, politics, which is often grounded in concerns deriving from women's responsibilities for care (Lister, 1997). Through its recognition of `informal politics' of this kind, feminism has broadened our understanding of the meaning of political participation and political citizenship. At the same time, it has challenged the practice of formal politics, as increasingly feminists have engaged with formal political arenas, while, in some cases, attempting to transform those arenas, the Scottish Parliament being a good example. With their levels of representation in parliament reaching 44 percent, Nordic feminists have been able to deploy their power resources within formal political institutions to extend benefits and services for care. The term femocrat is frequently applied to Nordic feminists who seek to use their positions of power and influence in the social policymaking bureaucracy, where the politics of care are embedded.

25 In the social sphere, a number of feminists are drawing on theorising around care to make the case for the incorporation of `care in the definition of citizenship, so the rights to time to care and to receive care are protected' as part of a more inclusive approach to citizenship' ( and Kremer, 1997, p357). Through its focus on women's responsibilities rather than supposed qualities and its claim that all citizens, male as well as female, have care responsibilities at some point in their lives, this approach is less likely than maternalism to lend itself to a biological essentialism that reifies the differences between women and men. Indeed, some of its proponents would argue that they are attempting to `de-gender' citizenship. By emphasising men's role in caring, they are using gender-differentiated tools to dissolve the gender-differentiated model. Nevertheless, in practice, an over-emphasis on care runs the risk of marginalisation and of treating women as a unitary group. Some disabled feminists, for instance, reject the very language of care on the grounds that it undermines disabled people's struggle for independent citizenship (Morris, 1993, 1996; see also Meekosha and Downes, 1997). A prominent critic of an ideal of a gender-differentiated citizen is Chantal Mouffe. She is critical of all attempts to replace the false universalism of traditional conceptualisations of citizenship with a `sexually differentiated, `bi-gendered' conception of the individual and to bring women's so-called specific tasks into the very definition of citizenship'. Instead of `making sexual difference politically relevant to its definition', she argues for `a new conception of citizenship where sexual difference should become effectively nonpertinent' (1992, p376).

26 The gender-pluralist citizen This is not an argument for a reversion to gender-neutrality but for what Mouffe terms `a radical democratic conception of citizenship' (1992, p377). This is based on an understanding of the subject as `constructed through different discourses and subject positions' as opposed to one whose identity is reduced `to one single position - be it class, race or gender' (1992, p382; see also Isin and Wood, 1999).

Mouffe explicitly distinguishes her own radical pluralist position from that of Iris Marion Young who has proposed a `group differentiated citizenship' (1990). In Young's original schema group differences would be affirmed and institutional mechanisms would be developed through which the voices of oppressed groups would be heard and represented in the political arena. A key criticism made of Young's position by Mouffe and others is that it runs the danger of freezing group identities, suppressing differences within groups and impeding wider solidarities (Mouffe, 1992; Phillips, 1993).11More fluid pluralist approaches, which attempt to guard against these dangers, have been articulated around the notions of a `a `politics of difference' (Yeatman, 1993); a `transversal politics' (Yuval-Davis, 1997); a `politics of solidarity in difference' (Lister, 1997) and a `reflective solidarity' (Dean, 1996). Each of these represents an attempt to articulate the idea of a politics that, in a spirit of solidarity in the face of oppression, traverses across and through the web of group differences, but without suppressing them (for a discussion see Lister, 1998). Gender-pluralist approaches, such as these, help to diffuse the gender binary at the heart of the equality vs. difference dichotomy. They acknowledge that gender does not stand alone in shaping the contours of citizenship. Gender intersects with other sources of social division such as `race', class, sexuality, disability and age.

27 However, an ideal of a gender-pluralist citizen on its own deprives us of citizenship's function as a universal yardstick against which marginalised groups can stake their claim and measure progress towards full inclusion (Pascall, 1993). If over-stated, it can mean the fragmentation of political constituencies and of political claims. Yet, if ignored, it can lead to a false universalism, which denies the reality of difference and differential power relations and camouflages the multiple identities that shape individual citizens' claims making.

New claims; new claimants One of the questions asked more and more in current academic discourse is what citizenship has to do with the identities people deploy in everyday life (Isin and Wood, 1999; Stevenson 2000). There is growing diversity in claims and claimants seeking recognition as groups with distinct historical circumstances, vulnerabilities and interests. (Tilly 1996). This is the result of new social movements fighting oppression rooted in gender, `race', ethnicity, sexuality, disability. All of these have made a similar challenge to the universalist framing of rights and social citizenship that shaded out their values, experiences, and needs, and did not redress the particular inequalities and injustices they faced. Will Kymlicka (1995) has been one of the most ardent spokespersons for a multicultural citizenship, realizing that formal civil and political rights are insufficient for guaranteeing fairness and equal participation of minorities (see also Raz, 1994; and Parekh, 2000). Embedded within Marshall's theory of social rights was a belief in the integrative function of citizenship rights (to bring the working class into a national culture). Kymlicka (1995) maintains that Marshall was actually more concerned with the cultural exclusion of the working class than the material per se. As

28 Kymlicka and others have argued, Marshall's redistributive remedies and universal social rights to education, health care and social security, however, did not address the complex processes shaping cultural exclusion (Barbalet 1988). The 1990s saw the rise of a strident identity politics and its critics, as well as an emergent academic discourse on cultural citizenship. Critical philosophers coined the term `recognition' to capture this dimension of citizenship, and have sought to construct a moral grammar of exclusion that goes beyond formulae of justice positing a universal individual and a standard basket of rights and immunities (see Fraser, 1997; Honneth, 1996; Taylor, 1996). Implicit in this discourse is a new construction of justice that contends that non-recognition not only inflicts harm on groups and individuals, but also is a form of oppression. (Taylor, 1996). Lack of recognition implies exclusion and marginalisation from `full participation' in the community; thus recognition struggles are struggles for participation and influence over the boundaries of meaning of citizenship. In what she describes as a paradigm shift Fraser (1997), has argued that claims for redistribution, those based on a fairer and more equal division of the pie, have been eclipsed by claims for recognition, based on cultural difference. Yet this is a false dichotomy (Fraser, 1997; Hobson, forthcoming; Phillips, 1997b), which is revealed in claims of social movement actors themselves. One can see this clearly in current feminism, in whichclaims involving redistribution of social goods, such as employment opportunities and daycare, are interwoven with claims for body integrity, sexual preference and campaigns against imagery that devalues and degrades women as a category, recognition of cultural domination, Lesbian and gay struggles are not an exception either.12 Not only do gay groups claim access to social benefits, pensions, parental leaves and services as partners in

29 gay couples, (redistribution), but they challenge the very organization of social rights and privileges that are structured around heterosexual relations and a family unit (Butler, 1998). Sexual citizenship, like gendered citizenship, challenges the traditional disembodied construction of citizenship and the public-private divide that underpins it (Lister, forthcoming). It is a concept that covers a broad range of claims (Evans, 1993) by gay and lesbian movements that include respect and recognition of sexual orientation as well as specific rights to marry, adopt children, to serve in the military and to accompany partners who are migrating to other countries because of employment (the same rights as spouses). Evans (1993) maintains that the socioeconomic infrastructures found in gay communities organized around identities concern housing and medical rights as well as distinctive life styles in gay social territories. These are spaces outside the `moral national community' but inside the civic nation (Yuval Davis, 1997). Accepting the principle of citizenship as `membership in a community,' Yuval Davis, has argued for a multi-tiered construct of citizenship, which acknowledges that people are members in various collectivities--local, ethnic, national and transnational. This is to recognize that individuals are not bounded by one group identity, and that these boundaries are continually being recast. Furthermore, individuals and groups can be oppressed by the very same collectivities that are claiming citizenship rights based on their group's disadvantage and discrimination. Yuval Davis maintains that women in particular can be denied rights of the dominant community, in the name of ethnic and religious collective rights. In some cases this can lead to violence and death for women who transgress religious and cultural codes. 13 Kymlicka makes a similar case for a liberal construction of individual rights while at the same time recognizing particularistic rights. Thus he distinguishes claims of a group against its

30 members and claims of a group against the larger society ( 1995:35). Recognition of cultural distinctiveness is conditional upon the respect, tolerance and rights of individual members; one condition for Kymlicka is a an acceptance of gender equality (Kymlicka, 1995). Yuval Davis concludes that citizenship cannot be analysed as completely an individual or collective phenomenon (1997. p 91).

Global citizenship and eurocitizenship Increasingly, it is the trans-national arena in which new citizenship claims are given play. Saskia Sassen, writing about global forums for citizenship, notes the growing number of supra and international arenas where individuals ­citizens or not--can claim human rights that go beyond the nation state boundaries of citizenship (1998:94-95). UN agreements and covenants and international courts offer a global citizenship to individuals who do not have the possibility to make claims in their own countries. But these sites for recognizing human rights do not reach into the injustices rooted in the economy and this is acute among workers of the developing world (Acker 2000).

There has been a plethora of books and articles on globalisation and its impact on citizenship, including civil, political, social and economic rights. Yet surprisingly little attention has been given to gender issues, despite the importance of supranational forums and advocacy groups in which gender issues have been centre stage. Over the last decades, there has been an exponential growth in the numbers of groups and networks making claims in global arenas. The UN has been an important actor in extending women's rights in a global arena. Beginning with the Decade for Women, the UN has provided a series of forums for women seeking to extend citizenship

31 rights in their respective countries. In addition, international conferences in Beijing and Cairo have not only produced international dialogues on women's rights but have put forward a set of principles and guidelines (Meyer and Prugl, 1999). WINGOs (women's international non-government organisations), have been increasingly important for women's claims making around civil, political and social rights, and have provided financial resources and support groups for mobilizing women and forming networks for political action (Meyer and Prugl, 1999). For instance, WINGOs were crucial for Black South African women's presence and influence in the rewriting of the new Constitution (Kadale, 1995; Seidman,1999).

The growing influence of trans-national policymaking bodies and global economic processes in shaping the lives of citizens opens up new theoretical discussions about citizenship rights across policy borders (Daly, 1996; Borchost, 1994). Lack of governance over the market (deregulation of markets and the free movement of capital) as well as the widening influence of global economic and political processes have penetrated national social policy in numerous ways. National governments have altered their political and economic strategies to position themselves better in competitive conditions of global finance, trade and production. This means pressures toward lower social spending and taxes and a weakening of social citizenship. Gender is conspicuously absent in the research on globalising economies. 14Isabella Bakker in her analysis of policy reform in an era of global restructuring, maintains that the dominant discourse is cast in gender neutral terms and that the polices are formulated with little regard to the `assymetrical relations of power based on gender'(Bakker, 1994).

32 Not to be forgotten in this discussion is that globalisation has been used a rationale for reductions in benefits and services, privatisation of service delivery, and flexibility in employment. These processes have gendered effects, the latter influencing women's access to employment and the conditions of work. Writing about the relationship between `economic privatisation and political privitisation,' Anne Sisson Runyan argues that when the becomes more beholden to global capital, the result is a depoliticised state, in which political issues are reduced to economic efficiency and `public' citizens reduced to `private consumers' (Marchand and Runyan 2002 p18).

Whereas few would agree that the national state is withering away, or there is a logic to globalisation that is operating in a similar way in all Western industrialized countries (Hirst and Thompson, 1996), there is recognition of a decentring of the nation state, which reflects the direct and indirect influence of supra-national bodies to dictate policy agendas (Mishra, 2000). In this context one cannot ignore the European Union (EU) and its potential impact on the framing of citizenship. Neither Marshall (1950) nor those who expanded his framework of social citizenship imagined that to be a full member in the community, with equal rights and duties could involve supra-national policymaking institutions constructing rights derived from a common market. Nor did they envisage that such rights could cut across policy borders and be applied to citizens from different nation states. Yet Marshall's frame of citizenship as membership of a community, not merely the nation state, allows for a broader discourse on local and global levels of citizenship.

Nevertheless, implicit in his analysis of social citizenship was a set of historical conjectures within nation states: the rise of social actors (parties representing a male

33 working class constituency) with the potential to alter the constellations of political power, and a growing number of worker citizens with rising expectations and beliefs that there should be societies with more egalitarian principles. Political rights were linked to social rights, in Marshall's account, that is, the extension of the franchise gave workers and workers parties the ability to exercise power.

How to extend the boundaries of citizenship within an institution that lacks democratic frameworks is a question that resonates among the critics of the EU. The `democratic deficit' is reflected in the weak position of the parliament and a bureaucratic infrastructure that favours highly mobilized business interests. Organized women's groups have been some of the most critical voices against the democratic deficit and its impact on women's influence on gender equality policy. These include both women's movements within nation states (especially in Denmark and Sweden) as well as organized lobbies within the EU. Eurobarometer surveys also reveal a gender gap in support for EU integration across member states that cuts across education and employment status (Liebert, 1999).

The EU has removed some of the most discriminatory policies against women's access to jobs, pensions and unemployment, However the EU construction of rights rooted in the flow of goods, services and labour limit the application of social rights only to those attached to paid work, and in many countries this includes only full time workers. There is a difference of opinion among scholars about the potential of EU law and policy to influence gender politics and gender equity. Feminist scholars have highlighted the weaknesses of EU law in shading out large segments of women's lives, defined outside the parameters of EU law, which include the organization of

34 unpaid work, the care of children, elderly and disabled people, as well as a range of issues connected to biopolitics, such as rights to abortion (Hobson 2000). Legal theorists, such as Hervey and Shaw (1996), and More (1994) have underscored the ways in which the European Court perpetuates false distinctions between public and private. The failure of the Court to acknowledge the interplay between women's employment opportunities and access to rights and their caring responsibilities, according to Scheiwe reproduces gendered norms and standards and creates false boundaries between subsystems of law and social spheres (1994: p. 253). Others, such as Catherine Hoskyns and Sylvia Walby (1999) are cautiously optimistic about the future role of the EU in developing policies that address the social dimension. The EU legislation on parental leave is seen as step in this direction, however it is not a social right, since the policy did not specify that the leave had to be paid. Attention to rights of part time workers, including the EU Directive on Part Time Work, and numerous court cases, have increased the rights of

Although the realisation of effective European citizenship appears to be a long way away, the appeal to a European notion of citizenship rights enhances the power resources of women to claim and extend the boundaries of citizenship in their respective countries. From this perspective, the EU has provided groups not only with a legal base for articulating rights and promoting gender equality policies, but also it has given women's organizations in Member States discursive resources to represent gender equality as European and modern. This has been documented in the passage of a Spanish law against sexual harassment (Valiente, 1998). In Ireland, EU law has modified a highly gender differentiated model of citizenship, in which married women were denied rights to work, pensions and social security.


If we take the idea of Eurocitizenship to apply to the rights protected under European law, we can see that the EU has facilitated the migration of persons among member states, providing them with access to benefits and services attached to workers in their country of residence. Thomas Hammer (1990) has coined the term, denizens, for the growing number of persons who reside in a country with social rights but not political rights. However the access to rights is limited to those migrants who are employed and their dependants (most often wives and children) (Ackers, 1996) These are derived rights based on a spouse's (most often a husband's) employment status. What this means in practice is that if the employed EU national (most often a husband) loses his job or if the couple divorces, the woman no longer has access to benefits and services as a wife of a `Eurocitizen,' In the case of non-EU nationals, divorced spouses are unable to remain in the EU country and seek employment.

Migrant and minority ethnic women have the least access to social citizenship rights in EU law and policy. Here the mechanisms of exclusion reveal the intersection of gender, race and ethnicity. Of course, migrant women are not a unified category within EU law and there is a hierarchy of migrants: at the top are EU nationals who migrate as workers; and below them EU nationals who migrate as spouses of men who find employment in another EU member state. EU nationals who are not permanent residents and illegal aliens have no rights under EU law; this last group are the most vulnerable and most exploited in their respective countries. A hierarchy also exists among non-EU nationals, which reflects devaluation and

36 discrimination of groups in the host country based upon race and class, and country of origin.

Along similar lines, EU law and practice privileges certain norms around marriage and hetereonormativity, reflecting the situation in the majority of member states. This means that cohabitant couples that have access to all benefits and services as married couples in some Scandinavian countries are denied the rights and access to benefits given to married couples in other EU countries. Several cases argued in the European Court of Justice claiming benefits and rights to employment for partners of EU employees, have been turned down. Also challenging--without success-- the heteronormitive presumption in EU law, gay couples, have sought to gain the same social rights for their partners as given to married spouses. The gay partnership law, which is equivalent to a marriage status for social citizenship rights in Denmark, Sweden, and Netherlands is not recognized in other EU countries.

The specific clause in the Amsterdam treaty that incorporates race, ethnicity, and sexual preference in anti-discrimination law suggest a more inclusionary definition of citizenship rights and protections in the European Union. This new antidiscrimination Directive, which will come into operation in the next few years, specifically forbids discrimination on the basis of racial or ethnic origin, age, sexual orientation, and disability (Article 141 replaces Article 119) But it is difficult to gauge what kind of politics will emerge in response to this new framing of rights, which might extend the boundaries of citizenship within and across policy borders, as seen in reformulation of anti-discrimination law in member states in response to the Directive.


At this stage in European integration, we cannot speak of Eurocitizen in any political sense. But perhaps we can imagine a form of economic citizenship in light of the market framing of rights in EU law. Given the growing numbers of women in paid work and the great variation across welfare states in the rights and protections for women in paid work, scholars have begun to reassess the meaning of decommodification15 with a gender sensitive lens. Kessler Harris (2001) and Hobson ( 2000) have coined the term economic citizenship to embrace both the access to employment, and social rights attached to paid work. Hobson, specifically addressing the framing of rights within EU law, argues while there is an intolerance toward direct forms of gender discrimination in the labour market inscribed in EU treaties and law, the formal coding of gender equality as equal treatment does not address the structural features of the labour market (sex segregated occupations; and part time, flexible and marginal work situations). Because a significant portion of women are employed in part time marginal jobs, they are denied the social rights attached to jobs. The possibility to become full participants in paid work, which economic citizenship implies, would involve gender sensitive models that go beyond the principle of equal treatment in EU law. This principle is constructed around norms concerning what is work and what is a working day that revolve around a full time worker citizen, usually a male citizen.


The gendering of citizenship involves reconfiguring a paradigm that has been patterned around a male citizen. Not only were women as a group consciously left out

38 of the script in classical theories of citizenship, but also the central spheres of their lives were shaded out of the realm of social citizenship. Within the tradition of civic republicanism, the very meaning of civicness has been challenged by a gendered analysis that locates the practice of citizenship in women's experiences and political modes of action (Jones, 1990, and Phillips, 1995). Within the tradition of social citizenship, the gendering of social rights, has meant confronting the rigid distinctions between public and private domains that circumscribed social citizenship theorizing. Feminists have extended the framing of social rights to include family and domestic rights and responsibilities, which address exclusion as a result of economic dependency in the family and posit a recasting of unpaid care work as work, which should be included into the calculus of social benefits.

While some theorists continue to ignore the spheres of home and family (Turner, 1993) or reject outright this dimension as a terrain of citizenship (Marquand, 1991; Pocock, 1992), there is a growing body of theoretical and empirical literature that has sought to incorporate questions of home and family into the construction of citizenship rights. Not only social benefits but also social services are now considered an important component in assessing the extent to which welfare states create encompassing forms of social citizenship (Borchorst, 1994; Hobson, 2000;Lewis, Orloff, 1993). The family has been integrated into typologies of welfare regimes as a dimension that is mediated by state/market relations. Most recently, Walter Korpi (2000) has developed the concept of agency inequality in an analysis of gender, which acknowledges that women's lack of independent income and economic dependency in the family does not allow them to develop their capacities as citizens or enable them to be full participants in social and political life.


Gendering of citizenship has posed fundamental dilemmas for those who do not wish to jettison the notion of universal rights. A universalistic framing of citizenship has been a legal strategy for women and minorities and a powerful discursive resource for individuals denied human rights (Vogel, 1994). However to ignore the different needs, claims and situations, the subjectivities and identities of citizens, is to perpetuate exclusionary processes embedded in false universalism. How to imagine a feminist project for citizenship that allows both universal and differentiated rights is not an issue for post modernists as they have delegitimated both the idea of universal rights as well as the category of gender as a basis for differentiated rights. Nevertheless, there are feminist scholars who have taken this challenge as one that is essential not only for the feminist citizenship project, but the citizenship project itself.

With the recognition of the multi-tiered layering of citizenship, we have added many new horns to Wollenstencraft's two-horned dilemma, which Carole Pateman applies to women's citizenship.16 Lister in confronting the tension between universal and differentiated rights concludes that it is a creative rather than an irresolvable dilemma, which can be accommodated in a theory and practice of citizenship. She asks us to combine the integration of universalistic principles with pluralistic perspectives. Along the same lines, Benhabib (1992), in positing a feminist universalism, argues for a context specific ambiguity in citizenship practices. She maintains that while it is important to recognize the differences in being human, one does not always have to accept all claims based on plurality. In focusing on specific contexts and practices, feminists scholars have asked us to consider when difference makes a difference in particular societal contexts.


The next challenge for citizenship theorizing is to begin to analyse how citizenship claims made in global and supra-national arenas might shape universal and differentiated configurations of gendered citizenship This entails exploring the intersections between the local, national and supra-national.

41 References

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Query #1 What this means in practice is that if the employed EU national (most often a husband) loses his job or if the couple divorces, the woman no longer has access to benefits and services as a wife of a `Eurocitizen,' In the case of non-EU nationals, divorced spouses are unable to remain in the EU country and seek employ Changes in Text: Reference added, p. 44 Furthermore, at the very heart of the feminist formulation of social citizenship as the right to exit untenable marriages and form an independent household, is the recognition that social rights are coupled to civil rights (Hobson, 1990; 1994; Orloff, 1993). Page/ line corrections

51 42/14 change reference: from Kittay and Meyers to Kittay, 1998 (see reference below 43/2 change to Fraser, 1989 (see reference below) 44/ bottom change to Bryson, 1999 (see below for reference) 45/8 delete to in "need to" 45/13 embeddness should be one word and not two 46/ second line from bottom: bodily should be "body rights" 47/19 delete extra t after "right" 61/9 change; "of meaning" to "and meaning" 64/last line change ref to Marchand and Runyan, p. 18. See reference below 65/11 change: membership of a community" to "membership in" 69/12 in the social science literature, decommodification is not hyphenated. 73 endnote 15 add: 1990 after Esping-Andersen

Missing references: Barbalet. J. 1988. Citizenship, Rights,Struggle and Class Inequality. Minneapolis: University of Minnesota Press. Bryson, V (1999) Feminist Debates: Issues of Theory and Political Practice.. Butler, J. (1998). `Merely Cultural', Social Text 53/54 (Winter/Spring).

Collier, R. (1995) Masculinity, Law and the Family, London: Routledge.

Colker, R. (1992). Abortion and Dialogue, Pro-choice, Pro-life and American Law. Bloomington: Indiana University Press.

52 Daly, M. (1996). `Social Security, Gender, and Equality in the European Union', European Commission, Employment Industrial Relations and Social Affairs. V/D. 5. Evans , D. T (1993) Sexual Citizenship. London: Routledge Fraser, N. and Gordon, L. (1994). `Dependency' Demystified: Inscriptions of Power in a Keyword of the Welfare State'. Social Politics: International Studies in Gender, State, and Society. 1:1: 4-32.

Hammar, T. (1990) Aliens, Denizens and Citizens in the World of International Migration, Aldershot: Avebury.

Kadale. R. (1995) `Constitutional Equality: The Implications for Women in South Africa'. Social Politics: International Studies of Gender, State and Society. 2:2. 208224. Kittay, E. (1998). Love's Labour: Essays in Women, Equality and Dependency. London: Routledge Jagger. Allison (1983). Feminist Politics and Human Nature. Brighton: Harvester. Lewis. J. (ed.). Gender, Social Care and Welfare State Restructuring. Aldershot: Ashgate. Marchand, M.H and Runyan, A.S. (eds.) (2 000). Gender and Global Restructuring: Sightings, Sites and Resistances. London: Routledge. McDonagh. E. (1996). Breaking the Abortion Deadlock: From Choice to Consent. New York: Oxford University Press. Prugl. E. and Meyer. M. (eds). (1995). Gender Politics in Global Governance. Lanham MD.: Rowman and Littlefield.

53 Raz, J. (1994). "Muliticulturalism: A Liberal Perspective." Dissent. Winter, 1994: 67-69, Schneider, E. (1991). `The Politics of Rights Politics: Perspectives from the Women's Movement' (Pp 301-319) in M. Fineman and N.S. Thomadsen (eds.), At the Boundaries of Law. New York: Routledge. Sevenhuijsen, S. (1991). `Justice, Moral Reasoning and the Politics of Child Custody' in E. Meehan and S. Sevenhuijsen (eds). Equality Politics and Gender.London: Sage.

Change this reference from Fraser 1997 to 1989. Fraser, N. (1989), `Struggle over Needs: Otline of a Socialist Feminist Critical Theory of Late Capitalist Political Culture', Pp. 161-190, in Unruly Practices, Power Discourse and Gender in Contemporary Social Theory. Minneapolis: University of Minnesota Press. You missed the fact that I did not have page numbers. Hobson, B. (1998), `Women's Collective Agency, Power Resources, and Citizenship Rights,' (Pp. 149-178) in Michael Hanagan and Charles Tilly (eds), Recasting Citizenship eds.. Roman and Littlefield.

Although Marshall has not been such a salient figure in Continental European societies, such as Germany and France, the contests over social rights and the obligations of citizenship are central to policy debates in all of Europe, even if they are not always explicitly framed in such terms.



SeeTurner, 1988 and Kymlicka, 1991 who have incorporated the dimension of political identities and social conflict into the theorizing of citizenship. 3 Writing in a Danish context, however, Birte Siim suggests that, as women, including mothers, have become more active as political citizens, `the public/private division has lost some of its gendered meanings' (Siim, 1999, p121). 4 This strand of liberalism has been referred to as new liberalism, or social or social democratic liberalism (O Connor, Orloff, and Shaver,1999). 5 Okin (1989) extends Rawls' concept of the veil of ignorance or original position, which asks us to perform a thought experiment: that is to suppose did not know our social position before birth, we would create more just institutions. Okin applies this to gender inequality in family and in society at large. 6 For a discussion see Plant and Barry (1990). 7 As discussed above, these feminists were critical of his analysis of the historical progression of civil, political and social rights, which lacked a gendered analysis of women's citizenship. (Lister, 1997; Fraser and Gordon, 1994). 8 Most of the empirical studies in Scandinavia confirmed her thesis, that women more than men support welfare state programs and vote for social democratic parties that espouse an active state (Svallfors, 1996) 9 These points were made at the meeting of contributors to this volume. 10 It is important to keep in mind that greater access to rights does not necessarily mean significant increases in participatory fatherhood. For example, the Swedish data show that despite the introduction of the daddy quota in 1995, the proportion of days father's took did not increase very much per calendar year. Whereas 50 percent of the fathers took the daddy month, it is often spread out over several years, as long weekends, or extra vacation days. But it had a marked effect in Norway which we should acknowledge ­ an increase from 1-2 per cent take-up to over 70 per cent as a result of its introduction in 1993, according to a paper by jane millar (`Expanding parental choice: some notes on policy options' paper given at National Council for One Parent Families and National Family and Parenting Institute Seminar, 17 February, 2000]. Ruth: The Norwegian case might also reflect the high use of take up rates, but little change in the actual division of who takes leave during the first year of birth. 11 Young's more recent work (2000) pays greater attention to these dangers. 12 Fraser identifies Lesbian and gay movements as those cases that come closest to `pure recognition struggles' involving anti-discrimination laws. 13 For example in Sweden family members defended killing a young Muslim women at a disco bar, claiming that different cultural values supersede laws and protections for human rights in the country of residence. 14 A recent exception is the edited collection, Gender and Global Restructuring by Marchand and Runyan, 2000). 15 Decommodification in this context refers to Esping-Andersen's conceptualisation of social rights in welfare states, as those policies and laws that reduce workers' dependence on market forces. This dimension of social rights did not take into account the numbers of women who were not in the labor market and their economic dependency in the family (see in this volume). 16 Pateman presents the dilemma in binary categories. Women in a universalistic gender neutral framework are treated as lesser men; where women's differences are acknowledged, they are treated as lesser citizens




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